Rupa Marya v. Warner Chappell Music Inc

Filing 236

MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION to DEFENDANTS MOTION FOR LEAVE TO FILE SUPPLEMENTAL EVIDENCE IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT 223 Plaintiffs' Brief in Opposition to Defendants' Motion for Leave to File Supplemental Evidence filed by Plaintiffs Good Morning to You Productions Corp, Majar Productions LLC, Rupa Marya, Robert Siegel. (Manifold, Betsy)

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1 8 FRANCIS M. GREGOREK (144785) BETSY C. MANIFOLD (182450) RACHELE R. RICKERT (190634) MARISA C. LIVESAY (223247) WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP 750 B Street, Suite 2770 San Diego, CA 92101 Telephone: 619/239-4599 Facsimile: 619/234-4599 9 Attorneys for Plaintiffs 2 3 4 5 6 7 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 WESTERN DIVISION 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ) ) ) ) Plaintiffs, ) ) v. ) WARNER/CHAPPELL MUSIC, ) ) INC., et al., ) ) Defendants. ) ) ) ) ) ) ) ) GOOD MORNING TO YOU PRODUCTIONS CORP., et al., Case No. CV 13-04460-GHK (MRWx) PLAINTIFFS’ BRIEF IN OPPOSITION TO DEFENDANTS’ MOTION FOR LEAVE TO FILE SUPPLEMENTAL EVIDENCE Judge: Courtroom: Fact Discovery Cutoff: MSJ Hearings Pretrial Conference: Trial: Hon. George H. King, Chief Judge 650 July 11, 2014 March 23, 2015 and July 29, 2015 N/A N/A 1 I. INTRODUCTION 2 In a last-ditch attempt to prove they own the copyright to Happy Birthday, not 3 just specific piano arrangement of Good Morning done by Preston Ware Orem, an 4 employee-for-hire of Clayton F. Summy Co. (“Summy”), Defendants have asked the 5 Court to consider some British copyright records as support for their argument that 6 Ex. 106 is a copy of the work deposited with the registration for E51990. 7 Notwithstanding that discovery closed over a year ago on July 11, 2014, Plaintiffs 8 were only recently given access to the British copyright records on July 13, 2015, 9 along with approximately 200 pages of additional documents that Defendants claim 10 to have failed to produce by “mistake.” 11 If the Court accepts Defendants’ explanation that they originally sought the 12 British copyright records in 2013 but were unsuccessful in obtaining them until after 13 the summary judgment hearing two years later, their desperate, thirteenth-hour 14 argument is irrelevant and insufficient for at least three reasons. First, even if the 15 Court were to consider the British records and accept the new evidence as proof of 16 what was deposited in the United States Copyright Office with E51990, it cannot 17 inform the Court’s determination of the scope of that copyright (regardless of what 18 “words” or “text” may have been printed on the sheet music) because, like Ex. 106, 19 the British copy does not include Patty Hill’s name on it, and she is the person who 20 Defendants insist wrote the lyrics. Second, the evidence Defendants now offer to 21 prove that E51990 covered the Happy Birthday lyrics is squarely contradicted by 22 other evidence already in the record, including Defendants’ own prior admission that 23 Mr. Orem (whose name also is not on Ex. 106 or the British copy) did not write 24 them. Whatever “text” may have been included in the deposit copy, E51990 – the 25 copyright for the piano arrangement done as a work-for-hire by Mr. Orem as 26 Summy’s employee – could not possibly have covered the lyrics since they were not 27 written by him. Offering more evidence to prove what “text” was printed on the 28 sheet music is merely a distracting sideshow. -1- 1 Third, and most importantly, the scope of E51990 (as well as the abandonment 2 issue on which the Court recently ordered supplemental briefing) is rendered moot by 3 the 1922 publication of the Good Morning and Birthday Song in The Everyday Song 4 Book, which is presently the subject of Plaintiffs’ ex parte application.1 Dkts. 224, 5 225. For the reasons explained in Plaintiffs’ ex parte application, the publication of 6 the Good Morning and Birthday Song in 1922, with permission from Summy but 7 without the mandatory copyright notice (see Dkt. 225-3 at 20), extinguished any 8 possible copyright.2 See Twin Books Corp. v. Walt Disney Co., 83 F.3d 1162, 1165 9 (9th Cir. 1996). Thus, regardless of the scope of E51990, and whether or not Patty 10 Hill abandoned any copyright she may have had to the Happy Birthday lyrics before 11 that narrow copyright was registered, when the Good Morning and Birthday Song 12 was published with Summy’s permission but without a copyright notice in 1922, the 13 lyrics entered the public domain forever, leaving nothing for Summy to copyright in 14 1935 except the specific piano arrangement done by Mr. Orem. Indeed, the 1922 15 publication of the Happy Birthday lyrics, as authorized by Summy, without a 16 copyright notice conclusively ends the case in Plaintiffs’ favor. 17 II. 18 A. 19 22 23 Defendants Should Not be Permitted to Supplement the Record Because They Hid Their Search of the British Copyrights No party has a right to supplement the summary judgment record. Rather, 20 21 LEGAL ARGUMENT whether to permit a party to supplement the factual record on summary judgment is a matter in the Court’s discretion. See Bell v. City of Los Angeles, 835 F. Supp. 2d 836, 848 (C.D. Cal. 2011) (Matz, J.) (citing Betz v. Trainer Wortham & Co., 610 F.3d 24 1 25 26 27 28 The Court heard oral argument on the supplemental briefing on July 29, 2015 and has taken the matter under submission. Dkt. 229. 2 In the interest of brevity, Plaintiffs will not repeat their argument here. The Court is respectfully referred to Plaintiffs’ Ex Parte Application and Plaintiffs’ Reply in Further Support of Their Ex Parte Application. Dkts. 224, 225, 232, and 233. -2- 1 1169, 1171 (9th Cir. 2010)). Because Defendants hid their efforts to obtain the 2 British Library records throughout discovery, the Court should exercise its discretion 3 to preclude them from supplementing the record now. 4 In the Declaration of Kelly M. Klaus in Support of Defendants’ Motion for 5 Leave to File Supplemental Evidence, Dkt. 223-1, submitted on July 23, 2015 (more 6 than a year after the close of discovery on July 11, 2014), Mr. Klaus describes 7 Defendants’ effort “in the fall of 2013” “to request an official copy of the deposit 8 copy of Happy Birthday to You! that the Clayton F. Summy Co. deposited [in Great 9 Britain] in 1935” from the British Library. Dkt. 223-1 at 1:11-15. According to Mr. 10 Klaus, in November of 2013, Defendants were informed that the British Library staff 11 was “unable to locate the British Library’s deposit copy of Happy Birthday to You!” 12 Id. at 1:18-20. 13 Throughout discovery, Defendants withheld information about their newly- 14 disclosed effort to obtain the British Library deposit copy of Happy Birthday. On 15 June 3, 2014, Plaintiffs took the deposition of Thomas J. Marcotullio, Esquire, Vice 16 President of Mergers and Acquisitions for Warner Music Group, whom Defendants 17 designated as the person most knowledgeable on the copyright applications for 18 E51988 and E51990, including the work deposited with the Copyright Office for 19 those two copyrights. Mr. Marcotullio testified for approximately seven hours. He 20 was asked, in particular, what efforts Defendants made to obtain a copy of the 21 deposit copy for E51990. Although he had no first-hand knowledge of the search, he 22 answered as follows: 23 24 25 26 27 28 I spoke with Jeremy Blietz and others at Warner/Chappell. I understand, I think, I believe we may have received this in connection with our request from the Copyright Office. In any case they conducted an extensive investigation of their records, including microfiche files that they had, hard copy files that were retained by Warner/Chappell, and other digital files that they had already copied and pdf’d into a digital file. So they went through a fairly extensive review of those materials including with respect to the copyrights, the Hills, Summy-Birchard and otherwise, in -3- 1 addition as I mentioned earlier the requests to the Copyright Office. 2 Dkt. 192-1 at 1368 (Tr. Marcotullio, at 144:5-22). The effort described by Mr. Klaus 3 in his declaration allegedly took place approximately seven months before Mr. 4 Marcotullio was deposed, but Mr. Marcotullio did not mention the British Library or 5 the British Copyright Office at any time during his seven-hour deposition. In fact, 6 Defendants never disclosed any attempt to obtain the British Library copy of this 7 hotly disputed document at any time during discovery. 8 The Court should exercise its discretion by refusing to supplement the record 9 when doing so would reward discovery abuse. Here, Defendants were asked to 10 identify their efforts to locate a copy of the work deposited with the application for 11 E51990. When asked point-blank to describe Defendants’ effort to locate the deposit 12 copy, Mr. Marcotullio, their only Rule 30(b)(6) designee, never mentioned the 13 British Library search.3 14 The Court has wide latitude in responding to such discovery abuses. Dahl v. 15 City of Huntington Beach, 84 F.3d 363, 367 (9th Cir. 1996). That discretion includes 16 the power to exclude evidence that “would unfairly prejudice an opposing 17 party.” Unigard Sec. Ins. Co. v. Lakewood Engineering & Mfg. Corp., 982 F.2d 363, 18 368 (9th Cir. 1992) (excluding testimony for failure to provide discovery) (citing 19 Campbell Indus. v. M/V Gemini, 619 F.2d 24, 27 (9th Cir. 1980)). The failure to 20 timely provide documents or information prejudices the propounding party’s ability 21 to prepare its case. That Defendants eventually produced the British copyright records and 22 23 24 25 26 27 28 3 Unfortunately, this is not Defendants’ only discovery abuse. As the Court is aware, Defendants failed to disclose the 1927 publication of the Good Morning and Birthday Song in The Everyday Song Book (15th ed.) until July 13, 2015. Dkt. 226 at 5-7. Defendants claim it was a “mistake” to withhold that smoking gun for two years. Id. Defendants have not explained why that crucial evidence was not included on a privilege log if they “mistakenly” believed it to be subject to the work product doctrine. Id. at 6-7. Plaintiffs have reserved all their rights in that respect. -4- 1 information about the British Library searches does not cure the prejudice to 2 Plaintiffs. A last-minute tender of documents (such as here) does not cure the 3 prejudice to the party seeking discovery. North American Watch Corp. v. Princess 4 Ermine Jewels, 786 F.2d 1447, 1451 (9th Cir. 1986) (citing G-K Properties v. 5 Redevelopment Agency, 577 F.2d 645, 647-48 (9th Cir. 1978)). As the Ninth Circuit 6 has held, “[t]he longer the delay, the more likely prejudice becomes.” Pearson v. 7 Dennison, 353 F.2d 24, 28 (9th Cir. 1965). 4 Here, the delay was two years, and more 8 than a year after discovery closed. Discovery tendered as the discovery period is 9 about to close, or (as here) after it has closed, deprives the party seeking discovery 10 from any meaningful opportunity to follow up on that information or incorporate it 11 into its litigation strategy. See Payne v. Exxon Corp., 121 F.3d 503, 508 (9th Cir. 12 1997) (affirming dismissal of claim for untimely discovery). 13 Here, Plaintiffs will be unfairly prejudiced if Defendants are permitted to 14 supplement the record with the British Library copy. Plaintiffs have not been able to 15 follow up on the documents and information by conducting their own search of 16 British or international copyright documents for additional relevant evidence that 17 might shed more light on the scope of the American copyright, E51990, on which 18 Defendants rely. Had Plaintiffs known that Defendants requested the British Library 19 deposit copy, they would have expanded their own investigation to include those 20 4 21 22 23 24 25 26 27 28 The cases that Defendants cite are easily distinguished. Dkt. 223 at 6. The party who receives newly discovered evidence at the last minute is routinely allowed to supplement the record, not the party who has delayed producing the discovery. For example, in Point Ruston LLC v. Pac. Nw. Reg’l Council of United Bhd. of Carpenters & Joiners of Am., No. C09-5232BHS, 2010 U.S. Dist. LEXIS 19883, at *3 (W.D. Wash. Mar. 4, 2010), the plaintiffs were permitted to supplement the record based on documents ordered to be produced by the defendants. Likewise, in George v. Northwestern Mut. Life Ins. Co., No. C10-668-RSM, 2011 U.S. Dist. LEXIS 99454, at *7 (W.D. Wash. Sept. 1, 2011), permission to supplement the record was granted because discovery of an arbitration award by the defendants was delayed by the plaintiff’s failure to produce it in discovery. -5- 1 British and international documents. For example, Plaintiffs may have uncovered 2 evidence questioning the scope of the British copyright, whatever the scope of that 3 copyright may be. Nor were Plaintiffs permitted to incorporate that information into 4 their summary judgment arguments or their litigation strategy. If the Court believes 5 the British deposit copy is at all relevant to the scope of E51990 – and Plaintiffs 6 explain below why it is not relevant at all – then it would have had a complete factual 7 record on this question had Defendants timely disclosed their efforts regarding the 8 British deposit copy when Plaintiffs asked direct questions about their efforts during 9 discovery. Put another way, should Defendants be allowed to submit this additional 10 evidence so late in the game, the Court would be left with the paradoxical and 11 prejudicial result of a less complete summary judgment record. 12 Moreover, the Court need not consider additional evidence at summary 13 judgment if the party seeking to supplement the record fails to prove that the new 14 evidence would preclude granting summary judgment. See Qualls v. Blue Cross of 15 Cal., Inc., 22 F.3d 839, 844 (9th Cir. 1994) (movant must show how additional 16 discovery would preclude summary judgment). Defendants have not met, and cannot 17 meet, that heavy burden here. To the contrary, as set forth in Plaintiffs’ ex parte 18 request for relief (Dkt. Nos. 224-25 & 232-33), and as discussed below, all the 19 relevant evidence in this case entitles Plaintiffs to summary judgment in their favor. 20 Exhibit 106 and the British copyright records do not change that outcome. 21 22 In the exercise of discretion, the Court should decline to allow Defendants to supplement the record in this one-sided and potentially misleading fashion. 23 B. Patty Hill’s Name Is Not On Ex. 106 24 Defendants urge the Court to accept the British copyright records to 25 corroborate their argument that Ex. 106 or the British version is an accurate copy of 26 the work that was deposited in the United States Copyright Office with the 27 registration for E51990, which covers the “easy piano solo” arrangement done by 28 Mr. Orem. Defendants argue that the “text” in E51990 must have referred to the -6- 1 Happy Birthday lyrics, because those lyrics appear in Ex. 106 and the British version. 2 Other text also appears in both versions of the sheet music, including “Happy 3 Birthday to You!” “Vocal or Instrumental,” and “Brightly.” Defendants do not claim 4 to own a copyright to the universal birthday wish, to the phrase “vocal or 5 instrumental,” or to the word “brightly.” Certainly, Defendants could not claim a 6 copyright simply because that text also appears on the sheet music, but that is the 7 entire basis for their superficial argument regarding the Happy Birthday lyrics: they 8 own the lyrics because they are printed on the sheet music. 9 Importantly, only Mildred Hill’s name appears on Ex. 106. Patty Hill’s name 10 does not appear anywhere on Ex. 106; nor is Mr. Orem’s name on Ex. 106. However, 11 Defendants themselves insist that Patty, not her sister Mildred or Mr. Orem, wrote 12 the Happy Birthday lyrics. See, e.g., Dkt. 208 at 19:17-19 (“the lyrics were written by 13 Patty Hill”); 20:18 (“Patty says she did it”); and 33:18-25 (admitting that Patty, not 14 Mildred, wrote the lyrics). Defendants admit that Mildred did not write the lyrics. 15 Nothing in Ex. 106, or anywhere else, links the Happy Birthday lyrics to Mildred or 16 Patty. 17 Thus, whether or not the Court accepts Ex. 106 as proof of what was in the 18 deposit copy for E51990, it cannot inform the Court’s determination of the scope of 19 that copyright because it does not include the name of the person who defendants 20 insist wrote the work in question. According to Defendants, the omission of Patty’s 21 name from the sheet music may have been a mistake. Whether the omission was a 22 mistake or not, even if the Court were to accept Ex. 106 as the deposit copy for 23 E51990, whatever “words” or “text” E51990 referred to, the simple fact is that Ex. 24 106 does not provide a basis for the Court to find that the copyright covers the lyrics 25 Defendants claim Patty wrote, any more than it gives them a copyright in the “Happy 26 Birthday to You!” wish. 27 C. Other Record Evidence Contradicts Defendants’ Argument 28 Even if the Court were to accept Ex. 106 as proof of what was in the deposit -7- 1 copy for E51990, other evidence directly contradicts Defendants’ argument that the 2 copyright covered the lyrics. The most significant evidence is Defendants’ own 3 admission that neither Mildred Hill nor Mr. Orem wrote the lyrics. As the Court 4 stated during the first summary judgment hearing on March 23, 2015, whatever 5 presumption Defendants may be entitled to under E51990 must be viewed in light of 6 their “admission that Mr. Orem did not author the lyrics.” Dkt. 208 at 15:23-24 7 (emphasis added). 8 9 10 11 12 13 14 15 As the Court noted during the hearing on March 23, 2015: . . . even if I accept this [Ex. 106] as evidence, what it does say is Mildred J. Hill wrote Happy Birthday to You, and the evidence also seems to show that she wrote the music to it. There’s no question she didn’t write the words. In fact, you assert Patty did. You don’t even assert that Mildred did. So if that’s true in combination, then Happy Birthday to You by Mildred Hill refers to the music as to which there was an arrangement for piano forte, with text or with words. Dkt. 208 at 24:13-20 (emphasis added). 16 Since that copyright covered only new work done by Mr. Orem as Summy’s 17 employee-for-hire (see Ex. 48), it could not have covered work done by someone 18 who was not Summy’s employee, such as Patty Hill, no matter what “words” or 19 “text” had been included on the sheet music deposited with the application for 20 E51990. And since Mr. Orem did not write the Happy Birthday lyrics, the copyright 21 could not cover them even if they were included on the sheet music. The copyright 22 conferred under E51990 was no broader than the claim made in the application, 23 which was limited to the work done by Mr. Orem as Summy’s employee-for- 24 hire. Norden v. Oliver Ditson Co., 13 F. Supp. 415, 418 (D. Mass. 1936) (copyright 25 covers nothing more than what is claimed in application). The claim in the 26 application for E51990 was limited to the new work that Mr. Orem did as Summy’s 27 employee-for-hire. See Ex. 40. That could not include writing the Happy Birthday 28 lyrics, no matter what “text” was printed on the sheet music. -8- 1 In light of Defendants’ admission that Mr. Orem – the employee who 2 composed the piano arrangement covered by E51990 – did not write the Happy 3 Birthday lyrics,5 together with the fact that only Mildred’s name is on Ex. 106 (again, 4 Defendants concede that Mildred did not write the lyrics) and the fact that Patty’s 5 name is not on Ex. 106, it simply proves nothing about what is covered by the 6 copyright even if it is accepted as proof of the deposit copy. Whatever the “text” may 7 have been – a fact Defendants seem intent on proving – in light of Defendants’ 8 admission that Mr. Orem did not write the Happy Birthday lyrics, E51990 – which 9 covered only new matter added by Mr. Orem – cannot include lyrics written by 10 anyone else, including Patty Hill, who was never employed by Summy. 11 D. 12 13 14 15 16 17 18 19 20 21 22 23 24 In Plaintiffs’ ex parte application, they ask the Court to consider the 1922 publication of the Good Morning and Birthday Song in the fourth edition of The Everyday Song Book, by The Cable Co. (“Cable”), a Chicago music publisher, with permission from Summy as definitive proof that there is no copyright in Happy Birthday. Dkt. 224. That publication is by far the most important evidence recently produced by Defendants. As Plaintiffs explain in their ex parte application, id. at 811, the 1922 publication of the Good Morning and Birthday Song, with Summy’s permission but without a copyright notice, is conclusive proof that the “work was interjected irrevocably into the public domain.” Twin Books Corp. v. Walt Disney Co., 83 F.3d 1162, 1165 (9th Cir. 1996) (emphasis added). To save the Court’s time, Plaintiffs will not repeat their thorough and detailed argument here. See Dkt. Nos. 224-25 & 232-33. 25 26 The Scope of E51990 and Patty’s Abandonment of Any Copyright to the Lyrics is Moot Because the Lyrics Were Irrevocably Interjected Into the Public Domain in 1922 The question of the scope of E51990 (i.e., what work was covered by that narrow copyright) now before the Court is rendered moot by the 1922 publication of 27 28 5 Dkt. 208 at 5:19-22. -9- 1 Good Morning and Birthday Song in The Everyday Song Book with Summy’s 2 permission but without the required copyright notice. No matter what anyone tried to 3 copyright in 1935, the song had been irrevocably interjected into the public domain 4 thirteen years earlier. The 1922 publication likewise renders moot the question 5 whether Patty abandoned any copyright in the Happy Birthday lyrics, which is also 6 before the Court. Whether or not Patty abandoned any copyright she may have had in 7 the lyrics, they were unquestionably irrevocably interjected into the public domain 8 in 1922, leaving Defendants with nothing to copyright in 1935 except for the specific 9 piano arrangements done by their employees-for-hire, Mrs. Forman and Mr. Orem, 10 and the second verse written by Mrs. Forman. This explains why Summy admittedly 11 obtained only copyrights to “various piano arrangements of the said musical 12 composition ‘Good Morning to All’” from Jessica Hill in 1934 and 1935. See Ex. 51 13 at 684. 14 III. CONCLUSION 15 Whatever text may have been included in the deposit copy of the work 16 submitted with the application for E51990, the scope of that copyright does not and 17 cannot extend to work that was not done by Summy’s employee-for-hire, Mr. Orem. 18 Defendants admit that Mr. Orem did not write the Happy Birthday lyrics. Whether 19 those lyrics were on the sheet music deposited with E51990 is irrelevant. Moreover, 20 the 1922 publication of Good Morning and Birthday Song with Summy’s permission 21 but without the requisite copyright notice ends this case in Plaintiffs’ favor. 22 Therefore, the Court should end this dispute and promptly enter summary 23 judgment in Plaintiffs’ favor on the basis that Happy Birthday, including the song’s 24 familiar lyrics, entered the public domain no later than 1922. 25 Dated: August 10, 2015 26 WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP 27 By: 28 - 10 - /s/ Betsy C. Manifold BETSY C. MANIFOLD 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 FRANCIS M. GREGOREK BETSY C. MANIFOLD RACHELE R. RICKERT MARISA C. LIVESAY 750 B Street, Suite 2770 San Diego, CA 92101 Telephone: 619/239-4599 Facsimile: 619/234-4599 WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP MARK C. RIFKIN (pro hac vice) JANINE POLLACK (pro hac vice) 270 Madison Avenue New York, NY 10016 Telephone: 212/545-4600 Facsimile: 212-545-4753 17 18 Interim Lead Counsel for Plaintiffs 19 RANDALL S. NEWMAN PC RANDALL S. NEWMAN (190547) 37 Wall Street, Penthouse D New York, NY 10005 Telephone: 212/797-3737 20 21 22 23 24 25 26 27 28 - 11 - HUNT ORTMANN PALFFY NIEVES DARLING & MAH, INC. ALISON C. GIBBS (257526) OMEL A. NIEVES (134444) KATHLYNN E. SMITH (234541) smith@ 301 North Lake Avenue, 7th Floor Pasadena, CA 91101 Telephone 626/440-5200 Facsimile 626/796-0107 Facsimile: 212/797-3172 1 2 3 4 5 6 7 8 9 10 DONAHUE FITZGERALD LLP WILLIAM R. HILL (114954) ANDREW S. MACKAY (197074) DANIEL J. SCHACHT (259717) 1999 Harrison Street, 25th Floor Oakland, CA 94612-3520 Telephone: 510/451-0544 Facsimile: 510/832-1486 11 12 13 14 15 16 17 18 19 GLANCY PRONGAY & MURRAY LLP LIONEL Z. GLANCY (134180) MARC L. GODINO (188669) KARA M. WOLKE (241521) 1925 Century Park East, Suite 2100 Los Angeles, CA 90067 Telephone: 310/201-9150 Facsimile: 310/201-9160 20 21 22 23 24 25 26 27 28 WARNERCHAPPELL:22018.opp. Attorneys for Plaintiffs - 12 -

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