Bill Mitchell - Consultant Solicitor

Bill Mitchell - Consultant Solicitor I am an experienced Consultant Solicitor with over 22 years in law.

High Court considers contractual construction of irrevocable letter of credit incorporating UCP 600In the context of a t...
17/11/2022

High Court considers contractual construction of irrevocable letter of credit incorporating UCP 600

In the context of a trade finance dispute, the High Court has considered the contractual interpretation of an irrevocable letter of credit incorporating the commonly used code in the Uniform Customs and Practice for Documentary Credits 600 (UCP 600), published by the International Chamber of Commerce (ICC). In particular, the court held that the issuer’s interpretation of the letter of credit would, in practice, render the instrument revocable, which was inconsistent with the UCP and therefore not the proper construction. Finding that there was no real or substantial dispute that the issuer of the credit was liable, the court held that a winding up petition presented by the beneficiary succeeded against the issuer: Heytex Bramsche GmbH v Unity Trade Capital Ltd [2022] EWHC 2488 (Ch).

One of the key issues considered in this case was whether or not the documents presented as part of the demand were compliant with the terms of the letter of credit, which required the documents to be signed by “all sides of [the letter of credit]”. The court roundly rejected the issuer’s contention that its own signature was required, emphasising the need to consider letters of credit as a whole and – as far as possible – to read the contractual terms consistently with the UCP. In the court’s view, the issuer’s construction would have resulted in the letter of credit becoming revocable, because the issuer could have chosen simply to withhold its signature from the demand. This would have created a fundamental internal inconsistency in the terms of the letter of credit and a very significant departure from the UCP 600.

The court also rejected the issuer’s proposition that the letter of credit incorporated its own “credit norms”, modifying and prevailing over the UCP 600. Assuming the issuer’s interpretation of the effect of those credit norms was correct, incorporation would have resulted in a dramatic departure from the scheme of the UCP 600 and from the commercial essence of a letter of credit. The court said that to have successfully incorporated these provisions into the credit would have required very clear notice, the equivalent of Denning LJ’s “red hand” in J Spurling Ltd v Bradshaw [1956] 1 WLR 461 (CA) 466. Alternatively, even if the credit norms were incorporated, they did not have the effect argued for by the issuer, which undermined a number of characteristics fundamental to the function of credits.

The present decision continues the trend of decisions considering the UCP 600 in which the courts have consistently favoured an international focus on the question of interpretation. We considered recently the interpretation of ICC standardised rules in trade finance disputes across a number of commonly used codes, including UCP 600, in this article published in Butterworths Journal of International Banking and Financial Law: Interpreting ICC standardised rules in trade finance disputes: courts take an international perspective.

We consider the decision in more detail below.

Background

In June 2020, Heytex Bramsche GMBH (Heytex, a German company) entered into a contract to sell fabric to Jibran Technical Services LLC (Jibran, a company in the UAE). In order to facilitate this purchase, UTC Trade Capital Limited (UTC, an English trade finance company), issued an expressly irrevocable letter of credit (LC) in the sum of around €200,000 in favour of Heytex, as beneficiary. The LC incorporated the standard terms contained in the UCP 600.

Following agreed payment deferrals between Heytex and Jibran, Heytex presented various documents to UTC seeking payment from UTC as the issuer (as per the terms of the LC). These documents were sent to UTC by Heytex’s own bank, Sparkasse Osnabruck (Sparkasse), via SWIFT message. However, nothing was paid to Heytex, whether by UTC or Jibran, and Heytex was left without payment, or documents, or goods.

On 25 November 2021, Heytex petitioned to wind up UTC on the basis of a statutory demand claiming payment under the LC, alleging that UTC was insolvent within the meaning of ss. 122(1)(f) and 123 of the Insolvency Act 1986, as it had failed to make payment pursuant to the irrevocable LC.

UTC disputed its liability under the LC, and opposed the petition on the following bases:

Firstly, it argued that it was not the issuer, and that the LC was issued by its parent company (rejected by the court and not considered further in this blog post).
Secondly, that the documents presented by Heytex to UTC demanding payment under the LC were discrepant because they were not signed by UTC and Sparkasse. UTC relied on a term of the LC, which stated that the documents presented had to be signed by “all sides of LC”.
Thirdly, that UTC’s “Credit Norms” were incorporated into the LC and prevailed over the terms of the UCP 600. UTC argued that the effect of the Credit Norms was to permit it to release the discrepant documents to Jibran, whilst at the same time making the credit void and releasing UTC from any further liability to Heytex.
Finally, under the Credit Norms, that the LC was rendered “void” by virtue of the variations to the payment schedule agreed between Heytex and Jibran.
The judgment relates to the final hearing of the winding up petition.

Decision

The court held that there was no real or substantial dispute in respect of the debt upon which the petition was based and the petition succeeded accordingly. We consider the key issues arising from the judgment in respect of letters of credit, which are likely to be of broader interest to financial institutions.

Construction of letters of credit

The court emphasised that the idea of a letter of credit is straightforward: an issuer commits itself to a financial undertaking that it will fulfil against presentation of stipulated documents. Letters of credit afford the buyer the protection of payment against documents and provide the seller with protection against buyer default by substituting a bank as the party to which the seller looks for payment, regardless of any dispute which the buyer might raise in respect of the underlying sale contract.

The court also noted that, in addition to these inherent features, letters of credit are useful because they benefit from a “remarkable degree of international standardisation”, because of the worldwide adoption of the UCP. It was noted that a court will hesitate before concluding that the parties to a letter of credit genuinely intended to depart from such an internationally accepted regime, and it is likely to require the clearest wording to evidence that intention. The court considered Fortis Bank SA/NV v Indian Overseas Bank [2011] EWCA Civ 58, where Thomas LJ said that “a court must recognise the international nature of the UCP and approach its construction in that spirit”. The court also considered a similar point made in Ta**us Petroleum Ltd v State Oil Marketing Co of the Ministry of Oil, Iraq [2017] UKSC 64.

Were the documents presented to the issuer compliant with the terms of the LC?

The court held that the documents presented by Heytex (via Sparkasse) to UTC, seeking payment under the LC, were compliant with the terms of the LC.

As noted above, UTC argued that the documents were discrepant because they were not signed by UTC and Sparkasse, contrary to the terms of the LC, which stated that the documents presented had to be signed by “all sides of LC”.

The court noted that when approaching the issues of construction of the LC “… the instrument must be construed as a whole” and “must as far as possible be read consistently with the UCP”. In the court’s view, the expression “all sides of LC” meant Heytex and Jibran only (excluding Sparkasse and UTC), for the following reasons:

Firstly, the LC was described as “irrevocable” by an express term. The UCP 600 also describes credits as irrevocable. There was nothing to suggest that a revocable credit would have been commercially acceptable to the parties or was genuinely intended. However, if UTC’s suggested construction (that the documents requesting payment had to be signed by UTC) was correct, then the credit would have been revocable, because UTC could have chosen to withhold its signature. This would have been a fundamental internal inconsistency in the terms of the LC and a very significant departure from the UCP 600.
Secondly, the sale contract between Heytex and Jibran was the contract underlying the LC, which was only required and brought into existence because of that contract, to facilitate payment under it and reconcile the interests of the parties to it. The two sides of the transaction were Heytex and Jibran. In that context, UTC’s suggested meaning of the provision served no obvious commercial purpose.
Given the above, the court found that Heytex’s presentation of the documents to request payment was compliant and crystallised UTC’s liability to Heytex under Articles 7 and 15 of the UCP 600. UTC was not entitled to give notice of rejection under Article 16, and owed the debt stated in the petition.

Assuming the Credit Norms were incorporated into the LC, what was the effect?

Turning to UTC’s argument that its Credit Norms were incorporated into the LC and relieved UTC of liability to Heytex, the court first considered the effect of the relevant clauses of the Credit Norms, on the assumption that they were indeed incorporated.

The court commented that the clauses of the Credit Norms relied upon, if given the meaning attributed by UTC, would be unusual in the context of a letter of credit and would entail a dramatic departure from the scheme of the UCP 600, and from the commercial essence of a letter of credit, in a number of key respects. In particular:

Process following receipt of discrepant documents demanding payment under the LC. Article 16 of the UCP 600 requires either the return of discrepant documents by the issuer to the beneficiary, or a waiver and acceptance of the issuer’s liability to the beneficiary. In either case, the beneficiary’s interests are protected. However, UTC argued that the Credit Norms modified Article 16, and allowed for the release of discrepant documents by the issuer/UTC to the applicant/Jibran, whilst at the same time making the credit “void” and “releasing” UTC from any further liability to the beneficiary/Heytex.
Impact of negotiations relating to the underlying sale contract. UTC submitted that the Credit Norms provided for termination and avoidance of the credit on the basis that the beneficiary/Heytex and applicant/Jibran renegotiated the terms of the underlying sale contract (i.e. by varying the payment schedule). The court said this construction would be surprising because: (a) it would tend to undermine the “autonomy principle” (that the credit is separate from the sale on which it is based and also from the facility between the buyer and issuing bank), which is one of the characteristics fundamental to the function of credits; and (b) it would require the issuer to consider matters beyond questions of narrow documentary compliance.
The court proceeded to construe the relevant clauses of the Credit Norms, finding that they should not be construed as having the effect contended by UTC.

Were the Credit Norms in fact incorporated?

The court held that UTC’s Credit Norms were not incorporated into the LC and did not prevail over the terms of the UCP 600. Accordingly, even if the court’s contractual interpretation of the Credit Norms was incorrect (and the clauses should be understood as UTC submitted) the petition nonetheless succeeded.

There was no real dispute about the general test governing the incorporation of terms into a contract by reference, which is that “all that was reasonably necessary as a matter of ordinary practice should have been done to bring to [the party’s] notice” the terms: Thompson v London Midland & Scottish Railway Co [1930] 1 KB 41 (CA) 52 (per Lawrence LJ). The question of what satisfies that notice requirement turns on three factors:

The nature of the document and whether it is objectively intended to have contractual force: Parker v South Eastern Railway Co (1877) 2 CPD 416 (CA) 422 (Mellish LJ).
The timing of the notice. The terms must be made available before or at the time of contracting, and not after contracting: Olley v Marlborough Court Ltd [1949] 1 KB 532 (CA).
The nature of the terms being incorporated. If the purported terms are onerous or commercially unusual, they may need to satisfy Denning LJ’s “red hand test” from Spurling v Bradshaw, i.e. to be “printed in red ink on the face of the document with a red hand pointing to it”.
In its reasoning as to why the Credit Norms were not incorporated into the LC, the court said their incorporation would entail a dramatic departure from the scheme of the UCP 600 and from the commercial essence of a letter of credit. In consequence, to have incorporated these provisions into the credit would have required very clear notice, the equivalent of Denning LJ’s “red hand”.

However, the terms and degree of notice relied upon by UTC were nowhere near enough.

Given that the LC was made expressly on the terms of the UCP 600, UTC therefore could not establish an arguable case that it gave sufficient notice to incorporate the terms of the Credit Norms into the LC and/or to modify the operation of the UCP 600 to such a significant and highly unusual extent.

Outcome

Accordingly, the court concluded that there was no real or substantial dispute in respect of the debt upon which the petition was based and the petition succeeded accordingly.

https://www.lexology.com/r.ashx?l=9W7DTP2

Focus on directors’ duties: UK Supreme Court’s “momentous” decision on creditors’ interestsNew Zealand, United Kingdom N...
17/11/2022

Focus on directors’ duties: UK Supreme Court’s “momentous” decision on creditors’ interests

New Zealand, United Kingdom November 16 2022
BTI 2014 LLC v Sequana SA

On 5 October 2022, the UK Supreme Court released its long-awaited and self-described “momentous” decision considering the fiduciary duty of directors to act in good faith in the interests of the company. Specifically, this decision is the first time that the UK Supreme Court (or the House of Lords) has confirmed that directors owe a duty to consider or act in the interests of the company’s creditors if the company becomes or is at risk of becoming insolvent. In so doing, the decision has implications for directors in New Zealand.

Facts

In May 2009, the directors of Arjo Wiggins Appleton Limited (AWA) declared a dividend of €135 million to its only shareholder, Sequana SA. The dividend payment extinguished almost all of a larger debt that AWA owed Sequana SA. This was a lawful dividend that complied with the Companies Act 2006 (UK) because it was paid out of distributable profits. At the time of distribution, AWA was both balance-sheet and cash-flow solvent and it was able to pay its debts as they fell due.

However, at the time AWA made the dividend payment, it had long-term pollution-related contingent environmental liabilities of an uncertain amount, and an insurance portfolio (assets) of an uncertain value. This meant that AWA had a real, although not probable, risk of becoming insolvent in the future.

In October 2018, almost ten years after the dividend payment, AWA went into insolvent administration. Not all creditors were paid in full through the insolvency process. BTI 2014 LLC (BTI) purchased AWA’s claim against its directors and brought proceedings based on their decision to distribute dividends. BTI alleged that the directors’ dividend decision breached a duty to act in the interests of creditors when there was a real risk of insolvency.

The UK Supreme Court’s decision

The UK Supreme Court held that a duty to have regard to creditors’ interests existed when a company is insolvent or nearing insolvency. This is recognition of the economic interests that creditors have in a company when it is near insolvent. Where there is a conflict with the interests of shareholders, the directors need to balance the competing interests. The Court also explained that the greater a company’s financial difficulties, the more directors should prioritise the creditors’ interest.

The majority agreed that the duty to creditors would be engaged when directors knew, or ought to have known, that the company was insolvent or bordering on insolvency, or that formal insolvency procedures were probable.

The Court dismissed the appeal and held that, in this case, the duty to creditors was not engaged because at the time of the 2009 dividend, AWA was not imminently insolvent, nor was insolvency probable.

Comment (Tom Pasley)

Directors’ duty to creditors has received considerable attention from New Zealand’s most senior courts. The New Zealand Supreme Court’s decision in Debut Homes (see our note here) left unanswered some significant questions. Last year, the Court of Appeal in the Mainzeal litigation (see our note here) emphasised that it is not open to the directors of a near-insolvent company to trade on unless they obtain the consent of affected creditors and/or ensure that creditors who have not consented are paid in full. The Court of Appeal also suggested that Parliament should review and reform New Zealand’s statutory insolvent trading regime.

The New Zealand Supreme Court is due to release its decision in the Mainzeal litigation very soon which should clarify the nature and extent of the duty to creditors in New Zealand. While there are both some key similarities and differences between New Zealand and UK law, we expect the Sequana decision will be considered by, and referred to, in the Supreme Court’s decision. The extent to which the UK approach influences our Supreme Court will be of interest to New Zealand directors and their insurers and lawyers.

https://www.lexology.com/r.ashx?l=9W7DTNW

Price review clauses: when can suppliers force through an increase?Against a background of high inflation and a challeng...
17/11/2022

Price review clauses: when can suppliers force through an increase?

Against a background of high inflation and a challenging economic environment, many businesses are looking at whether they can raise prices. However, as we explain below, even where a contract appears to allow for this, much depends on the precise wording and what constraints the courts may decide to impose. This is the first in a series of briefings on pricing and payment issues in commercial contracts.

Is the customer's agreement always needed?

The courts have in the past upheld clauses which give one party a clearly drafted unilateral right to change its pricing without the other party's agreement. For example, in Esso Petroleum v Addison (2004), the Court of Appeal upheld Esso's right to adjust the margins, fees and allowances received by its petrol station licensees on a unilateral basis. However, if the contract merely makes a vague reference, such as fees being "subject to review as costs increase", without making it clear that there is a right for one party to change prices, this is unlikely to be sufficient (see for example the decision of the Court of Appeal in Amberley v West Sussex County Council (2011)).

Are there any constraints on unilateral price review clauses?

A unilateral right to change prices is likely to involve the use of a contractual discretion, which the courts normally expect to be exercised honestly, in good faith and in a manner which is not arbitrary, capricious or irrational. In the Esso case referred to above, the Court of Appeal upheld the ruling at first instance that Esso was subject to these constraints and that it was also prevented from altering the financial terms in a way which made it commercially impossible for the licensee to operate the petrol station. The clause also required notice to be given to licensees of the change; in cases where there is no such express provision, the courts may also be prepared to imply a requirement for reasonable advance notice (i.e. in the absence of express wording, it may be difficult for a party to argue that the changes should take effect immediately). For an example of the level of scrutiny which the courts have been prepared to apply to the exercise of a contractual discretion, see our briefing.

Other types of price review clause

In practice, unilateral price review clauses of the type outlined above are most likely to be found in supplier standard terms and/or in agreements where one party has very significant bargaining power. For obvious reasons, most customers are likely to be resistant to their inclusion without the imposition of at least some express constraints, such as:

narrowing the range of circumstances in which prices can be raised;
capping any increase in prices, applying a pre-agreed formula or benchmarking/market-testing (see below);
limiting the number of times prices can be raised during the contract and the time "window" in which they can be put forward;
requiring significant advance notice of any price increase;
including a linked termination right allowing the customer to terminate it if is unwilling to continue with the contract at the increased price; and/or
including a mechanism for referring any disputed price increase to an independent expert.
Where a pre-agreed formula is used, it can often be helpful to include a worked example – see this video briefing. If constraints of the type outlined above are present, a party looking to raise prices will need to be confident that it is acting within any limits imposed by the clause and has followed any relevant procedures to the letter.

Benchmarking to limit price increases

An alternative approach to limiting a supplier's ability to increase prices is to impose some form of benchmarking or market testing, with a view to ensuring that the customer will not pay more than the prevailing market rate. However, it is important to be clear about what/who the comparators are. For example, in Manchester Airport v Radisson (2020), an airport agreed to supply energy to a hotel "at no more than prevailing commercial rates". Radisson argued that this referred to prices available from suppliers using the UK national public gas and electricity network. However, the airport was on a private utility network and was under obligations from the Civil Aviation Authority to ensure extra resilience in its energy supply, both of which tended to lead to higher costs. The court ruled that the correct comparators for determining "prevailing commercial rates" were the rates charged by private utility networks of other major UK airports which (like Manchester) handled both international and domestic flights. We will be looking at benchmarking/market-testing in more detail later in this series.

The approach adopted to rent review in commercial property leases can also be seen as an attempt to link price increases to market conditions; if the parties cannot agree, a surveyor will usually be appointed to decide what would be an appropriate rent on the open market. However, historically, most leases have provided for upwards only rent review, which limits the extent to which tenants can benefit from a fall in the level of market rents; more recently, this has led to increased interest in turnover rents.

Consumer contracts

This briefing is primarily concerned with business-to-business contracts. If the customer is a consumer, additional considerations will apply; in particular, any term purporting to allow the supplier to vary the price will need to be in clear, intelligible language and may be vulnerable to challenge on the basis that it is unfair under the Consumer Rights Act 2015. Particular care is also needed when advertising by reference to price.

https://www.lexology.com/r.ashx?l=9W7DTNM

Commercial DisputesBITE SIZE KNOW HOW FROM THE ENGLISH COURTSSanctionsThe Commercial Court has illustrated how to manage...
17/11/2022

Commercial Disputes

BITE SIZE KNOW HOW FROM THE ENGLISH COURTS

Sanctions

The Commercial Court has illustrated how to manage a case where one of the parties is subject to sanctions and unable to pay either its lawyers or court fees. VTB was a designated person under the Russian sanctions and its lawyers came off the record for non-payment. Its CEO was given permission to represent VTB at the case management hearings. An application by the intervener, Petraco, for security for costs was refused as the court was not persuaded that VTB’s position of having an indemnity in an undertaking enforced against it was sufficiently analogous to that of a claimant to justify ordering security for costs. The court considered the wording of the OFSI General Licence for provision of legal services and given the uncertainty as to whether it allowed VTB’s solicitors to be paid and come back on the record, the trial was adjourned from May to November 2023. VTB was ordered to apply to OFSI for a contingent licence in respect of any costs liability in the case. It was also required to respond to the requests for further information submitted by Petraco. Further, the court warned that VTB should prepare for disclosure and the November hearing on the assumption that it may not be able to instruct lawyers as the hearing was likely to go ahead.

Jurisdiction

Two defendants resisted enforcement in England of two judgments given by the Texas courts on the basis that the court did not have jurisdiction. The Commercial Court rejected D1’s argument that he had not been properly served with the claim and had no knowledge that an attorney had purportedly filed pleadings on his behalf until the day of the trial. D1 had a proper opportunity to defend the proceedings, but he had not raised any objection to the manner of service and had allowed the trial to proceed with the attorney as his representative. D2 argued that under section 33(1)(c) of the Civil Jurisdiction and Judgments Act 1982 she should not be treated as having submitted to the Texas jurisdiction as she had only appeared to protect or obtain release of property seized in the proceedings. This was also rejected. D2 had engaged with the proceedings on the merits and did not dispute the jurisdiction of the court. Further, she had invoked the Texas court’s jurisdiction by advancing a counterclaim.

Privilege

In a dispute relating to the purchase of notes by Loreley from Credit Suisse, Credit Suisse requested Loreley to disclose who was authorised to give instructions on its behalf, as Loreley was a special purpose vehicle with no employees whose directors were supplied by a professional services company. The court rejected Loreley’s claim that this information was inherently privileged. However, the court said that the question of privilege of individuals should be tested as it arose in relation to particular communications, not in the abstract. The general principle was that in order to determine whether litigation privilege extends to the identity of the persons communicating with a solicitor in relation to litigation, it is necessary to consider whether disclosure of that identity would inhibit candid discussion between the lawyer and the client. If so, the identity of such persons should be privileged. But if not, to extend privilege to the identity of such persons was unnecessary and may deprive the court of relevant evidence needed in order to arrive at a just determination of litigation.

Landlord and Tenant

The defendant leaseholder was a receiver appointed by a bank who had lent funds to the claimant freeholder. The receivership had been discharged but the lease remained vested in the defendant. The claimant sought specific performance of the defendant tenant’s repairing obligations. Although there was a common understanding that the defendant was no longer responsible for providing services at the building once the receivership ended, the defendant had not relied on that understanding to their detriment and therefore the claimant could hold them to future lease obligations. However, the defendant was entitled to be indemnified by the claimant as it acted as agent for the claimant. Specific performance was therefore not appropriate

https://www.lexology.com/r.ashx?l=9W7DTNF

So, you want to exit a business?In this uncertain economic climate, considering a business exit may make sense to some b...
17/11/2022

So, you want to exit a business?

In this uncertain economic climate, considering a business exit may make sense to some business leaders and entrepreneurs who will need to be prepared in the event that they need to sell quickly.

Currently, taxation is favourable for business leaders in the UK looking to exit due to Business Asset Disposal Relief which reduces tax on the gain to 10%, up to a limit of £1 million for each individual selling. But, in coming months, we may well see the new Chancellor introduce changes to the way that exits are taxed.

The combined impacts of the economic forecast as well as potential changes from the Government and its respective Chancellor might well therefore serve to expedite exits amongst those seeking to cash in before HMRC tax rules are changed.

There are a whole host of different ways to exit a business. This includes, but is not limited to, selling to an Employee Ownership Trust, selling to a family member, a management buyout, arms-length trade sales or IPOs.

Regardless of which type of exit a business owner chooses, and with economic (tax) reform potentially looming, it is more important than ever for businesses to get their ducks in a row ahead of time to allow them to exit quickly and efficiently, should the time be right.

One important first step for any business who wishes to be prepared when considering an exit would be to carry out a mock legal due diligence test.

A legal due diligence test can usefully stress test all legal aspects of a company and its business - it typically analyses areas such as company licences, HR issues, regulatory issues, contracts, and any legal liabilities that may be pending.

Completing a mock legal due diligence exercise like this beforehand will allow a business leader to identify any red flags or weaknesses in the business that they may want to address and iron out early and before selling.

This level of preparation is often crucial and valuable. A mock legal due diligence exercise can help a business leader to ensure all relevant information and documentation concerning the business is properly organised and in order ahead of a sale, often averting potential problems arising down the line which could delay the process of selling the business. Compiling this information properly beforehand typically assists in speeding up the process of exiting.

But a mock legal due diligence test can not only spot the red flags relating to a business, it can also help business leaders understand the real commercial worth/inherent value in the business which can helpfully assist in price justification discussions with potential acquirers.

Ultimately, a buyer is interested in the business, its systems and customers and not the owner. The more that a business owner can remove themselves from the daily operations of their business, the easier it will be to sell the business and secure an offer they are willing to accept.

Carrying out a mock legal due diligence exercise and lessons learned can enable a business owner to become comfortable in their ability to ultimately sell the business and remove themselves (perhaps in a phased handover way) without impacting the commercial value of the business to the buyer's detriment.

Moving through the mock legal due diligence process may make selling a business seem like a lengthy procedure. But, by beginning the process ahead of time, business owners can gain a deeper understanding of the process, ensure that any glaring problems in the business are fixed from the outset and ultimately, learn when to make their move in any economic climate.

https://www.lexology.com/r.ashx?l=9W7DTNC

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