The Albemarle Corporation submitted IL 141905 on 8 March 2001, as the National Phase of PCT/IL1999/020848 which published as WO2000014125 and claims priority from three separate US applications: 09/151194 from 10 September 1998, US 09/151193 from 10 September 1998 and US 09/170487 from 13 October 1998.
The application was allowed and published for opposition purposes on 8 March 2009. On 23 April 2009, Tirkovet Brome (Bromium Compounds) submitted an Opposition.
The name of the Application is “Improved brominated polystyrenic resins and their use”. The Application describes brominated polystyrenic resins which serve as fire retardant when combined with other plastics. As explained by Professor Gad Marom in his Expert Witness Statement on behalf of the Applicant, plastics are carbon based polymers that are inflammable and may be dangerous, since they release poisonous gases on combustion. Consequently, safety standards require that plastic products include fire retardants or are coated with a fire inhibitor. Brominated polystyrenes are incorporated in plastic products to slow down the spread of fire. One of the properties of these polymers is their delta ∆E color value. The parties do not disagree that the minimization of the ∆E color value (page 12 lines 2-10) is something desirable and aimed for by persons of the art.
The claims were amended during the proceeding and the following claims were approved in an Interim Commissioner Ruling of 12 November 2014 concerning amending the specification. The claim set includes 86 claims. The following are the independent ones:
- A brominated styrenic polymer that has ∆E solution value of said polymer if dissolved at the level of 10 wt% in chlorobenzene in the range of from about 3 to about 15, an ionic bromine content of 2000 ppm or less, and at least two of the following additional characteristics:
a) A TGA temperature for 1% weight loss which is 340°C. or higher and A chlorine content, if any, of less than about 700 ppm Cl,
b) An actual M w which is within about 20% of its calculated theoretical M w , the theoretical M w being based upon the actual bromine content of the brominated styrenic polymer and the M w of the styrenic polymer reactant used to produce the brominated styrenic polymer,
c) Essentially no content of impurities selected from the group consisting of bromodichloroethane, dibromochloroethane, dibromodichloroethane, and tribromochloroethane.
- A brominated polystyrene characterized in that it has:
A) An ionic bromine content of 1000 ppm or less;
B) A TGA temperature for 1% weight loss which is 340°C. or higher;
C) A chlorine content, if any, of less than about 100 ppm Cl;
D) A thermal stability in the Thermal Stability Test of 1500 ppm HBr or less;
E) An actual M w which is within about 20% of its calculated theoretical M w , the theoretical M w being based upon the actual bromine content of the brominated styrenic polymer and the M w of the styrenic polymer reactant used to produce the brominated styrenic polymer; and
F) Essentially no content of impurities selected from the group consisting of bromodichloroethane, dibromochloroethane, dibromodichloroethane, and tribromochloroethane.; and
G) ∆E solution color value of said polymer if dissolved at the level of 10 wt% in chlorobenzene in the range of from about 3 to about 15.
- A composition which comprises a thermoplastic polymer having blended therewith at least a flame retardant amount of brominated styrenic polymer having, prior to blending, a total bromine content of about 50 wt% or more, a TGA temperature for 1% weight loss which is 340°C. or higher, and a chlorine content, if any, of less than about 700 ppm, and a ∆E solution color value of said polymer if dissolved at the level of 10 wt% in chlorobenzene in the range of from about 3 to about 15.
- A composition which comprises a thermoplastic polymer having blended therewith at least a flame retardant amount of brominated styrenic polymer having, prior to blending, a total bromine content above about 50 wt%, and a thermal stability in the Thermal Stability Test of 200 ppm HBr or less, and a ∆E solution color value of said polymer if dissolved at the level of 10 wt% in chlorobenzene in the range of from about 3 to about 15.
The first aspect is claimed in independent claims 1 and 23 and refers to brominated styrenic polymer with a good color, a low bromium ion content (Br-) and two of the following three conditions: a specific thermal stability, a specific molecular weight and a lack of impurities. Professor Marom clarified in Section 58 of his opinion that claim 23 claims a low corrosion potential. This aspect is supported by Example 14.
The second aspect of the invention is supported by claim 27 and relates to brominated styrenic polymer with a bromium content of 60-66%, a low chlorine content and a good fuse rate, and a low corrosion potential. This aspect is supported by Example 23.
The third aspect of the invention is claimed in claims 48, 56 and 76. This aspect relates to the combination of brominated styrenic polymer in the thermoplastic composition. The required properties are an improved color, the bromium content, thermal stability and low chlorine content in claim 48; a high bromium content, a low corrosion potential and good color in claim 56, and a high bromium content, good color and one of thermal stability, low chlorine content, low free available bromium for hydrolization, low chlorine content, and low corrosion potential in claim 76.
The Opposer’s Main Objections
The Opposer alleges that the claimed patent lacks novelty as required by Section 4 of the Patent Law, since the claimed polymers are identical to those of US 5,677,390. The Opposer alleges that following the methodology described in that patent will lead to the polymers claimed in this application.
The Opposer further alleges that the differences in the color of the polymer (∆E color) are insignificant and are obtained when following the method of US 5,677,390.
The Opposer further alleges that the patent application claims polymers that were already protected in Israel in IL 138975, and so there is an overlap between these publications. They allege that the claimed polymers are already claimed in previous patents, but that they are claimed with relation to different properties in each publication.
The Opposer submits that the examples of the ‘975 patent are identical to those of the Application and so the claims, which are based on the same examples, claim the same material. In this regard, the Opposer notes that he is referring to claims 1-54 of the patent, and these do not necessarily include a stabilizer as the addition is found in a concentration of “less than about 1%”.
The Opposer raises various issues relating to the sufficiency of the specification and the clarity of the claims. The Opposer alleges that the invention is not claimed in a manner that persons of the art can implement since the ∆E color does not allow characterization of the claimed polymers. He alleges that he has proven that the average person of the art in the field cannot know the conditions under which the claimed polymer will display the identifying characteristics and under which conditions a polymer without the desired properties will be obtained.
The Opposer alleges that Claims 76-79 do not claim a specific intrinsic property, but rather that the hydrolysable bromine as claimed may be measured using the ‘hydrolysable bromine test’ which was not described. The Opposer further alleges that the ∆E value of 3 is impossible to achieve, but is nevertheless claimed, when in fact one can only achieve something in the range of 3-15 on a random basis. The Opposer further alleges that the tests described in application for testing bromium content of the polymer leads to a 50% error in the readings and so the results obtained are unreliable.
The Opposer further alleges that the applicant has demonstrated and is claiming advantages such as low chlorine, minimal impurities (see C and F of claim 23) that are imaginary advantages, since these impurities are not found in the claimed polymers anyway.
Finally, the Opposer alleges that the Applicant wrongfully obtained allowance under Section 17c.
The Applicant’s Main Claims
The purpose of the claimed invention is to obtain flame retardants with a high bromium content but which are thermally stable, i.e. those that will maintain their flame retarding properties at temperatures over 300ºC. However, high levels of brominization adversely affects the color and makes it difficult to mix the bromium flame retardant with the host plastic. Improving a number of properties in parallel is challenging and how to do so is not trivial.
The invention has three different aspects as follows:
- The first aspect (as claimed in clams 1 and 23) and the claims dependent thereon, relate to examples 16 and 17 of the Application and describe and claim brominated polystyrenes with low levels of free bromium ions and good color.
- The second aspect (claim 27 and the dependent claims and examples on page 42, examples 23-30 of the Application) describe and claim brominated polystyrene with high bromium content, low chlorine levels, and a molecular weight of between 500 and 800 kD, a better flow and a low corrosive potential.
- The third aspect of the invention, as described and claimed in claims 48, 56, 76 and their dependencies, describes and claims the composition of a thermoplastic polymer that includes brominated polystyrene as a fire retardant.
The Applicant claims that all the Opposer’s opposition is focused on the first aspect and is irrelevant to the additional aspects.
The Applicant further states that to get from the examples of the ‘390 patent to the claimed polymers as given in the examples of table 2 of the opposed Application, it is necessary to do further testing. Thus it is submitted that the ‘390 patent does not render the first aspect of the invention as lacking novelty; the infringement test in this regard being that for a single publication to cancel novelty, effecting the publication has to result in the later invention.
The Applicant submits that the Opposer has not reached this level of proof, and applying the ‘390 patent does not necessarily result in the claimed polymers. The Applicant further submits that that the Opposer themselves concede that examples 5 and 6 are beyond the claims since they obtain ∆E values beyond the range.
The Applicant further submits that one has to compare between the processes of specific examples, and not between general processes for creating polymers, since such processes include a massive range of alternatives. They claim that the present application includes process stages that are not mentioned in the ‘390 patent.
Furthermore, the Applicant claims that the ‘390 patent does not rule out inventive step from the present application.
As to the allegation that the invention claims non-existent advantages, the Applicant counters that the claimed advantages are real, since previous processes used chlorine and other solvents which resulted in impurities and chlorine within the product.
The Applicant claims that that the alleged overlap between the Israel patent and the present application only relate to claim 1 and its dependencies. In this regard, the Applicant claims that the examples of the ‘975 are for the starting material to which the thermal stabilizing additive of ‘975, is added. In the present application these are examples of the invention itself. This additive is not found in the claims of the Application under discussion, and consequently, there is no overlap between the ‘975 patent and the present patent application. The Applicant also clarifies that the present application does not have to use the materials of the ‘975 patent, which are anyway thermally stable. The Applicant claims that Dr. Zvieli acknowledged in his cross-examination that these are different inventions, and that examples 11-24 of the ‘975 patent are only the raw materials that the process of the claimed invention uses. The Applicant stresses that the different claim and the examples of the ‘975 patent include ingredients that do not fulfill the high standards of the application.
The Applicant responds to the accusation of insufficient description with regard to measuring the ∆E value by stating that this is a standard method and it is not possible that different measurements will result in vastly different results. The relevant example is Example 14 which is included in the claims and not examples 16 and 17 which are not relevant. These examples are intended to help the person of the art in field, as they indicate the result when adjusting the various parameters, such as temperature, for example.
As to the allegation that the hydrolysable bromine content is not defined, and that claims 76-79 are unclear, the Applicant responds that this methodology is known to persons of the art at the priority date. Furthermore, the applicant notes that in many examples of the application this was not challenged as those that support claim 76 were not measured.
As to the claims that the value of the ∆E of 3 is not attainable, this was contradicted by the testimony of Professor Marom relating to the amendment to the specification. The claim that this number was chosen randomly was dismissed by the Commissioner in the interim ruling concerning the amendments to the specification. Furthermore, the Applicant notes that reason for choosing a certain range does not have to appear in the specification.
As to the claim that Section 17c was wrongfully invoked, this was neither detailed nor substantiated, and is not relevant at this stage of the procedure.
Dr. Michael Zvieli testified on behalf of the Opposer. He has a PhD in Chemistry and much experience in R&D. Also on behalf of the Opposers, is Professor Lamkof, the head of the Chemistry Department in Ben Gurion University.
The Applicants were represented by Professor Gad Marom who has a PhD in polymers, and served as the Dean of the Mathematics and Natural Science Faculty of the Hebrew University and was a Professor of Applied Chemistry until 2013. The Expert Witnesses were cross-examined at two hearings before the Commissioner.
The requirement for novelty is found in Section 3 of the Patent Law and it is defined in Section 4 as follows:
An invention is considered new if it has not been published, in Israel or abroad, prior to the date of the Application:
- By description, in writing or by exhibition, or orally, or in any other manner, in a way that a person of the art can exploit the invention in its details; or
- (2) by utilization or demonstration in a manner that a person of the art can by the details revealed to him in this manner.
It is a general rule that claims will be considered as lacking novelty if there is a single publication that reveals all its details such that a person of the art can perform the invention. See Civil Appeal 345/87 Hughes Aircraft Company vs. State of Israel, page 105, 2 July 1990. In this regard, one should note that a publication is not considered as novelty destroying, unless all the properties of the examined invention appear in one single publication such that one can learn how to achieve the invention from it.
A first general rule is that for a piece of prior art to be considered a previous revelation that is novelty destroying, one has to be able to point to a document that includes the entire invention, and not create a mosaic of knowledge collected from different and separate documents to create a general picture…
A general description is insufficient, if one cannot learn how to perform the invention from it, and signposts that show the way are not enough….
The Opposer considers that all the aspects of the invention are described in the’390 American patent, which is certainly prior art to the priority date. In Dr. Zviel’s opinion, a comparison between the processes of the application and those of the ‘390 patent show that the processes are identical in their chemical characteristics regarding the active ingredients, the order of their addition, the solvent, the reaction period, the temperature and the post-reaction treatment.
In contrast, Professor Marom claims that the process described in the ‘390 patent is for a general process, wherein the preferred ranges of the reaction period finishes at the exact point that the ‘390 patent starts.
Examination of page 21 lines 2-10 of the present Application show that the recommended reaction time is from 5 minutes to two hours, or from 5 minutes to one hour. However, further on the Application notes that possibly there will be a need for a longer period and this depends on the extent of bromination when the reactant is added, and on the amount of bromination desired. In the ‘390 patent, it is advised for the reaction time to be between 30 minutes and six hours and is preferably over 3 hours. Examination of the examples of the ‘390 patent show that the reaction generally lasted two hours, and in examples 8-21 it lasted 35 minutes. In examples 1-3 it lasted two hours.
Professor Marom also noted the temperature difference. In the ‘390 patent, the temperature was from -5º to 10ºC. In practice, the reaction took place at 0º-5 ºC in the first example, and at 5ºC in the second example. In examples 8-21, the reaction took place between -10º to 20ºC, but those performed at 20ºC did not fulfill the conditions of the claims.
A further difference that Professor Marom noted (paragraph 102 of his Opinion) was that the two processes had different separation stages (decanting), which appears in the present application, but is missing from the ‘390 patent. However, examination of the ‘390 patent shows that this stage appears in column 8 lines 3-11:
“After the cook period, the reaction mass can be treated with water, sodium sulfite, sodium gluconate and sodium hydroxide to deactivate the catalyst, kill any remaining brominating agent and to adjust the reaction mass pH.
After these treatments, the reaction mass is settled to obtain a two-phase reaction mass containing an organic phase, which contains, as a solute, the brominated styrenic polymer product, and an aqueous phase. The aqueous phase is decanted and the remaining organic phase is stripped of its solvent component.”
The Applicant alleged that the fact that these stages is found in the ‘390 patent is a new legal issue that was first raised in the summation response and therefore asked to strike it from the record or to allow them to respond. However, the Deputy Commissioner Ms Jacqueline Bracha did not accept that this was new, since the witnesses of the Opposer claimed throughout the proceedings that the differences between the processes were insignificant. Furthermore, examination of the text of the ‘390 patent is sufficient to show that its language is similar to identical to that used in the present application.
Consequently, Ms Bracha dismisses the differences noted by Professor Marom as being insignificant. Firstly, there are a number of experiments that were conducted at 0ºC, i.e. within the range discussed in the ‘390 patent. Indeed, the first example of the ‘390 patent occurred in the range of 0-5ºC, so the difference that the Applicant noted is not a distinguishing feature. The difference in cooking time is also not a novelty destroying feature. The range from half an hour to six hours includes the 45 minutes given as the cooking time in examples 8 to 21.
It will be noted that the first aspect of the invention is not directed to a process, but rather is directed to materials with a specific range of properties. Thus if it were possible to attain these products by a different process prior to the priority date, then the product would not be new and the best case for patentability would be for a new process for making these products. Thus even if the Applicant’s process is new with respect to that of the ‘390 patent, and the Deputy Commissioner disputes this, if the products are the same, they cannot be protected.
The products of the ‘390 patent are described in the examples. The Applicant noted that the color quality (∆E <15) that was obtained in the ‘390 patent were not claimed. This was given as evidence that the product is not the same. In Example 2 of the ‘390, patent, the product obtained had a color quality (∆E) of 16.44. The Opposer alleges that this difference is insignificant, and the property is not accurately measurable, and the same polymer can give different results. The Deputy Commissioner thinks the Opposer is correct; Professor Marom was unable to explain the differences in readings of this property and so Ms Bracha was not convinced that a small difference in this property is indicative of a different product. (See protocol of hearing of 29 January 2017).
In light of the above, the Deputy Commissioner rules that the first aspect is anticipated by the ‘390 patent.
As Professor Marom explained in paragraphs 63 to 67 of his Opinion, the third aspect of the invention relates to thermoplastic compositions that include admixed brominated styrene flame retardants having desired properties. In the parent application, it was clarified that these are the same brominated styrene flame retardants that were prepared in accordance with the first aspect of the invention. The properties of the brominated styrenes claimed in claims 48-86 are those appearing in tables 1 and 2 of the Application. After ruling that the ‘390 patent anticipates the first aspect, it follows that the third aspect cannot be novel, since the combination of the fire-retardant as an admixture to other polymers is known, and is the purpose of the flame retardant as explained by Professor Marom himself (paragraph 17 of his Opinion). Thus the ‘390 patent is novelty destroying for claims 48-86 as well.
As to the second aspect of the invention, the Opposer alleges that it lacks novelty, since it is described in US 08/852,462 (see Opinion of Dr. Zvieli, page 3). In the Hearing it transpired that the Application was only published on 12 November 1998 as part of the publication of the international application. The relevant date for this application is 13 October 1998, which is a month before the US patent application was published. Thus this publication does not anticipate the second aspect of the invention which is based on Example 23 of the Application.
Dr. Zvieli further alleges that Example III(A) of the ‘462 application was prepared using processes taught in US 5,532,322 and so this patent also anticipates the present invention. Professor Marom responded that example III(A) of the ‘462 patent does not have the criteria of claim 27 since the thermal stability is 10 times that required. Furthermore, Professor Marom considers that example II(A) of the ‘462 patent is identical to example 2A of the present application which is not part of the claimed invention and is provided for comparison purposes only. Dr. Zvieli accepted this analysis under cross-examination at the hearing on 25 January 2017.
No further evidence was submitted to support the contention of lack of novelty of the second aspect. In the summations, the Opposer simply stated that the advantage of the lack of chlorine is a fictitious advantage since the process doesn’t use chlorine, and so chlorine would not be expected amongst the products. Firstly, this is not the only thing claimed in claims 27-47, and so even if the allegation was upheld, it is insufficient to render these claims invalid. Secondly, in Example 23 which is the basis of these claims, there is chlorine in the process. Although Professor Marom emphasized under cross-examination (page 50 of the protocol from 29 January 2019) that the examples referred to do not use chlorine, and so chlorine cannot be a product, the specification states clearly on page 2 lines 7-11 thereof, that although the main source of chlorine in brominated styrene is from the brominating agent which contains chlorine, for example, bromine chloride, other solvents and catalysts include chlorine which contributes to the chlorine content of the products. In example 23, use was made of solvents and catalysts that included chlorine.
In paragraph 22 of their summation, the Opposer alleges that an intrinsic advantage of this nature cannot provide inventive step. With this, in addition to the publications above, no prior art was brought to support the allegation that this aspect lacks inventive step.
In light of this, the Objection to the second aspect is rejected.
Section 2 of the Law states that an inventor of a patentable invention is entitled to request and to receive a patent for the invention. This section is interpreted by the case-law to mean that one is entitled to one patent per invention. See 477/93 the Welcome Foundation vs. Commissioner of Patents, Designs and Trademarks, 19 August 1993.
The way that overlap between applications is considered is done by looking at the claimed protections (See IL 203972 to Novartis, from 2 December 2014:
With regards to Overlap and to identity, the comparison will be done between the claims that define the scope of the protection. The scope of the invention can be understood from the total protection afforded to the applicant (see recent ruling concerning 2626/11 Fire protection Industries ltd. vs. Coniel Antonio (Israel ltd, from 11 April 2013, paragraphs 35-28.
The scale of the overlap is not limited to the examples or to the figures of the specification, but is determined with respect to the claims. The question of overlap is determined by the overlap of the claims, despite the fact that a claim may be construed by reference to the specification (including examples and drawings) and has to be reasonably based on the specification (as per Section 13(a) of the Law). Overlap between the patent Application under examination and that of another application or issued patent exists where that claimed is fully or partially claimed in the other patent or application.
The ‘975 patent has been owned by the Applicant since 6 October 2006. Claim 1 thereof claims admixtures of 55% to 70% brominated styrene having less than 1% alkaline metals and a pH of less than 9 as measured in accordance with the claims.
Professor Marom acknowledged that examples 11 to 17 of table 3 of the ‘975 patent of this applicant are identical to the examples of the present patent that are summarized in table 2 on page 35 and in the results 8 to 14. The expert witness further acknowledged that the processes for preparing the examples are the same for both publications.
In summary, Professor Marom agreed that both the issued patent and the present application claim the same polymers:
Q. Do you agree that they are the same examples?
A. They are the same examples, the examples supporting the claims of the ‘975 patent are the same as those that support the present application and which we are discussing. My logic tells me that both publications claim the same polymers since they are supported by the same examples and there are no two options.
There is no support for the Applicant’s claim that the Examples of the ‘975 patent are for the materials with the addition of some additive which is a thermal stabilizer in the ‘975 patent but is the invention itself in this instance. Although in his Opinion Professor Marom stated that the difference between the cases is this additive, this goes against the expert opinion and so cannot be accepted. Furthermore, examination of claim 1 of the ‘975 patent indicates that the concentration of thermal stabilizer is less than 1% and may indeed be 0%.
In light of this, one has to consider whether the overlap is only of claims 1 and 23 and their dependencies, i.e. the first aspect of the invention, or whether it extends over other aspects as well.
Dr. Zvieli was asked about this under cross-examination and acknowledged this. Furthermore, Dr. Zvieli did not analyze the claims of the third aspect with respect to the claims of ‘975 patent and so there is no evidence of overlap between claims 48, 56 and 76 and their dependencies with the claims of the ‘975 patent. However, where the third aspect is based on the first and deals with the combination of brominated styrenes and other polymers as flame retardants, it is doubtful that a third ingredient that is trivial is sufficient to make the third aspect patentably distinct from the ‘975 patent.
Finally, and beyond what is necessary, the Deputy Commissioner related to the Applicant’s allegation of a widening of the dispute in the summations by relating to overlap. The Applicant asserts that the allegation that claim 1 of the ‘975 patent does not require an additive was first raised in the summation response, in that the phrase “less than 1%” may mean 0%. The Opposer claims that this allegation is in direct response to the difference between the ‘975 patent and the present invention, which was raised by the Applicant in the evidence stage, and was not part of their statement of claims. However, the Applicant does manage to show this as being part of the statement of case.
Also alleged as being a claim only made by the Opposer only in the Summations, was that the PH of the first example was 9.3. However, review of the protocol shows that Professor Marom was extensively cross-examined about this and acknowledged that the processes described and claimed in the ‘390 patent lead to products having a pH of 9 or more (see page 37 of the protocol from 29 January 2019). The expert also conceded that the examples of the EP 1109864 (appendix 2) are identical to those of the ‘975 patent and in EP 1109864 it is stated that they have the same pH as those of the ‘975 patent. What is clear is that examples 10-23 of EP 1109864 are identical to examples 8-21 of the current Patent Application. It is also clear that the pH of the same examples that are the products of the same processes have to be identical. Since the Expert Witness was extensively cross-examined on this point, without any objection from the Applicant, it is impossible to substantiate the allegation that this issue was first raised in the summations and is an illegitimate widening of the basis of the Opposition
Additionally, the ruling that two of the three aspects of the patent overlap that claimed in the ‘975 patent is not based on the claims in the counter-summations, but rather on the clear testimony of Professor Marom that the polymers claimed in the two documents are identical. Furthermore, for determining that the expression ‘less than 1%’ can mean 0%, one does not need evidence or a specific claim, since this is self-evident and was widely debated in the Statement of Claims of the parties.
The conclusion from the above is that the first and second aspect overlap the claim 1 of the ‘975 patent and so claims 1 to 26 are not patentable under Section 2 of the Law.
The Opposition is accepted with regards to claims 1-26 and 48-86. For the sake of form, the Applicant is required to submit a new claim set of the allowed claims (27-47).
Since the Opposition was largely but not totally successful, the Applicant will pay 150,000 Shekels + VAT in costs. This sum is based on the weight of statement of case and evidence submitted, the number of days of hearings, the amendments to the specification during the opposition, the Opposition to the amendments and the fact that this interim opposition was rejected.
Decision by Ms Jacqueline Bracha
Ruling re Opposition to IL 141905 to Abermarle Corporation by Bromium Compounds Ltd, 19 May 2019
As a new immigrant graduate with a Materials Science background, I started researching for a PhD under Professor Marom in the Cassali Institute for Practical Chemistry. I worked on PE-PE composites for use as artificial tendons. There was no funding and eventually I got accepted as the materials scientist of a thermal coatings program at Soreq-NRC and did a PHD in Applied Physics under Professor Itzhak Roman, crossing the lawn at Givat Ram from the Chemistry North Side to the Physics on the South.
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