Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 1 of 43 PageID #: 904
`Case l:17—cv—OO300—UNA Document 1-30 Filed 03/20/17 Page 1 of 43 Page|D #: 904
`
`EXHIBIT 30
`
`EXHIBIT 30
`
`
`Case l:17—cv—OO300—UNA Document 1-30 Filed 03/20/17 Page 1 of 43 Page|D #: 904
`
`EXHIBIT 30
`
`EXHIBIT 30
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 2 of 43 PageID #: 905
`
`U.S. Patent No. 7,928,348
`
`Claims 24, 25, 26, and 27.
`Toyota / Aisin Pump
`Toyota P/N G9040-33030
`Aisin P/N WQT-002
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 3 of 43 PageID #: 906
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`24. A fluid conveying
`mechanism comprising:
`
`The Toyota / Aisin Water Pump (the “Aisin Pump”) has a Toyota part number G9040-33030 and Aisin part number WQT-
`002:
`
`Aisin Cooling Catalog 2016.pdf at 145 (hereinafter “Aisin
`Cooling Catalog”), availab le at
`http://aisinaftermarket.com/FlipBook/CoolingCatalog/mobile/i
`ndex.html (downloaded Dec. 6, 2016)
`
`20160808_151508.jpg
`
`The Aisin Pump is marked with the Aisin logo:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 4 of 43 PageID #: 907
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`20160809_095832.jpg
`
`The Aisin Pump is a water pump and is believed to be installed in the following 2016 Toyota models:
`
` Toyota Avalon Hybrid Limited 2.5L L4 – Electric/Gas
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 5 of 43 PageID #: 908
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`See, http://www.toyota.com/avalon/
`
` Toyota Camry Hybrid LE 2.5L L4 – Electric /Gas
`
` Toyota Camry Hybrid SE 2.5L L4 – Electric/Gas
`
` Toyota Camry Hybrid XLE 2.5L L4 – Electric/Gas
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 6 of 43 PageID #: 909
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`See, http://www.toyota.com/camry/
`
` Toyota RAV4 LE 2.5L L4 – Gas
`
` Toyota RAV4 Limited 2.5L L4 – Gas
`
` Toyota RAV4 XLE 2.5L L4 – Gas
`
` Toyota RAV4 SE 2.5L L4 – Gas
`
` Toyota RAV4 Hybrid XLE 2.5L L4 – Electric/Gas
`
` Toyota RAV4 Hybrid Limited 2.5L L4 – Electric/Gas
`
`See, http://www.toyota.com/rav4/
`
`http://parts.olathetoyota.com/oe-toyota/g904033030 (accessed December 12, 2016).
`
`The Aisin Pump is made in Japan:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 7 of 43 PageID #: 910
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`20160808_151508.jpg
`
`As shown in greater detail below, the Aisin Pump comprises a fluid conveying mechanism. For example, as shown in the
`images below, the Aisin Pump contains a fluid pathway to conduct fluid, in which fluid enters the motor via the fluid inlet,
`travels along the fluid pathway, and then exits the motor via the fluid outlet.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 8 of 43 PageID #: 911
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`IMG_9990 (2).JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 9 of 43 PageID #: 912
`U.S. Patent No. 7,928,348: Claim 24
`"24. A fluid conveying mechanism comprising:"
`
`20160809_101706.jpg
`
`
`
`a) an electromagnetic field-
`functioning device having a
`magnetically inducible core
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 10 of 43 PageID #: 913
`U.S. Patent No. 7,928,348: Claim 24
`"a) an electromagnetic field-functioning device having a magnetically inducible core"
`
`The Aisin Pump comprises an electromagnetic field-functioning device having a magnetically inducible core.
`
`For example, the Aisin Pump contains a stator assembly comprising poles with wire windings wrapped around said poles.
`The poles, combined with an electric input, create a rotating magnetic field containing moving polarities within the core. At
`least one (permanent) magnet is contained within a rotor, which sits in the middle of the stator assembly (i.e., the core). The
`rotor screws into a molded space in the monolithic body of the motor of the Aisin Pump, such space being located in the
`middle of the stator assembly, or within the core. This location situates the magnet within the core of the stator assembly, in
`the center of the poles with copper wire windings wrapped around them. An electric input provides a charge to these
`windings (conductors), which then allows the polarity of the poles to change. The magnet then rotates with the changing
`polarities of the poles.
`
`Pictured below is the rotor. The magnetic properties of the magnet within are displayed by the attraction of a metal object to
`the magnet:
`
`20160817_115132.jpg
`
`A cross section of the rotor shows the magnet within:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 11 of 43 PageID #: 914
`U.S. Patent No. 7,928,348: Claim 24
`"a) an electromagnetic field-functioning device having a magnetically inducible core"
`
`20160817_111712.jpg & 20160817_111855.jpg
`
`Pictured below is the monolithic body of the motor of the Pump displaying (1) the rotor within a molded space and (2)
`removed from the molded space;
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 12 of 43 PageID #: 915
`U.S. Patent No. 7,928,348: Claim 24
`"a) an electromagnetic field-functioning device having a magnetically inducible core"
`20160809_101659.jpg & 20160809_101718.jpg
`
`Pictured below are conductors (wire windings) situated around the molded space in which the rotor, containing the at least
`one magnet, sits:
`
`20160817_111906.jpg
`
`Pictured below is the electric input to the Aisin Pump:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 13 of 43 PageID #: 916
`U.S. Patent No. 7,928,348: Claim 24
`"a) an electromagnetic field-functioning device having a magnetically inducible core"
`
`20160808_152221.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 14 of 43 PageID #: 917
`U.S. Patent No. 7,928,348: Claim 24
`"and at least one electrical conductor that creates a magnetic field in the core when electrical current is conducted through the conductor;"
`
`and at least one electrical
`conductor that creates a
`magnetic field in the core
`when electrical current is
`conducted through the
`conductor;
`
`The Aisin Pump comprises at least one electrical conductor that creates a magnetic field in the core when electrical current is
`conducted through the conductor.
`
`For example, as explained above, the Aisin Pump comprises a stator assembly with copper wires wrapped around the poles
`of the stator assembly. These wires are conductors.
`
`20160817_111906.jpg
`
`These conductors create a magnetic field in the core when electrical current is conducted through the conductor.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 15 of 43 PageID #: 918
`U.S. Patent No. 7,928,348: Claim 24
`"and at least one electrical conductor that creates a magnetic field in the core when electrical current is conducted through the conductor;"
`
`https://www.nde-ed.org/EducationResources/HighSchool/Electricity/electrostaticfield.htm
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 16 of 43 PageID #: 919
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`b) a monolithic body of
`injection molded
`thermoplastic material
`
`The Aisin Pump comprises a monolithic body of injection molded thermoplastic material.
`
`The monolithic body of the Aisin Pump includes a “PPS – GF 30” label:
`
`IMG_9989.JPG
`
`“PPS – GF 30” refers to polyphenylene sulfide with 30% glass fiber filler (“PPS-GF30”). Se e , e .g., U.S. Patent Publication
`2009/0173903 (application No. 12/295,565), at ¶ 0114 (“The abbreviations of the resin names in the tables above are as
`follows. PPS-GF30: Polyphenylene sulfide resin containing 30 wt % of glass fibers”).
`
`PPS-GF30 is a thermoplastic – the excerpt pictured below is a summary of its properties (including the categories of which it
`is a member, which includes “thermoplastic”) from the MatWeb material property database.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 17 of 43 PageID #: 920
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`http://www.matweb.com/search/DataSheet.aspx?MatGUID=c43bc743bdc0413ead2b87aca2e38a30&ckck=1 (downloaded
`Dec. 9, 2016).
`
`The “PPS – GF 30” label on the Aisin Pump denotes that the plastic body of the Aisin Pump is made of this type of
`thermoplastic material.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 18 of 43 PageID #: 921
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`20160808_101659.jpg
`
`PPS-GF30 is commonly used in injection molding processes to manufacture parts:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 19 of 43 PageID #: 922
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`https://plastics.ulprospector.com/generics/41/polyphenylene-sulfide-pps (downloaded Dec. 15, 2016).
`
`The monolithically formed body of the motor of the Aisin Pump contains markings that indicate it as manufactured using
`injection molding. For example, as shown in the images below, the monolithically formed body of the Aisin Pump shows
`signs of gates and knockout pins, such markings being associated only with injection molded manufacturing.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 20 of 43 PageID #: 923
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`20160809_102710.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 21 of 43 PageID #: 924
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`20160808_151740.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 22 of 43 PageID #: 925
`U.S. Patent No. 7,928,348: Claim 24
`"b) a monolithic body of injection molded thermoplastic material"
`
`20160809_100245.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 23 of 43 PageID #: 926
`U.S. Patent No. 7,928,348: Claim 24
`"substantially encapsulating the at least one conductor;"
`
`substantially encapsulating
`the at least one conductor;
`
`The thermoplastic, injection molded, monolithic body of the Aisin Pump substantially encapsulates the at least one
`conductor.
`
`As explained above, the Aisin Pump comprises a stator assembly with copper wires wrapped around the poles of the stator
`assembly. These wires are conductors.
`
`20160817_111906.jpg
`
`The conductors are substantially encapsulated within the body of PPS – GF 30. For example, the photo below shows the
`conductors substantially encapsulated within the body of PPS – GF 30.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 24 of 43 PageID #: 927
`U.S. Patent No. 7,928,348: Claim 24
`"substantially encapsulating the at least one conductor;"
`
`20160817_111906.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 25 of 43 PageID #: 928
`U.S. Patent No. 7,928,348: Claim 24
`"and c) a fluid pathway at least partially embedded in and integral with the monolithic body,"
`
`and c) a fluid pathway at
`least partially embedded in
`and integral with the
`monolithic body,
`
`The Aisin Pump comprises a fluid pathway at least partially embedded in and integral with the monolithic body.
`
`The Aisin Pump comprises a fluid pathway contained within the monolithic body, with fluid inlets and outlets. As shown in
`the images below, the fluid pathway is molded within the thermoplastic material of the monolithic body, and is contained
`inside the body itself.
`
`The photo below shows the fluid inlet and fluid outlet into the fluid pathway of the Aisin Pump.
`
`IMG_9990 (2).JPG
`
`A cross-section of the Aisin Pump shows the fluid pathway molded and located within the monolithic body of the Aisin
`Pump.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 26 of 43 PageID #: 929
`U.S. Patent No. 7,928,348: Claim 24
`"and c) a fluid pathway at least partially embedded in and integral with the monolithic body,"
`
`20160809_101706.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 27 of 43 PageID #: 930
`U.S. Patent No. 7,928,348: Claim 24
`"with at least one of a fluid inlet into the pathway and a fluid outlet from the pathway being formed in the body of injection molded thermoplastic,"
`
`with at least one of a fluid
`inlet into the pathway and a
`fluid outlet from the
`pathway being formed in the
`body of injection molded
`thermoplastic,
`
`The fluid pathway of the Aisin Pump contains at least one of a fluid inlet into the pathway and a fluid outlet from the
`pathway being formed in the body of injection molded thermoplastic.
`
`As shown in the below images, the Aisin Pump comprises a fluid inlet and a fluid outlet, shaped from the thermoplastic
`material and attached to the monolithic body. The fluid inlet and the fluid outlet allow fluid (e.g., air) to enter and exit the
`fluid pathway, respectively.
`
`IMG_9990 (2).JPG
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 28 of 43 PageID #: 931
`U.S. Patent No. 7,928,348: Claim 24
`"with at least one of a fluid inlet into the pathway and a fluid outlet from the pathway being formed in the body of injection molded thermoplastic,"
`
`20160809_101706.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 29 of 43 PageID #: 932
`U.S. Patent No. 7,928,348: Claim 24
`"and the pathway through the body being confined within the body."
`
`and the pathway through the
`body being confined within
`the body.
`
`The fluid pathway through the body of the Aisin Pump is confined within the body.
`
`As shown in the image below, the fluid pathway is located within the monolithic body of the Aisin Pump. The photo below
`shows the body broken into two pieces in order to display the inside of the body. Both sections of the body are displayed
`with the inside portion facing upwards. The fluid pathway is confined within the body.
`
`20160809_101706.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 30 of 43 PageID #: 933
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`25. The fluid conveying
`mechanism of claim 24
`wherein the device is
`operable to power fluid
`conveyance through the
`mechanism and at least a
`portion of the fluid
`conveyed by the mechanism
`passes through the fluid
`pathway in the monolithic
`body.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24 wherein the device is operable to power fluid
`conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes through the fluid
`pathway in the monolithic body.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24. Se e the chart of claim 24, sup ra.
`
`The rotor of the motor of the Aisin Pump spins during motor operation due to a magnet located within the rotor. The rotor
`sits in the middle of the stator assembly of the motor (e.g., the core), screwed into a molded space in the monolithic body of
`the Aisin Pump, such space being located in the middle of the stator assembly. This location situates the magnet within the
`core of the stator assembly, in the center of poles with copper wire windings wrapped around them. An electrical input to the
`motor provides a charge to these windings (conductors), which then allows the polarity of the poles they are wrapped around
`to change. The rotor then rotates with the changing polarity of the poles due to the attraction of the magnet located within
`the rotor. The rotation of the rotor spins a fan attached to the top of the rotor.
`
`Pictured below is the magnet, the magnetic properties of which are displayed by the attraction of a metal object to the
`magnet:
`
`20160817_115132.jpg
`
`A cross section of the rotor shows the magnet within:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 31 of 43 PageID #: 934
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`20160817_111712.jpg & 20160817_111855.jpg
`
`Pictured below is the monolithic body of the Aisin Pump displaying (1) the rotor within a molded space and (2) removed
`from the molded space:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 32 of 43 PageID #: 935
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`20160809_101659.jpg & 20160809_101718.jpg
`
`Pictured below are conductors (wire windings) situated around the molded space in which the rotor, containing the at least
`one magnet, sits:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 33 of 43 PageID #: 936
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`20160817_111906.jpg
`
`Pictured below is the fan attached to the rotor:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 34 of 43 PageID #: 937
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`
`20160809_102633.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 35 of 43 PageID #: 938
`U.S. Patent No. 7,928,348: Claim 25
`"wherein the device is operable to power fluid conveyance through the mechanism and at least a portion of the fluid conveyed by the mechanism passes
`through the fluid pathway in the monolithic body."
`20160817_111710.jpg
`
`The fan attached to the rotor moves fluid through the fluid pathway during motor operation. At least a portion of the fluid
`(e.g., air, water) conveyed by the mechanism passes through the fluid pathway in the monolithic body. This is so because the
`fan that spins during motor operation is opposite the fluid pathway in the monolithic body, thereby forcing fluid to follow the
`fluid pathway during motor operation. The image below shows inside the monolithic body of thermoplastic material; during
`motor operation the two pieces are attached, with the fan fitting into the circular indentation of the fluid pathway.
`
`20160809_101706.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 36 of 43 PageID #: 939
`U.S. Patent No. 7,928,348: Claim 26
`"wherein the mechanism is selected from the group consisting of valves, pumps and blowers."
`
`26. The fluid conveying
`mechanism of claim 24
`wherein the mechanism is
`selected from the group
`consisting of valves, pumps
`and blowers.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24 wherein the mechanism is selected from the group
`consisting of valves, pumps and blowers.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24. Se e chart of claim 24, sup ra.
`
`The Aisin Pump is selected from the group consisting of valves, pumps and blowers. Specifically, the Aisin Pump is a
`pump.
`
`For example, the Aisin Pump is referred to as a water pump on the purchase receipts and packaging of the product, as seem
`in the images below.
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 37 of 43 PageID #: 940
`U.S. Patent No. 7,928,348: Claim 26
`"wherein the mechanism is selected from the group consisting of valves, pumps and blowers."
`
`20160808_151445.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 38 of 43 PageID #: 941
`U.S. Patent No. 7,928,348: Claim 26
`"wherein the mechanism is selected from the group consisting of valves, pumps and blowers."
`
`20160808_151449.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 39 of 43 PageID #: 942
`U.S. Patent No. 7,928,348: Claim 26
`"wherein the mechanism is selected from the group consisting of valves, pumps and blowers."
`
`20160808_151500.jpg
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 40 of 43 PageID #: 943
`
`27. The fluid conveying
`mechanism of claim 24
`wherein said at least one of
`a fluid inlet and a fluid
`outlet is in the form of a
`plumbing fitting.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24 wherein said at least one of a fluid inlet and a fluid
`outlet is in the form of a plumbing fitting.
`
`The Aisin Pump comprises the fluid conveying mechanism of claim 24. Se e chart of claim 24, sup ra.
`
`At least one of a fluid inlet and a fluid outlet of the Aisin Pump is in the form of a plumbing fitting. Specifically, the fluid
`inlet is in the form of a plumbing fitting. As shown in the images below, the fluid inlet connects the Aisin Pump to tubing
`within the engine.
`
`IMG_9990 (2).JPG
`
`A diagram which shows the placement of this part in relation to other parts shows a piece of tubing or piping being
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 41 of 43 PageID #: 944
`connected to the fluid inlet of this Aisin Pump. The Aisin Pump is highlighted in green.
`
`http://www.oempartworld.com/oe-toyota/g904033030
`
`Pictured below is an enlarged version of this diagram:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 42 of 43 PageID #: 945
`
`http://www.oempartworld.com/oe-toyota/g904033030
`
`A “clean” version of this diagram, without the Aisin Pump highlighted in green, is displayed below. These diagrams clearly
`show a pipe or tubing, labeled as 11, placed above the fluid inlet of the Aisin Pump:
`
`
`
`Case 1:17-cv-00300-UNA Document 1-30 Filed 03/20/17 Page 43 of 43 PageID #: 946
`
`http://www.oempartworld.com/oe-toyota/g904033030
`
`
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