Harold McElhinny Makes Closing Arguments for Apple in the Apple v Samsung Trial
This is a trial report, not a transcript. It is taken from my typed notes from the trial. In many cases I could not keep up and attempted to paraphrase or took shorthand. There may be errors.
So this report provides the gist of what occurred and could be useful in the time period before the official transcripts are released.
The day started with Judge Koh discussing instructions with the jury. And then giving the sequence of events for the day. That Apple would close with its affirmative case. That Samsung would then provide defense of affirmative case and Samsung would present their own affirmative case. And finally Apple would close its defensive case which would then conclude with the beginning of jury deliberations.
Apple’s closing arguments then began.
Closing Arguments of Harold McElhinny for Apple
Thank you may it please court. Ladies and gentleman of the jury. Good morning. Doesn’t matter how we got here. In January 2007 introduced iPhone multi-touch screen device, music, and browser into telephone. That product and new features accessible fun easy to use revolutionary. 1 Minute to explain process. Up til now lawyers have presented screens – you will be locked in room brought trays of exhibits on with binders with numbers. Pages not highlighted marked. Many slides will not be in evidence. So what I am going to do is call out exhibit numbers and you will be able to find.
This document is exhibit 145. This was prepared by Samsung’s consultant analyzing effect iPhone called it revolutionary. It created new market took world by storm. One of the most successful products ever. Until iPad. Entirely new revolutionary. Products created by true geniuses like Jobs. Like Apple inventors – Greg Christie, Tim Malllay the Frenchman. Roberto Garcia. They are real people through genius and hard work have made real contributions to how people communicate and share information. They came before cross exam and gave testimony.
Patents issued by PTO. Jobs warned and put on notice. Could not just. That part is history. Uncontroverted. Not a word challenged. We are here because of a series of decisions by Samsung. By June 2007 did not even have touchscreen – wasn’t even working on it. They were doing feature phones. We also know they were not successful. Less than 5% of the market. Not a leader. Not making progress. And then we showed you exhibit 149. We know Samsung brought all executives – Feb 2010 executives – crisis of design and its most sophisticated customers – the American phone customers – quote this is there words “make something like iPhone.” We know this was followed by month after month changed phone after phone. To copy feature after feature from iPhone. And Samsung began to sell infringing products in US.
We know that lead to second crisis. Meeting ?? Apple Samsung. At that time Apple was Samsung largest customer. Apple accused copying and infringing and did everything it could do to compete fairly instead of unfairly. Samsung rejected and release version after version phone and tablet
37 million devices. Unlike ?? we know illegal strategy wildly successful they have driven other competitors out of markets. The only products are Apple and infringing Samsung products. Literally two horse race. We know unfairly injured company and source of creativity. That is how we came to this place. Now it is to you to do justice. To assemble the facts apply law to facts and award damages you find appropriate. That’s why we are here. Four short weeks ago I stood before you and told you – there were problems with lawsuits it is not easy to be juror – testimony comes in piecemeal and legal concepts don’t come until end. We greatly appreciate. On Apple side it was our job to present clear helpful. It is Bill and my job to bring together evidence useful to your deliberations. To do that I am going to use verdict form instructions. Contains all questions. Jury instructions tell you how to answer those question. Critically help you decide which of the evidence useful and confuse. More different less accurate (your answers).
Obviously Apple plaintiff Apple invented the five patents and it owns 5. First defendant is SEC. As you heard SEC located Suwon South Korea. It owns the other two – SEA and STA. SEC manufacturers phones and tablets and sells directly through subsidiary. It decides what software installed. Decided Android. Set prices for subsidiaries in US. As you may remember Justin Denison – employees all see as part of SEC. Something strange – no executive SEC testified. Decisions. To tell why. Or do defend themselves against serious accusations. None brave enough to come an face cross exam.
SEA headquartered in New Jersey. Sells tablets directly to carriers stores and consumers in US. No SEA testified. STA sells smart phones to carriers’ stores and consumers. With the exception of one designer all worked at STA. All these guys marketing guys. Not one software engineer. Not one who can say how infringing phones came to be.
Now talk about patents for each of five patents – did any three Samsung companies infringe? Second if they infringe, was it willful. Third did Samsung prove clear and convincing evidence invalid. If you find valid patent infringed you find damages – I will deal with damages separately.
721′ lets start we are asserting claim 8. You will remember Cockburn – six Samsung phones divided into four families infringe. You again see four phones on slide. Lets be clear you heard no defense for five of six. Professor Greenberg only defended one phone – Galaxy Nexus – no defense. I want to point out one thing very specific. 4 weeks opening statement Samsung told puzzle you see here on start video clip. No Samsung witness backed this up. Greenberg didn’t because 721′ reads directly. There is nothing about moving along track. Requires contact with unlock image. Puzzle piece is the unlock image…
??? The is obviously the ??? visual cues ?? required to unlock device. Puzzle piece does all. Why would Samsung lawyer make argument make that there was no evidence. Was he trying to get you correct. Greenberg did defend one. He said it didn’t because graphic changes. But as Dr. Cockburn explained it is not limited to any particular image. He showed you animated graphics use. So Samsung has no basis for arguing non-infringement for any of the six.
Let me help you something or else you are going t have ton???. Each one will have exhibit number. If you want to find phone that demonstrates infringing for part patent you can find the right exhibit in column?? So if you want to test phone for this patent. Two things. Not all of your exhibits infringe every patent so you have to make sure right. Remember not to accept software updates ?? exhibit accurate.
Question which forms of infringement Samsung guilty of. As you will see instructions 3 separate ways. Direct infringement instruction ?24. Make – use – sell. That’s infringement. 25 provides guidelines for when sales occur U.S. Applying these we believe SEC directly infringed 721′ because it sells all phones through STA in U.S. We believe STA liable for direct infringement because sells accused product in U.S.. We believe address question 4 in verdict form you should find for infringement both SEC and STA.
Let me stop joint out despite all Samsung you will not find single – Google is not defendant in case. If you find direct STA infringement you will be asked if SEC induced. Inducement is separate way of committing infringement . 28 sets out 3 elements for inducement. 1 SEC must have intentionally taken action that actually induced. This why we brought evidence SEC makes all designs and set price and American units report sales and strategies as you saw exhibit. 2 SEC must be aware asserted. This is why we read undisputed that SEC has known since at least lawsuit was filed. 3 SEC must have known ?? infringe. This can be satisfied with willful blindness. Here we ask you to find ?? slide to lock intentional. Asked them to stop came with no defense and continued to sell. Samsung clearly knew causing infringement. We ask you to find 721 induced yes on question 5 verdict form.
Finally asked if SEC contributory infringement is defined 29 in jury instruction again 3 elements. That SEC supplied important component. Know SEC make all important decisions about software put on phones.. 2??? not common suitable ??? . Obviously all software for phones has no other use. 3. Samsung supplied ?? for use in an infringing manner. Similar to what we ?? before. Given intentional ?? patented features.
After considering these facts ask you to answer yes to question 6. After you ask infringement questions that Samsung patent invalid. Question 31 burden of proof. 34 test obviousness. 31 Tells us Samsung must prove invalidity by clear and convincing evidence – a higher standard of obviousness is whether obvious to someone of ordinary skill in the art at the time of the invention. Instruction sets out several very important. Content prior art. (1) 2) Additional factors relevant to obviousness. I think these are ?? world reaction. But you can’t prove obvious by finding bits and pieces. Can’ use hind-site. Can’t?? Can’t use patent as road-map for prior arts. You know in your own experience – you know this tell somebody an idea and others say well obvious. But where were they?
Samsung/ you know answer – they didn’t have.
Greenberg manual and an article. As you saw there were huge problems with this position. Both of these were before the PTO when issued. Let me pause here examiners were thorough. Prosecution history hundreds of pages. Many patents cited. Even in few instances Samsung cited. No Samsung expert has said the prior art they present was more important than what was before examiners. That’s important. No one ever said so.
Neo Note has no visual cues and not continuous movement. X’s show elements missing. P?son – people had more problem with sliders. No clear and convincing evidence ?? under instructions need clear convincing.
None of it waived in favor validity. He ignored ??? He ignored document after document showing Samsung copied feature from iPhone. Plaintiff Victory – Behold – Pl 219 ?? phone. 157 which was ???
?? not one suggested obvious or Samsung had first or in Google software. None is supported by single page Samsung internal documents. Trying to sell never ever happened.
Lets talk about that. This is trial. Not unusual difference. In that regard we have tried to prove every important using Samsung docs. They show what Samsung were actually thinking. Never thought documents see light of day. On the other hand every point made Samsung contradicted by documents. Witness says A document says B but somehow does not seem to embarrass them. Another factor is ??? field. When we saw Samsung European designers saw slide to unlock. They did not say obvious. They said creative way to solve user interface complexity. If you consider is important novel. If you agree you will answer question 8 no. Samsung did not proven invalid. T???
That will bring you to question of is the infringement willful. The standard is reckless disregard. Actually knew it or so obvious they should have known it.
Here again copying is evidence . With copying you can find willfulness.
Samsung knew about patents crisis of design – intentionally copied. When it got there it presented no infringement defense. 5 and invalidity argument previously rejected by PTO. IF you agree answer yes 7 for both STA and SEC.
That’s it for 721′.
Next patent 172′ auto-correct no question infringe. She (Judge Koh) already found. 7 Samsung infringe 172′ patent. Exhibit 222a pg 7. Here is – there is a lot of data in case lot of lists we have listed all our data you we think you will need. Numbers list of accused devices if useful to you. I’ve been showing you slides you won’t you will have 222a. We can move to validity.
Prof ??? argued invalid. Combination Robinson ?? patents. Didn’t on direct testimony but on cross examination had Robsinson PTO. Prof Cockburn because Robinson did not show ?? missing many claim 18 and gaps could not be filled ?exergonmous? word extension not correction. ?? also ignored Samsung 7.5 million infringing phones evidence commercial success and ignored ?? where T-mobile alternative dart phone too jarring. Nowhere did anyone that the patented feature was obvious. We ask you to answer whether got it right???
Finally on willfulness we know Samsung continued to use feature even after ?? and after no defense answer question 7 yes.(classid def will)
647′ referred to quick links data detectors. Apple asserting ?? against 9 Samsung phones. Exhibit 222a page 7. We called Dr. Todd Mowry – looked at software code in every accused phone each limitation representative phones took through software each claimed function – Samsung called Jufar – conceded represented and most claim elements present. Dr. Jufar argued no infringement an analyzer server could not be programmed as a shared library. Basically says server and library. We brought back Mowry back to show wrong. Showed testimony of Dr. Bonura inventor. Also showed 1996 Apple internal email defense exhibit 334 showing apple inventors had actually consider implementing as shared library exactly same Samsung later infringe phone. This is critical more than one way to implement ?? more than one way implement software. Apple/??? Samsung???
But here you’ll see Apple internal documents compl? consistent with position. Yesterday you’ll recall judge new. Experts came back testify. And he Jufar he came back raise two new issues he claimed shared is not separate from client. Frankly that argument was shell game. Everyone agrees code is called shared library. That is why is called that. It in not ???? shared by every ??? as he was forced to concede under cross examination same used browser messaging other apps. It is not part of any one application. Or part of any one client. Separate available to all of them. As Dr. Mowry showed it is stand alone code separate place in memory. Dr Jufar said it cannot run by itself. In claim construction in never does?? Mowry says everything runs together with something else. Test is whether code separate from application because shared library it is part another.
Second on ??? although Jufar admitted required connection?? court linking action construction he said it didn’t meet claim because it didn’t meet all ?? But again look construction claim yesterday. Does not require link does every step. Just a sequence operations on detected structure. Mowry walked you through shared library code operations both browser and messenger . When you get to question? we ask you to say yes as to both SEC STA and SEC ??? types infringement..
As to validity we had another weird moment. Product embedded buttons invented xerox park promised evidence invalid. But once again no evidence support what he told you. Dr Jufar said but did not rely and did not mention yesterday all. Instead relied on Sidekick. No evidence at all to support argument . Lets talk about Sidekick. Was a very primitive guidance system. Detected only simple structure. Single (or maybe simple?) phone number structure. It did not??? once it. That’s what made 647 ?? ???
?? Samsung cannot prove invalid.
Jufar ?? didn’t pop up menu. Yesterday required to admit didn’t have ?? required construction. What you have expert telling simply almost alll claim requirements obvious even though no evidence ever created filled in gaps created . Simply waived hands said obvious. That cannot be clear and convincing if thousands in field nobody. In this case additional factors helpful. You saw Samsung copied with menu – exhibit ?? . Why copy if obvious. So in question number 8 prove invalid you should answer no.
647′ mentioned by Apple stop copying. Samsung simply cut and pasted original paper into 2012 user experience ?? document (from inventor). And finally we know from testimony after – Google changed to eliminate. When that Samsung stopped using Google so that its would still copy smallest detail. That is willful infringement.
Fourth patent 959′ claim 25. Dr. Soren showed how each infringe accuse. Again Samsung narrow non-infringement. Does not deny no global search. Instead Dr. Reinert Google heuristic does not search info on internet because there is also separate on Google servers also internet searches. But as Dr. Soren not defense because Samsung locate both current and historical. Phone itself stores internet history and that searches. Ironically Soren use this drawing from Google engineer. Shows clearly phone searches for information on Internet. Because Samsung devices covered under claim. we ask answer yes to question 2. Under 959 both phones and tablets. So in this case all three are direct infringers (companies). SEC, STA, S??.
??? SEC induces both SCA and STA to infringe and it is is SEC
Validity Samsung freeways – 2nd combination Smith and Sh???
Freeway 1st. I’m sure this complicated evidence going in. In order to understand. As wee instruction 32 anticipation consider only evidence legal definition prior are. IN this case only to be prior art publicly known or used. Before Apple inventors conceived . Filed January 2000. In order for Freeways had to be known before ?? 2000. One Samsung no evidence Freeways search locally and internet in US before 2000..
??? Shell game. Samsung put in evidence Winks. wakes. American company software. that is not the software Reinart relied on. Not part of invalidity . Its simply to confuse what is in American and not. Software relied s on Freeway’s software. As you recall Samsung brought over software Germany – paid Reinert ?want? to argue because assume last year someone else must have one 15 years ago. No evidence that anyone did before he used our patent as road map.
So Samsung has lot of – claims computer readable medium. ?? source code is not computer readable. Source code cannot be prior art to those patent. Reinart testified had to compile source code Germany. Source code people read to computer readable. Samsung knew problem so brought back to try a little more ?? don’t rely software relying on disk because disk is computer readable medium Now rely disk no source code. Being back ?seme? because only got here last year so cannot be prior art. Put simply we don’t’ think you clear convincing evidence search before January 2000 . But that is something?? when it got it found out installing single computer does not meet claim 25. There is only one set of heuristics?? 3 ??? ???? Reinert had to set up two separate one to and the other to search Internet. Wrong place on second computer. What he ended up proving is how cool invention is. It perrmits ?? local and internet on same device. No one had ever done that before. Apple Reinart also mentioned – he literally just mentioned. He never tried to ?? actual technology patents.
Other factors also sign. This is the patent temporarily took out but which it rushed to put back because customers demanded. This is significant evidence willful. This is another case PTO through concluded. He never told you more relevant than what the examiner considered. No clear convincing to overturn PTO. Are we having fun? (I think there was a little laughter)
I’m sorry to march you through. I don’t want you to be in there??
414′ background sync. ?? source code /? Every ?? Samsung brought in Dr. Chase to ?? technical. Recall Chase testify had 6 4 of 6 not configured to sync because they did not complete every step. only starts process. On rebuttal Dr. Soren showed you ?? on perform sync and then he showed you two document Google that showed Dr. Soren correct. ?? Sync handles all ?? protocol logic.
102 document shows sync adapter provides necessary thread – and Soren testimony how infringement. Since tableet and phoen all three companies.
Tho try to prove invalid 2 pieces prior art. Windows mobile . As Soren explained doesn’t have specific 3 ?? instead email calendar contact same trhread slowing thingsd down. Windows mobile another example world before
Second program called evolution. Soren for email worked on summary table did not have database required by claim. Again we think didn’t prove invalidity.
Prove other factors – ?consoud? figure Samsung doing this . Showed you this slide 327 showed 2006 Google document that described feature in 2006 Google hoped to have. This is exactly jury instructions long felt need. Was ?? didn’t know how to do it. Evidence could not get into own sw until 2008. How could it take Google people 2 years if obvious? Samsung willful known patent made no effort whatsoever to remove.
That concludes liability issues. By this time 1 to 8 in verdict form.
If y any liable valid and infringed move on to damages. 2 things not find. Simply effort to misdirect. 1st is whether apple uses in products. You would find anywhere not relevant to infringement or validity. Samsung effort to convince you copied in 10 million refused to stop using no value.
Second issue Google issue. Again in opening Samsung – Apple war on Google. Now have seen there is no such war on Apple. Saw email snippet but the exhibit is DX489 when you look at exhibit competitive war making ?retrial? experience ?retrials?. So much for concept of holy war but what we now know Apple Samsung worked out. Samsung lawyer Google is helping to defend 2 patents but only two not all 5. [There was an objection here which was overruled]. No claim Google invented any features before Apple. No expert said Google prior art. ?Irr? invalidty. Google ‘s Samsung secret indemnity agreements take care of themselves. If Google any…??
Samsung Google pointed didn’t mention paying fees. Disinterested 3rd parties didn’t mention agree contract. We had to. Then as you saw if we ask if sought indemnity they lied to us under oath. If it strikes you lie under oath cannot be trusted. You will find jusry instruction 12.
Now like to turn to damages. This is heart of this case. Make no mistake. Two ways Samsung wins . Obviously if not infringed or invalid. If that decide Samsung win and ?serever?. But Samsung wins even if you award damages at level thatt rewards its strategy. If Samsung can infringe increase market share pay small fine its strategy successful. And whatever you intended Samsung big winner.
Exactly ?? trivial even though internal critical. Witness easy to design around even though Samsung resisted refused non-infringing alternative. So that is why position no lost profits that negotiations pennies dollars every one is lower damages.
Lets see what instructions say on damages. Lost profit reasonable royalty. Minimum reasonable royalty. Lost profits only if we have proven. Look first…
Lost profits. Test east state. – if we prove reasonable probability would have made more sales had not been on market. If you find any phone inf you ask what would have happened marketplace if had been taken off entirely. Would Apple have made some of those sales. In instruction ?? 4 factors 1 demand, 2 no acceptable on ?nnf? or if number of sales despite – 3 apple had capacity to manufacturer add phones 4 amount of profit apple made lost sales.
1 demand market – know there was. Know demand for slide to unlock ?products? we saw – wont’ waste time dozens articles. We also know demand for Samsung infringing sales figures skyrocketing intro infringing feature. Finally we saw from Samsung internal documents 2 horse race didn’t go to Samsung mostly likely go to apple.
2 non infringing alternatives. Other ways acceptable consumer but did not infringe Instruction 37 we can get lost profits either we can get no ?? even if there were alternative available Dr. Vellturo addressed both – off the market lost profits. The product itself off during times – and then found smaller number of lost profits after hypothetical because hyptothetical not as attractive. First question how long off market while being redesigned. Only seeking off market 3 647 172 ??? based testimony Vellturo only 4 month period. We think conservative. Quick links we know cannot design ever still haven’t 4 months favorable. Slide to unlock word correct – would take months to test – carrier. Samsung said 2 hours but produced no documents. There really is no evidence . Woulda shoulda coulda. During off market period Samsung sold millions. Vellturo calculation only fraction period. You can see number units 11. Apple lost those profits. That results in off market lost profits 570 million dollars.
Second element non infringing factors would have consumers disappointed with replacement. All evidence tell they would. First we had real world evidence we know eventually removed slide to lock and auto-correct. We are not seeking those two. Remaining three Samsung has never been able to design around ?? never could in real world. Universal search put back in 1st opportunity. Damages world easier. Real world actually decisions we can see Samsung never found satisfactory alternative. Some credit hypothetical that may never happened conservative. Then we ?? call on Hauser to conjoint survey to measure exactly how real consumers value.
That survey designed and carried out ?abs? expert valuable and prefer then to // do not ?invfing?. ?Susing? same and industry thousands Hauser confirmed what is obvious. There is demand for features. Carriers and consumers. What did Hauser do? He conducted survey of ??? Each of these participants had strong incentive because they got potential feature that they indicated survey..
Survey part walked through animated description features and distraction features replay anytime process including time end. These are not people in Reibstein survey. Hauser able to collect rich data set 16,000 data using industry standard gold Sawtooth. Hauser validates standard tests statistical . Samsung hates results Hauser survey because it shows so dramatically . Undermines every argument . Samsung declares war. Earlier Samsung expert Wagner told court conjoint exactly features in this case. You didn’t see Wagner in this courtroom he is history. No you would not see survey from Samsung. Know val. Know ay well design survey would how. Instead expert nitpick. Things like eye tracking , sentence count test. Admit never previous. And admitted none has Hauser expertise. Frankly he is best. Match what Samsung actions and common sense tell. If no value would not have copied and would have dropped years ago. Samsung decision makers who didn’t show decided needed to . There actions speak louder than any survey could. ?? tha t is ??
For second factor. Samsung off 4 months hypothesis world change continues sale Apple product.s As you saw Dr. Vellturo just under 560 million. Fortunately next is easy.
Rory ?? Apple testified they had capacity to product. Samsung did not dispute profit Apple. Proof of each 4 strong document.
Samsung other hand made argument ??? redesign less day even never had real woulda-coulda-shoulda. And exactly as I told you she would out of 37 million infringing sale apple did not lose one sale. Ironically out of all this instruction can you award simply market share infringing devices. In some ways easiest tells us exactly brand advertising screen size. As you may recall Apple market share during time 40 percent. Made number of down are instead Apple 40 percent Apple seeking only 10 percent. Either way just under ???? 9.5 percent Samsung infringe sales. Exhibit…
Second type reasonable royalty. Obviously we don’t get Vellturo careful not double county. But as instruction – reasonable royalty minimum. Ex – 15 factors. I submit each of these d 15 ?? . Lets look at 8, ?? think back to charts we have shown you commercial success iPhone. iPhone revolution phone ?scuuces?. Samsung driven out others making it 2 horse race.
In short iPhone rev and both . So successful Samsung substantially raised prices which compares avg price ?? 2012. Factor 8 calls for subsntial royalty. Lets look at 9 this is for course 9 – entirely different courtroom. Nothing speaks more clearly crisis design. 2010 stuck old technology. Differen heaven earh. Highest execs spelled exactly hypothetical negotiation. Opens Samsung said hardware not software. He stoodright ehre. Then he saw what Samsung saw internal documents. Samsung didn’t come in actually thinking . Truth software now driving. Even ?? admitted software had become more important to smart phones. Finally Lockheimer said background sync incredibly valuable. After that they stopped asking.
Lets look factor 11. Made use invention. You know this number by heart 37 million. Population San Jose 1 million. Give each person 37 cell phones. Size is beyond comprehension.
Judge Koh: Sorry to interrupt lets take break.
Missed about 2 minutes here.
Would have Apple have a did what Apple’s witnesses have told you. Take 1.75 per phone. You know that would not have happened. Remember Pendelton and Mr. Lee had been surprised him. He was talking about near field would he had licensed for pennies on the dollar because the concept of pennies on dollar. Swallowed tongue fall out of chair. Compare.
August ?? 60 million were going to buy first in next few months. And common sense tells you. To be honest I do not understand Samsungs evidence. Said we declared war. Samsung beaten down Apple worried. I submitted that true. Think for it were true suppose right . Would that have made Apple’s demand higher or lower? Do you charge less from competitor you are worried about. I don’ think so. If you are worried you charge them more.
Simple when you reach this point instructions ask questions asks you to ask. What would parties position taken you will see Vellturo accurate fair balanced. Royalties are not higher than apple asked and Samsung facing crisis design would have paid to stay in market. A…
After considering each ?? 5
you can see royalty rates in exhibit. So how will you fill you verdict form on this issue. ?? Question 10a asks your for a detailed break down by phone and ?atenta dn by ?? We have provided chart which shows verdict form would look like if you agree Vellturo. You can also 222?
Finally you will be asked 10b 3 phones 3 time periods. Vellturo here slide 97. But you will also see 222a at page 12. When u look at 222 a and 19 24 you will find alternative charts lower damages charts that you can use to fill out verdict form. We did not do because we think right we did if you not the one I am advocating. We promised we would give you what you need easy for you to use.
In closing I would like to say this bringing this lawsuit was Apple’s last choice last option. You know we Samsung and tried to persuade to compete fairly. You know however form Samsung internal document and they never considered. To focused own crisis design only way to succeed to make something like the iPhone. Samsung was committed to bring to get away with infringement. Apple cannot walk away from its inventions . Cannot do to people you saw and people like that who came up with such fabulous sides. We are here 37 million acts of infringement later and we are counting on you for justice.
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