[PC-NCSG] Fwd: Re: [NCSG-Discuss] Draft Comments for Whois Proceeding
Maria Farrell
maria.farrell
Sat Aug 2 12:37:44 EEST 2014
Hi Rafik,
Yes, these comments have achieved consensus and can be submitted on behalf of ncsg.
Cheers, m
Sent from my iPhone
> On 1 Aug 2014, at 19:34, Rafik Dammak <rafik.dammak at gmail.com> wrote:
>
> Hi Maria,
>
> thank you, I think we already passed the deadline for comment, can we consider that the comments are endorsed and ready to be submitted?
>
> Best,
>
> Rafik
>
>
> 2014-08-01 20:27 GMT+09:00 Maria Farrell <maria.farrell at gmail.com>:
>> My apologies, I made the call for consensus on the next-to-final draft.
>>
>> Draft 6, what should be the final draft, closes for comments at 1500 UTC today.
>>
>> Speak now or hold your peace, colleagues.
>>
>> All the best, Maria
>>
>>
>>> On 1 August 2014 12:20, Rafik Dammak <rafik.dammak at gmail.com> wrote:
>>> Thanks Stephanie for the edits and merging the comments.
>>> @Maria can you please make the call for consensus. I think Avri agrees with the changes but she will confirm that.
>>> we have less than 12 hours to submit the comments.
>>>
>>> Rafik
>>>
>>> 2014-08-01 19:24 GMT+09:00 Stephanie Perrin <stephanie.perrin at mail.utoronto.ca>:
>>>
>>>> Thanks for sending, I am having trouble with attachments but I got it. I think I have made all the corrections now, here is the amended version 6, I believe you can post it.
>>>> cheers Stephanie
>>>>
>>>>> On 2014-08-01, 6:11, Rafik Dammak wrote:
>>>>> Hi Stephanie,
>>>>>
>>>>> I think joy included her language in the attached document, can you please merge that with the latest draft you circulated?
>>>>> Lesson learned: using a shared online document and avoid the word document versioning nightmare.
>>>>>
>>>>> Best,
>>>>>
>>>>> Rafik
>>>>>
>>>>> ---------- Forwarded message ----------
>>>>> From: "joy" <joy at apc.org>
>>>>> Date: Jul 31, 2014 3:05 AM
>>>>> Subject: Re: [NCSG-Discuss] Draft Comments for Whois Proceeding
>>>>> To: <NCSG-DISCUSS at listserv.syr.edu>
>>>>> Cc:
>>>>>
>>>>> Hi - thanks everyone for the effort on this
>>>>> I have also added some information on the recent report of the UN High
>>>>> Commissioner for Human Rights on the right to privacy in the digital age
>>>>> - which includes aspects relevant for companies - plus one or two other
>>>>> minor comments
>>>>> Hope you get these in time!
>>>>> Joy
>>>>>
>>>>> On 31/07/2014 4:17 a.m., Kathy Kleiman wrote:
>>>>> > Hi All,
>>>>> > Attached is the revised version of the comments. It has the changes of
>>>>> > Stephanie and Ed incorporated (tx you!) I have drafted it for Rafik's
>>>>> > signature and submission on behalf of the NCSG (feel free to add an
>>>>> > electronic signature, Rafik!). (Track changes version showing edits
>>>>> > attached)
>>>>> >
>>>>> > If you could please use _this version _of the revised comments for
>>>>> > review and submission, that would be great.
>>>>> > Best,
>>>>> > Kathy
>>>>> >
>>>>> >
>>>>> > -----------------------------------------------------------------------------------------------------------------------------------------------
>>>>> >
>>>>> > NCSG Response to the Questions of the
>>>>> >
>>>>> > /Review of the ICANN Procedure for Handling WHOIS Conflicts with
>>>>> > Privacy Law /
>>>>> >
>>>>> > https://www.icann.org/public-comments/whois-conflicts-procedure-2014-05-22-en//
>>>>> >
>>>>> >
>>>>> > **
>>>>> >
>>>>> > The Noncommercial Stakeholders Group represents noncommercial
>>>>> > organizations and individual noncommercial users in their work in the
>>>>> > policy and proceedings of ICANN and the GNSO. We respectfully submit
>>>>> > as an opening premise that every legal business has the right and
>>>>> > obligation to operate within the bounds and limits of its national
>>>>> > laws and regulations. No legal business establishes itself to violate
>>>>> > the law; and to do so is an invitation to civil and criminal
>>>>> > penalties, in addition to reputational damage and a loss of the trust
>>>>> > of their customers and business partner. ICANN Registries and
>>>>> > Registrars are no different ? they want and need to abide by their laws.
>>>>> >
>>>>> > To that end, Registries and Registrars strive to comply with their
>>>>> > national and local laws.They strive affirmatively and proactively to
>>>>> > follow the laws and regulations under which they operate as legal
>>>>> > entities. To do otherwise is to violate the purpose of a legal regime,
>>>>> > to threaten the well being of the company, and to expose Directors,
>>>>> > Officers and Employees to fines, jail, or civil litigation. In the
>>>>> > matter of protection of personal and confidential information, which
>>>>> > is a very newsworthy issue in the 21^st century, privacy practices are
>>>>> > a matter of consumer trust, and therefore high risk for those
>>>>> > operating an Internet business.Even if customers have obediently
>>>>> > complied with demands for excessive collection and disclosure of
>>>>> > personal information up to this point, in the current news furor over
>>>>> > Snowden and the cooperation of business with national governments
>>>>> > engaged in surveillance, this could change with the next news
>>>>> > story.The Internet facilitates successful privacy campaigns.
>>>>> >
>>>>> > Thus, it is wise and timely for ICANN to raise the questions of this
>>>>> > proceeding, /Review of the ICANN Procedure for Handling WHOIS
>>>>> > Conflicts with Privacy Law/ (albeit at a busy time for the Community
>>>>> > and at the height of summer; we expect to see more interest in this
>>>>> > time towards the Fall and recommend that ICANN not construe the small
>>>>> > number of comments received to date as a reflection of lack of
>>>>> > interest). We submit these comments in response to the issues raises
>>>>> > and the questions asked.
>>>>> >
>>>>> > *Background*
>>>>> >
>>>>> > The /ICANN Procedure for Handling Whois Conflicts with Privacy Law
>>>>> > /was adopted in 2006 after years of debate on Whois issues. This
>>>>> > Consensus Procedure was the first step of recognition that data
>>>>> > protection laws and privacy law DO apply to the personal and sensitive
>>>>> > data being collected by Registries and Registrars for the Whois database.
>>>>> >
>>>>> > But for those of us in the Noncommercial Users Constituency (now part
>>>>> > of the Noncommercial Stakeholders Group/NCSG) who helped debate, draft
>>>>> > and adopt this Consensus Procedure in the mid-2000s, we were always
>>>>> > shocked that the ICANN Community did not do more. At the time, several
>>>>> > Whois Task Forces were at work with multiple proposals which include
>>>>> > important and pro-active suggestions to allow Registrars and
>>>>> > Registries to come into compliance with their national and local data
>>>>> > protection and privacy laws.
>>>>> >
>>>>> > At the time, we never expected this Consensus Procedure to be an end
>>>>> > itself ? but the first of many steps. We are glad the discussion is
>>>>> > now reopened and we support empowering Registrars and Registries to be
>>>>> > in full compliance with their national and local data protection,
>>>>> > consumer protection and privacy laws ? from the moment they enter into
>>>>> > their contracts with ICANN.
>>>>> >
>>>>> > We note there have been a number of recent decisions in higher courts
>>>>> > in various jurisdictions which impact the constitutional rights of
>>>>> > citizens to be free from warrantless disclosure and retention of their
>>>>> > personal information for law enforcement purposes.This reflects the
>>>>> > time it takes for data protection issues to wend their way to the high
>>>>> > courts for a ruling.We would urge ICANN, who otherwise sit on the
>>>>> > cutting edge of Internet technical issues, to reflect on their role as
>>>>> > a key global player in Internet governance.Do we lead or do we wait
>>>>> > until we are dragged into Court, to realize our responsibilities to
>>>>> > protect the fundamental rights of the citizens who depend on the
>>>>> > Internet to participate in modern society?//
>>>>> >
>>>>> > II. Data Protection and Privacy Laws ? A Quick Overview of the
>>>>> > Principles that Protect the Personal and Sensitive Data of Individuals
>>>>> > and Organizations/Small Businesses
>>>>> >
>>>>> > It is important to stress that while the discourse about data
>>>>> > protection requirements at ICANN has tended to focus on the European
>>>>> > Union and its Data Commissioners, as represented in the Article 29
>>>>> > Working Party on Data Protection, there are a great many countries
>>>>> > which have data protection law in place, including Canada, Mexico,
>>>>> > much of South America, Korea, Japan, Australia, New Zealand,
>>>>> > Singapore, South Africa, and many others.It is therefore quite
>>>>> > puzzling that ICANN does not assemble a working group to study the
>>>>> > matter and develop a harmonized approach to the issue, rather than
>>>>> > take this rather odd approach of forcing registrars and registries to
>>>>> > break national and local law.
>>>>> >
>>>>> > It is also important to note that there are many levels of data
>>>>> > protection law, from local municipal law to state and national
>>>>> > law.There is also sectoral law which applies to certain sectors.It
>>>>> > would be a reasonable approach to develop a policy that reflects
>>>>> > harmonized best practice, and abide by the policy rather than engage
>>>>> > in this adversarial approach to local law.Data protection law is
>>>>> > overwhelmingly complaints based, so it is inherently difficult for
>>>>> > registrars and registries to get a ruling from data protection
>>>>> > commissioners absent a complaint and a set of facts.
>>>>> >
>>>>> > In this regard, we also find it puzzling that despite the fact that
>>>>> > the Article 29 Working Party wrote to ICANN senior management to
>>>>> > indicate that they have reviewed the matter and reached an opinion
>>>>> > that the practices involving WHOIS do indeed violate EU law, ICANN has
>>>>> > not taken that message and developed a policy that guides their data
>>>>> > protection practices, starting with a clear statement of limited
>>>>> > purpose for the collection, use, and disclosure of personal information.
>>>>> >
>>>>> > The NCSG held a privacy meeting at the London ICANN 50 meeting, which
>>>>> > was quite well attended.While we did not specifically address or
>>>>> > attempt to brainstorm this particular problem, we feel it is safe to
>>>>> > summarize the following points:
>>>>> >
>>>>> > ?There is considerable interest, in civil society, in the protection
>>>>> > of personal information at ICANN.
>>>>> >
>>>>> > ?Policies and procedures such as were developed for the 2013 RAA are
>>>>> > very puzzling to those who are engaged in government and business in
>>>>> > the privacy field.This is not 1995, when the EU Directive on data
>>>>> > protection was passed and was still controversial.ICANN needs to catch
>>>>> > up with global business practice, preferably by developing binding
>>>>> > corporate rules which would take a harmonized approach to the
>>>>> > differing local laws. It is not appropriate for all data protection to
>>>>> > fall away in jurisdictions where there is not yet a data protection
>>>>> > law that applies to the provision of internet services, including
>>>>> > domain name registration.
>>>>> >
>>>>> > ?NCSG is ramping up a team of volunteers to provide more detailed
>>>>> > expertise and input on a number of privacy and free speech
>>>>> > issues.While civil society is inherently stretched and short of
>>>>> > resources, this is an issue that they care deeply about, and our
>>>>> > outreach has begun to bear fruit in engaging others who are outside
>>>>> > the immediate sphere of ICANN membership.This is important as they are
>>>>> > part of the constituency we seek to represent.
>>>>> >
>>>>> > ICANN spends considerable time on technical parameters, data accuracy,
>>>>> > and retention.More time needs to be spent on data protection policy.In
>>>>> > this respect, more expertise would be required as there is very little
>>>>> > evidence of privacy expertise in the ICANN community.
>>>>> >
>>>>> > III*/./*Questions asked of the Community in this Proceeding
>>>>> >
>>>>> > The ICANN Review Paper raised a number of excellent questions. In
>>>>> > keeping with the requirements of a Reply Period, these NCSG comments
>>>>> > will address both our comments and those comments we particularly
>>>>> > support in this proceeding.
>>>>> >
>>>>> > However we would first like to note that the paper appears to start
>>>>> > from the position that the procedures involved in this waiver process
>>>>> > simply need to be tweaked.Operating under the first principle that all
>>>>> > business must comply with local law, there is a need for ICANN to
>>>>> > embrace data protection law as a well recognized branch of law which
>>>>> > codifies well recognized business best practices with respect to the
>>>>> > confidentiality of customer data.We respectfully submit that, if ICANN
>>>>> > had a professional privacy officer, it is highly unlikely that he/she
>>>>> > would recommend to senior management that the current approach be
>>>>> > entertained in 2014.
>>>>> >
>>>>> > 1.1Is it impractical for ICANN to require that a contracted party
>>>>> > already haslitigation or a government proceeding initiated against it
>>>>> > prior to being able to invoke the Whois Procedure?
>>>>> >
>>>>> > 1.1 Response: Yes, it is completely impractical (and ill-advised) to
>>>>> > force a company to violate a national law as a condition of complying
>>>>> > with their contract. Every lawyer advises businesses to comply with
>>>>> > the laws and regulations of their field. To do otherwise is to face
>>>>> > fines, penalties, loss of the business, even jail for officers and
>>>>> > directors. Legal business strives to be law-abiding; no officer or
>>>>> > director wants to go to jail for her company's violations. It is the
>>>>> > essence of an attorney's advice to his/her clients to fully comply
>>>>> > with the laws and operate clearly within the clear boundaries and
>>>>> > limits of laws and regulations, both national, by province or state
>>>>> > and local.
>>>>> >
>>>>> > In these Reply Comments, we support and encourage ICANN to adopt
>>>>> > policies consistent with the initial comments submitted by the
>>>>> > European Commission:
>>>>> >
>>>>> > -that the Whois Procedure be changed from requiring specific
>>>>> > prosecutorial action instead to allowing ?demonstrating evidence of a
>>>>> > potential conflict widely and e.g. accepting information on the
>>>>> > legislation imposing requirements that the contractual requirements
>>>>> > would breach as sufficient evidence.? (European Commission comments)
>>>>> >
>>>>> > We also agree with Blacknight:
>>>>> >
>>>>> > -?It's completely illogical for ICANN to require that a contracting
>>>>> > party already has litigation before they can use a process. We would
>>>>> > have loved to use a procedure or process to get exemptions, but
>>>>> > expecting us to already be litigating before we can do so is, for lack
>>>>> > of a better word, nuts.? (Blacknight comments in this proceeding).
>>>>> >
>>>>> > -
>>>>> >
>>>>> > 1.1a How can the triggering event be meaningfully defined?
>>>>> >
>>>>> > This is an important question. Rephrased, we might ask together ?what
>>>>> > must a Registry or Registrar show ICANN in support of its claim that
>>>>> > certain provisions involving Whois data violate provisions of national
>>>>> > data protection and privacy laws?
>>>>> >
>>>>> > NCSG respectfully submits that there are at least four ?triggering
>>>>> > events? that ICANN should recognize:
>>>>> >
>>>>> > -Evidence from a national Data Protection Commissioner or his/her
>>>>> > office (or from a internationally recognized body of national Data
>>>>> > Protection Commissioners in a certain region of the world, including
>>>>> > the Article 29 Working Party that analyzes the national data
>>>>> > protection and privacy laws) that ICANN's contractual obligations for
>>>>> > Registry and/or Registrar contracts violate the data protection laws
>>>>> > of their country or their group of countries;
>>>>> >
>>>>> > -Evidence of legal and/or jurisdictional conflict arising from
>>>>> > analysis performed by ICANN's legal department or by national legal
>>>>> > experts hired by ICANN to evaluate the Whois requirements of the ICANN
>>>>> > contracts for compliance and conflicts with national data protection
>>>>> > laws and cross-border transfer limits) (similar to the process we
>>>>> > understand was undertaken for the data retention issue);
>>>>> >
>>>>> > -Receipt of a written legal opinion from a nationally recognized law
>>>>> > firm or qualified legal practitioner in the applicable jurisdiction
>>>>> > that states that the collection, retention and/or transfer of certain
>>>>> > Whois data elements as required by Registrar or Registry Agreements is
>>>>> > ?reasonably likely to violate the applicable law? of the Registry or
>>>>> > Registrar (per the process allowed in RAA Data Retention
>>>>> > Specification); or
>>>>> >
>>>>> > -An official opinion of any other governmental body of competent
>>>>> > jurisdiction providing that compliance with the data protection
>>>>> > requirements of the Registry/Registrar contracts violates applicable
>>>>> > national law (although such pro-active opinions may not be the
>>>>> > practice of the Data Protection Commissioner's office).
>>>>> >
>>>>> > The above list draws from the comments of the European Commission,
>>>>> > Data Retention Specification of the 2013Registrar Accreditation
>>>>> > Agreement, and sound compliance and business practices for the ICANN
>>>>> > General Counsel's office.
>>>>> >
>>>>> > We further agree with Blacknight that the requirements for triggering
>>>>> > any review and consideration by ICANN be: simple and straightforward,
>>>>> > quick and easy to access.
>>>>> >
>>>>> > 1.3Are there any components of the triggering event/notification
>>>>> > portion of the RAA's Data Retention waiver process that should be
>>>>> > considered as optional for incorporation into a modified Whois Procedure?
>>>>> >
>>>>> > 1.3 Response:Absolutely, the full list in 1.1a above, together with
>>>>> > other constructive contributions in the Comments and Reply Comments of
>>>>> > this proceeding, should be strongly considered for incorporation into
>>>>> > a modified Whois Procedure, or simply written into the contracts of
>>>>> > the Registries and Registrars contractual language, or a new Annex or
>>>>> > Specification.
>>>>> >
>>>>> > We respectfully submit that the obligation of Registries and
>>>>> > Registrars to comply with their national laws is not a matter of
>>>>> > multistakeholder decision making, but a matter of law and compliance.
>>>>> > In this case, we wholeheartedly embrace the concept of building a
>>>>> > process together that will allow exceptions for data protection and
>>>>> > privacy laws to be adopted quickly and easily.
>>>>> >
>>>>> > 1.4Should parties be permitted to invoke the Whois Procedure before
>>>>> > contracting with ICANN as a registrar or registry?
>>>>> >
>>>>> > 1.4 Response: Of course, Registries and Registrars should be allowed
>>>>> > to invoke the Whois Procedure, or other appropriate annexes and
>>>>> > specifications that may be added into Registry and Registrar contracts
>>>>> > with ICANN. As discussed above, the right of a legal company to enter
>>>>> > into a legal contracts is the most basic of expectations under law.
>>>>> >
>>>>> > 2.1Are there other relevant parties who should be included in this step?
>>>>> >
>>>>> > 2.1 Response: We agree with the EC that ICANN should be working as
>>>>> > closely with National Data Protection Authorities as they will allow.
>>>>> > In light of the overflow of work into these national commissions, and
>>>>> > the availability of national experts at law firms, ICANN should also
>>>>> > turn to the advice of private experts,such as well-respected law firms
>>>>> > who specialize in national data protection laws. The law firm's
>>>>> > opinions on these matters would help to guide ICANN's knowledge and
>>>>> > evaluation of this important issue.
>>>>> >
>>>>> > 3.1How is an agreement reached and published?
>>>>> >
>>>>> > 3.1 Response. As discussed above, compliance with national law may not
>>>>> > be the best matter for negotiation within a multistakeholder process.
>>>>> > It really should not be a chose for others to make whether you comply
>>>>> > with your national data protection and privacy laws. That said, the
>>>>> > process of refining the Consensus Procedure, and adopting new policies
>>>>> > and procedures, or simply putting new contract provisions, annexes or
>>>>> > specifications into the Registry and Registrar contracts SHOULD be
>>>>> > subject to community discussion, notification and review.But once the
>>>>> > new process is adopted, we think the new changes, variations,
>>>>> > modifications or exceptions of Individual Registries and Registrars
>>>>> > need go through a public review and process. The results, however,
>>>>> > Should be published for Community notification and review.
>>>>> >
>>>>> > We note that in conducting the discussion with the Community on the
>>>>> > overall or general procedure, policy or contractual changes, ICANN
>>>>> > should be assertive in its outreach to the Data Protection
>>>>> > Commissioners. Individual and through their organizations, they have
>>>>> > offered to help ICANN evaluate this issue numerous times. The Whois
>>>>> > Review Team noted the inability of many external bodies to monitor
>>>>> > ICANN regularly, but the need for outreach to them by ICANN staff
>>>>> > nonetheless:
>>>>> >
>>>>> > *Recommendation 3:Outreach*
>>>>> >
>>>>> > *ICANN should ensure that WHOIS policy issues are accompanied by
>>>>> > cross-community outreach, including outreach to the communities
>>>>> > outside of ICANN with a specific interest in the issues, and an
>>>>> > ongoing program for consumer awareness. (Whois Review Team Final Report)*
>>>>> >
>>>>> > This is a critical policy item for such outreach and input.
>>>>> >
>>>>> > 3.2If there is an agreed outcome among the relevant parties, should
>>>>> > the Board be involved in this procedure?
>>>>> >
>>>>> > 3.2 Response: Clearly, the changing of the procedure, or the adoption
>>>>> > of a new policy or new contractual language for Registries and
>>>>> > Registrars, Board oversight and review should be involved. But once
>>>>> > the new procedure, policy or contractual language is in place, then
>>>>> > subsequent individual changes, variations, modifications or exceptions
>>>>> > should be handled through the process and ICANN Staff ? as the Data
>>>>> > Retention Process is handled today.
>>>>> >
>>>>> > 4.1Would it be fruitful to incorporate public comment in each of the
>>>>> > resolution scenarios.
>>>>> >
>>>>> > 4.1 Response: We think this question means whether there should be
>>>>> > public input on each and every exception?We respectfully submit that
>>>>> > the answer is No. Once the new policy, procedure or contractual
>>>>> > language is adopted, then the process should kick in and the
>>>>> > Registrar/Registry should be allowed to apply for the waiver,
>>>>> > modification or revision consistent with its data protection and
>>>>> > privacy laws.Of course, once the waiver or modification is granted,
>>>>> > the decision should be matter of public record so that other
>>>>> > Registries and Registrars in the jurisdiction know and so that the
>>>>> > ICANN Community as a whole can monitor this process' implementation
>>>>> > and compliance.
>>>>> >
>>>>> > Step Five: Public notice
>>>>> >
>>>>> > 5.2Is the exemption or modification termed to the length of the
>>>>> > agreement? Or is it indefinite as long as the contracted party is
>>>>> > located in the jurisdiction in question, or so long as the applicable
>>>>> > law is in force.
>>>>> >
>>>>> > 5.2 Response:We agree with the European Commission in its response,
>>>>> >
>>>>> > ?/By logic the exemption or modification shall be in place as long as
>>>>> > the party is subject to the jurisdiction in conflict with ICANN rules.
>>>>> > If the applicable law was to change, or the contacted party moved to a
>>>>> > different jurisdiction, the conditions should be reviewed to assess if
>>>>> > the exemption is still justified.?/
>>>>> >
>>>>> > //
>>>>> >
>>>>> > But provided it is the same parties, operating under the same laws,
>>>>> > the modification or change should continue through the duration of the
>>>>> > relationship between the Registry/Registrar and ICANN.
>>>>> >
>>>>> > 5.3Should an exemption or modification based on the same laws and
>>>>> > facts then be granted to other affected contracted parties in the same
>>>>> > jurisdiction without invoking the Whois Procedure.
>>>>> >
>>>>> > 5.3 Response. The European Commission in its comments wrote, and we
>>>>> > strongly agree: /?the same exception should apply to others in the
>>>>> > same jurisdiction who can demonstrate that they are in the same
>>>>> > situation.? /Further, Blacknight wrote and we support: /?if ANY
>>>>> > registrar in Germany, for example, is granted a waiver based on German
>>>>> > law, than ALL registrars based in Germany should receive the same
>>>>> > treatment.? /Once a national data protection or privacy law is
>>>>> > interpreted as requiring and exemption or modification, it should be
>>>>> > available to all Registries/Registrars in that country.
>>>>> >
>>>>> > Further, we recommend that ICANN should be required to notify each
>>>>> > gTLD Registry and Registrar in the same jurisdiction as that of the
>>>>> > decision so they will have notice of the change.
>>>>> >
>>>>> > We thank ICANN staff for holding this comment period.
>>>>> >
>>>>> > Respectfully submitted,
>>>>> >
>>>>> > Rafik Dammak
>>>>> >
>>>>> > Chairman, NCSG
>>>>> >
>>>>> > On behalf of the Noncommercial Stakeholders Group
>>>>> >
>>>>> >
>>>>> >
>>>>>
>>>>
>>>
>>>
>>> _______________________________________________
>>> PC-NCSG mailing list
>>> PC-NCSG at ipjustice.org
>>> http://mailman.ipjustice.org/listinfo/pc-ncsg
>>>
>>
>
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