UNITED STATES � ANTI-DUMPING MEASURES ON
STAINLESS STEEL PLATE IN COILS AND STAINLESS
STEEL SHEET AND STRIP
FROM KOREA

Report of the Panel

(Continued)

ANNEX 1-6

ORAL STATEMENT OF KOREA

SECOND MEETING OF THE PANEL

(12-13 July 2000)

CONTENTS

1. UNPAID SALES 

1. Permissible Allowances for Differences Affecting Price Comparability under the Third Sentence of Article 2.4

(a) Article 2.3 

(b) Allowances for Differences in Conditions and Terms of Sale and Other Differences Affecting Price Comparability 

(c) Bad Debt and Warranty 

2. The Fair Comparison Requirement

2. MULTIPLE AVERAGING 

1. Article 2.4.2 
    
2. Article 2.4.1 
    
3. "Fair Comparison" Requirement of Article 2.4 
    
4. The US Justifications 

(a) Comparable Transactions 

(b) The Timing Requirement of Article 2.4

(c) Zeroing and Multiple Averaging 

(d) "Disguised" Dumping 

3. DOUBLE-CONVERSION 

1. Article 2.4.1
    
2. The Fair Comparison Requirement of Article 2.4
    
3. The DOC's Justifications
    
4. Revised US Justifications 

1. I have the honour to present the Republic of Korea's response to the arguments that have been made in the United States' oral and written submissions. I should start with the usual caveats: I will not address today every issue in the case, but will instead rely on the written submissions for a more comprehensive presentation of Korea's views. I also reserve the right to make further comments as necessary.

2. As with Korea's previous oral statement, I shall divide my presentation by the three main subjects that gave rise to the US errors at issue: unpaid sales, multiple averaging, and double conversion. Before turning to the substantive issues before the Panel, however, I would like to make a few introductory observations.

3. I have always thought that the issues in this case are fairly straightforward. I would like to use my time today to cut through all of the distractions and try as much as possible to crystallize the points that are really in dispute.

4. Unfortunately, this task is more difficult than I had hoped, because the US arguments in this case have been a constantly moving target. In our initial submission, we addressed the reasoning actually relied upon by the US Department of Commerce in its final determinations and in the underlying record of the Plate and Sheet investigations. Then, in reading the first US submission, I found that the United States had more or less abandoned the DOC's reasoning, and was offering entirely new justifications for the DOC's actions. When I received the second round of submissions, I found that the US had shifted ground once again. Their new arguments in many instances contradict their earlier assertions and the reasoning originally offered by the DOC. By this point, I am quite confused as to what the United States really is arguing.

5. I hope that the Panel does not share this confusion. But, in the end, whatever confusion there may be in the US arguments is irrelevant. The issue before this Panel is not whether the United States can now come up with creative new explanations for the DOC's actions. Those explanations are nothing more than post hoc justifications that should be ignored. In keeping with the standard of review applied by Panels in past anti-dumping cases such as Corn Syrup and Polyacetal Resins, the Panel should base its analysis of the issues in this case on the reasons announced in the DOC's final determinations.¹ I will do my best, therefore, to focus my attention on the DOC's final determinations, and not on the subsequent rationalizations the US has offered.

6. In the same vein, I would offer another introductory observation. Throughout the final round of US submissions, there is a suggestion that POSCO is somehow to blame for the unfair actions taken by the DOC. The United States seems to imply that, if POSCO had only been a little more forthcoming in providing certain critical information, the DOC's determinations might well have been different. This is an improper argument to make post hoc, when it is too late for POSCO to do anything about it. It would have been a very different thing if the DOC had informed POSCO during the investigation of these alleged deficiencies in its information. The truth is that POSCO itself identified the key issues in this case to the DOC. It told the DOC what the issues were and how it thought the issues should be resolved. It provided to the DOC all of the information that the DOC had deemed relevant in addressing similar situations in past cases.

7. The final sentence of Article 2.4 of the Anti-Dumping Agreement specifically provides that "The authorities shall indicate to the parties in question what information is necessary to ensure a fair comparison and shall not impose an unreasonable burden of proof on those parties."² Having failed to do so, the United States cannot now argue at the very final stages of a Panel proceeding that it was the respondent that did not submit sufficient information.

8. Let me turn now to the substantive issues in the case.

A. UNPAID SALES

9. I will begin with the US treatment of POSAM's unpaid sales to the "ABC Company." To begin with, it should be noted that there are no facts in dispute with regard to this issue. It is undisputed that POSAM made sales to the ABC Company, that POSAM was not paid for some of those sales, and that the Commerce Department accounted for these unpaid sales by either reducing POSCO's export price or increasing POSCO's normal value - which have exactly the same effect on the dumping analysis - for all of POSCO's US sales.

10. The Commerce Department's treatment of the unpaid sales was flawed in numerous respects. Of these, I shall focus on two. First, as we have shown previously, the US treatment of the unpaid sales was inconsistent with the rules governing allowances for differences affecting price comparability. And, second, the US treatment of the unpaid sales was inconsistent with the "fair comparison" requirement of the Anti-Dumping Agreement.

1. Permissible Allowances for Differences Affecting Price Comparability under the Third Sentence of Article 2.4

11. In its final determinations in the Plate and Sheet cases, the DOC classified the cost of the non-payment for the unpaid sales as a "direct selling expense." Under US law, this meant that the expenses would be included in the "circumstance-of-sale adjustment." (And, I would note here that the United States has since told this Panel that a "circumstance-of-sale adjustment" is the US law equivalent of an allowance for "differences affecting price comparability" under the third sentence of Article 2.4.) The DOC explained that its treatment of the cost of non-payment as a "direct" expense was appropriate because "but for the sale made to the bankrupt customer, the bad debt expense would not have been incurred."³ Significantly, the DOC did not indicate that the so-called "bad debt" was a consequence of any of the "conditions and terms" of the sale.

12. Korea's first submission addressed the permissibility of the adjustment for the cost of non-payment under the third sentence of Article 2.4, because that is the provision logically connected to the DOC's final determinations. By calling the cost of non-payment a "direct" selling expense, the DOC implicitly invoked that provision. And, because the DOC's final determination had not identified any differences between the home-market sales and the US unpaid sales in the "conditions and terms of sale, taxation, levels of trade, quantities, [or] physical characteristics," Korea specifically addressed the applicability of the final phrase of the third sentence of Article 2.4 - which permits adjustments for "any other differences which are also demonstrated to affect price comparability."

13. In its first submission, Korea demonstrated that the adjustment for the cost of the unpaid sales was not permissible under that standard for two reasons: First, as a procedural matter, the cost of the unpaid sales had not been demonstrated to affect price comparability. Second, as a substantive matter, it was simply not possible for such a demonstration to be made. Because the prices for the sales were fixed before POSCO knew that the customer would not pay, the cost of the unpaid sales could not have affected the prices or price comparability of the sales under consideration.⁴ As I mentioned at the outset, these are straightforward issues.

14. The United States did not choose to defend the DOC's determination on the grounds actually stated by the DOC. Instead, it has raised a variety of post hoc arguments. Let me try to summarize them:

• First, in its first submission and in its first oral statement, the US argued that the adjustment for the cost of non-payment was not an adjustment for a direct selling expense as a "circumstance of sale adjustment," but was instead an adjustment made to construct an export price under Article 2.3 of the Anti-Dumping Agreement. In response to Korea's questions, however, the United States belatedly admitted that it had made the same adjustment for the direct sales to unaffiliated US customers. With that admission, the US argument simply falls apart.

• Second, the United States also argued in its first submission that, if the adjustment for the cost of non-payment had to be analyzed under the third sentence of Article 2.4, it could be justified as an adjustment for a difference in the conditions and terms of sale in the two markets. In its oral statement, the United States revised its position and argued that, although the actual non-payment was not a condition or term of sale, the risk of non-payment was a direct consequence of the decision to grant sales terms that allowed the customer to delay its payment. This position was modified yet again in the most recent US submissions, where the United States argued that the actual current cost of unpaid sales was the only practical measure of the risk of non-payment - and that, in any event, POSCO was to blame if the record of the Plate and Sheet investigations did not contain any further information on the risk of non-payment in the two markets.

• Third, in its first oral statement, the United States argued that the adjustment for the cost of unpaid sales was analogous to the adjustments normally made for warranty expenses.⁵ However, after we pointed out in our questions that the DOC normally makes the adjustment for warranty expenses based on historical experience, the analogy to warranty expenses disappeared from the US second submission.

15. I will address each of these issues in turn as briefly as possible. In the end, however, I would hope that the complications of these arguments will not distract the Panel from the fundamental point: No matter how convoluted the US arguments may be, they are ultimately irrelevant. They do not address the fundamental issues - that is, whether the DOC's determinations and the rationales given by the DOC for those determinations are consistent with the requirements of the Anti-Dumping Agreement.

(a) Article 2.3

16. I will start with the contention that the adjustment for the cost of non-payment was justified as an adjustment to "construct" an export price under Article 2.3 of the Anti-Dumping Agreement.

17. Let me begin by recapping the key undisputed facts. In both the Plate and Sheet cases, POSCO made some "indirect" sales to US customers through its affiliated US importer POSAM. It also made some "direct" sales that were sold directly to unrelated US customers without the involvement of POSAM. The adjustment for the cost of unpaid sales was made for comparisons involving both categories of sales: The adjustment was deducted from the final US sales price for comparisons involving the sales through POSAM. For comparisons involving the direct sales, the adjustment was not deducted from the US price, but was instead added to normal value. The amount of the adjustment was in both cases calculated in precisely the same manner. And, because a deduction from US price has the same effect on the dumping margins as an addition to normal value, the net effect of both adjustments was the same.

18. I know I keep returning to the fact that the US made the same adjustment for the cost of non-payment to both the direct export price sales and the indirect constructed export price sales. I apologize for the repetition. But the point is fundamentally important.

19. To begin with, at the absolute minimum, the fact that the DOC made the adjustment for the cost of non-payment to the direct sales means that the Article 2.3 defense is at best incomplete. The adjustment made to the direct export price sales cannot possibly be justified under Article 2.3, because Article 2.3 only applies to indirect sales through an affiliated importer, and it does not apply to direct sales. The adjustment made to the direct sales must, therefore, be justified, if at all, under the provisions of the third sentence of Article 2.4 addressing "allowances for differences affecting price comparability."

20. Moreover, the fact that the adjustment was made to the direct sales also eliminates the viability of the Article 2.3 defense for the adjustment made to the indirect sales as well.

21. In this regard, three important points should be noted:

•  First, the third sentence of Article 2.4 (which describes the allowances for "differences affecting price comparability") does not distinguish between direct and indirect export sales. Instead, the third sentence applies equally to all export transactions.

• Second, the fourth sentence of Article 2.4 (which provides concrete guidance on the adjustments permitted when constructing an export price under Article 2.3) is not independent of the third sentence. It does not describe an entirely separate scheme for making adjustments. Instead, it describes adjustments that should "also" be made to construct an export price for sales through an affiliated importer. The use of the word "also" in this sentence is highly significant. It means that the adjustments for differences affecting price comparability under the third sentence of Article 2.4 are to be made to all export sales, including both the direct sales and the indirect sales. Only after those adjustments have been made, should the additional adjustments to construct the export price "also" be made.

• Third, the fourth sentence of Article 2.4 does not permit adjustments for all costs incurred by the affiliated importer. Instead, it permits an adjustment only for costs incurred between importation and resale. The cost of non-payment does not occur between importation and resale. As both a temporal and functional matter, payment (or non-payment) cannot occur until after the resale has been made. I certainly am not aware of any definition of the term "between" that would encompass events that occur after resale.

Thus, a careful review of the text of the Agreement reveals that the cost of non-payment cannot be an appropriate adjustment to construct the export price under the fourth sentence of Article 2.4.

22. It should also be noted that the US defense cannot be reconciled with the objective and purpose of Article 2.3. As explained in Korea's second submission, where the exporter sells to an affiliated importer, Article 2.3 permits the investigating authorities to construct what an arm's-length price would be from the exporter to a hypothetical importer standing in the same point in the transaction as the actual affiliated importer. (A diagram illustrating this idea was provided at paragraph 57 of Korea's second submission.)

23. The purpose of the Article 2.3 adjustments, then, is to use the affiliated importer's resale price as the basis for constructing this hypothetical arm's-length price to a hypothetical unaffiliated importer. (In the diagram, the concept is to construct price A from the known price B.) Only costs that the hypothetical unaffiliated importer could have passed back to the exporter should be included in this calculation. If the hypothetical unaffiliated importer would have had to "eat" the costs, then it is not consistent with the purpose of Article 2.3 to deduct those costs from the resale price to construct the export price.

24. The actual non-payment by the resale customer is the type of cost that the hypothetical unaffiliated importer would have to "eat." The cost of the non-payment would not affect the price that the exporter charged this hypothetical importer, because that price would have been fixed before the non-payment could ever have occurred. Since the export price from the exporter to the hypothetical unaffiliated importer would not have been affected by the final customer's ultimate non-payment, there is no basis for deducting the cost of non-payment by the final customer when constructing the export price.

(b) Allowances for Differences in Conditions and Terms of Sale and Other Differences Affecting Price Comparability

25. As mentioned, the United States' second post hoc argument is that the adjustment for the cost of non-payment was permissible as an allowance for differences in the "conditions and terms of sale." In particular, the first US initial submission asserted that the non-payment itself was the relevant "condition or term of sale."⁶ That argument was plainly absurd: No contract contains terms authorizing a customer to go bankrupt and refuse to pay. To the contrary, contracts require payment in accordance with specified terms and conditions. Non-payment is a breach of the sales contract.

26. In its first oral statement, the United States retreated from this ludicrous position. Its revised position was that, by agreeing to extend credit to the customer, POSCO accepted a risk of non-payment. The US asserted that, because this risk was a direct consequence of the contractual terms that allowed the customer to delay payment, the risk could be included in the allowance for the delayed payment terms of the sale.

27. This fallback position is also flawed. Even if one assumes that the risk of non-payment is part of the "conditions and terms of sale," this new US argument faces an insuperable obstacle: The Commerce Department did not make an adjustment for differences in risk of non-payment. Instead, the Commerce Department adjusted for the full costs of the actual non-payments by the ABC Company - which is a very different thing.⁷

28. So, how does the United States attempt to reconcile its legal argument with the adjustment it actually made? In its very latest round of submissions, the United States now contends, in essence, that the difference in "actual bad debt expenses" is a proxy for differences in risk. It even claims that adjusting for actual non-payments is "the only practical means of making due allowance for any difference in bad debt risk."⁸ This latest argument by the United States does not withstand scrutiny.

• To begin with, this latest US argument is entirely a post hoc rationalization. The DOC did not make any finding that the risk of non-payment was higher in the United States than in Korea. Instead, its decision to treat the cost of non-payment as a direct selling expense was based solely on the fact that the non-payment in the United States was a direct consequence of the fact that POSCO sold to the ABC Company. As I noted at the outset, the Panel should not allow the United States now to substitute new reasoning for that actually employed by the investigating authority.

• Moreover, this post hoc rationalization has absolutely no support in the record of the investigations. There was no evidence of any difference in the terms of the home-market and US sales that made it more likely that US customers would default. Furthermore, there was no evidence that, at the time POSCO set its prices during the investigation period, it had any reason to believe that its risk of non-payment was higher in the United States than in Korea.

• More generally, there is no reason to believe that the actual non-payments in a single market in a single year will correspond to the risk of non-payment. In any given year a large default by a single customer in one market could lead to a large difference in actual non-payments. A deduction for differences in "actual bad debt expenses" in a given year may grossly overstate the true differences in risk. Simply put, the adjustment made by the DOC confused the small risk of being hit by lightning with the large damage that is caused if one happens to be one of the few people hit. The United States essentially adjusted for differences in actual ex-post insurance claims for lightning damage during a single year, when it should have adjusted for differences in the premiums to buy a lightning insurance policy ex-ante for that year.

• The US confusion about actual occurrences and risks is well illustrated by the following US argument:

during the period of investigation, POSCO actually recognized greater bad debt expenses, as a proportion of sales, in the US market than in the Korean market. This evidence would indicate that POSCO should be charging higher prices in the US market due to the greater proportion of bad debt expenses."⁹

This argument plainly confuses the fact that an event actually happened with the question whether it was known beforehand to be likely to happen (or, in this case, relatively more likely to happen in the United States than in Korea). The United States assumed that because something happened, POSCO should have known that it was going to happen and raised its prices accordingly. In fact, however, as the United States concedes, "there was no evidence in either case that POSCO had any knowledge at the time of sale that ABC Company was in precarious financial condition."¹⁰ This is simply a case of 20-20 hindsight.

• Finally, I note that the latest US submissions offer a new argument based on accounting principles to support its use of "actual bad debt expenses" as a proxy for risk of non-payment. The United States claims that:

"[I]n accordance with GAAP, companies normally account for bad debt through a reserve accounting method that is based on the company's experience. Therefore, the bad debt expenses reflected in a company's accounting records for a particular market provides a reasonable measure of the price effect of the risk of bad debt in that market....

"As discussed above, companies normally account for bad debt using a reserve accounting method that is based on the company's historical experience. Under a reserve accounting method, the bad debt expense recognized in a given period reflects that experience."¹¹

This argument does not support the US case. It is true that many companies do use "bad debt reserves" - which are based on estimates in light of historical experience. But the United States has expressly conceded that "POSAM did not use a bad debt reserve"¹² and "POSAM's accounting methodology was not based on experience."¹³ This was consistent with the fact that POSAM had never before had a non-payment in the United States.¹⁴

On the other hand, POSCO did use a bad debt reserve and it did calculate the amount of the reserve based on historical experience. Nevertheless, the DOC refused to make an adjustment for differences in terms and conditions of sale based on POSCO's records.¹⁵ In other words, the accounting principles the United States now cites would have required the DOC to make an adjustment for POSCO's bad debt reserve but not for POSAM's actual costs. That is, of course, precisely the opposite of what the DOC did.

29. Thus, an adjustment for an actual non-payment cannot be accepted as a proxy for differences in the risk of non-payment.

(c) Bad Debt and Warranty

30. In its first oral statement, the United States also made the argument that the adjustment for the cost of unpaid sales was analogous to the adjustments normally made for warranty expenses.¹⁶ However, after Korea pointed out that the DOC normally makes the adjustment for warranty expenses based on historical experience, the analogy to warranty expenses was very much down-played in the second US submission.

31. I must confess that I was very sorry to see this analogy withdrawn. To me, it describes precisely what was wrong with the US claim that its adjustment measured differences in the risk of non-payment in the two markets.

32. The United States has asserted that it used the cost of non-payment during the current year as a "slice of time" to determine the risk of non-payment.¹⁷ It asserts that this approach is "the only practical means" of measuring risk.¹⁸ And, it suggests that POSCO is to blame if more complete information was not available. But the analogy to warranty expenses demonstrates that these US assertions are simply false.

33. For your reference, I have handed you pages on which I have reproduced the instructions the DOC gave POSCO regarding the reporting of warranty expenses and bad debt expenses.¹⁹ As you can see, the DOC explicitly asked POSCO to provide historical warranty expenses data for a three year period. By contrast, the DOC simply did not ask POSCO to provide information on the risks of non-payment in the two markets. So, when the US states that it had no information to make a proper adjustment for the risk of non-payment in this case, it is only reflecting the fact that it gave POSCO absolutely no instructions on what information was required.

34. The United States implicitly seeks to reverse the applicable burden here, by asserting that POSCO never provided any historical data.²⁰ It is plain, however, that the burden was on the United States to ask for the data needed to determine what adjustments to make.²¹ Since the United States did not ask for historical data on non-payments, it cannot now justify its use of actual non-payment as a proxy for risk of non-payment by claiming that the record was insufficient to allow it to measure the risk of non-payment in any other way.

2. The Fair Comparison Requirement

35. As explained in Korea's previous submissions, the "fair comparison" requirement of the first sentence of Article 2.4 establishes a separate and free-standing obligation. Moreover, while the precise contours of this "fairness" requirement may be difficult to draw in the abstract, two points at a minimum are undisputable: First, it is not fair to penalize an exporter by including "atypical" sales that distort the results in the analysis. Second, it also is not fair to penalize an exporter for an event that it could not have anticipated and that was beyond its control. Indeed, as noted in Korea's submissions, the US courts have defined the "fairness" required in the dumping analysis under US law in precisely this manner.

36. The DOC's treatment of the unpaid sales plainly was not consistent with these standards. It unfairly included in the analysis US sales that were, by the DOC's own admission, "atypical" and that distorted the calculations. Moreover, its adjustment for the cost of the unpaid sales unfairly penalized POSCO for an event that was beyond its control.

37. In response, the United States has attempted to read the "fair comparison" requirement out of the Anti-Dumping Agreement altogether. It argues that the fair comparison requirement of the first sentence of Article 2.4 must be deemed to be met whenever the methodologies described in the remaining sentences of that Article have been followed.

38. That argument is, however, without merit. The first sentence of Article 2.4 explicitly provides that "A fair comparison shall be made between the export price and the normal value." That sentence must have substance and meaning. Any other interpretation would improperly render that sentence "inutile."²²

39. In the interests of time, I will not address the US arguments concerning the relationship between the Tokyo Round Code and the current version of Article 2.4 in detail. Let me just say that the argument presented by the United States is absurd on its face. To accept the US argument, one would have to believe that all of the provisions of Article 2:6 of the Tokyo Round Code were discretionary - including those requiring allowances for differences affecting price comparability.²³ Such an interpretation cannot be correct, because it contradicts the provisions of GATT Article VI, which made such allowances mandatory.

B. MULTIPLE AVERAGING

40. I shall turn now to the second of the three main subjects at issue: The US decision to split the period of investigation, calculate separate averages for each sub-period, "zero out" the averages for sub-periods with "negative margins," and then combine the multiple averages into a distorted overall average.

41. There are no facts in dispute with respect to this issue. It is undisputed that the United States engaged in "multiple averaging." It is also undisputed that this methodology led to a higher dumping margin than would have been calculated under a single-average methodology. Finally, it is undisputed that the United States adopted this methodology because it concluded that, without multiple-averaging, the depreciation of the Korean won during the period would have resulted in the calculation of dumping margins that were too low.

42. The only question is whether that methodology is permitted under the provisions of the Anti-Dumping Agreement. I believe, once more, that the issue is straightforward. For the reasons set forth in our previous submissions, this multiple-averaging methodology is directly contrary to the requirements of Article 2.4.2. It is also inconsistent with the provisions of Article 2.4.1. And, it violates the fair comparison requirement of Article 2.4.²⁴

1 See Responses of the Republic of Korea to the Questions Posed by the Panel at the First Meeting, at 1-2 ("Korea�s Responses to Panel Questions").

2 See also Anti-Dumping Agreement, art. 6.1 ("[a]ll interested parties in an antidumping investigation shall be given notice of the information which the authorities require....").

3 SSSS Final Determination, at 30674 (ROK Ex. 24); see also SSPC Final Determination, at 15448-49 (ROK Ex. 11).

4 See Korea�s First Submission, paras. 4.17 - 4.19.

5 US First Oral Statement at paras. 14-15.

6 See US First Submission, para. 82 ("The United States interprets differences in �conditions and terms of sale� as including differences in selling expenses such as bad debt.") (emphasis added).

7 See US Responses, para. 78; Korea�s Second Submission, paras. 60-68.

8 See US Responses, paras. 78, 80.

9 See US Responses, para. 24.

10 See US Responses, para. 12.

11 See US Responses, para. 80-81 (emphasis added).

12 See US Responses, para. 82.

13 US Second Submission, para. 35.

14 See Korea�s Responses Panel Questions, at 9-10 (Response C.3).

15 See US Second Submission, para. 37.

16 US First Oral Statement, paras. 14-15.

17 See US Second Submission, para. 34; US Responses, paras. 81-82.

18 See US Responses, paras. 78, 80.

19 These passages are taken directly from the DOC questionnaires to POSCO in the SSPC and SSSS cases, which were reproduced in POSCO�s questionnaire responses. See SSPC Questionnaire Responses, at B-34, and C-38 to C-39 (ROK Ex. 87); SSSS Questionnaire Responses, at B-35 and C-38 (ROK Ex. 88).

20 See US Responses, at para. 82.

21 See Anti-Dumping Agreement, art. 2.4 (".... The authorities shall indicate to the parties in question what information is necessary to ensure a fair comparison...."); Id., art. 6.1 ("All interested parties in an anti-dumping investigation shall be given notice of the information which the authorities require....").

22 See Korea�s Second Submission, paras. 77-83.

23 See US Responses to Panel Questions, para. 3 ("One possible reading of this language was that the fair comparison was not required, but if a member wished to make one, it should do so as instructed in Article 2.6. Thus, all of Article 2.6 could have been read as non-mandatory." (emphasis added)).

24 See Korea�s First Submission, paras. 4.43 - 4.63.

To continue with 1. Article 2.4.2

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