Initial briefs of parties and third parties


Applications for export credit guarantees, by commodity



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Applications for export credit guarantees, by commodity,

Fiscal year 2002, Percent share

92. Thus, as the United States does not have export subsidy reduction commitments specified in its Schedule for cotton and other products such as soya, maize (corn) and oilseeds and given the existence of United States export subsidies for cotton and other products, the United States is in violation of Articles 3.3, 8 and 10.1 of the Agreement on Agriculture.


93. Finally, it should be noted that the GSM 102, GSM 103 and SCGP programmes can be granted both to products for which reduction commitments exist and to those for which no such commitments exist180. With the respect to the products for which there are reduction commitments, the amounts exported by the United States are well in excess of the levels of those commitments.181 Accordingly, Argentina considers – as indicated by Brazil182- that the burden lies with the United States to prove that its excess exports did not benefit from export subsidies, including export credit guarantees.
94. Moreover, since the GSM 102, GSM 103 and SCGP programmes are intended to promote exports of cotton, confirmation of their export subsidy component would imply the presence of a subsidy prohibited within the meaning of Article 3.1 (a) of the SCM Agreement and a violation of Article 10.1 of the AoA –
- ETI ACT

95. With respect to the export subsidies granted to cotton under the ETI Act, which provides tax exemptions for US exporters who sell products outside the United States, Argentina refers to the fact that this Act was declared inconsistent with Article 3.1 (a) of the SCM Agreement and Articles 10.1 and 8 of the AoA in the "United States - FSC183" dispute.

V. CONCLUSION
96. For the above reasons Argentina considers that both the domestic support measures and the export subsidies granted by the United States to its cotton sector and called into question in these proceedings do not qualify for the protection provided under Article 13, paragraphs (b) (ii) and (c) (ii) of the Agreement on Agriculture.
97. Furthermore, the export subsidies for cotton and other products provided for in the United States legislation in the form of export credit guarantees (GSM 102, GSM 103, and SCGP) are likewise not protected by Article 13 (c) (ii).
98. Argentina also maintains that the subsidies for cotton exports provided for in the United States legislation are inconsistent with Articles 3.3, 8 and 10.1 of the Agreement on Agriculture.
Annex B-4

AUSTRALIA'S THIRD PARTY SUBMISSION



TABLE OF CONTENTS

I. INTRODUCTION 38

II. ARTICLE 13 OF THE AGREEMENT ON AGRICULTURE 38

A. AA Article 13 is in the nature of an affirmative defence and the United States has the burden of proof 38

B. The meaning of AA Article 13(b)(ii) 40

(i) “Implementation period” 40

(ii) “Domestic support measures that conform fully to the provisions of [AA] Article 6” 40

(iii) “Exempt from actions based on paragraph 1 of Article XVI of GATT 1994 or Articles 5 and 6 of the [SCM Agreement]” 41

(iv) “Such measures” 41

(v) “Grant support” 41

(vi) “To a specific commodity” 41

(vii) “That decided during the 1992 marketing year” 42

(viii) Summary of the meaning of AA Article 13(b)(ii) 42

III. “PRODUCTION FLEXIBILITY CONTRACT PAYMENTS” AND “DIRECT PAYMENTS” MAY NOT BE CLAIMED AS “GREEN BOX” MEASURES UNDER ANNEX 2 TO THE AGREEMENT ON AGRICULTURE 42

A. The relevant requirements of paragraphs 1 and 6(b) of AA Annex 2 42

(i) “No, or at most minimal, trade-distorting effects or effects on production” 43

(ii) “The amount of such payments in any given year shall not be related to, or based on, the type or volume of production (including livestock units) undertaken by the producer in any year after the base period” 43

B. “Production Flexibility Contract (PFC) Payments” could not be claimed as “green box” payments 44

(i) PFC payments had more than a negligible trade-distorting effect or effect on production, contrary to paragraph 1 of AA Annex 2 44

(ii) PFC payments were related to the type of production undertaken by the producer, contrary to paragraph 6(b) of AA Annex 2 45

C. “Direct Payments” for upland cotton may not be claimed as “green box” payments 45

(i) Direct payments are likely to have more than a negligible trade-distorting effect or effect on production, contrary to paragraph 1 of AA Annex 2 45

(ii) Direct payments are related to the type of production undertaken by the producer, contrary to paragraph 6(b) of Annex 2 of the Agreement on Agriculture 45

(iii) Direct payments are related to, or based on, the type or volume of production undertaken by the producer in a year after the base period, contrary to paragraph 6(b) of Annex 2 of the Agreement on Agriculture 46


IV. “STEP 2” PAYMENTS ARE PROHIBITED SUBSIDIES CONTRARY TO ARTICLES 3.3 AND 8 OF THE AGREEMENT ON AGRICULTURE AND/OR ARTICLE 3 OF THE SCM AGREEMENT 46

A. “Step 2” export payments are prohibited export subsidies contrary to Articles 3.3 and 8 of the Agreement on Agriculture and Article 3.1(a) and 3.2 of the SCM Agreement 47

(i) “Step 2” export payments are subsidies contingent upon export performance 47

(ii) “Step 2” export payments are export subsidies contrary to Articles 3.3 and 8 of the Agreement on Agriculture 48

(iii) “Step 2” export payments are prohibited export subsidies contrary to SCM Article 3 48

B. “Step 2” domestic payments are local content subsidies contrary to Article 3 of the SCM Agreement 49

C. The United States cannot avoid its obligations relating to prohibited subsidies by designing a measure under which entitlements are ostensibly available in multiple circumstances 49

V. CONCLUSION 50

I. INTRODUCTION
1. Australia welcomes the opportunity to present its views in this proceeding on US subsidies for upland cotton.
2. Australia notes that this dispute is the first to involve the interpretation and application of Article 13 of the Agreement on Agriculture (AA), the so-called “peace clause”. As such, this dispute has particular systemic as well as commercial significance.

3. In this third party Submission, Australia addresses:



  1. the nature of AA Article 13 as an affirmative defence, and the meaning of Article 13(b)(ii);




  1. whether “production flexibility contract payments” and their successor “direct payments” may be claimed as “green box” support within the meaning of AA Annex 2;




  1. whether s.1207(a) of the Farm Security and Rural Investment Act of 2002 (“the FSRI Act”) mandating payments to exporters of US cotton (“Step 2” export payments) is inconsistent with AA Articles 3.3 and 8 and thus is also inconsistent with Article 3 of the Agreement on Subsidies and Countervailing Measures (the SCM Agreement); and




  1. whether s.1207(a) of the FSRI Act mandating payments to domestic users of US cotton (“Step 2” domestic payments) is inconsistent with Article 3 of the SCM Agreement.

4. Because of the very limited time that has been available to consider the First Written Submission of the United States, Australia will address issues raised in that Submission in its oral statement before the Panel.


II. ARTICLE 13 OF THE AGREEMENT ON AGRICULTURE
A. AA ARTICLE 13 IS IN THE NATURE OF AN AFFIRMATIVE DEFENCE AND THE UNITED STATES HAS THE BURDEN OF PROOF
5. Australia agrees with Brazil that AA Article 13 is in the nature of an affirmative defence and that the United States has the burden of proof on the question of whether the measures at issue fully conform with the applicable conditions of Article 13.

6. Like Article XX of the General Agreement on Tariffs and Trade (“GATT”), AA Article 13 “does not establish any ‘positive obligations’ relevant to determining the proper scope of the obligations under [the specified provisions of GATT 1994 and the SCM Agreement]. Instead, it sets out circumstances in which Members are entitled to ‘adopt or maintain’ measures that are inconsistent with the obligations imposed under other provisions of [the GATT 1994 and the SCM Agreement]”.184

7. AA Article 13 does not of itself impose any obligation on a Member granting domestic support measures falling within Annex 2 or Article 6 or granting export subsidies falling within Part V of the Agreement on Agriculture.
8. Instead, AA Article 13 sets out the circumstances in which Members will be immune, either wholly or partially, from the consequences of granting domestic support measures or export subsidies that otherwise constitute grounds for a claim of infringement of the obligations contained in the provisions of GATT 1994 and the SCM Agreement specified in that Article. Thus, for example, under AA Article 13(b)(ii), “domestic support measures that conform fully to the provisions of Article 6 of [the Agreement on Agriculture] … shall be: … exempt from actions based on” the specified provisions of GATT 1994 and the SCM Agreement, “provided that such measures do not grant support to a specific commodity in excess of that decided during the 1992 marketing year”.
9. The nature of AA Article 13 as an affirmative defence is confirmed by an examination of the protection afforded by Article 13.
10. Under AA Article 13(a)(i), domestic support measures that conform fully to the provisions of AA Annex 2 “shall be non-actionable subsidies for purposes of countervailing duties”. Under AA Article 13(b)(i), domestic support measures that conform fully to AA Article 6 shall be “exempt from the imposition of countervailing duties unless …”. Under AA Article 13(c)(i), export subsidies that conform fully to the provisions of AA Part V shall be “subject to countervailing duties only upon a determination of …”.

11. Under the other provisions of AA Article 13, domestic support measures or export subsidies that conform fully with the prescribed conditions “shall be exempt from actions based on …” the specified provisions of GATT 1994 and the SCM Agreement. If domestic support measures or export subsidies infringe the relevant provisions specified in Article 13, they are nevertheless “free or released from a duty or liability to which others are held”185 in relation to a proceeding186 “found[ed], buil[t] or construct[ed] on”187 those provisions, as long as the measures meet the relevant conditions specified in Article 13.

12. Thus, the protection afforded by AA Article 13 becomes available only in circumstances where the domestic support measures or export subsidies at issue have been found:


  1. to be actionable subsidies, or to be otherwise countervailable, under Article 13(a)(i), 13(b)(i) or 13(c)(i); or




  1. in all other cases, to be inconsistent with the relevant specified provisions of GATT 1994 and/or the SCM Agreement;

and if the applicable conditions for the availability of that protection as specified in Article 13 are met.


13. Further, had the negotiators of the Agreement on Agriculture intended that AA Article 13 should mean that a Member would not be liable to a legal process of dispute, it is reasonable to assume that they would have said so. For example, the negotiators could have provided that the specified provisions of GATT and the SCM Agreement could not be “invoked”, as they did in footnote 35 to Article 10 of the SCM Agreement in relation to non-actionable subsidy measures.
14. The Appellate Body has previously clarified that “the burden of proof rests upon the party, whether complaining or defending, who asserts the affirmative of a particular claim or defence”188, and that “[i]t is only reasonable that the burden of establishing [an affirmative defence] should rest on the party asserting it”.189

15. Thus, in order to qualify for the protection afforded by AA Article 13, the United States must prove that the measures at issue conform fully to the applicable provisions of the Agreement on Agriculture. Further, in the case of the protection potentially afforded by Article 13(b)(ii), as well as by Article 13(b)(iii), the United States must prove that it has not granted, and does not grant, support to a specific commodity in excess of that decided during the 1992 marketing year.

B. THE MEANING OF AA ARTICLE 13(B)(II)190
16. In its First Written Submission, Brazil correctly highlights that there are a number of interpretative issues raised by the text of AA Article 13(b)(ii).191
(i) “Implementation period”
17. Under AA Article 1(f) and 1(i) read together, the “implementation period” is, for the purposes of Article 13, defined as the nine-year period commencing in 1995 according to the calendar, financial or marketing year specified in the Schedule relating to that Member.
(ii) “Domestic support measures that conform fully to the provisions of [AA] Article 6
18. Australia supports Brazil’s interpretation that the chapeau of AA Article 13(b) includes all non-“green box” domestic support measures, including product specific and non-product specific, de minimis and production-limiting domestic support, as well as investment subsidies and “diversification” support in developing countries.192
(iii) “Exempt from actions based on paragraph 1 of Article XVI of GATT 1994 or Articles 5 and 6 of the [SCM Agreement]

19. As noted in Section II.A above, if domestic support measures within the scope of the chapeau of AA Article 13(b) infringe the specified provisions, they are nevertheless “free or released from a duty or liability to which others are held”193 in relation to a proceeding194 “found[ed], buil[t] or construct[ed] on”195 those provisions as long as the conditions specified in Article 13 are met. Again, had the negotiators of the Agreement on Agriculture intended that a Member would not be liable to a legal process of dispute, it is reasonable to assume that they would have said so, for example, by providing that the specified provisions may not be “invoked” as in footnote 35 to Article 10 of the SCM Agreement in relation to non-actionable subsidy measures.

20. Australia notes, however, that only actions based on paragraph 1 of GATT Article XVI and Articles 5 and 6 of the SCM Agreement are covered under AA Article 13(b)(ii). Thus, for example, any actions based on paragraph 3 of GATT Article XVI or on SCM Article 3 would not benefit from the protection afforded by AA Article 13(b)(ii). In Australia’s view, the limitation of protection under Article 13(b)(ii) to actions based on GATT Article XVI:1 and on SCM Articles 5 and 6 is consistent with the object and purpose of the Agreement on Agriculture as expressed in the preamble to the Agreement, including to “[prevent] … distortions in world agricultural markets” and “to [achieve] specific binding commitments in … export competition”. The attainment of those objectives would be too easily subverted if commitments in regard to export subsidies could be circumvented through the provision of domestic support.
(iv) “Such measures”
21. In Australia’s view, the phrase “such measures” in AA Article 13(b)(ii) refers to the universe of non-“green box” measures covered by the chapeau of Article 13(b), consistent with the ordinary meaning of “such” as “of the kind, degree, or category previously specified or implied contextually”.196
(v) “Grant support”

22. In Australia’s view, having regard to the ordinary meaning of the words in their context and in light of the object and purpose of the Agreement on Agriculture, “support” means the actual support, other than legitimate “green box” support, provided to an agricultural product. Thus, to “grant support” is to “agree to”, “promise”, “bestow”, “allow”, “give”, “confer” or “transfer”197 non-“green box” domestic support of the type referred to in the chapeau of AA Article 13(b), which calculation must include that portion of non-product specific support that benefits the specific commodity at issue.

(vi) “To a specific commodity”
23. Australia agrees with Brazil’s interpretation198 that the ordinary meaning of this phrase, read in its context and in light of the object and purpose of the Agreement on Agriculture, is support granted to an individual agricultural commodity covered by AA Annex 1, such as upland cotton, whether through product specific, or non-product specific, support.
(vii) “That decided during the 1992 marketing year”
24. In Australia’s view, this phrase, read in its context and in light of the object and purpose of the Agreement on Agriculture, means the level of non-“green box” domestic support, including support provided through non-product specific non-“green box” domestic support measures, “decided” by a Member in the course of the 1992 marketing year to be provided to the benefit of a specific agricultural commodity in the future.
25. The use of the word “decided” in this context was deliberate.
26. Australia notes that the other operative provision of the Agreement on Agriculture in which the word “decided” is used is Article 13(b)(iii), which relates to non-violation nullification or impairment actions. Australia notes too that Article 13(b)(iii) contains precisely the same language – “provided that such measures do not grant support to a specific commodity in excess of that decided during the 1992 marketing year” – as used in Article 13(b)(ii). Thus, the meaning of the word “decided” in the context of Article 13(b)(ii) must be capable of having that same meaning in the context of non-violation nullification and impairment actions under Article 13(b)(iii).
(viii) Summary of the meaning of AA Article 13(b)(ii)

27. During the nine calendar, financial or marketing year period specified in a Member’s Schedule period commencing in 1995, all non-“green box” domestic support measures that conform fully to the provisions of AA Article 6 are immune from the consequences of infringing GATT Article XVI:1 or Part V of the SCM Agreement, provided that the level of support to an individual commodity does not exceed the level of support for that commodity that was decided by the Member to be made available during the relevant 1992 marketing year.

III. “PRODUCTION FLEXIBILITY CONTRACT PAYMENTS” AND “DIRECT PAYMENTS” MAY NOT BE CLAIMED AS “GREEN BOX” MEASURES UNDER ANNEX 2 TO THE AGREEMENT ON AGRICULTURE
28. The United States has previously notified “Production Flexibility Contract (PFC) Payments”199 as AA Annex 2 “green box” measures.200 The United States has not made a domestic support notification since PFC payments were replaced by “Direct Payments” (DP)201 under the 2002 FSRI Act. Like Brazil202, Australia considers that neither of these payments programs may be claimed as “green box” measures for the reasons outlined below.
A. THE RELEVANT REQUIREMENTS OF PARAGRAPHS 1 AND 6(B) OF AA ANNEX 2
29. AA Annex 2.1 provides that “[d]omestic support measures for which exemption from reduction commitments is claimed shall meet the fundamental requirement that they have no, or at most minimal, trade-distorting effects or effects on production”.
30. In addition, in relation to decoupled income support, AA Annex 2.6(b) provides that “[t]he amount of such payments in any given year shall not be related to, or based on, the type or volume of production (including livestock units) undertaken by the producer in any year after the base period”.
(i) “No, or at most minimal, trade-distorting effects or effects on production”

31. In requiring that domestic support measures “shall meet the fundamental requirement that they have no, or at most minimal, trade-distorting effects or effects on production”, AA Annex 2.1 imposes a stringent standard. Annex 2.1 requires that such measures must, as a primary or essential condition, not “bias” or “unnaturally alter”203 trade or production. Alternatively, Annex 2.1 requires that, at most, such measures must have “extremely small; of a minimum amount, quantity or degree; very slight, negligible”204 effects on trade or production.

32. In Australia’s view, this standard cannot be met if the domestic support measure at issue directly and specifically stimulates production and/or trade of a particular commodity, or if that support measure directly retards or halts the transfer of economic resources to other forms of economic activity, other than as specifically provided for under paragraphs 2-13 of AA Annex 2. If a domestic support measure results in a level of production and/or trade in a particular product or group of products higher than would otherwise be the case except as specifically provided for in Annex 2, the support measure cannot meet the standard established in Annex 2.1. Thus, if the direct effect of a support measure is that farmers keep producing, or keep producing a particular product, in circumstances that would be uneconomic but for the support measure, that measure cannot meet the requirements of Annex 2.1.
(ii) “The amount of such payments in any given year shall not be related to, or based on, the type or volume of production (including livestock units) undertaken by the producer in any year after the base period”
33. Paragraph 6 of AA Annex 2 is headed “decoupled income support”. Paragraph 6(a) provides that “[e]ligibility for [decoupled income support] payments shall be determined by clearly defined criteria such as income, status as a producer or landowner, factor use or production level in a defined and fixed base period”. Thus, consistent with the customary rules of interpretation codified at Article 31 of the Vienna Convention on the Law of Treaties, “after the base period” in paragraph 6(b) means after the base period defined and fixed pursuant to paragraph 6(a).

34. Accordingly, the meaning of paragraph 6(b) of AA Annex 2 is clear. Once a base period has been defined and fixed pursuant to paragraph 6(a), decoupled income support payments may not be “connected”205 to or “found[ed], buil[t] or construct[ed] on”206 the type of production or the volume of production undertaken by a producer in a later period.

B. “PRODUCTION FLEXIBILITY CONTRACT (PFC) PAYMENTS” COULD NOT BE CLAIMED AS “GREEN BOX” PAYMENTS
(i) PFC payments had more than a negligible trade-distorting effect or effect on production, contrary to paragraph 1 of AA Annex 2$
35. Like Brazil, Australia considers that PFC payments directly stimulated, and stimulated by more than a negligible amount, US production of, and trade in, upland cotton and Australia endorses Brazil’s arguments in this respect.207
36. Further, the value of PFC payments rates as a proportion of the marketing year average farm price received by US upland cotton growers can be seen from data published by the United States Department of Agriculture (USDA) and included in Table 1 below.
Table 1: The value of PFC payments as a percentage proportion of the marketing year average farm price received by US upland cotton growers


Marketing or Crop Year

Production flexibility contract (PFC) payment rates US¢/lb.208

Average farm price US¢/lb.209

PFC payment rates as a proportion of the marketing year average farm price %

1996/97

8.882

69.3

12.82

1997/98


7.625

65.2

11.69

1998/99

8.173

60.2

13.58

1999/2000

7.990

45.0

17.76

2000/01

7.330

49.8

14.72

2001/02

5.990

29.8

20.10

37. In addition, data published by the USDA for this period show that PFC payments constituted 26.37%, 36.5% and 22.90% of government payments by crop year for the 1999, 2000 and 2001 years respectively.210

38. PFC payments constituting such high proportions of the marketing year average farm prices and of domestic support measures must have a production and trade-distorting effect.

39. But this view is further confirmed when the marketing year average farm prices as shown in Table 1 are considered against the fact that in 1997 the average of total economic costs for all US cotton farms was approximately 73 cents per pound and operating costs averaged 38 cents per pound211. In such circumstances, economically rational producers should have begun to transfer resources to other forms of economic activity. This did not happen. USDA data shows that the area planted to cotton in the United States over this period increased, from 13.1 million acres in 1998 to 15.5 million acres in 2001.212 It is clear that many US producers of upland cotton could only have remained viable over this period through subsidisation. Further, US exports of upland cotton increased from 4.1 million bales in 1998 to 10.6 million bales in 2001.213
40. In Australia’s view, PFC payments during this period contributed directly to increased production and export levels and that they did so contrary to the express requirement of AA Annex 2.1 that the domestic support measures at issue not, or only negligibly, bias or unnaturally alter trade or production.
(ii) PFC payments were related to the type of production undertaken by the producer, contrary to paragraph 6(b) of AA Annex 2

41. By excluding fruits and vegetables (other than lentils, mung beans, and dry peas) from the planting flexibility otherwise available in respect of the contract acreage for which PFC payments could be made, s.118 of the Federal Agriculture Improvement and Reform Act of 1996 (the FAIR Act) related, or connected, PFC payments to the type of production undertaken by the producer in any year after the base period, contrary to the requirements of AA Annex 2.6(a).

C. “DIRECT PAYMENTS” FOR UPLAND COTTON MAY NOT BE CLAIMED AS “GREEN BOX” PAYMENTS
(i) Direct payments are likely to have more than a negligible trade-distorting effect or effect on production, contrary to paragraph 1 of AA Annex 2
42. Australia considers that direct payments for upland cotton are likely to stimulate, by more than a negligible amount, US production of, and trade in, upland cotton. The 2002 FSRI Act has established a direct payment rate for upland cotton of 6.67 cents per pound for each of the 2002 through 2007 crop years.
43. In addition to the arguments put forward by Brazil214, which Australia endorses, Australia considers that, so long as there is a reasonable possibility of continuing and significant longer-term volatility in the gross returns to producers (as measured by the marketing year average farm price), the assured availability of a direct payment for upland cotton at the rate of 6.67 cents per pound must be presumed to influence directly and specifically the decisions of growers to continue producing upland cotton, notwithstanding significant peaks and troughs in their income, rather than to transfer resources to other forms of economic activity.
(ii) Direct payments are related to the type of production undertaken by the producer, contrary to paragraph 6(b) of Annex 2 of the Agreement on Agriculture

44. Under s.1106(b) of the 2002 FSRI Act, fruits, vegetables (other than lentils, mung beans and dry peas) and wild rice are generally prohibited from being planted on base acreage unless the commodity, if planted, is destroyed before harvest except that trees and other perennial plants are prohibited. The implementing regulations make clear that, where it is determined that a producer made a good faith effort to comply with the “planting flexibility” provisions of s.1106 of the FSRI Act but that that producer’s acreage report of fruits, vegetables or wild rice planted on a farm’s base acreage is inaccurate and exceeds the allowed tolerance levels, the producer “shall accept a reduction in the direct and counter-cyclical payments for the farm …”.215

45. Thus, direct payments are related, or connected, to the type of production undertaken by the producer, contrary to paragraph 6(a) of AA Annex 2.
(iii) Direct payments are related to, or based on, the type or volume of production undertaken by the producer in a year after the base period, contrary to paragraph 6(b) of Annex 2 of the Agreement on Agriculture
46. Sections 1101 and 1102 of the 2002 FSRI Act allow producers to update their base acres and payment yields respectively for the purposes of receiving direct payments. As set out in Section III.A.ii above, only one base period is possible for the purposes of paragraph 6 of AA Annex 2. Once the base period has been defined and fixed, no further updating of either the type or volume of production is permissible if a support program is to comply with the conditions of paragraph 6 of Annex 2.
47. Under the 2002 FSRI Act, direct payments replaced PFC payments.216 Since the United States has claimed PFC payments as “green box” decoupled income support217, Australia considers that the United States has selected the base period that it used to determine base acres and payment yields under the 1996 FAIR Act as its defined and fixed base period for the purposes of paragraph 6 of AA Annex 2.

48. By providing for base acres and payment yields to be updated under the 2002 FSRI Act, the United States has related the amount of direct payments to, or based the amount of direct payments on, the type and volume of production undertaken by a producer in any year after the base period, contrary to paragraph 6(b) of AA Annex 2.


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