IPR2023-00332
`U.S. Patent No. 9,158,745
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`AKAMAI TECHNOLOGIES, INC.,
`
`Petitioner,
`
`v.
`
`EQUIL IP HOLDINGS LLC,
`
`Patent Owner.
`
`____________
`
`Case IPR2023-00332
`
`U.S. Patent No. 9,158,745
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 9,158,745
`
`Akamai Ex. 1039
`Akamai Techs. v. Equil IP Holdings
`IPR2023-00332
`Page 00001
`
`
`U.S. Patent No. 9,158,745
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`AKAMAI TECHNOLOGIES, INC.,
`
`Petitioner,
`
`v.
`
`EQUIL IP HOLDINGS LLC,
`
`Patent Owner.
`
`____________
`
`Case IPR2023-00332
`
`U.S. Patent No. 9,158,745
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 9,158,745
`
`Akamai Ex. 1039
`Akamai Techs. v. Equil IP Holdings
`IPR2023-00332
`Page 00001
`
`
`
`IPR2023-00332
`U.S. Patent No. 9,158,745
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`1.
`
`I, Jonathan Bradford, make the following Declaration pursuant to 28
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`U.S.C. § 1746: I am a Senior IP Paralegal at the law firm of Ropes & Gray LLP.
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`2.
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`I provide this Declaration in connection with the above-identified
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`Inter Partes Review proceeding that is before the United States Patent and
`
`Trademark Office (“USPTO”). Unless otherwise stated, the facts stated in this
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`Declaration are based on my personal knowledge.
`
`3.
`
`Ex. 1001 is a true and correct copy of U.S. Patent No. 9,158,745
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`(“’745”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`4.
`
`Ex. 1002 is a true and correct copy of File History of U.S. Application
`
`No. 13/752,110 (“’745 FH”), which led to U.S. Patent No. 9,158,745, which was
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`obtained from the USPTO’s Patent Center system. This document has been
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`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made
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`to this document.
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`5.
`
`Ex. 1004 is a true and correct copy of U.S. Patent No. 6,421,733
`
`(“Tso”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`1
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`IPR2023-00332 Page 00002
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`IPR2023-00332
`U.S. Patent No. 9,158,745
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`6.
`
`Ex. 1005 is a true and correct copy of U.S. Patent No. 6,438,576
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`(“Huang”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`7.
`
`Ex. 1006 is a true and correct copy of U.S. Patent No. 5,905,522
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`(“Lawler”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`8.
`
`Ex. 1007 is a true and correct copy of U.S. Patent Application
`
`Publication No. US 2002/0078093 (“Samaniego”), which was obtained from the
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`USPTO’s Patent Center system. This document has been marked with an exhibit
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`label and page numbers on each page at the bottom right corner. However, no
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`alterations, other than these noted markings, have been made to this document.
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`9.
`
`Ex. 1008 is a true and correct copy of U.S. Patent No. 5,420,967
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`(“Delp”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`2
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`IPR2023-00332 Page 00003
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`IPR2023-00332
`U.S. Patent No. 9,158,745
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`10.
`
`Ex. 1009 is a true and correct copy of U.S. Patent No. 5,969,716
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`(“Davis”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
`
`11.
`
`Ex. 1010 is a true and correct copy of Application No. 11/269,916
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`(“’916 FH”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document. Patent Center
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`12.
`
`Ex. 1012 is a true and correct copy of U.S. Patent No. 6,792,575
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`(“’575”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
`
`13.
`
`Ex. 1013 is a true and correct copy of Change-Pro Redline Samaniego
`
`vs. ’745 patent, which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`3
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`IPR2023-00332 Page 00004
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`IPR2023-00332
`U.S. Patent No. 9,158,745
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
`
`14. Ex. 1014 is a true and correct copy of Loralee Stevens, Internet Video
`
`Startup Gets $3.5 Million, N. BAY BUS. J. (Apr. 14, 2008), available at
`
`https://web.archive.org/web/20080421191837/www.northbaybusinessjournal.com/
`
`article/20080414/BUSINESSJOURNAL/19773530/1207/BUSINESSJOURNAL0
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`2, which was obtained at my direction. This document has been marked with an
`
`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
`
`15. Ex. 1015 is a true and correct copy of LinkedIn Profile for Chris
`
`Samaniego, available at https://www.linkedin.com/in/chris-samaniego-18b6a01,
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`which was obtained at my direction. This document has been marked with an
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`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
`
`16. Ex. 1016 is a true and correct copy of Equil IP Holdings LLC v.
`
`Akamai Technologies, Inc., 1:22-cv-00677 (D. Del. 2022) First Amended
`
`complaint (Aug. 3, 2022), which was obtained at my direction. This document has
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`been marked with an exhibit label and page numbers on each page at the bottom
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`right corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`4
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`IPR2023-00332 Page 00005
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`IPR2023-00332
`U.S. Patent No. 9,158,745
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`17. Ex. 1020 is a true and correct copy of Docket Report for Barger-Great
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`South Ventures LLC v. Equilibrium Techs., which was obtained at my direction.
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`This document has been marked with an exhibit label and page numbers on each
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`page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`18. Ex. 1021 is a true and correct copy of Change-Pro Redline Samaniego
`
`vs. ’916 Application, which was obtained at my direction. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`19. Ex. 1026 is a true and correct copy of File History of U.S. Application
`
`No. 12/173,747 (“’046 FH), which led to U.S. Patent No. 8,656,046, which was
`
`obtained from the USPTO’s Patent Center system. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`20. Ex. 1027 is a true and correct copy of File History of U.S. Application
`
`No. 12/238,842 (“’110 FH), which led to U.S. Patent No. 8,381,110, which was
`
`obtained from the USPTO’s Patent Center system. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
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`5
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`IPR2023-00332 Page 00006
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`IPR2023-00332
`U.S. Patent No. 9,158,745
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`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`21.
`
`Ex. 1028 is a true and correct copy of Change-Pro Redline Samaniego
`
`vs. ’747 Application, which was obtained at my direction. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`22.
`
`Ex. 1029 is a true and correct copy of Change-Pro Redline Samaniego
`
`vs. ’842 Application, which was obtained at my direction. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`23.
`
`Ex. 1033 is a true and correct copy of Gerald Graef, Graphics
`
`Formats for Linux, 23 LINUX J., March 1996, available at
`
`https://dl.acm.org/doi/fullHtml/10.5555/325530.325533, which was obtained at my
`
`direction. This document has been marked with an exhibit label and page numbers
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`on each page at the bottom right corner. However, no alterations, other than these
`
`noted markings, have been made to this document.
`
`24.
`
`Ex. 1034 is a true and correct copy of File History of U.S. Application
`
`No. 09/425,326 (“’575 FH”), which led to U.S. Patent No. 6,792,575, which was
`
`6
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`IPR2023-00332 Page 00007
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`
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`IPR2023-00332
`U.S. Patent No. 9,158,745
`
`obtained from the USPTO’s Patent Center system. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`25. Ex. 1035 is a true and correct copy of File History of U.S. Application
`
`No. 09/929,904 (“’009 FH”), which led to U.S. Patent No. 6,964,009, which was
`
`obtained from the USPTO’s Patent Center system. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`26. Ex. 1036 is a true and correct copy of Luca Delgrossi et al., Media
`
`Scaling in a Multimedia Communication System, 2 MULTIMEDIA SYS. 172 (1994),
`
`available at https://link.springer.com/article/10.1007/BF01210448, which was
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`obtained at my direction. This document has been marked with an exhibit label
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`and page numbers on each page at the bottom right corner. However, no
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`alterations, other than these noted markings, have been made to this document.
`
`27. Ex. 1037 is a true and correct copy of Armando Fox and Eric A.
`
`Brewer, Reducing WWW latency and bandwidth requirements by real-time
`
`distillation, COMPUT. NETWORKS & ISDN SYS., PROCS. 5TH INT’L WORLD WIDE
`
`WEB CONF. (May 1996), available at
`
`7
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`IPR2023-00332 Page 00008
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`
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`IPR2023-00332
`U.S. Patent No. 9,158,745
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`https://www.sciencedirect.com/science/article/abs/-pii/016975529600027X, which
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`was obtained at my direction. This document has been marked with an exhibit
`
`label and page numbers on each page at the bottom right corner. However, no
`
`alterations, other than these noted markings, have been made to this document.
`
`28. Ex. 1038 is a true and correct copy of U.S. Patent No. 6,144,996
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`(“Starnes”), which was obtained from the USPTO’s Patent Center system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`29. Certain pages have been resized to 8.5 x 11 inches. No content was
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`removed by this resizing.
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`30.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under 18 U.S.C. § 1001. If called to testify as to the
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`truth of the matters stated herein, I could and would testify competently.
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`31.
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`I declare under penalty of perjury that the foregoing is true and
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`correct.
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`
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`8
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`IPR2023-00332 Page 00009
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`IPR2023-00332
`U.S. Patent No. 9,158,745
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`Executed this 10th day of January, 2023, in Boston, Massachusetts.
`
`
`
`
`/Jonathan Bradford/
`Jonathan Bradford
`ROPES & GRAY LLP
`
`9
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`IPR2023-00332 Page 00010
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