Modernization of ocean shipping liability has been the subject of so much analysis, conjecture, lobbying, posturing and contention over the past 20 years that it’s almost difficult to present developments as news – however much the work of numerous organizations and individual players seem to be making progress. You can find Legal Lookout articles from the mid-1990s heralding a new era of shipping liability law by way of soon-to-be ratified reform to the U.S. Carriage of Goods by Sea Act (COGSA). A year or so later, you’ll see sheepish retractions of those announcements based on post-deregulation torpedoing of proposed Congressional bills (it’s amazing what a one-page protest letter from a dozen steamship lines can do!).
The Maritime Law Association of the United States and National Industrial Transportation League have dedicated hard-working committees since the George Bush Senior years to study, propose and promote reform legislation and, later, a new international treaty. All we currently have to show for that work are various versions of proposed bills and engaging commentary about why they would or wouldn’t work.
But that’s not to say we aren’t making progress! COGSA, the U.S. legislation based largely on international liability regimes Uncle Sam refused to accept, is antiquated and the subject of too much discontent and dispute to carry us into the new millennium, especially with our country’s current economic challenges. Enacted in 1936 with some subsequent amendments, COGSA has just lost pace with the times. It doesn’t recognize modern shipping practices, volumes and technologies. 500 bucks a package – the minimum to which COGSA allows ocean carriers to limit their liability for lost/damaged cargo, was quite a lofty sum in 1936. It’s now peanuts in most circumstances.
Similarly, the Hague-Visby Rules (the largest international cargo liability regime, and COGSA’s genesis, but a treaty the U.S. refused to sign) and Hamburg Rules (a newer treaty designed largely for developing countries, again rejected by Uncle Sam) are largely obsolete. But, along with COGSA, they provide a good deal of valuable background and experience – from both legal and industry perspectives – for creation of a modernized regime suitable for the world’s largest trading partners.
The movement toward an international uniform liability system was long in the making, and brought U.S. domestic reform endeavors to a halt. Years were spent by maritime organizations (some more law-oriented than others) of various countries, as well as the Comité Maritime International, analyzing the issues and boiling them down to proposed solutions. This was followed by a seven-year effort by the United Nations Commission on International Trade Law (UNCITRAL). Finally, on September 23, 2009, a formal ceremony was held in Rotterdam wherein a finalized treaty was presented for signing. It will take 20 ratified signatures of the world’s major trading parties to bring the “Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea,” informally, “the Rotterdam Rules” (and here, “the new treaty”) into action.
So what would happen if the U.S. charts a new course, and joins the rest of the world in adopting this international, uniform cargo liability program? As is the case with most liability legislation, much is left to speculation and ultimate determination by piecemeal litigation. How this all will work in practice cannot be predicted with much certainty. But we can certainly scrutinize what the Rotterdam Rules seek to accomplish based on input from numerous sources and the wisdom of delegates and committee members. This paper takes a look at some of the proposed new regime’s most salient features, and suggests what they might mean for U.S. industry and law if we ratify and implement them.
The Rotterdam Rules surface at just the time the U.S. finds itself embroiled with conflict occasioned by the U.S. Supreme Court’s 2004 decision in Norfolk Southern Railway Co. v. Kirby, et al, the Second Circuit Court of Appeals’ ruling in Sompo Japan Ins. Co. v. Norfolk Southern Ry. Co., and those cases’ progeny (see May-August 2008 Legal Lookout articles for a thorough analysis). At issue there was whether COGSA and the limitation of liability terms of a through ocean bill of lading could effectively be extended to inland carriers and other non-maritime participants in a through move. Many observers believe the Second Circuit, in Sompo Japan, improperly disregarded the High Court’s proclamation, in Kirby, that multimodal hauls will be fully subject to the predominant maritime contract’s terms and governing law (absent available provisions to the contrary). Subsequent cases have gone all over the place, leaving motor carriers and railroads anywhere from confused to clueless as to what law and liability limitations control them in the event of loss.
Early rumblings suggested that UNCITRAL’s forthcoming regime might encompass land-based elements of through ocean hauls, thereby clearing up the disarray. That’s not the way it worked out, unfortunately. Rail and motor carrier interests decided they wanted nothing to do with the formation of liability guidelines designed by and for their salty cousins, and declined to submit themselves to the new terms. We’ll just have to wait for the Supreme Court to straighten out the mess by a subsequent decision.
Nonetheless, the Rotterdam Rules do contain provisions for their applicability door-to-door for contracted multimodal moves. This is in contrast to COGSA’s “tackle-to-tackle” applicability that may be extended by contract to include other service providers. Thus, inland carriers could stay out of the new treaty’s shadow if they want to.
Notably, the Rotterdam Rules are designed not to apply to charter parties. Some rules can be opted out of for “volume contracts,” which is the treaty’s more-defined term for service contracts. This might give some comfort to those who like the newly deregulated, market-driven shipping world occasioned by the Ocean Shipping Reform Act of 1998.
Documentation of shipping relationships has transformed since the era of deregulation’s onset, with service contracts playing a more pivotal role, at least from the standpoint of economics.
Preliminarily, a bill of lading under the new treaty would represent the contract of carriage, as opposed to just being evidence of a contract of carriage as provided under current law. There are requirements for documented control over a shipment to destination.
The Rotterdam Rules provide for three types of paper: negotiable transport documents, non-negotiable transport documents and straight bills of lading. Required particulars are stated for each variety; provisions are made for electronic documentation; and the evidentiary effect of stated terms is explained (i.e., certain transport documents will be prima facie proof of a cargo’s condition and count at time of tender under certain circumstances, while others could leave open questions). This is one place where the new treaty becomes messy and complex; so much so that many observers have decried its documentation aspects as prohibitively complicated. You shouldn’t have to be a highly specialized attorney or 20-year industry veteran just to understand how shipping contacts work. Advantages and disadvantages of the various documentation forms aren’t spelled out and may hinge on legal and business circumstances that negotiating and drafting individuals don’t understand.
One source of discontent the American shipping community has experienced over the past fifteen years is U.S. courts’ recognition and enforcement of foreign jurisdiction selection and arbitration clauses in bills of lading issued by steamship lines flagged in other countries. Since the U.S. Supreme Court’s decision in Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, American shippers have been forced to pursue cargo claims against most steamship lines in foreign countries. This can complicate – or even render financially infeasible – recovery actions by the world’s largest consumers of transportation services. Needless to say, U.S. shippers and, most certainly, their work-deprived attorneys have long sought to legislatively reverse Sky Reefer in any liability regime overhaul. Foreign steamship lines, on the other hand, are quite happy to dissuade litigation or arbitration against them by forcing it to take place in, say, Seoul.
The Rotterdam Rules address foreign jurisdiction selection, but not with the certainty some of us would like to see. Suit is allowed in any one of four specified venues (including places of tender and delivery), which would seem to expunge Sky Reefer’s “the carrier decides” holding. However, volume contracts can still mandate foreign jurisdiction. Depending on who controls the market, this can be significant, given that the vast majority of freight moves by contract. Also, these jurisdiction provisions are optional, and signatory nations are free to develop their own statutes and regulations which might dictate where dispute resolution must take place. One wonders how much progress this point of the new treaty makes regarding forum selection.
The Rotterdam Rules preserve most cargo liability concepts found in earlier international treaties and COGSA. Basically, the shipper must demonstrate tender of its cargo to an ocean carrier in good order and condition, and either non-delivery or delivery in damaged or short condition. After jumping that hurdle, the burden of proof shifts to the carrier to demonstrate the loss was caused by one or more enumerated defenses. The Rotterdam Rules incorporate most of the established COGSA defenses, which essentially dictate what amounts to liability-generating fault. One adjustment is that the defenses aren’t necessarily absolute, and courts could apportion liability based on degrees of fault and their contribution to the loss for specified defenses. This is something of a departure from COGSA’s process, but one which may make little practical difference.
The most significant deletion from COGSA’s list is the “Error in Navigation” defense, one that has never made much sense to most observers, especially shippers. It basically allows carriers to escape liability by demonstrating they were negligent, an illogical concept that has left many freight-claim litigants disenchanted with the entire system.
Also adjusted, or perhaps clarified, is the fire defense. Under COGSA, the fire defense is somewhat unclear with regard to burdens of proof, and the U.S. circuits have gone in different directions applying it. On its face, COGSA’s fire defense language is applicable only if the carrier’s “privity and fault” caused it, which introduces another element someone must prove before it applies. When and who must demonstrate privity and fault, as well as when they must do so, just aren’t clear. The new treaty’s fire defense isn’t subject to that lack of clarity; “fire on the ship” is listed as a defense like any other.
Deviation terms are preserved to dissuade carriers from departing from their planned routes and service agreements, but with less vigor than certain U.S. and foreign case precedents have imposed. The current rule, though applied erratically, is that a carrier which deviates in a manner that causes loss loses its right to enforce limitation of liability provisions. Under the treaty, deviation won’t destroy limitation of liability unless it was done “with the intent to cause such loss or recklessly and with the knowledge that such loss would probably result.” This leaves the door open to claims that altered routes caused delay that a carrier knew (or should have known) would cause a shipper to, say, miss a sales season in the country of destination.
Another frequent subject of deviation claims regards carriage of cargo on deck. Deviation in that manner still wouldn’t necessarily be with the level of reckless intent required to destroy limitation of liability (although, for some cargoes, it very well may be). However, limited liability would be unavailable for carriers which expressly agreed to carry cargo under deck, but didn’t.
Time to Sue
The treaty provides a two-year statute of limitations for filing suit (like the Hamburg Rules, but unlike the one-year time to sue imposed by Hague-Visby and COGSA). The longer time period allows cargo interests more time to determine the nature and extent of their losses before deciding to file suit, and provides a more workable opportunity for players in certain countries to gather documentation needed for litigation. Usually a year is enough in the States, and when it’s not, shippers’ and carriers’ adjusters usually stipulate to a deadline extension to avoid potentially unnecessary court action. The two-year period would commence on the date of delivery, or when delivery was scheduled, even if a loss isn’t discovered until some time later. If two years has passed, a shipper could assert a lost/damaged freight claim as offset in response to a freight charge or other claim brought against it by the carrier.
Recoverable damages for lost/damaged cargo are calculated based on the goods’ value at the time and place of delivery. The valuation technique speaks for itself: “The value of the goods is fixed according to the commodity exchange price or, if there is no such price, according to their market price, or, if there is no commodity exchange price or market price, by reference to the normal value of the goods of the same kind and quality at the place of delivery.” A provision allows shippers and carriers to specify liquidated damages amounts in their contracts.
Limitation of Liability
Nothing impacts cargo claims like that carrier’s ace-in-the-hole, limitation of liability. Of course, the new treaty preserves this age-old feature of maritime law, but does so with some significant revisions.
The Rotterdam Rules’ provisions regarding limitation of liability apply only to carriers and “maritime performing parties,” which include stevedores and such, but exclude inland carriers. So what about Himalaya Clauses and other contractual extensions of maritime contract terms to railroads and truckers? How is the Kirby/ Sompo Japan debacle addressed? Put simply, it’s really not. The U.S. and other countries struggling with the issues of dual ocean and inland liability regimes in a multimodal transportation world will just have to keep sorting that out themselves. One potentially problematic loophole some observers have noted is that a railroad could set itself up as a carrier simply by getting a non-vessel operating common carrier license from the U.S. Federal Maritime Commission. This might require some regulatory attention before Uncle Sam ratifies the treaty.
COGSA’s per-package minimum liability of $500, and the Hague-Visby Rules’ 666.67 Special Drawing Rights (a valuation set by the International Monetary Fund based international currency fluctuations), have long been criticized as antiquated figures which don’t reflect inflation over the past century. They also ignore the fact that much more valuable cargoes are now ocean shipped, taking advantage of technological developments such as containerization, faster vessels, and more reliable refrigeration.
Under the new treaty, a carrier’s liability is limited to 875 SDRs (currently around $1,500) or 3 SDRs per kilogram of weight (about $2.20 pound), whichever is higher (a break COGSA doesn’t give shippers). The weight option would be significant to break bulk shippers of heavy industrial equipment that might otherwise constitute a single package. Clearing up some conflicting principles from U.S. and other courts, a “package” for limitation of liability purposes is the smallest unit definitively listed on a bill of lading, even if it is palletized with other packages. To escape full liability, carriers still must offer their shippers an option to declare full cargo value and pay a higher freight rate. Limited liability will not be available to a carrier if its owner (i.e., not just some deckhand) recklessly or knowingly caused the loss.
Liability for damages caused by delayed delivery are limited to two and a half times the freight charges. They are subject to the damages calculation provisos described above, and may be limited to 875 SDRs/package or 3 SDRs/kilogram if the carrier has properly limited its liability.
So where is this headed? Will we get the 20 ratified signatures needed to bring this thing to life? How many of the current 21 John Hancocks will they all be ratified? And what about Uncle Sam?
The U.S. signed the treaty at its formal ceremony earlier this year. Notably, some particularly important players – the United Kingdom, Canada, China and India, among others – haven’t stepped up. Some observers question whether we will get the needed number of ratifications, or if we do, whether years will pass before it happens. The world in general, and the U.S. in particular, have gotten very used to deregulation over the past decade, and lobbying forces might not be particularly psyched to (potentially) give up newly acquired freedoms by way of an untested international treaty. The effects certain provisions of the Rotterdam Rules would have on the economic recovery are uncertain, and could be fodder for naysayers to stall or prevent ratification.
On the other hand, the uniformity and international predictability the new treaty (at least theoretically) provides have distinct advantages. Economic and legal reliability actually might enhance economic recovery, and the risks of certain Rotterdam principles are really just theoretical. Efforts to provide contracting parties some leeway produced terms in significant areas.
We’ve waited a very long time for cargo liability reform. The current system of COGSA versus the world isn’t a long-term option. It’s time to strike a deal with our trading partners and move forward. The Rotterdam Rules are the best we can hope for by way of an immediate progress in the right direction.
Ref: Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea, available here; Norfolk Southern Railway Co. v. James N. Kirby, PTY Ltd., d/b/a Kirby Engineering, and Allianz Australia Insurance Limited, 543 U.S. 14, 125 S.Ct. 385 (2004); Sompo Japan Ins. Co. v. Norfolk Southern Ry. Co., 456 F.3d 54 (2nd Cir. 2006); and Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528, 115 S.Ct. 2322 (1995).
The following case summaries represent a survey of admiralty and maritime case decisions issued since last year’s TLA Conference.
Customary freight unit can be determined by flat rate a carrier charges for entire load.
Vigilant Ins. Co. v. M/T “Clipper Legacy,” et al., 656 F.Supp.2d 352 (SDNY 2009)
The U.S. Carriage of Goods by Sea Act, 46 USC §30701, et seq. (“COGSA”), allows ocean carriers to limit their liability to a minimum of $500/package. Unfortunately, the statute doesn’t define the term “package.” Courts have come to define it based on quantities forming the basis of calculated freight charges, or “customary freight units.” In this matter, a carrier quoted a shipper a “flat rate” for a large load of peanut oil. Contrary to agreed shipper’s instructions, the carrier allegedly carried in its preceding haul a chemical that ruins peanut oil. When the consignee learned this, it reject the delivery.
The shipper sued the carrier in the Southern District of New York to recover the peanut oil’s $231,963.34 value, and the carrier sought to limit its liability to $500 per COGSA. At issue was the definition of “package.” The shipper urged that each one of the designated 303.736 metric tons in its order constituted a package, and that the carrier calculated the freight rate on that basis. But the parties had a course of dealing whereby the carrier quoted flat rates which were not adjusted even when the freight tonnage tendered differed from what was ordered. The bill of lading unambiguously quoted a flat rate, and parol evidence as to how it was calculated wasn’t admissible.
On a separate but related note, this case addressed the concept of “deviation” as the basis for destroying a carrier’s otherwise effective limitation of liability. When a carrier alters its intended routing – usually for its own economic reasons – and cargo loss follows, courts have held them fully liable for deviating from the agreed course of travel. The concept has been extended to include a carrier’s deviation from cargo stowage plans, such that carriers become fully liable for cargo they stow on deck despite under-deck terms specified to the shipper. In this case, the shipper argued that deviation from the agreement regarding prior loads should destroy the carrier’s limited liability, but the court refused to extend the doctrine to that new extent.
Cross motions for summary judgment are denied as to what’s a “package.”
Garland Corporation v. Evergreen Marine Corp., 2009 WL 1660311 (S. D. Fla 2009)
Here, the subject bill of lading contained a standard $500/package limitation of liability clause. The parties disputed what constituted a package, when lost cargoes of garlic had been bagged, palletized and containerized. The bill of lading stated both bag and pallet numbers, and the freight charge calculation wasn’t clear. While determination of what constitutes a package may be determined as a matter of law based on submitted documentation, the parties’ intentions and course of dealing just weren’t clear here. Going through a nice review of how courts typically address the issue (this case demonstrates the various factors considered in determining what a “package” is), the court denied both motions in favor of further factual development.
And similarly, who’s an “agent” for purposes of extension of COGSA to land-based service providers?
Dewanchand Ramsaran Industries (P), Ltd. V. Ports America Texas, Inc., et al., 2010 WL 707380 (S.D. Tex. 2010)
Issues surrounding extension of COGSA to include stevedores and others have been in the news since the U.S. Supreme Court’s decision in Norfolk Southern Railway Co. v Kirby, 125 S. Ct. 385 (2004), and subsequent federal court rulings such as the Sompo Japan cases and others interpreting it. This case didn’t address the effect or propriety of Himalaya Clauses or other contractual provisions bringing the maritime statute’s terms ashore. Rather, it dealt with whether or not the stevedore at issue was the agent of the ocean carrier, the shipper or someone else.
The ocean carrier’s bill of lading contained a standard Himalaya Clause, and Ports America Texas, the entity that allegedly caused the dockside loss, claimed it was covered as a carrier sub-contractor. Problematically, the cargo owner had hired Ports America Texas as well, and it wasn’t clear whose work the stevedore was performing at the time of loss. The fact that “stevedores” were specifically named as entities subject to the clause was irrelevant; Ports America Texas would have to be under carrier sub-contract for it to enjoy the benefit. Moreover, the work would have to be done “in performance of the carriage,” which the bill of lading doesn’t define. Motions for summary judgment denied pending further factual development.
It probably doesn’t much matter. The court found that the cargo, a drill rig, had been shipped as a single package. The shipping documents treated the cargo as a single unit, even though it listed “and accessories” as part of the package (the shipper argued there were 45 such “accessories”, each constituting a “package”). Consequently, the parties find themselves fighting over peanuts.
Forum selection clause in bill of lading is enforceable – against carrier.
BBC Chartering & Logistic, GMBH & Co. v. Vestas American Wind Technology, Inc., 2009 WL 1812251 (W. D. Wash. 2009)
A feature of U.S. maritime law that is the source of considerable consternation for U.S. shippers and, perhaps more so, their lawyers, is the enforceability of foreign forum selection clauses in ocean carrier bills of lading. Now that there are no major U.S.-owned ocean carriers, the vast majority of ocean freight moves subject to terms mandating that freight claim litigation take place in the courts of foreign countries. Since the U.S. Supreme Court’s decision in Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528 (1995), ocean carriers have been able to force their U.S. shippers to endure often cost-prohibitive claims litigation in distantly located and unpredictable foreign courts. All they must do is include a clause in the shipping documentation.
Recently, the Western District of Washington tackled the surprising circumstance of a shipper that wanted to enforce an ocean carrier’s foreign forum selection clause, while the steamship line wanted to litigate stateside. The carrier filed a declaratory judgment action in Washington’s federal court seeking to avoid liability for lost freight. When the shipper sought to dismiss the action in favor of litigation in Leer, Germany per the bill of ladings’ selection clause, the carrier argued that the clause was for the carrier’s exclusive benefit. Accordingly, it urged, its enforceability hinged on whether the carrier exercised it.
The court didn’t agree. Just because forum selection clauses are widely regarded as a carrier tool operating for their benefit doesn’t make them any less mutually enforceable contract terms. They presumptively are for both parties’ benefit. The parties are going to Germany.
Suit in a non-designated forum results in dismissal of case and sanctions.
A.P. Moller-Maersk d/b/a/ Maersk Sea-Land v. Ocean Express Miami, et al., 648 F.Supp.2d 490 (SDNY 2009)
This case shows you that forum selection clauses can be far more than procedural inconveniences, and that courts sitting in admiralty have limited patience for abuse of process. Shipper Quality Print arranged through a pair of forwarders shipment of printing machinery from Milwaukee to Guatemala with ocean carrier Maersk. Maersk’s bill of lading contained a forum selection clause mandating that litigation take place in New York City. The port of departure was New Orleans. Hurricane Katrina intervened, and the container was surveyed for damage. A maritime surveyor found none, but prompt testing was recommended. If the shipper did any such testing, it wasn’t reported to Maersk.
The shipper brought suit against Maersk in the Second Maritime Court of Panama, claiming replacement value (not invoice costs) of the freight, plus a variety of consequential damages totaling some $10 million. To avoid an order of arrest of its vessel, Maersk posted a $10 million cash bond, as Quality Print refused to accept a “letter of undertaking” customarily posted by steamship lines’ insuring entities. A second suit in Guatemala ensued, and the court there, on the shipper’s motion, appointed an “intervenor” to occupy and oversee Maersk’s Guatemala City office, causing significant disruption. The Panama court subsequently knocked down the claim to less than 800 grand, finding no evidence of Quality Print’s original claim amount. Needless to say, the whole mess cost Maersk a bundle.
Maersk filed suit in the Southern District of New York seeking to enforce the forum selection clause and an array of damages and sanctions based on the shipper’s disregard of the forum selection clause. Quality Print’s motion to dismiss was denied, whereupon its counsel withdrew from representation, and the shipper defaulted on all subsequent proceedings.
That’s when the U.S. federal court went to work. It found Quality Print liable for huge damages based on abuse of process, breach of contract (by violating the forum selection clause), and contempt. Maersk should be able to recover all of its losses (it’s uncertain what’s left of the defendants, and whether Maersk will be able to collect). While reactions like this aren’t typical, U.S. federal courts clearly won’t tolerate violations of forum selection clauses, especially when they involve the kind of forum shopping and abuse shown here.
Even though ocean transit is a regulated aspect of commerce, it’s not a basis of federal jurisdiction independent of admiralty.
Villegas v. Magic Transport, Inc., 641 .Supp.2d 108 (2009)
Unlike other modes of transportation, federal courts specifically hold original jurisdiction over matters within admiralty jurisdiction. 28 USC §1333. However, a qualifier of that code provision, known as “the saving to suitors clause,” provides that an admiralty plaintiff can still elect to bring its action in any court that otherwise would have jurisdiction, including state courts. In order to remove to federal court, the defendant must show another basis of federal jurisdiction, which often is diversity.
Recently, the District of Puerto Rico addressed a creative maritime defendant’s attempts to successfully remove based on 28 USC §1337(a), which reserves to federal courts jurisdiction over “any civil action or proceeding arising under any Act of Congress regulating commerce to protecting trade against restraints and monopolies.” The claim, brought in Puerto Rico’s Superior Court, was one that COGSA would govern (even though the statute wasn’t pleaded). The defendant argued that if regulated commerce is impacted, federal jurisdiction ipso facto applies.
This interpretation would circumvent decades of interpretation of the jurisdictional statutes, and subject to mandatory federal jurisdiction all claims “occurring within earshot of a dock or pier.” That clearly isn’t the saving to suitors clause’s intended effect. This one goes back to the Superior Court per the plaintiff’s original designation.
Admiralty, and not state law, governs rights even though claim was cast in terms of “corporate regulation.”
In re M/V Rickmers Genoa Litigation, 643 F.Supp.2d 553 (SDNY 2009)
This action arose from the explosion of a cargo of freight aboard a vessel. The dispute involved elements of the commodity sale and purchase agreements, and the parties’ relationship regarding them. This, the defendant argued, meant that New York state law should control, as the state has more of an interest in corporate governance than federal doctrine about a uniform admiralty law.
The Southern District of New York disagreed. That approach would open the door to arguments that any number of otherwise clearly admiralty-governed issues are subject to state law, States frequently have interests – often significant ones – in the subject matter of admiralty actions. This accident occurred on navigable waters, and otherwise satisfied admiralty jurisdiction tests. The court noted that while admiralty jurisdiction doesn’t always mandate that federal maritime law applies, that usually is the case.
* Originally published on ForwarderLaw, www.forwarderlaw.com, as part of the author’s Legal Lookout column, copyright of Steven W. Block.
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