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2008 UNCITRAL Digest of case law on the United Nations Convention on the International Sale of Goods

Digest of Article 78 case law [reproduced with permission of UNCITRAL] [*]

[Text of article
Prerequisites for entitlement to interest
Interest rate]

Article 78

If a party fails to pay the price or any other sum that is in arrears, the other party is entitled to interest on it, without prejudice to any claim for damages recoverable under article 74.

INTRODUCTION

1. Article 78 deals with the right to interest on the price or any other sum that is in arrears. The provision does not, however, apply where the seller has to refund the purchase price after the contract has been avoided, in which case article 84 of the Convention governs as lex specialis.

2. Article 78 entitles a party to interest on the price and any other sum that is in arrears. According to case law, Article 78 entitles a party to interest on damages.[1]

Prerequisites for entitlement to interest

3. Entitlement to interest requires only [2] that the sum for which interest is sought is due,[3] and that the debtor has failed to comply with its obligation to pay the sum by the time specified either in the contract [4] or, absent such specification, by the Convention.[5] According to several decisions, entitlement to interest under article 78 of the Convention -- unlike under some domestic legal regimes -- does not depend on giving formal notice to the debtor.[6] As a consequence, interest starts to accrue as soon as the debtor is in arrears. A court has stated that interest on damages accrues from the time damages are due.[7]

4. Both an arbitral tribunal [8] and a court,[9] however, have stated that interest does not accrue unless the creditor has sent to the debtor in default a formal notice requiring payment.

5. Entitlement to interest under article 78 does not depend on the creditor proving that he suffered a loss. Interest can therefore be claimed independently from the damage caused by the fact that a sum is in arrears.[10]

6. As stated in article 78, the entitlement to interest on sums in arrears is without prejudice to any claim by the creditor for damages recoverable under article 74.[11] Such damages might include finance charges incurred because, without access to the funds in arrears, the debtor was forced to a bank loan;[12] or lost investment income that would have been earned from the sum in arrears.[13] This has led one arbitral tribunal to state that the purpose of article 78 is to introduce the distinction between interest and damages.[14] It must be noted that, in order for a party successfully to claim damages in addition to interest on sums in arrears, all requirements set forth in article 74 must be met [15] and the burden of proving those elements carried by the creditor,[16] i.e. the damaged party.

Interest rate

7. Several courts have pointed out that article 78 merely sets forth a general entitlement to interest;[17] it does not specify the interest rate to be applied,[18] which is why one court considered article 78 a "compromise".[19] According to a court [20] and an arbitral tribunal,[21] the compromise resulted from irreconcilable differences that emerged during the Vienna Diplomatic Conference at which the text of the Convention was approved.

8. The lack of a specific formula in article 78 to calculate the rate of interest has led some courts to consider this to be a matter governed by, but not expressly settled in, the Convention.[22] Other courts treat this issue as one that is not governed by the Convention. This difference in the characterization of the issue has led to diverging solutions concerning the applicable interest rate. Matters governed by but not expressly settled in the Convention have to be dealt with differently than questions falling outside the Conventions scope. According to article 7(2) of the CISG, the former must be settled, first, in conformity with the general principles on which the Convention is based; only in the absence of such principles is the law applicable by virtue of the rules of private international law to be consulted. An issue outside the Convention's scope, in contrast, must be settled in conformity with the law applicable by virtue of the rules of private international law, without recourse to the "general principles" of the Convention.

9. Several decisions have sought a solution to the interest rate question on the basis of general principles on which the Convention is based. Some courts and arbitral tribunals [23] have invoked article 9 of the Convention and determined the rate of interest by reference to relevant trade usages. According to two arbitral awards [24] the applicable interest rate is to be determined autonomously on the basis of the general principles underlying the Convention. These decisions reason that recourse to domestic law would lead to results contrary to the goals of the Convention. In these cases, the interest rate was determined by resorting to a general principle of full compensation; this led to the application of the law of the creditor because it is the creditor who must borrow money to replace sums in arrears.[25] Other tribunals simply refer to a "commercially reasonable" rate,[26] such as the London InterBank Offered Rate (LIBOR).[27]

10. The majority of courts consider the interest rate issue to be a matter outside the scope of the Convention and therefore subject to domestic law.[28] Most such courts have resolved the question by applying the domestic law of a specific country, determined by employing the rules of private international law of the forum;[29] others have applied the domestic law of the creditor without reference to whether it was the law applicable by virtue of the rules of private international law.[30] There also are a few cases in which the interest rate was determined by reference to the law of the country in whose currency the sum in arrears was to be paid (lex monetae);[31] in other cases, the courts applied the interest rate of the country in which the price was to be paid,[32] the rate applied in the debtor's country,[33] or even the rate of the lex fori.[34]

11. A few decisions have applied the interest rate specified by article 7.4.9 of the UNIDROIT Principles of International Commercial Contracts.[35]

12. Despite the variety of solutions described above, tribunals evince a clear tendency to apply the rate provided for by the domestic law applicable to the contract under the rules of private international law,[36] that is, the law that would be applicable to the sales contract if it were not subject to the Convention.[37]

13. Where, however, the parties have agreed upon an interest rate, that rate is to be applied.[38]


NOTES

* This presentation of the UNCITRAL Digest is a slightly modified version of the original UNCITRAL text at <http://www.UNCITRAL.org/pdf/english/clout/CISG_second_edition.pdf>. The following modifications were made by the Institute of International Commercial Law of the Pace University School of Law:

   -    To enhance access to contents by computer search engines, we present in html rather than pdf;
 
   -    To facilitate direct focus on aspects of the Digests of most immediate interest, we inserted linked tables of contents at the outset of most presentations;
 
   -    To support UNCITRAL's recommendation to read more on the cases reported in the Digests, we provide mouse-click access to (i) CLOUT abstracts published by UNCITRAL (and to UNILEX case abstracts and other case abstracts); and also (ii) to full-text English translations of cases with links to original texts of cases, where available, in [bracketed citations] that we have added to UNCITRAL's footnotes; and
 
   -    To enable researchers to themselves keep the case citations provided in the Digests constantly current, we have created a series of tandem documents, UNCITRAL Digest Cases + Added Cases. The new cases and other cases that are cited in these updates are coded in accordance with UNCITRAL's Thesaurus.

In addition, this presentation introduces each section of the UNCITRAL Digest with a Google search button. This is to help you access doctrine (relevant material from the over 1,200 commentaries, monographs and books on the CISG and related subjects that we present on this database) as well as the texts of the cases that UNCITRAL cites in its Digests and that we present in our updates to UNCITRAL's Digests.

1. [SWITZERLAND Kantonsgericht des Kantons Zug 21 October 1999 (PVC and other synthetic materials case)] (see full text of the decision); [SWITZERLAND Handelsgericht des Kantons Zürich 5 February 1997 (Sunflower oil case)] (see full text of the decision).

2. See [SWITZERLAND Handelsgericht des Kantons Zürich 21 September 1998 (Catalogue case)] (see full text of the decision); [SWITZERLAND Bezirksgericht Arbon 9 December 1994 (Cloth case)].

3. [SWITZERLAND Handelsgericht des Kantons Aargau 26 September 1997 (Cutlery case)] (see full text of the decision); [GERMANY Amtsgericht Nordhorn 14 June 1994 (Shoes case)].

4. [SWITZERLAND Handelsgericht des Kantons Aargau 19 December 1997 (Garments case)] (see full text of the decision).

5. For cases where courts had to resort to the rules of the Convention specifically, article 58 to determine when the payment was due because the parties had not agreed upon a specific time for payment, see [GERMANY Landgericht Stendal 12 October 2000 (Granite rock case)]; GERMANY Oberlandesgericht Frankfurt a.M. 18 January 1994 (Shoes case)] (see full text of the decision); [GERMANY Oberlandesgericht Frankfurt a.M. 13 June 1991 (Textiles case)] (see full text of the decision).

6. See [BELGIUM Tribunal de commerce de Namur 15 January 2002 (Milling machine case)]; [BELGIUM Rechtbank van koophandel Kortrijk 3 October 2001 (Ribbon case)]; [BELGIUM Rechtbank van koophandel Kortrijk 4 April 2001]; [GERMANY Landgericht Stendal, 12 October 2000 (Granite rock case)]; [SWITZERLAND Handelsgericht des Kantons Aargau 26 September 1997 (Cutlery case)] (see full text of the decision); [SWITZERLAND Tribunal Cantonal Vaud 11 March 1996 (Aluminal granules case)]; [GERMANY Landgericht Aachen 20 July 1995]; [ICC International Court of Arbitration, Award 7585 of 1992 (Foamed board machinery case)]; [GERMANY Arbitration-Schiedsgericht der Handelskammer Hamburg, 21 March 1996 and 21 June 1996 (Chinese goods case)]; [FRANCE Cour d'appel, Grenoble 26 April 1995 (Candy case)]; [ICC International Court of Arbitration, Award 7331 of 1994 (Cowhides case)] (see full text of the decision); [GERMANY Amtsgericht Nordhorn 14 June 1994 (Shoes case)]; [SWITZERLAND Pretore della giurisdizione di Locarno Campagna 16 December 1991 (Optical equipment case)].

7. [SWITZERLAND Kantonsgericht des Kantons Zug 21 October 1999 (PVC and other synthetic materials case)] (see full text of the decision); [SWITZERLAND Handelsgericht des Kantons Zürich 5 February 1997 (Sunflower oil case)] (see full text of the decision).

8. [BULGARIA Arbitral Tribunal at the Bulgarian Chamber of Commerce and Industry, Award 11/1996 of 12 February 1998 (Steel ropes case)].

9. See [GERMANY Landgericht Zwickau 19 March 1999 (Chemical products case)].

10. See GERMANY Oberlandesgericht Frankfurt a.M. 18 January 1994 (Shoes case)] (see full text of the decision); [GERMANY Landgericht Hamburg 26 September 1990 (Textiles case)] (see full text of the decision); [GERMANY Amtsgericht Oldenburg in Holstein 24 April 1990 (Fashion textiles case)] (see full text of the decision).

11. This has often been emphasized in case law. See, e.g., [BELGIUM Rechtbank van koophandel Hasselt 17 June 1998 (Koning & Hartman and Klaasing Electronics v. Beerten)]; [SWITZERLAND Bundesgericht 28 October 1998 (Meat case)] (see full text of the decision); [ICC International Court of Arbitration, Award 8962 of September 1997 (Glass commodities case)]; [SWITZERLAND Handelsgericht des Kantons Zürich 21 September 1995 (Air conditioners case)]; [GERMANY Oberlandesgericht Frankfurt a.M. 18 January 1994 (Shoes case)] (see full text of the decision); [GERMANY Oberlandesgericht Düsseldorf 14 January 1994 (Shoes case)] (see full text of the decision); [GERMANY Oberlandesgericht Koblenz 17 September 1993 (Computer chip case)] (see full text of the decision); [ICC International Court of Arbitration, Award 7197 of 1992 (Failure to open letter of credit and penalty clause case)]; [GERMANY Amtsgericht Oldenburg in Holstein 24 April 1990 (Fashion textiles case)] (see full text of the decision).

12. See [SWITZERLAND Bundesgericht 28 October 1998 (Meat case)] (see full text of the decision); [GERMANY Amtsgericht Koblenz 12 November 1996 (Shoes case)]; [SWITZERLAND Handelsgericht des Kantons Zürich 21 September 1995 (Air conditioners case)]; [GERMANY Landgericht Kassel 14 July 1994 (Test tubes case)]; GERMANY Oberlandesgericht Frankfurt a.M. 18 January 1994 (Shoes case)] (see full text of the decision).

13. [GERMANY Amtsgericht Oldenburg in Holstein 24 April 1990 (Fashion textiles case)] (see full text of the decision).

14. [ICC International Court of Arbitration, Award 7585 of 1992 (Foamed board machinery case)] (see full text of the decision).

15. See [SWITZERLAND Kantonsgericht des Kantons Zug 25 February 1999 (Roofing materials case)]; [GERMANY Landgericht Oldenburg 9 November 1994 (Lorry platforms case)] where the creditors claim for damages caused by the debtors failure to pay was dismissed on the grounds that the creditor did not prove that it had suffered any additional loss.

16.It has often been stated that the damages referred to in the final clause of article 78 must be proved by the damaged party; see [GERMANY Landgericht Darmstadt 9 May 2000 (Video recorders case)] (see full text of the decision); [GERMANY Oberlandesgericht Düsseldorf 24 April 1997 (Shoes case)] (see full text of the decision); [GERMANY Amtsgericht Koblenz 12 November 1996 (Shoes case)]; [GERMANY Amtsgericht Bottrop, 25 June 1996 (Shoes case)]; [GERMANY Oberlandesgericht Hamm 8 February 1995 (Socks case)]; [GERMANY Landgericht Kassel 14 July 1994 (Test tubes case)]; GERMANY Oberlandesgericht Frankfurt a.M. 18 January 1994 (Shoes case)] (see full text of the decision).

17. See [SWITZERLAND Bundesgericht 28 October 1998 (Meat case)] (see full text of the decision); [ICC International Court of Arbitration, Award 7585 of 1992 (Foamed board machinery case)]; [GERMANY Landgericht Aachen, 20 July 1995]; [GERMANY Oberlandesgericht München 2 March 1994 (Coke case)] (see full text of the decision); GERMANY Oberlandesgericht Frankfurt a.M. 18 January 1994 (Shoes case)] (see full text of the decision); [GERMANY Oberlandesgericht Koblenz 17 September 1993 (Computer chip case)] (see full text of the decision); [GERMANY Oberlandesgericht Frankfurt a.M. 13 June 1991 (Textiles case)] (see full text of the decision).

18. [GERMANY Landgericht Berlin 21 March 2003 (Fabrics case)]; [ITALY Tribunale di Pavia 29 December 1999 (High fashion textiles case)]; [BULGARIA Arbitral Tribunal at the Bulgarian Chamber of Commerce and Industry, Award 11/1996 of 12 February 1998 (Steel ropes case)].

19. [SWITZERLAND Canton del Ticino, Pretore di Locarno Campagna 16 December 1991 (Optical equipment case)].

20. [SWITZERLAND Handelsgericht des Kantons Zürich 9 September 1993 (Furniture case)] (see full text of the decision).

21. [ICC International Court of Arbitration, Award 8128 of 1995 (Chemical fertilizer case)].

22. For a case listing various criteria employed in case law to determine the rate of interest, see [ICC International Court of Arbitration, Award 7585 of 1992 (Foamed board machinery case)],

23. See [BELGIUM Rechtbank van koophandel Ieper, 29 January 2001 (Cooling installations case)]; [ICC International Court of Arbitration, Award 6653 of 26 March 1993 (Steel bars case)]; [ARGENTINA Juzgado Nacional de Primera Instancia en lo Comercial n. 10, Buenos Aires, 6 October 1994 (Looms and other goods case)]; [ARGENTINA Juzgado Nacional de Primera Instancia en lo Comercial n. 10, Buenos Aires 23 October 1991 (Aguila Refractarios / Conc. preventivo)].

24. See [AUSTRIA Arbitration-Internationales Schiedsgericht der Bundeskammer der gewerblichen Wirtschaft Wien, 15 June 1994 (SCH-4366) (Rolled metal sheets case)] and [AUSTRIA Arbitration-Internationales Schiedsgericht der Bundeskammer der gewerblichen Wirtschaft Wien, 15 June 1994 (SCH-4318) (Rolled metal sheets case)] (see full text of the decisions).

25. For another arbitral award applying the interest rate of the country in which the damage occurred (i.e., the country in which the creditor has its place of business), see [ICC International Court of Arbitration, Award 7331 of 1994 (Cowhides case)].

26. See [ICC International Court of Arbitration, Award 8769 of December 1996 (Electrical appliances case)].

27. See [ICC International Court of Arbitration, Award No. 8908 of December 1998 (Pipes case)]; [ICC International Court of Arbitration, Award 6653 of 26 March 1993 (Steel bars case)]; this arbitral award was later annulled on the grounds that international trade usages do not provide appropriate rules to determine the applicable interest rate; see [FRANCE Cour d'appel de Paris 6 April 1995 (Steel bars case)].

28. Some decision not specify which law was applicable because all the countries involved in the particular dispute provided for either the same rate of interest (see, for example, [GERMANY Oberlandesgericht Frankfurt a.M. 20 April 1994 (New Zealand mussels case)]; [SWITZERLAND Canton of Ticino Pretore di Locarno Campagna 27 April 1992 (Furniture case)] (see full text of the decision) or an interest rate higher than the one claimed by the plaintiff (see [GERMANY Oberlandesgericht Dresden 27 December 1999 (Chemical products case)].

29. See [GERMANY Landgericht Stendal 12 October 2000 (Granite rock case)]; [GERMANY Oberlandesgericht Stuttgart 28 February 2000 (Floor tiles case)]; [ICC International Court of Arbitration, Award 9448 of July 1999 (Roller bearings case)]; [ITALY Tribunale di Pavia 29 December 1999 (High fashion textiles case)]; [ICC International Court of Arbitration, Award 9187 of June 1999 (Coke case)]; [SWITZERLAND Kantonsgericht des Kantons Zug 21 October 1999 (PVC and other synthetic materials case)] (see full text of the decision); [SWITZERLAND Kantonsgericht des Kantons Zug 25 February 1999 (Roofing materials case)]; [GERMANY Landgericht Flensburg 24 March 1999 (Vine wax case)]; [SWITZERLAND Bundesgericht 28 October 1998 (Meat case)] (see full text of the decision); [GERMANY Oberlandesgericht Koblenz 31 January 1997 (Acrylic blankets case)]; [ICC International Court of Arbitration, Award 8611 of 23 January 1997 (Industrial equipment case)] (stating that the relevant interest rate is either that of the lex contractus or, in exceptional cases, that of the lex monetae); [GERMANY Landgericht Bielefeld 2 August 1996 (Pig case)]; [SWITZERLAND Tribunal de la Glâne 20 May 1996 (Fashion textiles case)]; [GERMANY Arbitration-Schiedsgericht der Handelskammer Hamburg, 21 March 1996 and 21 June 1996 (Chinese goods case)] (see full text of the decision); [SWITZERLAND Canton del Ticino Tribunale d'appello 12 February 1996 (Copy paper case)] (see full text of the decision); [GERMANY Amtsgericht Augsburg 29 January 1996 (Shoe case)]; [SWITZERLAND Handelsgericht des Kantons St. Gallen 5 December 1995 (Computer hardware devices case)] (see full text of the decision); [GERMANY Landgericht Kehl 6 October 1995 (Knitware case)]; [SWITZERLAND Handelsgericht des Kantons Zürich 21 September 1995 (Air conditioners case)]; [GERMANY Oberlandesgericht Rostock 27 July 1995 (Plants case)]; [GERMANY Landgericht Aachen 20 July 1995]; [GERMANY Landgericht Kassel 14 July 1994 (Test tubes case)]; [GERMANY Oberlandesgericht Celle 24 May 1995 (Used printing press case)]; [GERMANY Landgericht Alsfeld 12 May 1995 (Flagstone tiles case)]; [GERMANY Landgericht Landshut 5 April 1995 (Sport clothing case)]; [GERMANY Landgericht München 20 March 1995 (Rancid bacon case)]; [GERMANY Landgericht Oldenburg 15 February 1995 (Textiles case)]; [GERMANY Oberlandesgericht Hamm 8 February 1995 (Socks case)]; [ICC International Court of Arbitration, Award 7565 of 1994 (Coke case)]; [SWITZERLAND Kantonsgericht Zug 15 December 1994 (Valves case)]; [GERMANY Landgericht Oldenburg 9 November 1994 (Lorry platforms case)]; [SWITZERLAND Kantonsgericht Zug 1 September 1994 (Fashion textiles case)]; [GERMANY Landgericht Düsseldorf 25 August 1994 (Fashion goods case)]; [GERMANY Landgericht Giessen 5 July 1994 (Women's clothes case)]; [NETHERLANDS Rechtbank Amsterdam 15 June 1994 (Lithographs case)]; [GERMANY Amtsgericht Nordhorn 14 June 1994 (Shoes case)]; [GERMANY Oberlandesgericht München 2 March 1994 (Coke case)]; [GERMANY Oberlandesgericht Düsseldorf 10 February 1994 (Fabrics case)]; [GERMANY Oberlandesgericht Düsseldorf 10 February 1994 (Shirts case)]; [GERMANY Kammergericht Berlin 24 January 1994 (Wine case)] (see full text of the decision); [NETHERLANDS Rechtbank Arnhem 30 December 1993 (Live lambs case)]; [SWITZERLAND Tribunal Cantonal Vaud 6 December 1993 (Fruits and vegetables case)]; [GERMANY Oberlandesgericht Koblenz 17 September 1993 (Computer chip case)]; [SWITZERLAND Handelsgericht des Kantons Zürich 9 September 1993 (Furniture case)]; [NETHERLANDS Rechtbank Roermond 6 May 1993 (Gruppo IMAR S.p.A. v. Protech Horst BV, Arrondissementsrechtbank Roermond) (Electric kettles case)]; [GERMANY Landgericht Verden 8 February 1993 (Shoes case)]; [SWITZERLAND Zivilgericht Basel-Stadt 21 December 1992 (Textiles case)]; [GERMANY Amtsgericht Zweibrücken 14 October 1992]; [GERMANY Oberlandesgericht Hamm 22 September 1992 (Frozen bacon case)] (see full text of the decision); [GERMANY Landgericht Heidelberg 3 July 1992 (Computer components case)]; [SWITZERLAND Pretore della giurisdizione di Locarno Campagna 16 December 1991 (Optical equipment case)]; [GERMANY Landgericht Hamburg 26 September 1990 (Textiles case)]; [GERMANY Amtsgericht Oldenburg in Holstein 24 April 1990 (Fashion textiles case)].

30. Several court decisions have referred to the domestic law of the creditor as the applicable law, independently of whether the rules of private international law designated that law; see [[SWITZERLAND Bezirksgericht Arbon 9 December 1994 (Cloth case)]; [GERMANY Landgericht Frankfurt a.M. 16 September 1991 (Shoe case)] (see full text of the decision); [GERMANY Landgericht Stuttgart 31 August 1989 (Shoes case)]; for criticism of the latter decision, see [GERMANY Landgericht Kassel 22 June 1995 (Clothes case)].

31. See [BELGIUM Rechtbank van koophandel Ieper 18 February 2002 (Pork meat case)]; [BELGIUM Rechtbank van koophandel Veurne, 25 April 2001 (Diesel tram case)]; [HUNGARY Arbitration Court attached to the Hungarian Chamber of Commerce and Industry 5 December 1995 (Waste containers case)]; [HUNGARY Arbitration Court attached to the Hungarian Chamber of Commerce and Industry, 17 November 1995 (Mushrooms case)].

32. See [SWITZERLAND Kantonsgericht Nidwalden 3 December 1997 (Furniture case)]; [NETHERLANDS Rechtbank Almelo 9 August 1995 (Wolfgang Richter Montagebau v. Handelsonderneming Euro-Agra and Te Wierik)]; [ICC International Court of Arbitration, Award 7153 of 1992 (Hotel materials case)].

33. See [GERMANY Landgericht Berlin 21 March 2003 (Fabrics case)] (see full text of the decision); [SWITZERLAND Tribunal Cantonal Vaud 11 March 1996 (Clay case)].

34. [UNITED STATES Federal District Court, Northern District of New York, 9 September 1994 (Delchi Carrier, S.p.A. v. Rotorex Corp.)].

35. See [ICC International Court of Arbitration, Award 8769 of December 1996 (Electrical appliances case)]; [ICC International Court of Arbitration, Award 8128 of 1995 (Chemical fertilizer case)]; [AUSTRIA Arbitration - Internationales Schiedsgericht der Bundeskammer der gewerblichen Wirtschaft Wien, 15 June 1994 (SCH-4366) (Rolled metal sheets case)] and [AUSTRIA Arbitration - Internationales Schiedsgericht der Bundeskammer der gewerblichen Wirtschaft Wien, 15 June 1994 (SCH-4318) (Rolled metal sheets case)].

36. Some courts have characterized this approach as a unanimous one; see [GERMANY Oberlandesgericht Hamm 8 February 1995 (Socks case)]; [SWITZERLAND Handelsgericht des Kantons Zürich 9 September 1993 (Furniture case)]. As the foregoing discussion demonstrates, however, this solution, although the prevailing one, has not been unanimously accepted.

37. See [GERMANY Landgericht Aachen 20 July 1995]; [GERMANY Amtsgericht Riedlingen 21 October 1994 (Ham case)]; [GERMANY Amtsgericht Nordhorn 14 June 1994 (Shoes case)].

38. See [BELGIUM Hof Antwerp 4 November 1998 (I.S. Trading v. Vadotex)]; [GERMANY Landgericht Kassel 22 June 1995 (Clothes case)].


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