Is it Time to End the USITC’s Jurisdiction over Patent Cases?

Presidential review of USITC exclusion orders is designed to directly inject politics into the ultimate legal determination between the parties. In his recent letter of disapproval, US Trade Representative Michael Froman recognized that the review is based upon a number of policy goals, including considerations of how the decision impacts the US economy, US consumers, US competitive manufacture, and US-Foreign relations. Although Froman’s letter of disapproval focused on FRAND issues, an undercurrent of the decision is that the American company (Apple) is avoiding its penalty after being judged as an infringer of a patent held by a foreign company (Samsung). Supporting the undercurrent of US-company favoritism is the fact that the USITC is designed as to protect US industry.

In an email, Hal Wegner draws a parallel analogy:

Imagine an American movie studio, book publisher, high tech electronics manufacturer or other intellectual property rights holder going to a Shanghai Court and successfully winning an infringement suit. Then, imagine that President Xi Jinping blocks enforcement “[a]fter extensive consultations with … interested … persons … based on … review of … considerations … as they relate to … the effect on [domestic] consumers.

The question then is how can the US expect for China, India, South Korea and Brazil to strongly enforce foreign-owned intellectual property rights when the US is unwilling to do so itself.

Of course, as I wrote earlier, Samsung is still able to enforce its patent rights in Federal Court and, in that process will be able to seek both injunctive relief (to block imports of the iPhone) and monetary damages for past and ongoing infringement.

In addition to the US/Foreign divide, the USTR involvement brings politics into the dispute at a level orders-of-magnitude beyond what is seen in Federal Courts. Apple is able to get the ear of the US Administration and other influential politicians, and that influence almost certainly impacted the outcome. If adjudged infringer had been a smaller company or perhaps Koch Ind., the outcome may well have been different. The best outcome here is probably to take-away the USITC’s jurisdiction over patent cases and simply allow those cases to be heard in Federal Courts.

= = = = =     

A different perspective on the administrative disapproval here is that it is designed as a signal to the USITC to stop issuing injunctive relief without full consideration of the public interest at stake. If the USITC takes that message to heart then we may observe some interesting development of the law and theory of public-interest in enforcing patent rights. Public interest is also one of the four factors used by Federal Courts when determining whether to issue injunctive relief in patent cases under eBay. In the eBay line of cases, the public interest is typically the least-explored factor. However, it is the only factor available for consideration by the USITC under the Tariff-Act. As the USITC develops its law of public-interest, the next step in the law’s evolution will be for the Federal Courts to begin picking-up that analysis and applying it under eBay.

77 thoughts on “Is it Time to End the USITC’s Jurisdiction over Patent Cases?

  1. It is pretty simple here actually – since the patent owner needs to voluntarily assent to the 337 investigative scheme i,.e, file the 337 request – and therefore assent to the exclusion order as the only remedy – any 7th amendment, 5th, 4th arguments have probably been waived by the patent owner. The analysis would never reach the issue of ‘suits at common law.’

  2. This would’ve been a great time to send a message.

    What would that message have been, Ned? That if you’re going to infringe, please do it domestically?

  3.  Mr. Reply, I don't have any statistics and how many limited exclusion orders have been overturned by the president over time, but I this may be a first as far as I know where the exclusion order was against an American company that was manufacturing abroad.

    I wonder at the politics of the Obama administration that has time and again criticized American companies manufacturing abroad and yet does this. This would've been a great time to send a message. But the message they sent was the wrong one.

     
     
     

  4. Hi Ned. I can’t disagree that it probably makes things worse. Do we have any data to go on, by the way?

    Or is this the first time a non-US company has gotten an ITC ruling for it, but had its hopes dashed by the Obama Admin (or before that, Bush and/or Clinton admins)?

  5. They may also be willing to license everyone else on the same basis.

    Except for the fact that that basis does not NECESSARILY include cross-licensing of non-SEP patents.

    It simply is error to think so.

  6. are acting as if FRAND was a legal standard.

    No Ned – sorry, but it is still you that is misconstruing what the term means by attempting to force an equivalency that simply is not there.

    The fact that it may be there for certain patents (SEP) is simply not dispositive of what you are trying to establish.

    As my Boston friends say, “You can’t get there from here.”

  7. In reply, given that Apple is hometowning Samsung, you are going to bet that foreign governments are going to hometown Apple. Apple just bought itself a world, literally, of hurt.

  8. Agreed – as anyone can see for certain little circle club members that when you lose credibility on a topic, trying to regain that credibility can be very difficult.

  9. anon, that is not how it works in many cases.  Companies do not identify any patents or applications.  They simply agree to license any SEPs FRAND.  But what that means is context sensitive flexible.  Cross licenses of SEPs are expected.

     
     
     

  10. anon, you are acting as if FRAND was a legal standard.  It is not.  Typically various private bodies meet to hammer out a standard for something.  They agree to license their patens FRAND, which means to them that they will cross license the SEP patents with fair balancing payments for contributed technology.  They may also be willing to license everyone else on the same basis.
     
    There are other ways to do it, for example, pooling patents and then licensing all comers using a standard royalty.
     
    But, as others have noted, what is fair and reasonable depends on the context.
     

  11. Guest, I think you missed a nuance.  In Zoltek, the product made outside the US only partially practiced a patented process.  If those activities were conducted in the US, those steps alone would not directly infringe any US patent.  Further, under prevailing Federal Circuit Law, no one would directly infringe the patent if the last step or steps were carried out by a party different from the party performing the first steps.
     
     
     

  12. Ned – you are STILL assuming the conclusion you want.

    You are now conflating the status of ‘essential patents’ into the mix.

    Clearly, any standards group that has deliberated and deemed a patent to be an essential patent will include that as something that must be cross-licensed. But you are using this fact to confuse what may entail in any FRAND discussion with ANY entity outside of a holder of an essential patent.

    Just as clearly, not ALL FRAND licensees hold patents deemed essential.

    Stop kicking up dust.

  13. In practice, this meant cross licensing SEPs,

    Ned, why are you still maintaining this as a ‘critical’ assumption?

    It is telling that you have not answered the question of someone taking a FRAND license who has no patents at all themselves.

  14. “Hal Wegner correctly pointed out that we will have a very hard time getting others to enforce American IP rights outside the US after THIS. The stench is appalling.”

    Well, I’ll at least agree that the smell of your histrionics in the morning isn’t too pleasant.

    But more seriously, how was the stat of “getting others to enforce American IP rights outside the US” BEFORE this?

  15. Section 337 covered importation of product of a process long before 271(g) was implemented. No reason to remove that from 337. But where the process doesn’t create any tangible product? You have two problems, one on the enforcement end (how does CBP figure out if it’s covered when it’s a new product) and one on proving violation of 337 as it stands right now.

    (B) The importation into the United States, the sale for importation, or the sale within the United States after importation by the owner, importer, or consignee, of articles that—

    (i) infringe a valid and enforceable United States patent or a valid and enforceable United States copyright registered under title 17; or

    (ii) are made, produced, processed, or mined under, or by means of, a process covered by the claims of a valid and enforceable United States patent.

    337(a)(1)(B)(ii) predates 271(g) by quite a bit.

  16. A set of manufactures of apparatus X agree to license FRAND SEPs. In practice, this meant cross licensing SEPs, perhaps with balancing payments. Newcomer are also covered by FRAND, but they also must agree to cross license essential patents.

    Along come upstart who willfully infringes but who refuses to cross license their own essential patents that may cover the standard or become essential for implementing next-gen iterations of the standard.

    I think there might be a case for no FRAND obligations here, but I do agree that the SEP holder must show that the infringer is not fulfilling a condition precedent for a FRAND license.

  17. “In an email, Hal Wegner draws a parallel analogy:

    Imagine an American movie studio, book publisher, high tech electronics manufacturer or other intellectual property rights holder going to a Shanghai Court and successfully winning an infringement suit. Then, imagine that President Xi Jinping blocks enforcement “[a]fter extensive consultations with … interested … persons … based on … review of … considerations … as they relate to … the effect on [domestic] consumers.”

    Is this really a parallel? Is it even close?

    The exclusion order of ITC was blocked, yes.

    But Samsung still gets its day in Shanghai (er, US District) Court. Where it is free to win its infringement suit. And where it is free, if it does so win, to seek to enjoin Apple’s sales.

    Doesn’t seem so parallel after all….

  18. Andrew, but bribery and corruption are the “American Way.” Create a right that can be denied at the whim of the president… what did you expect? Really.

    Hal Wegner correctly pointed out that we will have a very hard time getting others to enforce American IP rights outside the US after THIS. The stench is appalling.

  19. American, Due Process?

    It is the US Govt. vs an importer. If the importer bribes the president and gets a order denied, whose due process rights are being violated?

  20. Guest, on point to your post is Zoltek. link to scholar.google.com

    Japanese company partially makes a product by performing critical steps of a patented process in Japan. The product is finished in the US.

    The en banc Federal Circuit held that importing the partially made product infringed 271(g).

    271(b) and (c) are not involved.

    What say you?

  21. If the structural solutions

    LOL – Someone once voluntarily admitted that ‘configured to’ is structural language.

    Take a guess who said that (hint: it’s in the archives).

  22. The answer isn’t eliminating the ITC, it’s clarifying the statute and tightening up what domestic industry means. Domestic industry has been watered down, that’s problem #1. The bigger issue, however, is the coverage of indirect infringement and method/process patents beyond section 337′s scope. Indirect infringement has no place at the ITC under the current statute or under the idea of it as a trade remedy. Contributory infringement perhaps does, as the act of importation does evince an intent to cause infringement. But inducement is purely within US borders and can be dealt with in the courts.

    The ITC absolutely has a place over preventing importation of infringing products, but perhaps not to the extent it has been used in recent years.

  23. LOL – no struggle whatsoever. Unlike you, who must find it a mighty struggle to get up every day and go to a job and do work with which you do not believe in.

    As they say, Svcks to be you.

  24. See the guest post at IPWatchdog by Mark Nowotarski:

    link to ipwatchdog.com

    Ah yes, design patents on the “look and feel” of displayed information — the final frontier after the utility patent strategy implodes. Promote the progress!

  25. MM, re: “A portable computer with,” the older phones did all that.  But when the iPhone came, they went.
     
    It appears from a post by Anon that one of the most important Apple patents is their design patent on the GUI.

     
     
     

  26. Ned: It had far better optical clarity on the screen.

    That’s nice, assuming it’s true. In any event, whatever structural improvements provided the improved “optical clarity” over previous screens should be recited in any claim covering that improved screen.

    Nothing at all controversial about this, unless you’re a patent t—b-gger who believes that you can own the future merely by describing the “new” improved (or alternative) functions for a computerized device that someone else will do all the work to implement.

    Let’s say Apple or someone else engineers an iPhone that can withstand up to 10,000 atmospheres pressure. Do they get to claim it? Of course not. That’s true for two reasons: (1) first, as functionally described, it’s anticipated by my statement which assumes that it’s built by a skilled artisan using whatever knowledge is available to that artisan — that’s the scope of functional language in a claim (unless it’s construed to be limited by structure…); (2) such a claim would be found invalid as non-enabled — Apple is entitled to the particular novel, non-obvious structural solution(s) it has invented, not to all such solutions that can ever be conceived or implemented.

    Fundamental stuff.

  27. Maybe you should make a big papier mache puppets and get all your friends to march around the White House with signs that say “WE SUPPORT SAMSUNG’S RIGHTS AGAINST APPLE” and “KEEP THE GOVERNMENTS HANDS OFF MY PATENT”.

    Jason can make low-calorie, palatable, papier mache puppets, using cellulose and hydrocolloids. They might even be patentable.

    (Google it – leaving out the papier mache puppets.)

  28. this atrocity of justice still exists?

    Atrocity of justice? Wow. That’s impressive.

    Maybe you should make a big papier mache puppets and get all your friends to march around the White House with signs that say “WE SUPPORT SAMSUNG’S RIGHTS AGAINST APPLE” and “KEEP THE GOVERNMENTS HANDS OFF MY PATENT”.

    I’m serious. You really need to turn up the “blowback”. By the end of the week, I expect Obama to call a press conference that will be broadcast live on every channel to announce that “the people have spoken” so he will reverse the policy and beg the nation’s forgiveness.

    Maybe Gene Limbaugh will pick up this “atrocity” meme and run with it. That can only help, right?

  29. That you even ask the question reveals far more than you think.

    Really, Tr0 llb0y? Tell everyone exactly what you think that comment “reveals”.

    Maybe when you struggle with your answer, you can explain to us whether it’s the case that anytime a law passes which decreases the value of X, it is invariably the case that people favoring the law have an “agenda” to “destroy X” because they “h*te X” because they are “socialists” or “thieves”.

    Or you can just explain how my asking “So” leads you to the mysterious conclusion which you will shortly articulate to everyone. Make everyone’s day, Tr0 llb0y!

  30. MM, if it is the GUI that is the reason for the iPhone’s success, a lot of those individual features can be patented, and the design as a whole may be copyrightable.

    Put the goalpost back.

    I was reading a comparison of the iPhone’s technology. It had far better response to user’s touches. It had far better optical clarity on the screen.

    That’s nice. If the structural solutions to the problems of touch screen response are important inventions, they should be claimed and the claims should recite those solutions.

    It may not have done anything individually new, but as a whole, it did them better.

    Let’s just assume this is correct. The question is: better than what, Ned? Better than the obvious concept of a protable touch screen wireless computing device that preceded the actual manufacture of an iPhone? The obvious concept worked perfectly, Ned. In fact, the concept of a new portable wireless computing device that I and many others have envisioned works much better (faster and more intuitive with more functionality) than the newest iPhone model. So what?

    As a reminder, here’s my statement to which you seem to be responding:

    A portable computer with a touch screen that can send, receive and process data received wirelessly? You think Apple owns that? They don’t own that. They also don’t “own” methods of swiping an old touch-screen in a certain way to initiate a certain act. They might think they do and their lawyers might make a lot of noise and huff and puff and threaten people. But they don’t own that. Nobody can own that, ever.

  31. I’m highly offended that Dennis would suggest that we abolish either the ITC or the Fuhrer’s supreme power over it. Hehe. More seriously, where’s the drop box for the COWH (Court of the White House) if we need to file an appeal brief? Oh, and where’s the rules pdf url? And do we get oral hearings? A jury trial, as is promised? Does one need have campaign contributions in one’s budget? Dennis, did you forget to mention there’s no res judicata? Yeah, judges just can do what they feel like. Very cool. Definitely no kangaroo court no sirree. Right. They go through a ton of hurt to put through the AIA but this atrocity of justice still exists?

    Nice url about POTUS’s duties here: link to mayerbrown.com

    Funny aside: The notion that someone who uses a Motorola Razr (link to coolspotters.com) would have anything to say about smart phones (let alone patents). link to gawker.com

    Jason

  32. Ned, you keep on asking me to think of a different (and separate) issue.

    You need to stop conflating these things.

  33. anon,

    Nokia sued Apple because it was being driven from he market. It needed (they thought) a cross license from Apple to stay in the market.

    Now think on that. The Feds, by denying an injunction to the likes of Nokia, would eliminate, totally, Nokia’s leverage. No cross license. No competition.

    That, to me, doesn’t make sense for the consumer.

    I hardly think that Nokia would have agreed to license its key patents to Apple for a song without any cross license back. That doesn’t make any sense.

  34. Well, MM, if it is the GUI that is the reason for the iPhone’s success, a lot of those individual features can be patented, and the design as a whole may be copyrightable.

    I was reading a comparison of the iPhone’s technology. It had far better response to user’s touches. It had far better optical clarity on the screen. It may not have done anything individually new, but as a whole, it did them better.

  35. What did the iPhone do that allowed it to dominate the market when first introduced?

    Caused massive eye strain? Had an Apple logo on it? Unlocked when you swiped the screen?

    Seriously, Ned, I’m not dissing the prettiness of the *concept* of the portable computer with a touch screen and wireless data receipt transmission/capability. It’s just that nobody can own that concept. It’s way to broad and obvious and has been so since touch screens and wireles computing devices existed, at least.

    The same applies for “virtual world accessable through eye lens or eye wear or brain implant that can be manipulated with body movements or brain waves.” Or “portable computer with touch screen and wireless access with band to attach to your body” or “foldable/disposable portable computer with touch screen and wireless access”. The list goes on and on. Anybody can “invent” these concepts and “narrower” one, too.

    Of course, the softiewoftie crowd knows this and they’ve been exploiting the PTO’s incompetence for quite a while now, gambling on filing the right application at the right time so that when a popular product is engineered and marketed they can jump in and “take their share.” And now they want to remove the prior art that discloses the concepts because it’s “not enabled”! Nobody could have predicted.

  36. Two threads by Prof. Crouch, and a couple of email alerts by Hal Wegner,

    I think President Obama had something to say as well.

  37. Seems to me that if changes in the law are needed, then it encompasses one item only:

    Do away with presidential oversight. An adverse ITC ruling is already appealable to the FedCir. Why have executive branch review, too? It only invites political meddling which seems to me to be a denial of due process.

  38. on the other hand, is arguably a breach of the FRAND commitment.

    Thanks Matt, that’s the point that I am attempting to impress upon Ned, who has assumed his own conclusion with his reliance on a equivalency that simply is not there.

  39. Actually, it’s not at all, and it’s common practice within the technology industry. Requiring a cross-license to non-SEPs as a condition for a license to FRAND-encumbered SEPs, on the other hand, is arguably a breach of the FRAND commitment. But it seems to me that the latter scenario requires a “take it or leave it”-type offer that you’d rarely see.

    Many companies (Apple chief among them) now want to ascribe some particular definition to “FRAND terms” — a specific royalty base, a specific rate, etc. That’s simply not the way it’s been done. Since its inception — for better or worse (and better for lawyers) — FRAND has been all about flexibility.

  40. Andrew, were you asleep for the last 8 years as the AIA process unfolded?

    The lobbying money here is quite literally a drop in the bucket compared to how much money was spent by lobbyists during the transformation of patent law in the AIA.

    For all the rhetoric, what we really achieved with the AIA was to have two sets of law on the books for the foreseeable future, more uncertainty of patent rights, weaker patent rights, more costly patent rights, and slower processing of patent rights.

    By any stretch of the imagination, patent value can only be seen as having been diminished with this ‘improvement’ in patent law.

  41. I suspect the founders wanted a cross license, which Apple denied them.

    A cross-license is basically contrary to FRAND conditions (more specifically, to the “non-discriminatory” part).

  42. Because its entitled to it by the LAW?

    As in LAW, and not INTERPRETATION of law?

    ITC operate on specific law, and that was not invalidated by eBay.

    As You can READ in Apple vs Samsung rulling, ITC ALWAYS used exclusion orders as its tool, and its only tool they have. (Monetary awards can not be granted by ITC at all).

    So if You take away patent dispute away from ITC, then they will have only copyright, trademark and the like to judge upon.

    Nice, but reverting 100y of precedent.

    And there is NO recognition of SEP in patent law, so one just can not exclude just those from ITC. (Unless you change the law, that is).

    And on top of that ITC found THIS PARTICULAR patent NON-SEP, and thus FRAND have nothing to do with this case. (And also Samsung DID behaved well enough, so that FRAND commitments would be SATISFIED if FRAND applaied…)

    Which also suggest that ITC should put more Public Interest consideration into ALL patent disputes…

  43. It’s a good analogy, Dennis, and it’s disheartening to see that important decisions like this are essentially purchased with lobbying money. Lots of lobbying money.

  44. Fs,

    btw, ‘keeping up’ with Malcolm means throwing yourself in full reverse and being wrong as fast as you can.

  45. far your team seems to be failing.

    You cannot help but be wrong, can you Malcolm?

    Two threads by Prof. Crouch, and a couple of email alerts by Hal Wegner, and ALL that you see is the red cape of “anon said” and cannot help yourself.

    LOL

  46. Under 103– please make your invalidity argument over specific pieces of prior art.

    Specific pieces of prior art? For you? LOL.

    Besides, I’ve already explained this to you.

    link to patentlyo.com

    Try to keep up.

  47. if the blowback on this misstep is loud enough

    Good luck with that. You have to convince people that this “misstep” matters. Thus far your team seems to be failing. Maybe you can try using more caps, bold fonts, and italics.

    I disagree that having another enforcement process in place outside of the courts is a bad thing.

    Who are you disagreeing with?

    the signal may be clear to the Executive Branch not to do such ‘bonehead’ moves

    Or the “move” really isn’t that ‘boneheaded’ and all the screeching will just be lost amongst the perpetual noise made by the usual crowd as certain assumptions about their beloved patent rights fail to hold up.

    This is a massive Fail, and a potential runaway blackeye for Obama.

    Care to bet on that?

  48. Nobody can own it because patent protection should not be available? Under 103– please make your invalidity argument over specific pieces of prior art. Under 101 — what is the abstract idea, and why are the claims not specific application(s) of that abstract idea.

    [If it is not patentable because MM knows what is not patentable when he sees it, then that is a different story.]

  49. If Apple can continue to infringe basic patents with impunity, or with a payment of some nominal royalty, while denying their competitors a license to their own patents, the net result may be an Apple monopoly

    Monopoly on what exactly? A portable computer with a touch screen that can send, receive and process data received wirelessly? You think Apple owns that? They don’t own that. They also don’t “own” methods of swiping an old touch-screen in a certain way to initiate a certain act. They might think they do and their lawyers might make a lot of noise and huff and puff and threaten people. But they don’t own that. Nobody can own that, ever.

  50. Yes, but the flood of ITC cases came only after eBay eliminated the injunctions that were routinely granted in district court patent cases.

    Apart from general exclusion orders, I don’t think that Congress ever intended for the ITC to have its own patent laws. And if general exclusion orders no longer exist, why do we have a special executive branch patent court?

  51. Public interest?

    Tell me if I have something wrong.

    A number of companies develop smartphones and agree to license essential patents FRAND. After a dozen years, Apple introduces a revolutionary phone and soon captures the lions share of the market. But Apple refuses to pay any royalties to the founding members on standard essential patents while in turn demanding that those same founders avoid infringing the patents on Apple’s revolutionary design. (I suspect the founders wanted a cross license, which Apple denied them.)

    If Apple can continue to infringe basic patents with impunity, or with a payment of some nominal royalty, while denying their competitors a license to their own patents, the net result may be an Apple monopoly, which of course is in the interest the American people….

    Huh?

  52. Almost 100 years and how many missteps such as this?

    Compare to the fiasco that the Court has left 101 in (go ask Alice).

  53. I agree with you regarding having “an” enforcement process in place that is largely outside of direct political influence.

      But singular process, and within the Courts’ control are both problematic.

    I disagree that having another enforcement process in place outside of the courts is a bad thing.

    As most can recognize – the Courts’ control of the process has its own issues.

    The situation of having power in the ITC is a good thing, and quite in fact, if the blowback on this misstep is loud enough, the signal may be clear to the Executive Branch not to do such ‘bonehead’ moves and STILL leave a healthy alternative to Court control.

  54. I disagree in that I do believe it is important that there is an enforcement process in place through the courts that is largely outside of direct political influence.

  55. Quite the opposite RB – the rarity draws even more attention to this action, and as noted, the action itself is far too thin on expressed reasoning.

    The questions (as reflected in musings shared by Hal Wegner: why now? why this?)

    This is a massive Fail, and a potential runaway blackeye for Obama.

    • The question then is how can the US expect for China, India, South Korea and Brazil to strongly enforce foreign-owned intellectual property rights when the US is unwilling to do so itself.

    That indeed is a good question.

    And it matters not whether the patent holder still has options – the signal beign sent is one of policy by the Administration, quite apart from the merits of the case (and quite, in fact a powerfully negative signal if the patent holder ends up prevailing in court).

  56. As the letter correctly pointed out, near the end, Samsung still retains the right to go to court to enforce any rights it may have, viz-a-viz the disputed FRAND patent. This presidential veto seldom happens, so no need to overreact.

  57. A different perspective on the administrative disapproval here is that it is designed as a signal to the USITC to stop issuing injunctive relief without full consideration of the public interest at stake. … As the USITC develops its law of public-interest, the next step in the law’s evolution will be for the Federal Courts to begin picking-up that analysis and applying it under eBay.

    That would be nice.

  58. Dennis,

    What was Congress’ justification for vesting the ITC with patent investigation powers to being with? I had thought it was the ITC’s ability to issue a general exclusion order (an injunction not limited to the parties). But after Kyocera, general exclusion orders can rarely be granted and a limited exclusion order is no different than an injunction issued by a federal court.

  59. You may have missed that day in Civil Procedure where we discussed the Seventh Amendment. Based on our current understanding of the history of the common law, there is basically no way that the USITC determination would by considered a “Suit at Common Law.”

  60. 1) The US Constitution guarantees the right to trial by a jury, due process and equal protection.

    2) There is no right to a jury trial provided at the ITC — in violation of due process and equal protection.

    3) The ITC is therefore unconstitutional and must be reformed or abolished.

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