20-1001 Thursday “Daily Bugle”

20-1001 Thursday “Daily Bugle”

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Thursday, 1 October 2020

  1. Treasury/OFAC: “International Criminal Court-Related Sanctions Regulations”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: ITAR / USML Updates FAQs for Patent and Trademark Office Publications
  4. Treasury/OFAC Publishes International Criminal Court-Related Sanctions Regulations; Amended Weapons of Mass Destruction Proliferators Sanctions Regulations and Iranian Transactions and Sanctions Regulations
  1. CNBC: “U.S. Sanctions on Chipmaker SMIC Hit at the Very Heart of China’s Tech Ambitions”
  2. Export Compliance Daily: “Multilateral Export Control Bodies Need Modernization, Experts Say”
  1. DLA Piper: “New CFIUS Regulations Change Mandatory Filing Requirements and Increase the Importance of US Export Controls”
  2. Fasken: “Out with NAFTA, In with CUSMA”
  3. Steptoe: “Shipping Carrier Sent Packing as Court Rejects Challenge to New US Export Controls Rules”
  4. Thomsen & Burke: “Changes to Export Controls in September 2020”
  1. FCC Academy Presents: 6-7 Oct; “Designing an ICP” & “Implementing an ICP”
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Find the Latest Amendments Here. 
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EXIM_a11. Treasury/OFAC: “International Criminal Court-Related Sanctions Regulations”
(Source: Federal Register, 1 Oct 2020) [Excerpts]
85 FR 61816: Rule
* AGENCY: Office of Foreign Assets Control, Treasury.
* ACTION: Final rule.
* SUMMARY: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adding regulations to implement Executive Order 13928 of June 11, 2020 (“Blocking Property of Certain Persons Associated With the International Criminal Court”). OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy.
* DATES: This rule is effective October 1, 2020.
* FOR FURTHER INFORMATION CONTACT: OFAC: Assistant Director for Licensing, 202-622-2480; Assistant Director for Regulatory Affairs, 202-622-4855; or Assistant Director for Sanctions Compliance & Evaluation, 202-622-2490.

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* Commerce Department: RULES; Identification of Prohibited Transactions to Implement Executive Order 13942 and Address the Threat Posed by TikTok and the National Emergency with Respect to the Information and Communications Technology and Services Supply Chain: Preliminary Injunction Order Entered by a Federal District Court [Pub. Date: 2 Oct 2020] (PDF)

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OGS_a23. Commerce/BIS: (No new postings)

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(Source: State/DDTC, 30 Sep 2020)
Q: Does DDTC restrict the United States Patent and Trademark Office (USPTO) from including ITAR-controlled technical data when publishing a patent application?
A: Information published by the USPTO as part of a patent application and available at any patent office is public domain information (see ITAR section 120.11(a)(5)).  By definition, it is not technical data (see ITAR section 120.10(b)).  Technical data submitted as part of a patent application and not published and available at any patent office is not information in the public domain and remains ITAR-controlled. 
  DDTC does not restrict the USPTO from publishing and making available at any patent office information submitted by a patent applicant.  The U.S. Government may, however, impose an invention secrecy order on certain applications for patents, such that the USPTO will withhold the publication of the application or the grant of a patent therefor.  Section 120.11(a)(5) does not apply to any ITAR-controlled technical data submitted as part of a patent application that is subject to an invention secrecy order because that information is not published and available at any patent office.

Note: This FAQ applies only to domestic patent applications.

* * * * * * * * * * * * * * * * * * * *  

  The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adding regulations to implement Executive Order 13928 of June 11, 2020 (“Blocking Property of Certain Persons Associated With the International Criminal Court”).
  In addition, OFAC is amending the Weapons of Mass Destruction Proliferators Sanctions Regulations and Iranian Transactions and Sanctions Regulations.
For more information on today’s action, please visit this Recent Action page.

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(Source: CNBC, 28 Sep 2020) [Excerpts]

  The U.S. government has reportedly imposed restrictions on exports to SMIC, China’s biggest chip manufacturer, a move that threatens Beijing’s push to become more self-reliant in one of the most critical areas of technology.

  Suppliers for certain equipment to SMIC will need to apply for an export license, according to a letter sent to companies by the U.S. Department of Commerce, reported by several media outlets. The commerce department claims there is “unacceptable risk” that equipment sold to SMIC may be diverted to “military end use.”

  The move threatens to hit at the heart of China’s plans to boost its domestic semiconductor  industry, a need that has been accelerated by the trade war with the U.S. 
  SMIC is seen as a critical part of China’s ambitions and the commerce department’s sanctions could hold back the company’s development for several years, experts warned. …
  Earlier this year, the U.S. amended a rule which requires foreign manufacturers using U.S. chipmaking equipment to get a license before selling semiconductors to Huawei. That came into effect on Sept. 15 and has cut Huawei off from chips manufactured by TSMC which goes into its smartphones and other gear. Huawei has very few options to make up the shortfall and SMIC would have been a natural option.
  The problem is that SMIC cannot manufacture, on scale, the advanced chips Huawei needs for its handsets which are only made right now by TSMC and Samsung. …

(Source: Export Compliance Daily, 30 Sep 2020) [Excerpts]
  Multilateral export regimes need to be modernized to address new export and proliferation controls surrounding emerging technologies, technology proliferation experts said. While groups such as the Wassenaar Arrangement work well to control physical categories of items, they may overlook advancements in exports and other technology areas that could lead to proliferation of dual-use goods, the experts said.


(Source: DLA Piper, 30 Sep 2020)
* Principal Author: Nicholas Klein, Esq., 1-202-799-4129, DLA Piper 

  On September 15, 2020, the Department of the Treasury published a final rule that modifies the regulations that govern mandatory filings with the Committee on Foreign Investment in the United States (CFIUS). CFIUS is an interagency committee chaired by the Department of the Treasury and is responsible for reviewing foreign investments in, or acquisitions of, US businesses and real estate to determine if the transaction threatens to impair US national security. Although CFIUS is largely a voluntary process, CFIUS introduced mandatory filing requirements with the launch of a critical technology pilot program in November 2018 and formalized and expanded the mandatory filing requirements in February 2020.  The new rule modifies the criteria that trigger a mandatory filing with CFIUS, potentially subjecting more transactions to mandatory CFIUS review.  These changes will apply to transactions that have not yet entered into a definitive agreement as of October 15, 2020.

  The new rule addresses a CFIUS concern that transaction parties were previously able to avoid a mandatory filing based on a relatively subjective and often imprecise limitation on the filing requirement involving certain North American Industry Classification System (NAICS) codes, despite engaging with technologies that may be considered sensitive to national security.  These circumstances also yielded inconsistent regulatory restrictions whereby a foreign investor could be restricted from access to the technology of a target US business under the US export control regime, but could invest in or own the US business and potentially influence decisions about the development, production and sales of critical technology without CFIUS review.  
  Shifting away from the relatively subjective NAICS code assessment, the rule will now be based on the national security foundations of established export control regimes.  Investors from excepted foreign states, FOCI-mitigated entities as well as investment funds managed exclusively and ultimately controlled by US nationals will continue to be excluded from the filing requirement.

  Foreign investors and US companies that are contemplating a transaction or joint venture arrangement that involves a foreign party should evaluate the applicability of CFIUS review and assess whether a filing is mandatory.  Transaction parties would be best served by accounting for these regulatory developments in the course performing due diligence and determining realistic deal closing dates.

Export control licensing replaces NAICS codes for mandatory filing analysis
  Under the existing CFIUS regulations, parties to a covered transaction are required to file a declaration (or may opt to file a notice) if the transaction involves a US business that produces, designs, tests, manufactures, fabricates or develops one or more “critical technologies” that are either used by the US business in, or designed specifically for use in, one of 27 industries identified by their NAICS code. 
  Under the final rule, the filing requirement will continue to apply to both controlling transactions and “covered investments” (ie, non-controlling investments that afford the foreign person access to material non-public technical information, board director or observer rights, or substantive decision-making power).  The definition of “critical technologies” has been and will continue to be defined by reference to US export control regimes, including the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and a few other more specialized export control regulations.[FN/1]

  The new CFIUS regulation alters the criteria that trigger a mandatory filing with CFIUS by eliminating the requirement that a critical technology be used in or specifically designed for use in one of the 27 NAICS code industries, instead tying the critical technologies mandatory filing requirement to export authorization requirements under US export controls.   Specifically, a filing with CFIUS will be mandatory where:[FN/2]

  (I) the US business involved in the transaction produces, designs, tests, manufactures, fabricates, or develops certain types of “critical technologies” and

  (II) a “U.S. regulatory authorization” would be required to provide such critical technology to any of the following persons, based on principal place of business, nationality (for individuals), or other reasons (eg, if the person is designated on the Entity List under the EAR):

    1. any person that could “directly control” the US business as a result of the covered transaction
    2. any person that is “directly acquiring an interest” or already has a “direct investment” in the US business and is acquiring certain relevant non-controlling rights or
    3. any person that individually holds or is part of a group of foreign persons that holds a 25 percent or more voting interest [FN/3] in a foreign person described in (II)(1) and (2) above.

Assessing US regulatory approval requirements

  For purposes of the new mandatory filing rule, the term “US regulatory authorization” is a license or other approval issued by the relevant US export control authority.  Determination of whether a license or other approval is required is largely based on (1) the export classification of the critical technology and limited applicable license exceptions and (2) the nationality of the recipient.  
  Understanding the export classification regimes under the ITAR and EAR is a critical component of the CFIUS mandatory filing analysis.  Not only does the classification determine whether the products, software or technologies involved in the transaction are “critical technologies,” but the classification also drives the potential licensing requirements and applicable license exceptions, and thus the mandatory CFIUS filing obligation.
  Under the final rule, only three exceptions under the EAR may be considered in evaluating the applicable export licensing requirements.  Specifically, products, software or technologies that are eligible for the following license exceptions will not trigger a mandatory filing:

  • License Exception Technology and Software Unrestricted (TSU) (15 CFR 740.13) – authorizes the provision of limited software updates, sales technology and low-level operation technology and software to certain destinations and end users.
  • License Exception Encryption Commodities, Software, and Technology (ENC) (15 CFR 740.17(b)) – authorizes the export to certain categories of end users of most standard and some non-standard encryption source code and certain other cryptographic commodities, software and components for use in network infrastructure.  The current CFIUS regulations exempt encryption technology that is eligible for any part of License Exception ENC, but the final rule narrows that exemption to include only those items eligible for export under the authority of subsection (b) of License Exception ENC.  Subsection (b) includes a self-classification provision for certain eligible items and mandatory written review by the Bureau of Industry and Security (BIS) for others.  Thus, companies that have not submitted a written encryption classification request, where required for License Exception ENC export authorization for their technology, software and products may lose the opportunity to invoke this exemption unless they file with BIS at least 30 days before closing in most cases.
  • License Exception Strategic Trade Authorization (STA) (15 CFR 740.20(c)(1)) – authorizes the provision of items subject to certain controls to a limited set of destinations that are considered to pose a lower risk of unauthorized or impermissible end uses.

  All aspects of these license exceptions must be satisfied to relieve the CFIUS filing requirement, including the foreign person’s eligibility to rely on the exception.  Notably, other export license exceptions that may be available under the EAR for the technology at issue are not to be considered when assessing the export licensing requirements for purposes of the CFIUS mandatory filing.

Practical impacts of the new mandatory CFIUS filing criteria
  The changes in this final rule may increase the burden on some US companies considering foreign investment, as it will require them to undergo a careful assessment of their hardware, software, technology, and services to determine their export control classifications and whether export licenses or authorizations are applicable or if exceptions would be available.  In this regard, software or SaaS businesses will need to be especially careful in assessing the encryption features of their technology under US export controls.  Notably, this mandatory filing provision may be triggered based on theoretical access to the critical technologies, meaning that no intent to provide any critical technologies to a foreign party is required.  Thus, classifying products, technology and services under US export controls will be necessary for CFIUS purposes even if the US business involved in the transaction does not actually export in practice.
  Although the short-form declaration process provides a faster alternative to a full notice filing, even the 30-day review period (plus preparation and filing time) might delay the speed at which many investments would otherwise close – particularly in the venture capital space.  Thus, to avoid timing issues should a mandatory filing be required with CFIUS, companies that anticipate foreign investment would be best positioned to consider export controls at as early a stage as possible.

(Source: Fasken, 15 Sep 2020)

* Principal Author: Clifford Sosnow, 1-613-696-6876, Fasken Martineau DuMoulin LLP 
  The agreement to replace NAFTA, the Canada-United States-Mexico Trade Agreement (CUSMA) came into force on July 1, 2020 and Canadian importers and exporters should be aware of how the new agreement will affect their business. This bulletin highlights some of the major differences between NAFTA and CUSMA.

Rules of Origin

  A notable change under CUSMA is in the rules that apply to the origin of goods. While most rules of origin will remain the same under CUSMA, there have been significant changes in the automotive sector, pharmaceuticals and health care products, information technology products, cosmetics and chemicals. In many cases, the rules have become stricter, and products that used to qualify for preferential treatment under NAFTA may not qualify under CUSMA.
  Particularly, the rules applicable to automotive vehicles and products are more burdensome than existed under NAFTA. Every company that has been exporting or importing its products under NAFTA is well advised to review whether and how they may be affected by any changes to the rules under CUSMA.
  Further, the rules that traders must follow to establish the origin of a good are different under CUSMA. CUSMA moves away from a formal certification of origin and gives traders more options. However, importers that relay on origin certification by their suppliers should review their contracts with those suppliers to ensure they can claim against the supplier for any additional duty and other costs associated with improper certification.

Digital Trade

  CUSMA’s Digital Trade chapter provides a slew of new protections for the digital economy, including eliminating customs duties on digital products distributed electronically, protection for cross-border data transfers, minimizing limits on where data can be stored and processed, limiting government’s ability to require disclosure of proprietary computer source code and algorithms, and limiting the civil liability of internet platforms for third-party content that such platforms host or process.

Government Procurement

  While CUSMA does contain a chapter addressing government procurement, Canada is not a party to it. Therefore, once CUSMA comes into force, suppliers in Canada, the U.S. and Mexico will no longer have one trade agreement that provides a common “rule set” for government procurement in North America. Rather, there will be one agreement governing procurement between Canada and the U.S. (the World Trade Organization Agreement on Government Procurement – WTO-AGP), another between the U.S. and Mexico (CUSMA), and, when it comes into force, a third agreement between Canada and Mexico (the Comprehensive and Progressive Agreement for Trans-Pacific Partnership – CPTPP). As a result, it is important for suppliers to be aware of and understand which rules govern the procurement they are bidding on.

U.S. Section 232 Tariffs on Steel and Aluminum Goods

  A number of side letters accompany CUSMA. Canada and the U.S. concluded a side letter to CUSMA that provides Canada with two narrow protections from tariffs imposed by the U.S.:
  1. Section 232 Tariffs – Future Measures: One side letter requires the U.S. to delay the imposition of any tariffs or import restrictions under Section 232 of the Trade Expansion Act on Canadian goods for 60 days, during which time the two countries must attempt to negotiate an appropriate alternative.
  2. Section 232 Tariffs – Autos and Auto Parts: The second side letter, provides that if the U.S. chooses to impose tariffs under Section 232 of the Trade Expansion Act on Canadian automobile exports, Canada will have guaranteed, duty-free access for a specified quantity of automobiles and their parts.
  Although one of the goals of CUSMA is to reduce regulatory burdens, it is important to understand that these side letters are limited in scope. For instance, the side letters have not prevented the recent Canada-U.S. trade dispute regarding imports of aluminum to the U.S. This dispute originated in March 2018, prior to the conclusion of CUSMA because the U.S. claimed that the volume of aluminum imported into the U.S. from foreign countries, including Canada, raised Section 232 national security concerns.
  Canada and the U.S. subsequently came to an agreement in May 2019 under which the U.S. exempted Canadian imports from the Section 232 tariffs on the condition that import levels would not rise meaningfully beyond historic levels. In August 2020, the U.S. determined that imports from Canada have risen meaningfully and in turn imposed 10 per cent tariffs on Canadian aluminum. While the U.S. has since conditionally retracted such tariffs, the threat remains if the actual volume shipments from Canada exceeds 105 per cent of the expected volume for any month. As a result, Canada will not, at this time, impose the retaliatory tariffs it had announced on August 18, 2020. However, Canada states that it remains ready to impose such retaliatory tariffs, pursuant to the May 2019 agreement, if necessary.



  Although CUSMA has been hailed as both an improved NAFTA and not much different than NAFTA, neither is quite true. There are provisions that have changed significantly, and those changes will require a re-think of corporate strategy. In other areas, it will be business as usual. Canadian companies need to understand what changes affect them and what they need to do to adapt to the new trade environment. Knowing the rules can help increase revenues but also avoid costly mistakes.

* Principal Author: Wendy Wysong, Esq., 852-3729-1804, Steptoe & Johnson LLP 
  On September 10, 2020, Judge John Bates of the DC District Court issued a memorandum opinion dismissing a lawsuit against the US Department of Commerce filed by a US-based carrier in June 2019 in response to the Bureau of Industry and Security’s (BIS) decision to add a major Chinese telecommunications manufacturer and numerous affiliates to the Entity List in May 2019. The carrier argued that the BIS rule infringed on its due process rights because the carrier could be held strictly liable for violations of the Export Administration Regulations (“EAR”) caused by its customers. It also argued that BIS exceeded its authority under the Export Control Reform Act of 2018 (“ECRA”).
The Decision
  Under the EAR, carriers and other intermediaries can be held liable for facilitating violations of their customers. For example, a carrier that transports US-origin goods to a person on the Entity List who is not licensed to receive those goods could violate the EAR in addition to the sender who initiated the shipment. The carrier in this case had argued that it could not know the contents of every package it transported and that holding it strictly liable for its customers’ violations would not advance US national security or foreign policy goals. It also challenged the rationality of imposing strict liability on common carriers while holding customers liable only if they “knowingly” engage in a prohibited shipment.
  The carrier argued that the EAR’s strict liability standard would require the company either to cease all business operations that create a reasonable risk of violating the EAR (e.g., shipping packages to persons on the Entity List) or to “proceed with its business operations and face a substantial risk that it will violate the EAR and suffer harm.”
  In granting the US government’s motion to dismiss the claims, Judge Bates found that BIS’s strict liability standard for carriers was “rationally related to a legitimate government interest” (i.e., US national security and foreign policy) and that it was reasonable for BIS to hold carriers to a higher standard because they are “repeat players with the institutional knowledge and scale to navigate the EAR.” Under prevailing case law, these findings were sufficient to reject the carrier’s due process claims.
  Judge Bates also considered the carrier’s arguments that BIS could not, per the scope of its authority under ECRA, hold carriers liable for both “transferring” items in breach of the EAR and “aiding and abetting” violations of the EAR. While conceding that the language of ECRA was “inelegant,” Judge Bates found BIS had not exceeded its authority in drafting the EAR to cover both types of conduct.
  The carrier’s suit was a long shot given the high bar to challenging US agency actions. However, its arguments about liability for customers’ violations of the EAR take on added urgency given BIS’s more recent changes to the EAR. These changes include amendments to the military end-use / military end-user rule, the foreign-produced direct product rule, and expanded prohibitions under the Entity List targeting all parties to a transaction, which significantly increase the compliance burden of many transactions involving goods, technology, and software controlled under the EAR.
  The focus is now on what carriers can do to comply with the EAR in a risk-based and reasonably efficient manner. The EAR does not mandate any particular compliance measures. However, as pointed out by the plaintiff in this case, failing to take steps could expose a carrier to liability if its customer is engaged in prohibited conduct.
  Examples of compliance measures would include screening the names of all parties to a shipment and scrutinizing shipments involving parties on the Entity List. The EAR does not prohibit all shipments, and shipments of items that are not subject to the EAR would fall outside BIS’s jurisdiction entirely. However, a carrier would not ordinarily know the contents of a package or be in a position to evaluate whether a particular item is subject to the EAR, if the shipment originated outside the United States.
  Ultimately, a carrier’s real liability will depend on how BIS goes about enforcing the EAR in the context of the Entity List. Although the plaintiff in this case has a history of EAR violations, this challenge did not relate to a specific BIS enforcement action. BIS could resolve some of the ambiguity by issuing guidance clarifying the application of the EAR to carriers. In that regard, the agency has received considerable feedback from a wide range of companies in response to recent rulemakings demanding clarifications.
  In some ways, carriers are now in a similar position as financial institutions, which can also be held accountable for their customers’ violations of sanctions regulations issued by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”). OFAC has alleviated some of the industry’s concerns through guidance about liability of intermediary financial institutions and expectations for due diligence. Carriers may soon look to financial institutions for models of how to build risk-based programs for compliance with the EAR.



EN_a113. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Rufus Choate (1 Oct 1799 – 13 Jul 1859; was an American lawyer, orator, and Congressman.
  – ” Happy is he who has laid up in his youth, and held fast in all fortune, a genuine and passionate love of reading.”
  – “A book is the only immortality.” 
* Daniel J. Boorstin (Daniel Joseph Boorstin; 1 Oct 1914 – 28 Feb 2004; was an American historian at the University of Chicago who wrote on many topics in American and world history. He was appointed the twelfth Librarian of the United States Congress in 1975 and served until 1987. He argued in The Genius of American Politics (1953) that ideology, propaganda, and political theory are foreign to America.)    – “Time makes heroes but dissolves celebrities.”
  – “Technology is so much fun but we can drown in our technology. The fog of information can drive out knowledge.”
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The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments are listed below.
Latest Update 


5 Apr 2019: 84 FR 13499:

Civil Monetary Penalty Adjustments for Inflation. 
22 Sep 2020: 85 FR 59419 Additions of Entities to the Entity List and Corrections of entries on the Entity List.

DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.   24 Apr 2018: 83 FR 17749: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates.  

: DoD 5220.22-M. Implemented by Dep’t of Defense. 

18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary here.)  
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810.    23 Feb 2015: 80 FR 9359: comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. 

15 Nov 2017, 82 FR 52823: miscellaneous corrections include correcting references, an address and a misspelling.

DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War. 
14 Mar 2019: 84 FR 9239: Bump-Stock-Type Devices.


28 Sep 2020: 85 FR 60874: Temporary Amendment for Republic of Cyprus. The latest edition of the BITAR is 28 Sep 2020. 

DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
International Criminal Court-Related Sanctions Regulations.

1 Jan 2019: 19 USC 1202 Annex.
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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