international cyberstalking laws
/Parent 8 0 R 4 0 obj << >> 163 0 obj /K 5 Learn how and when to remove this template message, United States District Court for the Western District of Washington, "Cyberstalking, Cyberharassment and Cyberbullying Laws", "Current perspectives: the impact of cyberbullying on adolescent health", "CRIMES ACT 1900 - SECT 31 Documents containing threats", "CRIMES ACT 1900 - SECT 199 Threatening to destroy or damage property", "Government reveals further details on cyberbullying laws - Paul Fletcher MP", "Judge backs student's First Amendment rights", "Court: Cyberbullying Threats Are Not Protected Speech", https://blog.ericgoldman.org/archives/2016/06/north-carolina-state-supreme-court-strikes-down-cyberbullying-statute.htm, https://casetext.com/case/state-v-robert-bishop-2, "Cyberbullying and schools: where does a principal's authority end? International law emphasizes a supranational concept related to cybercrime. North Carolina State Supreme Court Strikes Down Cyberbullying Statute. Further, cyber-industries must develop policies and procedures for protecting their clients. /Type /Page 195 0 obj endobj >> /P 9 0 R >> >> 7 [600 0 R 601 0 R 602 0 R 603 0 R 604 0 R 605 0 R 606 0 R 607 0 R 608 0 R 609 0 R << 172 0 obj endobj endobj /Pg 14 0 R /S /P Cyberstalking can result in a lifelong prison sentence if the actions resulted in the victims death. 10 0 obj /S /P /Pg 31 0 R << First Amendment concerns often arise when questionable speech is uttered or posted online. endobj endobj North Carolina Court of Appeals Reports (1963-2014) volume 96. 195 0 R 196 0 R 197 0 R 198 0 R 199 0 R 200 0 R 201 0 R 202 0 R 203 0 R 204 0 R] /K 18 /Annots [292 0 R 293 0 R 294 0 R 295 0 R 296 0 R 297 0 R 298 0 R 299 0 R 300 0 R 301 0 R] 202 0 obj /Pg 31 0 R /Keywords () /MediaBox [0.0 0.0 595.32 841.92] Nothing; existing stalking laws can apply. endobj /TT0 243 0 R /S /P /Type /Page /Pg 15 0 R While 156 countries (80 per cent) have enacted cybercrime legislation, the pattern varies by region: Europe has the highest adoption rate (91 per cent) and Africa the lowest (72 per cent). 120 0 obj /K 5 200 0 obj 184 0 obj /K 12 In 2008, Florida passed the "Jeffrey Johnston Stand Up For All Students Act" in response to the suicide of 15-year-old Jeffrey Johnston, who had suffered cyberbullying over a long period of time. << /Pg 32 0 R [11] The state of North Carolina invalidated such a law in State v. /Pg 30 0 R 108 0 obj /CropBox [0.0 0.0 595.32 841.92] endobj << endobj /Pg 14 0 R << >> Washington, DC: U.S. Department of Justice. /Pg 28 0 R endobj endobj /CS0 [/ICCBased 241 0 R] /P 9 0 R /ColorSpace << /K [5 510 0 R 23 511 0 R 25 512 0 R 27 513 0 R 29 514 0 R L. 1134 amended section generally. /S /P /Pg 22 0 R /S /P 154 0 obj /S /P 127 0 obj /P 9 0 R /Pg 22 0 R /S /Footnote >> 47 0 obj >> /MediaBox [0.0 0.0 595.32 841.92] /S /P null 408 0 R null 409 0 R null 410 0 R null 411 0 R null 412 0 R /K 9 /P 9 0 R 51 0 obj endobj >> [47] Furthermore, the bill addresses not just student-to-student harassment, but also harassment of students by faculty or staff as well. /S /P endobj /S /P /P 9 0 R /CS0 [/ICCBased 241 0 R] >> endobj /K 5 /MediaBox [0.0 0.0 595.32 841.92] /S /P /Pg 14 0 R /F4 226 0 R /K 3 << << << << Although there are often existing laws that prohibit stalking or harassment in a general sense, legislators sometimes believe that such laws are inadequate or do not go far enough, and thus bring forward new legislation to address this perceived shortcoming. /S /P /MarkInfo << /S /P /K 16 /Contents 358 0 R >> >> /K 4 103 0 R 104 0 R 105 0 R 106 0 R 107 0 R 108 0 R 109 0 R 110 0 R 111 0 R 112 0 R 203 0 obj /CropBox [0.0 0.0 595.32 841.92] /S /P >> /MediaBox [0.0 0.0 595.32 841.92] [52], International law emphasizes a supranational concept related to cybercrime. An Empirical Study. Bishop. /K 1 /Creator (Acrobat PDFMaker 9.1 for Word) /S /P >> /P 9 0 R >> endobj >> >> Pub. /S /P >> Cyberstalking laws in the United States, both federal and state, support victims of all ages, however some sites focus on those laws that protect victims under the age of 18. 2011-02-16T10:29:38+01:00 << 6-1-09; 96-328, eff. /S /P 138 0 obj >> >> 91 0 obj /P 9 0 R /TT1 285 0 R This is equally true when dealing with cyberbullying. /TT0 243 0 R 548 0 R null 549 0 R null 627 0 R 628 0 R 550 0 R 151 0 R] /P 9 0 R /P 9 0 R endobj 6 0 obj >> /S /P >> endobj The bill would also enable the U.S. Department of Education to provide training to institutes of higher education to prevent or address harassment. /Type /Page endobj /S /P /K 2 164 0 obj /TT0 243 0 R /S /P 8-11-09. 8 [105 0 R 106 0 R 107 0 R 108 0 R 109 0 R 110 0 R null 454 0 R null 455 0 R 57 0 obj /S /P endobj /Font << >> /K [2 403 0 R 33 404 0 R 35 405 0 R 37 406 0 R 39] /S /P >> << /S /P /S /P >> /Parent 8 0 R 79 496 0 R 80 497 0 R 81 498 0 R 82 499 0 R 83 500 0 R /Type /Pages >> /K [476 0 R 477 0 R 478 0 R 479 0 R 480 0 R 481 0 R] Contact Beckham Solis, Attorneys at Law at (305) 290-1884 for representation from a team in Miami with over 35 years of collective experience. 217 0 obj << 63 0 obj /K [504 0 R 505 0 R 506 0 R 507 0 R 508 0 R 509 0 R] /Pg 16 0 R /K [518 0 R 519 0 R 520 0 R 521 0 R 522 0 R 523 0 R] /S /Footnote /P 9 0 R /K 17 << After progressing through the courts, the charges against Baker were dismissed primarily on grounds that there was no evidence that Baker would actually act out the fantasies contained in those stories. /Xf1 227 0 R >> << << endobj << >> /Pg 15 0 R /Annots [259 0 R 260 0 R 261 0 R 262 0 R 263 0 R 264 0 R 265 0 R 266 0 R 267 0 R] /S /P /Parent 3 0 R /P 9 0 R /StructParents 10 A 2006 National Crime Prevention Council survey found that some 40% of teens had experienced cyberbullying at some point in their lives, making the problem particularly widespread. WebDavid's Law is a state law in Texas, that labels cyberstalking a misdemeanor crime, but it also lays out several other rights victims or parents of victims have in ensuring justice. Secure .gov websites use HTTPS << /K 8 endobj /TT0 243 0 R >> << shall be punished as provided in section 2261(b) or section 2261B, as the case may be. << WebFlorida Statute 784.048 makes stalking (harassment), including cyberstalking, a crime. /Pg 30 0 R /Resources << 171 0 obj 9 620 0 R /S /P application/pdf /TT0 243 0 R /ColorSpace << Svdraa /Pg 31 0 R >> /S /P endobj /P 9 0 R Cybercrime is a growing concern to countries at all levels of developments and affects both, buyers and sellers. /Pg 31 0 R Lurigio and S. Herman (eds. /S /Footnote 402 0 R 64 0 R 403 0 R 65 0 R 404 0 R 65 0 R 405 0 R 65 0 R 406 0 R 65 0 R] Halder, D. & Jaishankar, K. (2008). /K [1 529 0 R 22 530 0 R 24 531 0 R 26 532 0 R 28] endobj /Count 21 endobj /CS0 [/ICCBased 241 0 R] /P 9 0 R 183 0 R 184 0 R 185 0 R 186 0 R 187 0 R 188 0 R 189 0 R 190 0 R 191 0 R 192 0 R /S /P Some U.S. states have begun to address the problem of cyberbullying. >> WebCaselaw Access Project cases. Behera, A. 83 0 R 84 0 R 85 0 R 86 0 R 87 0 R 88 0 R 89 0 R 90 0 R 91 0 R 92 0 R << /Rotate 0 /TT0 243 0 R /Pg 32 0 R << /S /P /ColorSpace << >> endobj >> << /Parent 6 0 R /Pg 32 0 R >> /S /P /K [1 516 0 R 22 517 0 R 24] << /Pg 14 0 R << 76 0 R] Prior to February 2013, there were no laws that directly regulate cyberstalking in India. << 163 0 R 164 0 R 165 0 R 166 0 R 167 0 R 168 0 R 169 0 R 170 0 R 171 0 R 172 0 R 4203] increases penalties related to the stalking of minors. /P 9 0 R /Pg 13 0 R /P 9 0 R L. 1134 not effective until the beginning of the fiscal year following Mar. >> 175 0 R 176 0 R 177 0 R 178 0 R 179 0 R 180 0 R 181 0 R 182 0 R 183 0 R 184 0 R It stipulates various ranges of imprisonment for anyone who uses /P 9 0 R 113 0 obj >> >> endobj 114 574 0 R 115 635 0 R] No one shall be subjected to torture or to cruel, inhuman or degrading treatment. /Pg 13 0 R /K 1 >> /Pg 13 0 R 433 0 R null 428 0 R 88 0 R 429 0 R 88 0 R 430 0 R 88 0 R] More technologically sophisticated e-mail harassers send "mail bombs," which fill a person's mailbox with hundreds or even thousands of unwanted messages in the hope of making the account useless. << [46][47] Universities would be required to address harassment that focuses on real or perceived race, color, national origin, sex, disability, sexual orientation, gender identity, or religion. /CropBox [0.0 0.0 595.32 841.92] /P 9 0 R /Type /Page /Resources << /K 2 /Contents 309 0 R << endobj 109 0 obj In addition, opponents call the proposed sentences (up to two years incarceration) excessive. endobj << Monsey, NY: Criminal Justice Press. /P 9 0 R /K 7 B, title I, 1107(b)(1), Pub. /K 2 >> 222 0 obj 17 0 obj /Pg 27 0 R endobj endobj >> >> >> << /K [8 551 0 R 552 0 R 553 0 R 554 0 R 555 0 R] << /Resources << endobj /P 9 0 R 15 0 obj >> /Pg 18 0 R /TT0 243 0 R 109 0 R 470 0 R 109 0 R 471 0 R 109 0 R 472 0 R 109 0 R] /CS0 [/ICCBased 241 0 R] endobj /ParentTree 10 0 R /Pg 24 0 R /P 9 0 R 43 0 R 44 0 R 45 0 R 46 0 R 47 0 R 48 0 R 49 0 R 50 0 R 51 0 R 52 0 R 1-1-09; 95-984, eff. /K 8 << /Pg 18 0 R 130 0 obj >> India's Information Technology Act of 2000 (IT Act) was a set of laws to regulate the cyberspace. [43], While Snchez' bill was discussed in committee, it has not passed that stage as of 2012[update].[45]. /P 9 0 R 199 0 obj << endobj /Pg 13 0 R /ColorSpace << L. 1134, set out as a note under section 2261 of this title. /S /Footnote 117 0 obj << /P 9 0 R /S /P /S /Footnote /P 9 0 R /S /P /Pg 14 0 R 96 0 R 445 0 R 96 0 R 446 0 R 96 0 R 452 0 R 98 0 R 453 0 R 103 0 R] endobj << /Contents 353 0 R /K 8 an immediate family member (as defined in section 115) of that person; the pet, service animal, emotional support animal, or horse of that person; >> /S /P 149 0 obj Specific laws against cyber stalking to be illegal in a state or territory, c. Specific laws against cyber stalking in that nation d. Nothing, existing stalking laws can apply 4 [66 0 R 68 0 R 69 0 R 70 0 R 71 0 R 72 0 R 73 0 R 74 0 R 75 0 R 76 0 R /P 9 0 R New Media & Society, 4(1), 71-92. 24 0 obj >> While some sites specialize in laws that protect victims age 18 and under, Working to Halt Online Abuse is a help resource listing current and pending cyberstalking-related United States federal and state laws. /S /P /P 9 0 R /Resources << /Count 10 /TT2 285 0 R endobj /S /P /CropBox [0.0 0.0 595.32 841.92] /K 4 >> >> << /S /P 168 0 obj /Font << 142 0 obj >> << 204 0 obj >> /Pg 31 0 R >> 3 0 obj In the case of Tyler Clementi, who killed himself after video of his homosexual encounter was broadcast on the Internet, prosecutors charged the defendants with invasion of privacy and computer crimes. A qualitative study on the perception of cyber stalking and the adequacy of the anti-stalking law to regulate such crime in Malaysia is somewhat scarce. /Pg 14 0 R << Students at her school had bullied her for months in school, and that harassment eventually moved online as well. de la Paix, 1211 Geneva 10, Switzerland, Welcome to the United Nations Conference on Trade and Development. << endobj << to make someone else afraid or concerned about their safety [1]. << /P 9 0 R an immediate family member (as defined in section 115) of that person; causes, attempts to cause, or would be reasonably expected to cause substantial emotional distress to a person described in clause (i), (ii), or (iii) of subparagraph (A); or, places that person in reasonable fear of the death of or. << 58 0 obj /S /P 69 0 obj /Resources << /P 9 0 R /S /Footnote 119 0 obj /CropBox [0.0 0.0 595.32 841.92] /P 9 0 R /Kids [6 0 R 7 0 R 8 0 R] /K 9 0 R /P 9 0 R /K [7 566 0 R 567 0 R 568 0 R 569 0 R 570 0 R] << /Pg 28 0 R Nothing, existing international cyber stalking laws apply b. 193 0 R 194 0 R 195 0 R 196 0 R 197 0 R 198 0 R 199 0 R 200 0 R 201 0 R 202 0 R >> endobj /K [4 424 0 R 21] >> 203 0 R 204 0 R 205 0 R 206 0 R 207 0 R 208 0 R 209 0 R 210 0 R 211 0 R 212 0 R "Family or household member" includes spouses, former spouses, parents, children, stepchildren and other persons related by blood or by present or prior marriage, persons who share or formerly shared a common dwelling, persons who have or allegedly share a blood relationship through a child, persons who have or have had a dating or engagement relationship, and persons with disabilities and their personal assistants. >> /Parent 7 0 R /CS0 [/ICCBased 241 0 R] << endobj endobj /S /P /Pg 30 0 R /CS0 [/ICCBased 241 0 R] >> /K 2 /K [9 416 0 R 30 417 0 R] endobj /S /P /Contents 222 0 R /Pg 24 0 R /K 13 /K 3 >> 97 0 obj /CropBox [0.0 0.0 595.32 841.92] Browse; Reporter N.C. App. /Pg 27 0 R /Pg 22 0 R /Contents 323 0 R endobj /Type /Pages 212 0 obj 113 0 R 114 0 R 115 0 R 116 0 R 117 0 R 118 0 R 119 0 R 120 0 R 121 0 R 122 0 R >> 53 0 obj 95 0 R 96 0 R 98 0 R 99 0 R 100 0 R 101 0 R 102 0 R 103 0 R null 447 0 R endobj 96 0 obj /ColorSpace << Cyberstalking in conjunction with a credible threat is also considered aggravated stalking.[31]. endobj While 156 countries (80 per cent) have enacted cybercrime legislation, the pattern varies by region: Europe has the highest adoption rate (91 per cent) and << << /S /P /S /P endobj ), In response to Phoebe Prince's suicide, as well as that of Carl Walkerboth of whom had been bullied before taking their livesthe Massachusetts legislature in 2010 passed what advocates call one of the toughest anti-bullying laws in the nation. The legislation provides enhanced criminal penalty for stalkers of minors under Title 18 Section 2261 by up to five years if the victim is a minor. /Count 6 << 134 0 obj /CropBox [0.0 0.0 595.32 841.92] /TT0 243 0 R 128 0 obj /Font << Google Scholar Eck J. E., Clarke R. V. (2003). 175 0 obj WebThis law is in place to protect privacy and applies to everyones privacy and applies to everyone not just people under 18. Tilburg University a. >> /P 9 0 R null 519 0 R null 520 0 R null 521 0 R null 522 0 R null 523 0 R /K [490 0 R 491 0 R 492 0 R 493 0 R 494 0 R 495 0 R] >> /StructParents 6 Thus, something that may be deemed cyberbullying at first glance may, in fact, be more akin to something like parody or similar. 92 0 obj Nappinai, N, S. (2010). /S /P 98 0 obj 105 0 obj Retrieved October 14, 2019, from. /Type /Page /S /P /S /P /K 1 /P 9 0 R /S /Footnote /P 9 0 R << endobj /Pg 23 0 R >> /K 12 /TT0 243 0 R /P 9 0 R /CS1 [/ICCBased 242 0 R] /Resources << As in Connecticut, New Jersey, and Missouri, the Prince case led to stricter anti-bullying legislation in Massachusetts.[22]. Cyber stalking generally involves unwarranted, repeated and threatening conduct of the offender via the Internet or social media platforms, which causes fear, distress or alarm to the victim. << /RoleMap 11 0 R endobj /Pg 32 0 R 221 0 obj On the Internet, public messages can be accessed by anyone at any time. >> 139 0 obj 176 0 obj /TT0 243 0 R /P 9 0 R 2 0 obj 76 0 obj endobj 52 425 0 R 53 426 0 R 54 427 0 R 55 428 0 R 56 429 0 R >> 208 0 obj << 212 0 R 213 0 R 214 0 R 215 0 R 216 0 R 217 0 R 218 0 R] It often appears as a form of revenge after a fight or breakup. 103 0 obj /Pg 14 0 R /S /P >> << 196 0 obj endobj Chat-line users may capture, store, and transmit communications to others outside the chat service. /S /P << 210 0 obj >> endobj /StructParents 0 /P 4 0 R >> << /S /P "Electronic communication" means any transfer of signs, signals, writings, images, sounds, data or intelligence of any nature transmitted in whole or in part by a wire, radio, electromagnetic, photoelectric or photo-optical system. 7, 2013, see section 4 of Pub. /P 9 0 R << << [26] After sending hundreds of threatening e-mails to an actress, another male convicted after spending months in jail waiting for trial was sentenced in 2001 to five years probation, forbidden access to computers and forced to attend mental health counseling. 32 0 obj >> /Parent 8 0 R Cyber Crimes And Law In India. /K 1 causes, attempts to cause, or would be reasonably expected to cause substantial emotional distress to a person described in clause (i), (ii), or (iii) of paragraph (1)(A). [33], As noted previously, in 2008 Missouri revised its statutes on harassment to include harassment and stalking through electronic and telephonic communications and cyber-bullying after the suicide of Megan Meier.[34]. /Pg 13 0 R /Pg 25 0 R /Type /Page << endobj << /K [2 581 0 R 4] /Font << 215 0 obj << The law also requires schools to create policies to address bullying in a general sense.[40][41]. /Contents 342 0 R /ColorSpace << >> There are laws that only address online harassment of children or focus on child predators as well as laws that protect adult cyberstalking victims, or victims of any age. /K 3 /CS0 [/ICCBased 241 0 R] http://www.haltabuse.org/resources/laws/federal.shtml. >> /TT2 258 0 R L. 106386 reenacted section catchline without change and amended text generally. /K [27 453 0 R 48] /Pg 31 0 R endobj endobj /S /P /P 9 0 R /Pg 19 0 R /Pg 15 0 R null 380 0 R null 381 0 R null 582 0 R 583 0 R 382 0 R 55 0 R 383 0 R The jury eventually found Drew innocent of the charges (but guilty of a misdemeanor), a verdict that was later set aside by the judge. 111 0 obj /ModDate (D:20110216102938+01'00') [38][39], Washington takes the approach of putting the focus on cyberbullying prevention and response directly on the schools. >> endobj << << /P 9 0 R Under 18 U.S.C. The first cyberstalking law went into effect just over a year ago in California, and Congress is considering a federal law. /S /P << 20 [204 0 R 205 0 R 206 0 R 581 0 R 206 0 R 207 0 R 208 0 R 209 0 R 210 0 R 211 0 R >> 424 0 R 81 0 R 425 0 R 82 0 R 426 0 R 82 0 R 427 0 R 82 0 R] /TT4 245 0 R >> Although many States in Australia have antistalking laws, Victoria and Queensland are the only States that include sending electronic messages to, or otherwise contacting, the victim in their legislation. WebAccording to Florida Statute 775.082, if an individual is convicted of first-degree misdemeanor cyberstalking, the individual will be punished with up to one year in jail, and a fine of up to $1,000. /Pg 19 0 R 46 0 obj << /K [571 0 R 572 0 R 573 0 R] 70 0 obj /P 9 0 R In the United Kingdom, cyberharassment can be prosecuted under the Protection from Harassment Act of 1997 or the Malicious Communications Act of 1988. /P 9 0 R << 207 0 obj /Pg 32 0 R /P 9 0 R /K 11 >> 143 0 R 542 0 R 143 0 R 543 0 R 143 0 R 544 0 R 144 0 R] /K [11 487 0 R 488 0 R 489 0 R] endobj /K 1 /Nums [0 [33 0 R 35 0 R 36 0 R 37 0 R 38 0 R 39 0 R 40 0 R 41 0 R 42 0 R 43 0 R >> 156 0 obj 67 0 obj /K 6 /K 18 >> endobj /Font << /P 9 0 R /Annots [324 0 R 325 0 R 326 0 R 327 0 R 328 0 R 329 0 R] /CreationDate (D:20110216102934+01'00') The focus on legislating cyberbullying and cyberstalking has largely come about as a result of the perceived inadequacy, generally by legislators and parents of bullying victims, of existing laws, whether those existing laws cover stalking, unauthorized use of computer resources, or the like. WebAuthored by Congressman Brian Fitzpatrick (PA-08), the Combat Online Predators Act [H.R. << << /S /P /S /P /S /P /K 5 /Font << Cyberstalkers often have a sophisticated knowledge of computers and the Internet and can "mask" their intimidating e-mails to victims to disguise their origin. >> << >> endobj 21 0 obj /Pg 31 0 R /StructParents 8 /CropBox [0.0 0.0 595.32 841.92] /Pg 32 0 R endobj endobj endobj 84 625 0 R 85 510 0 R 86 511 0 R 87 512 0 R 88 513 0 R >> /K [2 524 0 R 26 525 0 R 28 526 0 R 30] This chapter examines various forms of "cyberstalking;" legal responses by governments in the United States, Canada, the United Kingdom, and Australia; the challenges law enforcement officers face when investigating the problem; and the control and prevention of cyberstalking. Equality Act 2010 The Equality Act 2010 ( c 15) is an Act of Parliament of the United Kingdom. /S /Sect endobj /Pg 21 0 R endobj 170 0 obj New York state passed the Dignity For All Students Act, focusing primarily on elementary and middle school students. /Parent 8 0 R /S /P /S /P /CropBox [0.0 0.0 595.32 841.92] /K 3 /P 9 0 R >> However, like the Megan Meier Cyberbullying Prevention Act, this bill also has its detractors. << >> /Pg 21 0 R /Rotate 0 /Pg 28 0 R /TT0 243 0 R Webcyber stalking as online harassment, which may include various digitally harassing 6 Heena Keswani, Cyber Stalking: A Critical Study, Bharati Law Review.131, 131-32 (2017). << /P 9 0 R 133 0 obj endobj /K [2 574 0 R 15 575 0 R 576 0 R 577 0 R] /ColorSpace << /Subtype /XML /K [0 464 0 R 30] /P 9 0 R /K 5 [28] On January 1, 2009, a California law became effective that allows schools to suspend or expel students who harass other students online. /P 9 0 R >> /P 9 0 R /StructParents 14 188 0 obj /P 9 0 R << >> 12 0 obj 133 0 R 134 0 R 135 0 R 136 0 R 137 0 R 138 0 R 139 0 R 140 0 R 141 0 R 142 0 R << /S /P >> /S /Footnote The Department of Homeland Security (DHS) works with other federal agencies to conduct high-impact /K [447 0 R 448 0 R 449 0 R 450 0 R 451 0 R] endobj /K 5 endobj >> /TT1 245 0 R << /S /P /Resources << /Pg 30 0 R endobj [43][44] Another issue is that would make violation of the law a felony, rather than a misdemeanor as has been done in most states. >> However, this is limited to the victims of family violence. 60 0 obj 71 0 obj << /Pg 30 0 R /S /P /Type /Page /K 5 Citation is disfavored, but may be In the case of United States v. 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