Somehow over turn enough electors so that Biden does not have 270 electoral votes – thus “kicking the presidential election to the House of Representatives. In the House, state delegations would have each cast one vote for president. While Democrats have a slim control of the 2021 House (at least 222 Democrats with 218 needed for a majority), the state delegations favor Republicans, 26-24.”(https://www.newsmax.com/headline/election-biden-trump-lawsuits/2020/12/13/id/1001277/)