Mid-Century Insurance Company v. General Electric Company et al

Filing 20

STIPULATED PROTECTIVE ORDER signed by Magistrate Judge Erica P. Grosjean on 2/7/2018. (Rooney, M)

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1 TUCKER ELLIS LLP Rebecca M. Biernat SBN 198635 2 rebecca.biernat@tuckerellis.com One Market Plaza 3 Steuart Tower, Suite 700 San Francisco, CA 94105 4 Telephone: 415.617.2400 Facsimile: 415.617.2409 5 TUCKER ELLIS LLP 6 David Harley Jones SBN 298719 david.jones@tuckerellis.com 7 515 South Flower St., 42nd Floor Los Angeles, CA 90071 8 Telephone: 213-430-3400 Facsimile: 213-430-3409 9 Attorneys for Defendants 10 ELECTROLUX HOME PRODUCTS, INC. and GENERAL ELECTRIC COMPANY 11 UNITED STATES DISTRICT COURT 12 EASTERN DISTRICT OF CALIFORNIA 13 14 MID-CENTURY INSURANCE COMPANY a/s/o Brooks Landing 15 Plaintiff, 16 v. 17 GENERAL ELECTRIC COMPANY; 18 ELECTROLUX HOME PRODUCTS, INC.; and DOES 1- 10, 19 Defendants. 20 PURPOSES AND LIMITATIONS 21 1. 22 ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.1:17-cv-00157-DAD-EPG Judge: Honorable Erica P. Grosjean Trial Date: February 12, 2019 STIPULATED PROTECTIVE ORDER The parties hereby petition the Court to enter the following Stipulated Protective 23 Order pursuant to Eastern District of California Local Rule 141.1, and hereby agree and 24 stipulate to the following facts: 25 26 a. Information To Be Protected from Disclosures This case involves allegations that Defendants’ residential clothes dryer, was 27 defective and said defect caused damage to Plaintiff’s Insured’s apartment complex; 28 Discovery in this matter, including document production and depositions, will involve the production of trade secret and other confidential business, proprietary and 1 personal information related to Defendants’ product, including product research, 2 development, analyses and testing; product design specifications and related documents; 3 manufacturing procedures, processes and related documents; third party identification 4 information; personnel or employment records of nonparties; confidential licensing, 5 distribution, financial, and insurance information; confidential claims procedures and 6 processes; confidential communications with third party agencies. 7 It may also include confidential proprietary and financial information produced by 8 third parties, including Plaintiff’s Insured. b. 9 10 Good Cause Exists for Protection from Disclosure There is a particularized need for protection of this information as disclosure of 11 this confidential, proprietary or trade secret information without the structure of a 12 protective order would present serious compromises to Defendants’ business practices, 13 open them to theft of trade secrets, unfair competition, and possible economic injury. 14 See In Re Jenoptik, AG, 109 F. 3RD 721 (Fed. Cir. 1997). c. 15 16 Good Cause Exists for the Entry of Court Order Protecting the confidentiality of documents and information via court order, as 17 opposed to private agreement, is necessary to ensure enforcement of the order and the 18 interest of judicial economy, especially as the production of the confidential information 19 is made only in the context of the litigation. If a court order is violated, the court has 20 jurisdiction and the parties have a remedy without filing a separate action. Conversely, 21 breach of a private agreement requires a separate action. 22 Good cause exists also exists for the issuance of this Order as the parties seek to 23 have reasonable and quick access to information relevant to liability and damages in this 24 lawsuit while providing them with a means for limiting access to, and disclosure of, 25 confidential, private, or trade secret information. 26 Further, the parties acknowledge that this Order does not confer blanket 27 protections on all document production, disclosures or responses to discovery, and that 28 the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. 1 The parties further acknowledge, as set forth in Section 12.3, below, that this 2 Stipulated Protective Order does not entitle them to file confidential information under 3 seal; Civil Local Rule 141 sets forth the procedures that must be followed and the 4 standards that will be applied when a party seeks permission from the court to file 5 material under seal. 6 2. DEFINITIONS 7 2.1 Challenging Party: a Party or Non-Party that challenges the designation of 8 information or items under this Order. 9 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how 10 it is generated, stored or maintained) or tangible things that qualify for protection under 11 Federal Rule of Civil Procedure 26(c), including but not limited to (a) information 12 protected from disclosure by statute; (b) information that reveals trade secrets; (c) 13 research, development, technical, commercial or financial information that the party has 14 maintained confidential, including information related to proprietary licensing, 15 distribution, marketing, product analyses, design, and manufacturing; (e) personal 16 identity information; or (f) personnel or employment records of a person who is not a 17 party to the case. 18 2.3 Counsel (without qualifier): Outside Counsel of Record and House 19 Counsel (as well as their support staff). 20 2.4 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 22 2.5 Disclosure or Discovery Material: all items or information, regardless of 23 the medium or manner in which it is generated, stored, or maintained (including, among 24 other things, testimony, transcripts, and tangible things), that are produced or generated 25 in disclosures or responses to discovery in this matter. 26 2.6 Expert: a person with specialized knowledge or experience in a matter 27 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 28 expert witness or as a consultant in this action. 2.7 1 House Counsel: attorneys who are employees of a party to this action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 2.8 4 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 2.9 6 Outside Counsel of Record: attorneys who are not employees of a party to 7 this action but are retained to represent or advise a party to this action and have appeared 8 in this action on behalf of that party or are affiliated with a law firm which has appeared 9 on behalf of that party. 2.10 Party: any party to this action, including all of its officers, directors, 10 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 13 14 Discovery Material in this action. 2.12 Professional Vendors: persons or entities that provide litigation support 15 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 18 their employees and subcontractors. 2.13 Protected Material: any Disclosure or Discovery Material that is designated 19 20 as “CONFIDENTIAL.” 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material 21 22 from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only Protected 25 Material (as defined above), but also (1) any information copied or extracted from 26 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 27 Material; and (3) any testimony, conversations, or presentations by Parties or their 28 Counsel that might reveal Protected Material. However, the protections conferred by this Stipulation and Order do not cover the following information: (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of 1 the public domain after its disclosure to a Receiving Party as a result of publication not 2 involving a violation of this Order, including becoming part of the public record through 3 trial or otherwise; and (b) any information known to the Receiving Party prior to the 4 disclosure or obtained by the Receiving Party after the disclosure from a source who 5 obtained the information lawfully and under no obligation of confidentiality to the 6 Designating Party. Any use of Protected Material at trial shall 7 4. DURATION 8 Even after final disposition of this litigation, the confidentiality obligations 9 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 10 in writing or a court order otherwise directs. Final disposition shall be deemed to be the 11 later of (1) dismissal of all claims and defenses in this action, with or without prejudice; 12 and (2) final judgment herein after the completion and exhaustion of all appeals, 13 rehearings, remands, trials, or reviews of this action, including the time limits for filing 14 any motions or applications for extension of time pursuant to applicable law. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 17 Party or Non-Party that designates information or items for protection under this Order 18 must take care to limit any such designation to specific material that qualifies under the 19 appropriate standards. To the extent practicable prior to production, the Designating 20 Party must designate for protection only those parts of material, documents, items, or 21 oral or written communications that qualify – so that other portions of the material, 22 documents, items, or communications for which protection is not warranted are not 23 swept unjustifiably within the ambit of this Order. 24 If advised that information or items designated for protection do not qualify for 25 protection, Designating Party must promptly notify all other Parties that it is 26 withdrawing the mistaken designation. 27 5.2 Manner and Timing of Designations. Except as otherwise provided in this 28 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so designated before the material is disclosed or produced. 1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, but 3 excluding transcripts of depositions or other pretrial or trial proceedings), that the 4 Producing Party affix the legend “CONFIDENTIAL” to each page that contains 5 protected material. If only a portion or portions of the material on a page qualifies for 6 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 7 by making appropriate markings in the margins).A Party or Non-Party that makes 8 original documents or materials available for inspection need not designate them for 9 protection until after the inspecting Party has indicated which material it would like 10 copied and produced. During the inspection and before the designation, all of the 11 material made available for inspection shall be deemed “CONFIDENTIAL.” After the 12 inspecting Party has identified the documents it wants copied and produced, the 13 Producing Party must determine which documents, or portions thereof, qualify for 14 protection under this Order. Then, before producing the specified documents, the 15 Producing Party must affix the “CONFIDENTIAL” legend to each page that contains 16 Protected Material. If only a portion or portions of the material on a page qualifies for 17 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 18 by making appropriate markings in the margins). 19 (b) for testimony given in deposition or in other pretrial or trial proceedings, that 20 the Designating Party identify on the record, before the close of the deposition, hearing, 21 or other proceeding, all protected testimony. 22 (c) for information produced in some form other than documentary and for any 23 other tangible items, that the Producing Party affix in a prominent place on the exterior 24 of the container or containers in which the information or item is stored the legend 25 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant 26 protection, the Producing Party, to the extent practicable, shall identify the protected 27 portion(s). 28 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate qualified information or items does not, standing alone, waive the Designating Party’s right to secure protection under this Order for such material. Upon 1 timely correction of a designation, the Receiving Party must make reasonable efforts to 2 assure that the material is treated in accordance with the provisions of this Order. 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time. Unless a prompt challenge to a Designating 6 Party’s confidentiality designation is necessary to avoid foreseeable, substantial 7 unfairness, unnecessary economic burdens, or a significant disruption or delay of the 8 litigation, a Party does not waive its right to challenge a confidentiality designation by 9 electing not to mount a challenge promptly after the original designation is disclosed. 10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 11 resolution process by providing written notice of each designation it is challenging and 12 describing the basis for each challenge. To avoid ambiguity as to whether a challenge 13 has been made, the written notice must recite that the challenge to confidentiality is 14 being made in accordance with this specific paragraph of the Protective Order. The 15 parties shall attempt to resolve each challenge in good faith and must begin the process 16 by conferring directly (in voice to voice dialogue; other forms of communication are not 17 sufficient) within 14 days of the date of service of notice. In conferring, the Challenging 18 Party must explain the basis for its belief that the confidentiality designation was not 19 proper and must give the Designating Party an opportunity to review the designated 20 material, to reconsider the circumstances, and, if no change in designation is offered, to 21 explain the basis for the chosen designation. A Challenging Party may proceed to the 22 next stage of the challenge process only if it has engaged in this meet and confer process 23 first or establishes that the Designating Party is unwilling to participate in the meet and 24 confer process in a timely manner. 25 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 26 intervention, the parties shall request an informal discovery dispute conference pursuant 27 to the undersigned Magistrate Judge’s case management procedures. If the Parties 28 cannot resolve a challenge without court intervention, the Designating Party shall file and serve a motion to retain confidentiality r within 14 days of the parties agreeing that the meet and confer process will not resolve their dispute. Each such motion must be 1 accompanied by a competent declaration affirming that the movant has complied with 2 the meet and confer requirements imposed in the preceding paragraph. Failure by the 3 Designating Party to make such a motion including the required declaration shall 4 automatically waive the confidentiality designation for each challenged designation. In 5 addition, the Challenging Party may file a motion challenging a confidentiality 6 designation at any time if there is good cause for doing so, including a challenge to the 7 designation of a deposition transcript or any portions thereof. Any motion brought 8 pursuant to this provision must be accompanied by a competent declaration affirming 9 that the movant has complied with the meet and confer requirements imposed by the 10 preceding paragraph. 11 The burden of persuasion in any such challenge proceeding shall be on the 12 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 13 to harass or impose unnecessary expenses and burdens on other parties) may expose the 14 Challenging Party to sanctions. Unless the Designating Party has waived the 15 confidentiality designation by failing to file a motion to retain confidentiality as 16 described above, all parties shall continue to afford the material in question the level of 17 protection to which it is entitled under the Producing Party’s designation until the court 18 rules on the challenge. 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this case 22 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 23 Material may be disclosed only to the categories of persons and under the conditions 24 described in this Order. When the litigation has been terminated, a Receiving Party must 25 comply with the provisions of section 13 below (FINAL DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a 27 location and in a secure manner that ensures that access is limited to the persons 28 authorized under this Order. 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 2 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 3 may disclose any information or item designated “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 5 employees of said Outside Counsel of Record to whom it is reasonably necessary to 6 disclose the information for this litigation and who have signed the “Acknowledgment 7 and Agreement to Be Bound” that is attached hereto as Exhibit A; 8 (b) the officers, directors, and employees (including House Counsel) of the 9 Receiving Party to whom disclosure is reasonably necessary for this litigation and who 10 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 12 is reasonably necessary for this litigation and who have signed the “Acknowledgment 13 and Agreement to Be Bound” (Exhibit A); 14 (d) the court and its personnel; 15 (e) court reporters and their staff, professional jury or trial consultants, mock 16 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this 17 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” 18 (Exhibit A); 19 (f) during their depositions, witnesses in the action to whom disclosure is 20 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be 21 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 22 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 23 Protected Material must be separately bound by the court reporter and may not be 24 disclosed to anyone except as permitted under this Stipulated Protective Order. 25 (g) the author or recipient of a document containing the information or a 26 custodian or other person who otherwise possessed or knew the information. 27 28 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation that 3 4 compels disclosure of any information or items designated in this action as 5 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 6 7 include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to issue 8 9 in the other litigation that some or all of the material covered by the subpoena or order is 10 subject to this Protective Order. Such notification shall include a copy of this Stipulated 11 Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by 12 13 the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the 14 15 subpoena or court order shall not produce any information designated in this action as 16 “CONFIDENTIAL” before a determination by the court from which the subpoena or 17 order issued, unless the Party has obtained the Designating Party’s permission. The 18 Designating Party shall bear the burden and expense of seeking protection in that court 19 of its confidential material – and nothing in these provisions should be construed as 20 authorizing or encouraging a Receiving Party in this action to disobey a lawful directive 21 from another court. 22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 23 IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a Non- 25 Party in this action and designated as “CONFIDENTIAL.” Such information produced 26 by Non-Parties in connection with this litigation is protected by the remedies and relief 27 provided by this Order. Nothing in these provisions should be construed as prohibiting a 28 Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to produce a Non-Party’s confidential information in its possession, and the Party is subject to an 1 agreement with the Non-Party not to produce the Non-Party’s confidential information, 2 then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party that 3 4 some or all of the information requested is subject to a confidentiality agreement with a 5 Non-Party; 6 (2) promptly provide the Non-Party with a copy of the Stipulated 7 Protective Order in this litigation, the relevant discovery request(s), and a reasonably 8 specific description of the information requested; and 9 (3) make the information requested available for inspection by the Non- 10 Party. 11 (c) If the Non-Party fails to object or seek a protective order from this court 12 within 14 days of receiving the notice and accompanying information, the Receiving 13 Party may produce the Non-Party’s confidential information responsive to the discovery 14 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not 15 produce any information in its possession or control that is subject to the confidentiality 16 agreement with the Non-Party before a determination by the court. Absent a court order 17 to the contrary, the Non-Party shall bear the burden and expense of seeking protection in 18 this court of its Protected Material. 19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 21 Protected Material to any person or in any circumstance not authorized under this 22 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 23 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 24 all unauthorized copies of the Protected Material, (c) inform the person or persons to 25 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 26 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 27 that is attached hereto as Exhibit A. 28 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain 3 4 inadvertently produced material is subject to a claim of privilege or other protection, the 5 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or information 10 covered by the attorney-client privilege or work product protection, the parties may 11 incorporate their agreement in the stipulated protective order submitted to the court. 12 12. MISCELLANEOUS 13 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 14 person to seek its modification by the court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 15 16 Protective Order no Party waives any right it otherwise would have to object to 17 disclosing or producing any information or item on any ground not addressed in this 18 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 19 to use in evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. Without written permission from the Designating 20 21 Party or a court order secured after appropriate notice to all interested persons, a Party 22 may not file in the public record in this action any Protected Material. A Party that seeks 23 to file under seal any Protected Material must comply with Civil Local Rule 141. 24 13. FINAL DISPOSITION 25 II. Within 60 days after the final disposition of this action, as defined in 26 paragraph 4, each Receiving Party must return all Protected Material to the Producing 27 Party or destroy such material. As used in this subdivision, “all Protected Material” 28 includes all copies, abstracts, compilations, summaries, and any other format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a written certification to the 1 Producing Party (and, if not the same person or entity, to the Designating Party) by the 2 60 day deadline that (1) identifies (by category, where appropriate) all the Protected 3 Material that was returned or destroyed and (2) affirms that the Receiving Party has not 4 retained any copies, abstracts, compilations, summaries or any other format reproducing 5 or capturing any of the Protected Material. Notwithstanding this provision, Counsel are 6 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 7 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 8 expert reports, attorney work product, and consultant and expert work product, even if 9 such materials contain Protected Material. Any such archival copies that contain or 10 constitute Protected Material remain subject to this Protective Order as set forth in 11 Section 4 (DURATION). 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 DATED: February 5, 2018 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: February 5, 2018 Dean A. Alper Attorneys for Plaintiff Rebecca M. Biernat Attorneys for Defendant ORDER 1 2 Pursuant to the parties’ stipulation and the Court’s modification to Paragraph 6.3 3 above, the stipulated protective order is hereby adopted. 4 5 IT IS SO ORDERED. 6 Dated: February 7, 2018 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 /s/ UNITED STATES MAGISTRATE JUDGE 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of _________________ 4 [print or type full address], declare under penalty of perjury that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States District 6 Court for the Eastern District of California on [date] in the case of _Mid-Century Insurance 7 Company v. General Electric Company, Electrolux Home Products, Inc., Case No.1:17-cv8 00157-DAD-EPG . I agree to comply with and to be bound by all the terms of this 9 Stipulated Protective Order and I understand and acknowledge that failure to so comply 10 could expose me to sanctions and punishment in the nature of contempt. I solemnly 11 promise that I will not disclose in any manner any information or item that is subject to this 12 Stipulated Protective Order to any person or entity except in strict compliance with the 13 provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Northern District of California for the purpose of enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________

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