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I just read the USA Today article (link posted somewhere above) and it mentioned that a second study was conducted to check the overvotes, but hadn't been completed when the article was published. The overvotes were ballots where more than one name in any given race was selected (not just for President), thereby automatically disqualifying the entire ballot. There were 110,000 of these and Franken may be referring to this recount for the entire state. But if a ballot is invalid because two people were picked, then they should never be counted. SCOTUS disagrees in the USA Today article.

Having worked an election (2000 at the county level), the types of mistakes is astounding. I remeber one ballot that had no votes cast, but had the voter's signature. Another had ALL the bullets for President filled in EXCEPT for the one for W. Any number had two bullets filled in in the same section. The one thing that really got to me was if 2 votes were cast for pres, that voided that part of the ballot, unless they had filled in the straight party bullet. Then that vote went to that party's candidate.

There were also some that filled in 3 of the 4 straight party bullets - so nothing counted.