|9th Circuit Rules on
Trademark Infringement in Web Pages and Meta Tags
|2/1. The U.S.
Court of Appeals (9thCir) issued its opinion
[PDF] in PEI
v. Welles, a case involving claims of trademark
infringement and dilution in a web site, and its meta tags.
The Appeals Court largely affirmed the District Court's
summary judgment for the web site defendants.
Background. Terri Welles was Playboy's Playmate
of the Year in 1981. More than twenty years later, she is
still posing for the camera, although, no longer for Playboy
Enterprises, Inc. (PEI). Her body of work is now published in
her own web site, which bears her name -- "Terri Welles".
Her web site also carries the subtitle "Playboy
Playmate of the Year 1981".
The web site also includes similar information in meta tags.
That is, the source code, which is read by some search
engines, includes the following: <META
NAME="description" CONTENT="Playboy Playmate
Of The Year 1981 ... ">. Her web site also prominently
displays the disclaimer that the web site is not endorsed or
sponsored by PEI; it also lists terms that are trademarked by
PEI, including "Playboy", and "Playmate
of the Month". Welles' web site also uses the term PMOY,
which is not trademarked by PEI, as a watermark.
District Court. Playboy Enterprises, Inc. (PEI)
filed complaints in U.S. District Court (SDCal)
against Welles, Terri Welles, Inc., and others, alleging
trademark infringement, dilution, false designation of origin,
and unfair competition. PEI objected to the following: (1) use
of the trademarked terms in metatags, (2) use of trademarked
terms in the masthead of the web site, (3) use of trademarked
terms in banner ads placed in other web sites, and (4) use of
"PMOY 81" as a watermark on pages of her web site.
The District Court granted Welles' motion for summary
Court of Appeals. A three judge panel of the 9th
Circuit, following the precedent set in New
Kids On The Block v. New America Publishing, 971 F.2d 302
(9th Cir. 1992), held that Welles' uses of PEI's trademarks in
headlines, banner ads, and meta tags, are permissible,
nominative uses. The Court held in New Kids that to be
a permissible use of a trademark, based upon nominative use,
the use must satisfy the following three part test:
"First, the product or service in question must be one
not readily identifiable without use of the trademark; second,
only so much of the mark or marks may be used as is reasonably
necessary to identify the product or service; and third, the
user must do nothing that would, in conjunction with the mark,
suggest sponsorship or endorsement by the trademark
However, the Appeals Court held that Welles' use of "PMOY
81" is not nominative and remanded for a determination of
whether it infringes on a PEI trademark.
The Appeals Court also affirmed on the trademark dilution
claims. It stated that "nominative uses, by definition,
do not dilute the trademarks."
Trademark Law and the Free Flow of Information on the
Internet. The Appeals Court's analysis of the first prong
of the New Kids test in the context of meta tags may be
noteworthy. "Forcing Welles and others to use absurd
turns of phrase in their metatags, such as those necessary to
identify Welles, would be particularly damaging in the
internet search context. Searchers would have a much more
difficult time locating relevant websites if they could do so
only by correctly guessing the long phrases necessary to
substitute for trademarks. We can hardly expect someone
searching for Welles' site to imagine the same phrase proposed
by the district court to describe Welles without referring to
Playboy -- ``the nude model selected by Mr. Hefner's
organization . . . .´´ Yet if someone
could not remember her name, that is what they would have to
do. Similarly, someone searching for critiques of Playboy
on the internet would have a difficult time if internet sites
could not list the object of their critique in their metatags."
The Court concluded that "There is simply no descriptive
substitute for the trademarks used in Welles' metatags.
Precluding their use would have the unwanted effect of
hindering the free flow of information on the internet,
something which is certainly not a goal of trademark
law." However, the Court stopped short of stating that
promoting the free flow of information on the Internet is a
goal of trademark law.
|8th Circuit Rules in
|2/1. The U.S.
Court of Appeals (8thCir) issued its opinion
[PDF] in Ozark
v. Radio Shack, a price fixing antitrust case
involving the marketing of satellite TV services. Affirmed.
Facts. Ozark Heartland Electronics was a retail
electronics store in Missouri affiliated with Radio Shack, a retail
electronics chain. Primestar provided satellite television
service. Primestar distributed the satellite television
service to consumers through its Partner Affiliate
Distributors (PADs). Primestar has since been acquired by DirecTV.
Radio Shack entered into a marketing agreement with Primestar
under which Radio Shack and its affiliated stores would
promote Primestar's satellite TV service to consumers on
behalf of Primestar's PADs. The agreement authorized
participating Radio Shack stores to display the Primestar
service, solicit subscribers, answer customer inquiries, and
collect from subscribers a prepayment on the local PADs'
installation fee. Primestar suggested a prepayment fee of
Ozark participated in this Radio Shack marketing campaign.
However, it only charged a $99 prepayment fee, to undercut
competitors' prices. Radio Shack then stripped Ozark of its
authority to sign new Primestar subscribers.
District Court. Ozark and Boone filed a complaint in U.S. District Court (WDMO)
against Radio Shack, Primestar, and others alleging resale
price maintenance, in violation of the Sherman Act, 15 U.S.C.
§ 1, and breach of contract and tortious
interference with contract under Missouri state law. The
District Court granted summary judgment to defendants.
Court of Appeals. The 8th Circuit affirmed. It wrote
that "The Sherman Act imposes liability on manufacturers
who fix the minimum price at which buyers must resell their
products. ... But this rule does not apply when a manufacturer
directs his agent to sell at a particular price." It
found that Ozark was Primestar's agent, and hence, there was
no antitrust violation.
|AAI Seeks to Enjoin
|2/1. The American
Antitrust Institute (AAI) filed a motion
[PDF] for a preliminary injunction with the U.S. District Court (DC)
in the case AAI
v. Microsoft and DOJ. See also, memorandum
On January 24, the AAI filed a complaint
[PDF] against Microsoft
and the Department of Justice
(DOJ) seeking declaratory relief pursuant to 15 U.S.C.
§ 16(b), which is also known as the Tunney Act. In the
complaint, the AAI seeks to compel Microsoft and the DOJ to
disclose further information about their Proposed
Final Judgment (PFJ), which the AAI opposes. In the motion
for a preliminary injunction, the AAI seeks to enjoin the DOJ
"from closing the period which public comments may be
submitted to and considered by the Justice Department under
the Tunney Act pending this Court’s ruling on the merits of
The Tunney Act provides, in part, that "Any proposal for
a consent judgment submitted by the United States for entry in
any civil proceeding brought by or on behalf of the United
States under the antitrust laws shall be filed with the
district court before which such proceeding is pending and
published by the United States in the Federal Register at
least 60 days prior to the effective date of such
The Act further provides that "the United States shall
file with the district court ... a competitive impact
statement which shall recite (1) the nature and purpose of the
proceeding; (2) a description of the practices or events
giving rise to the alleged violation of the antitrust laws;
(3) an explanation of the proposal for a consent judgment,
including an explanation of any unusual circumstances giving
rise to such proposal or any provision contained therein,
relief to be obtained thereby, and the anticipated effects on
competition of such relief; (4) the remedies available to
potential private plaintiffs damaged by the alleged violation
in the event that such proposal for the consent judgment is
entered in such proceeding; ..."
The AAI complaint asserts that the DOJ's competitive impact
statement must be amended "(1) to include an explanation
of why certain remedies previously pursued by the Justice
Department were abandoned; (2) to include an explanation of
the Justice Department’s evaluation and comparison of
the remedies that are being pursued in the PFJ and the various
alternative remedies that are not; and (3) to include an
explanation of how the PFJ will affect private
Jonathan Zuck, President of the Association for Competitive
Technology (ACT), offered this reaction to the AAI's
motion: "We hope that Judge
Kotelly rules on this Oracle
funded legal stunt quickly, so that she can dismiss it and go
back to concentrating on the real legal issues before her.
These continued efforts to delay settlement are only harming
the industry and consumers."
|2/1. The World Trade
Organization (WTO) announced that its Trade
Negotiations Committee (TNC) reached an agreement on the
structure of the negotiations launched at Doha, Qatar. The WTO
stated in a release
that "The TNC agreed there should be seven negotiating
bodies, on agriculture, services, non-agricultural market
access, rules, trade and environment, geographical indications
for wines and spirits under the agreement on Trade Related
Intellectual Property and reform of the Dispute Settlement
Understanding. Negotiations on agriculture, services,
environment, TRIPS, and the DSU reform will all be conducted
in Special Sessions of the regular committees and councils
where these issues are discussed. New negotiating groups will
be created for negotiations in non-agricultural market access
|FCC Commissioner Martin
Addresses Spectrum Management
|2/1. FCC Commissioner Kevin Martin
gave a speech
to the Federal Communications
Bar Association in Washington DC. Among the issues which
he addressed were spectrum management and copy protection.
Spectrum Management. He stated that "recent
technological changes allow us to take sharing to new levels.
Satellite and terrestrial sharing scenarios, once believed
impossible, are now becoming more realistic. Sophisticated
ultrawideband technology -- promising to deliver data at
faster speeds and lower power -- can potentially co-exist with
spectrum users in any frequency. Software defined radios allow
quick modification to transmit and receive on any frequency
and in any desired transmission format. Priority access
capability allows for flexibility for a higher valued use some
of the time, without having to dedicate specific frequencies
to those uses all of the time. And DoD's “XG” program --
which focuses on Next Generation communications devices to
support military deployment -- seeks to produce even further
advances in spectrum sharing technology through dynamic
assignment of frequency, time and space."
Martin continued that "Our spectrum management objective
should be to create incentives for the efficient utilization
of this valuable resource at every given point in time, by
both established users and new entrants. What the Commission
can do now to further these goals is set policies that make
sharing easier, and even desirable. For example, a robust
secondary market for spectrum and flexible allocations can
create strong incentives for making use of excess
Copy Protection. Marting stated that "The movie
studios, broadcasters, cable industry, and consumer
electronics industry need to reach an agreement on how digital
content will be protected, and what rights consumers will
retain to make personal recordings. With Ken Ferree and Rick
Chessen's leadership, we've had several industry wide meetings
on this issue that I understand brought the sides closer
together. But they’re not there yet, and the lack of
progress is seriously impeding the availability of digital
content -- and thwarting any progress in the transition. If
further progress is not made soon, the Commission may need to
become more directly involved."
|NTIA Reports on Spectrum
Use by Energy, Water and RR Industries
|2/1. The National
Information and Telecommunications Administration (NTIA)
released a report
[93 pages in PDF] titled "Current and Future Spectrum Use
by the Energy, Water, and Railroad Industries".
This NTIA report states that "the energy, water, and
railroad industries use spectrum between 20 megahertz (MHz)
and 25 gigahertz (GHz). Although they use numerous frequencies
in a variety of bands, all three industries agreed and
informed NTIA that spectrum currently used is either congested
or quickly approaching critical mass, thus leading to problems
of interference." Moreover, industry commenters assert
that "additional spectrum is needed".
However, the report continues that since it was "based
predominantly on comments received from the industry and
public, and information from federal agencies with oversight
or regulatory authority over these industries, NTIA is unable
to validate specific requirements and issues highlighted
herein, such as exclusivity and congestion. However, NTIA
suggests some of these issues may be addressed or mitigated
with the use of advanced communications technology or newly
allocated frequency bands, such as the 700 MHz guard bands.
The FCC is responsible for managing the spectrum used by the
private sector industries, as well as state and local
governments. Hence, the NTIA can only report recommendations
to the FCC in this area. The NTIA report recommends that
"it is of utmost importance that the Federal
Communications Commission revisit these critical issues in
order to accommodate the increasing role these industries play
in maintaining quality of life."
|FTC Official Addresses
|1/24. Howard Beales, Director of the Bureau of Consumer
Protection of the Federal Trade
Commission (FTC), gave a speech
titled "Privacy Notices and The Federal Trade
Commission's 2002 Privacy Agenda" in San Francisco,
Beales said that "The events of September 11 make it
clear that privacy is not, and cannot be, an absolute
He stated that the FTC has "changed the focus of the
program somewhat. For example, in the past the Commission's
privacy program was focused primarily on information
collection. In contrast, we believe that the focus should be
on misuse of information."
He also stated that the FTC's "past focus was primarily
directed to online privacy ... . Adverse consequences can
occur whether the information was originally collected online
or off. The risk of identity theft is real, and the
consequences are the same, whether the thief steals your
credit card number from an online website or from your
mailbox. Thus, many of our initiatives focus on the misuse of
personal information collected offline as well as information
Beales reviewed several recent FTC privacy related actions,
including its settlement with Eli Lilly, its proposed changes
to the Telemarketing Sales Rule, its monitoring of compliance
with the Fair Credit Reporting Act, and its role regarding
identity theft. He also discussed the role of privacy notices,
and the FTC's recent workshop on privacy notices by financial
institutions under the Gramm Leach Bliley Act.
He then spoke at length about privacy notices. He stated that
"privacy notices need to be written for consumers. That's
their intended audience, not the regulators who prescribed
them or the lawyers who will dissect them."
He concluded by listing "three key principles that should
guide our next steps. First, it takes time to digest
significant regulatory changes. ... Second, there remains an
enormous amount that we do not know. ... Finally, we need to
focus more clearly on what consequences we are trying to
|More Privacy News
|2/1. The Federal Trade
Commission (FTC) published a notice
in the Federal Register regarding its settlement with Eli Lilly. Eli Lilly
accidentally disclosed the e-mail addresses of 669 subscribers
to a Prozac related e-mail list. The settlement requires Eli
Lilly to establish a security program. This notice sets a
deadline of February 19, 2002 for public comments on the
proposed consent agreement. See, Federal Register, February 1,
2002, Vol. 67, No. 22, at Pages 4963 - 4964.
1/31. Chris Israel gave a speech
titled "Online Privacy -- Observations, Acknowledgements,
Actions Taken and Challenges" at the Privacy Officers
Association Second Annual Privacy and Data Security Summit
Washington DC. Israel is the Deputy Assistant Secretary for
Technology Policy at the Department
|People and Appointments
|1/31. The Silicon Valley based law firm of Gray Cary merged
with the nine attorney Washington DC law firm of Blumenfeld
& Cohen. Gray Cary has over 470 attorneys in offices in
Palo Alto, San Diego, San Francisco, Austin, Sacramento, and
Seattle. Blumenfeld & Cohen focuses on telecommunications
and technology law. See, GC
1/31. The Washington DC law firm of Wiley Rein & Fielding added
Glover and Attison
Barnes as partners, and Charles
Lemley as an associate. All three previously worked in
the Washington DC office of the law firm of Gardner Carton & Douglas.
They are litigators who represent technology based companies.
DuMont joined the Washington DC law firm of Wilmer Cutler & Pickering
as counsel in the firm's litigation section. He was previously
Assistant to the Solicitor
General of the U.S. He also worked briefly on computer
crime and privacy issues an Associate Deputy Attorney General.
He is also a former law clerk to Judge
Richard Posner of the U.S. Court of Appeals
(7thCir). See, WCP
Kaminer joined the Washington DC office of the law
firm of Fulbright &
Jaworski as a senior associate. He focuses on intellectual
property, information technology and corporate matters. See, FJ
Karamali joined the Menlo Park office of the law firm
of Perkins Coie as a
partner. He focuses on corporate finance, mergers and
acquisitions, and venture capital transactions for technology
companies and investors in such companies. He was previously a
partner with General
Counsel Associates in Mountain View, California. Before
that, he an associate with the law firm of Gibson Dunn & Crutcher.
1/28. Ernest Kelly will retire as President of the Association of Communications
Enterprises (ASCENT) on April 30, 2002. His replacement
has not been named. See, release.
|2/1. The FCC now has a web
page for its Homeland Security Policy Council (HSPC).
2/1. The U.S.
Court of Appeals (8thCir) issued its opinion
[PDF] in Mitchell
Green v. Ameritrade, a case involving
preemption and jurisdiction under the Securities Litigation
Uniform Standards Act (SLUSA).
2/1. The Copyright
Office published a notice
in the Federal Register listing the arbitrators eligible for
service on a Copyright Arbitration Royalty Panel (CARP) during
2002 and 2003. See, Federal Register, February 1, 2002, Vol.
67, No. 22, at Pages 5000 - 5001.
|Monday, Feb 4
|The House will meet in pro forma session only. The Senate
will meet at 1:00 PM to take up S 622, the Adoption Tax Credit
9:00 AM. The Cato Institute
will release a study titled "The Digital Dirty
Dozen" which lists and evaluates the worst high tech
legislative proposals of this Congress. The speakers will be Wayne Crews
Thierer. This study will be released at an invitation only
press breakfast. For more information, contact Jerry Brito at
202 218-4621. Location: Cato, 1000 Massachusetts Ave., NW.
10:00 AM. The U.S. Court of
Appeals (FedCir) will hear oral argument in Telecom
Technical Services v. Siemens Rolm. Plaintiffs sued
Seimens Rolm alleging violation of federal antitrust laws;
they alleged monopolization of alleged markets for telecom
equipment; they also sought class action status. Seimens
asserted various counterclaims, including patent infringement.
District Court (NDGa) denied class action status. (This is
Appeals Court No. 01-5090 and D.C. No. 95-CV-549-WBH.)
Location: Courtroom 201, 717 Madison Place, NW.
10:00 AM. The House
Judiciary Committee will hold a hearing on HR 2341,
the Class Action Fairness Act of 2001, sponsored by Rep. Bob Goodlatte
(R-VA). Location: Room 2141, Rayburn Building.
Deadline to submit petitions and comments to the FCC's Cable Services Bureau
regarding the applications of Hughes Electronics Corporation
and EchoStar Communications Corporation to the FCC requesting
consent to the transfer of control of licenses and
authorizations involved in the EchoStar DirecTV merger. See,
[MS Word]. Oppositions and responses are due by February 25,
2002. This is CS Docket No. 01-348.
|Tuesday, Feb 5
|The House will meet at 12:30 PM for morning hour and at 2:00
PM for legislative business. No recorded votes are expected
before 6:30 PM. The House will consider several non tech
related bills under suspension of the rules.
9:30 AM. The U.S.
Court of Appeals (DCCir) will hear oral argument in EchoStar
v. FCC, No. 01-1032. Judges Ginsburg, Edwards and Sentelle
RESCHEDULED FOR FEB 12.
PM. The FCBA's
Transactional Practice Brown Committee will host a brown bag
lunch on wireless transactions.
1:30 PM. The U.S. International Telecommunication Advisory
Committee (ITAC) will hold a meeting. See, notice
in Federal Register, October 17, 2001, Vol. 66, No. 201, Page
52825. Location: State Department.
2:30 PM. The Senate
Finance Committee will hold a hearing to hear testimony on
the President's FY 2003 budget and tax proposals. Treasury
Secretary Paul O'Neill will testify. Location: Room
215, Dirksen Building.
4:00 PM. The Cato Institute
will host a book forum on Against
the Dead Hand: The Uncertain Struggle for Global Capitalism
[Amazon], by Brink
Lindsey (Cato Institute). The commenters will be Robert
Zoellick (USTR), Sebastian
Mallaby (Washington Post), and Douglas Irwin (Dartmouth). See,
information and registration page. Location: The Cato
Institute, 1000 Massachusetts Ave., NW.
5:30 PM. The House Rules
Committee will meet to adopt a rule for consideration of HR
3394, the Cyber Security Research & Development Act.
Deadline to submit applications to the NTIA
for planning and construction grants for public
telecommunications facilities under the Public
Telecommunications Facilities Program (PTFP) for FY 2002. See,
in Federal Register, November 20, 2001, Vol. 66, No. 224, at
Pages 58301 - 58310.
|Wednesday, Feb 6
|The House will meet at 10:00 AM. It may take up HR
3394, the Cyber Security Research and Development Act,
sponsored by Rep. Sherwood
Boehlert (R-NY). The House Science Committee
approved the bill on December 12, 2001, by a unanimous voice
vote. The bill would authorize the funding of new research and
education programs pertaining to cyber security. See, TLJ
Alert No. 323, Dec. 7, 2001.
10:00 AM. The Senate
Finance Committee will hold a hearing titled Ongoing
U.S. Trade Negotiations. The scheduled witnesses are
Robert Zoellick (USTR), Gary Broyles
(National Association of Wheatgrowers), George Scalise (Semiconductor Industry
Association), and Arthur Wainwright (National Association of
Manufacturers). See, release
[PDF]. Location: Room 215, Dirksen Building.
10:00 AM - 12:00 NOON. The FCC's Advisory Committee for the
2003 World Radiocommunication Conference (WRC-03) will meet.
Location: FCC, 445 12th Street, SW, Room TWC305 (Commission
Meeting Room), Washington DC. This meeting had previously been
scheduled for January 30. See, FCC
notice of postponement [PDF].
12:15 PM. The FCBA's
Online Committee will host a brown bag lunch. RSVP to Scott
Harris at sharris
2:00 PM. The FTC and the Antitrust Division of the
Department of Justice (DOJ) will hold the first of a series of
joint hearings on antitrust and intellectual property.
The hearings are titled "Competition and Intellectual
Property Law and Policy in the Knowledge Based Economy".
The speakers at the opening hearing will be Timothy Muris (FTC
Chairman), Charles James (Assistant Attorney General for the
Antitrust Division), James Rogan (Director of the USPTO), Judge
Pauline Newman (U.S. Court of
Appeals for the Federal Circuit), Robert Pitofsky
(Professor at Georgetown University Law Center), Todd
Dickinson (Howrey Simon),
Gerald Mossinghoff (Oblon
Spivak), Richard Gilbert (Professor at U.C. Berkeley), and
Richard Levin (President of Yale). See, FTC
release and DOJ
release. Location: Room 432, FTC, 600 Pennsylvania Ave.,
Deadline to submit comments to the FCC regarding Verizon's Section
271 application to provide in region interLATA services in
the state of Vermont. See, FCC
notice [PDF]. This is CC Docket No. 02-7.
Extended deadline to submit additional comments to the Copyright Office in
response to its March 9, 2001, Notice
of Inquiry concerning the interpretation and application
of the copyright laws to certain kinds of digital
transmissions of prerecorded musical works in light of an
agreement between the Recording
Industry Association of America (RIAA), the National Music Publishers
Association (NMPA), and The Harry Fox Agency (HFA). See, 17 U.S.C.
§ 115. See, notice
in Federal Register. This is Docket No. RM 2000-7B.
|Thursday, Feb 7
|The House will meet at 10:00 AM. It may take up HR
3394, the Cyber Security Research and Development Act,
sponsored by Rep. Sherwood
10:00 AM. The Senate
Judiciary Committee has scheduled an executive business
meeting. Location: Room 226, Dirksen Building.
12:30 PM. Tom Ridge, Director of the Office of Homeland
Security will speak at a luncheon. Location: Ballroom,
National Press Club, 529 14th St. NW, 13th Floor.
|Friday, Feb 8
|The House will not be in session.
9:00 AM - 12:30 PM. The FTC and the Antitrust Division of the
Department of Justice (DOJ) will hold the second in a series
of joint hearings on antitrust and intellectual property.
There will be two concurrent sessions, titled "Patent Law
for Antitrust Lawyers" and "Antitrust Law for Patent
Lawyers". See, FTC
release and DOJ
release. Location: Rooms 432 and 332, respectively, of the
FTC, 600 Pennsylvania Ave., NW.
TO BE DECIDED ON THE BRIEFS.
9:30 AM. The U.S. Court of Appeals (DCCir)
will hear oral argument in Chameleon Radio Corp v. FCC,
No. 00-1546. Judges Edwards, Sentelle and Silberman will
10:00 AM - 12:00 NOON. The American
Enterprise Institute (AEI) will host a panel discussion
titled "Should the Government Promote Open Source
Software? " The speakers will be Robert Hahn (AEI-Brookings
Joint Center), James Bessen (Research on
Evans (NERA), Lawrence
Lessig (Stanford University), and Craig
Mundie (Microsoft). See, online registration
page. Location: 12th Floor, AEI, 1150 17th Street, NW.
10:00 AM. Chris Murck, Chairman of the American Chamber of
Commerce in China, will speak on the U.S. relationship
with China after the September 11 events, and in advance of
President Bush's trip to Beijing on February 21. He will also
comment on China's membership into the WTO and its likely
impact on the global marketplace. For more information,
contact Micaela de Leon Vivero at mdeleon @apcoworldwide.com
or 202 778-1024. Location: Murrow Room, National Press Club, 529 14th
St. NW, 13th Floor.
12:15 PM. The FCBA's
Wireless Telecommunications Practice Committee will host a
lunch. The topic will be "Hot Wireless Issues on the
Hill". The price to attend is $15.00. RSVP to Wendy
Parish at firstname.lastname@example.org
by 12:00 NOON on February 6. Location: Sidley & Austin,
Room 6-E, 1501 K Street, NW.
Sixth Anniversary of passage of the Telecommunications Act of
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