Free Speech

The Vote-by-Tweet Memes Prosecution

The First Amendment and statutory questions in the Douglass Mackey / Ricky Vaughn case.


I have an article about it at Tablet Magazine; here's the opening:

In 2016, a Florida man named Douglass Mackey (using the online alias "Ricky Vaughn") allegedly conspired to distribute a meme aimed at deceiving pro-Hillary voters.

Four years later, Mackey is now being prosecuted (as to this and as to other memes) for violating 18 U.S.C. § 241, a federal law that punishes conspiracies "to injure, oppress, threaten, or intimidate any person … in the free exercise or enjoyment of any right or privilege secured to him by the Constitution"—namely, the right to vote. Lying to voters in a way that keeps them from voting, the theory goes, is a crime.

Is this sort of prosecution constitutional? After all, people often lie in political campaigns. Candidates do it, activists do it, political operatives do it. Can election lies simply be outlawed?

Surprisingly, the Supreme Court has never resolved the question. It hasn't resolved the big-picture question: When can the government punish lies? It hasn't resolved the medium-size question: Can the government punish lies in election campaigns? And it hasn't resolved the particular question: Can the government punish lies about the mechanisms of voting, and in particular about how to vote?

NEXT: Libel Case Involving Controversy Over Allegations of Manipulated Medical Research

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  1. there has been a common meme/memo circulating every election year since at least the 1970’s with the minor variations of the same message –

    Party A vote on tuesday (election day), Party B should vote on Wednesday (the day after the election)

    This prosecution if for same stunt that has been done for the last 50+ years.

    1. I can’t count how many times a week I’m asked to vote for something on the internets. What I don’t see in that ad is any assertion that it is a official vote in a federal or state election.

  2. This prosecution is ridiculous. I hate where the country has gone/is going.

    1. The not so subtle joke is that you would have to be as dumb as a bag of hammers to take this seriously. The sad punchline is that pretty much describes the entire progressive movement.

      The folks bitching and moaning about this are the same idiots who were convinced Trump was telling them to inject bleach. Not so strangely, it was only progressives who believed that as well.

      1. You have to be dumb as a bag of hammers to believe the 2020 election was stolen. But here we are.

        1. You need to update your software Orbital. Now they are admitting that it was stolen, but calling it “protecting” the election:

          The Secret Bipartisan Campaign That Saved the 2020 Election | Time

          It’s called a confession

          1. Actually, thanks to this I am considering writing an apology to all bags of hammers everywhere.

            1. What do you have against hammers? They are a very useful tool for all kinds of things. How many tools do you know that you can both do and undo the same thing? (Ok, a screwdriver too.)

          2. Reading isn’t your forte, is it?

          3. Is today “opposite day”?

            1. Tonight is “opposite of day.” Does that count?

        2. I myself made the “joke” that:

          “Any true Georgia patriot should know better than to vote in any election supervised by Brad Raffensburger.”

          I made statments to that effect on numerous platforms. Do I claim responsibility for the subsequent Dem senatorial victories in GA?
          I have on numerous platforms. But I shouldn’t be prosecuted for it. Or if I should, they should get in line behind any charges that I’m currently indicted for…

      2. But a lot of MAGAs, who knew better than to inject bleach, took Scrump’s suggested remedy orally, which resulted in a fourfold increase in calls to poison centers nationwide.

        1. That is definitely not what that says, in addition to the fact that it’s talking about the period of time before the bleach speech.

    2. There ought to be sanctions on the prosecutors. This language either doesn’t fit the alleged facts, or is unconstitutionally vague and could fit almost any facts: “to injure, oppress, threaten, or intimidate any person … in the free exercise or enjoyment of any right or privilege”.

    1. It’s not a crime to gaslight the public.

      It’s not a crime to make in-kind contributions to political campaigns, when your company is big enough.

      It’s not a crime to undermine or outright ignore laws that protect the integrity of votes.

      Maybe it should be, but it’s not.

    2. Read the original source before you come in here with The Federalist’s lies, you narritivist twit.

      1. Insulting the messenger instead of refuting the message shoos who is the twit.

        1. My refutation is that the Federalist lied about the original source.

          Read the articles and come back and tell me different.

      2. Read the original source before you come in here with The Federalist’s lies, you narritivist twit.

        This from the hypocritical shitbird who is always whining about being called names (that he’s repeatedly earned over the course of years).

      3. The Federalist piece is a nice collection of scare quotes and innuendo to change aggressive GOTV, including litigation and messaging efforts, into something sinister and undemocratic. It reminds me of the street-corner commie proselytizers and marxist college students who’d tell you that “there is only freedom of the press for those who own the presses” (catchy phrase, no?) as they tried to sell you their own crazy paper that they somehow got printed. Poor Trump couldn’t get his message out. And, if, say, media does a “catch and kill” of a negative story hurting one side, that invalidates the election!
        Welcome to capitalism. Welcome to coalition politics. Welcome to political organizing. This is not the grand fraud conspiracy about a “stolen” election. It was coalition attempting to win by getting more votes.
        I particularly liked the allegation of an “election-manipulation ‘conspiracy’ among the nation’s rich and powerful.” In other words, Trump got screwed by Citizens United. Sad. The influence of the Kochs, Mercer and Adelson, Sinclair Broadcasting–so unfair! The marketplace of ideas is rigged! I also love how the election was insecure because of the “unconscious bias” of poll workers.
        (Has anybody else noticed that the Trumpy far right has adopted the same tropes and reasoning of the wacky left of the 70s including revering Russia and voraciously consuming propaganda “straight from the Kremlin”–basically they’re commies who hate gays and abortion. That is, they hate capitalism, specifically free trade, corporations, big business, banks, finance, professionals, NATO, the media, the rich, the WSJ and apparently some will only eat organic food. )

    3. The federalist is egregious in its agitprop, but I think still protected under 1A.

      1. I see what you did there.

        1. Surveying the resultant scrum he whispered “My work here is done.”
          “What? WTF did you just say?” The person immediately in front of him at the breadline, growing agitated; it had only been five weeks since the last terrorist attack/righteous freedom fight/orgy of proud gullibility. “Nothing, you’re hearing things!” he hollered to the rube who’d already begun searching the throng for a cop to report to. “Fuck your government bread…” he thought bitterly to himself as he abandoned his place in the que.

  3. If people fall for that, they are too stupid to vote.

    1. I look forward to meeting you in the camps.

      1. Me too, but I’m hoping by then to be commandant, so I won’t have to remember your names.

    2. Easier to fall for that than to fall for Trump’s claims of election fraud. Which 40% of Republicans still fall for.

  4. Good gravy, this isn’t coddling of the American mind, it’s coddling of complete stupidity. At what point do we say that voters are adults, and whether or not they act like they are, it is entirely — ENTIRELY! — up to them. It is not the court’s role to step in an wag the finger at someone stupid enough to think that sending a hash-tagged text message is equivalent to ACTUAL VOTING.

    And what does it say about our legal system that our best legal minds think that these are the important legal issues of the day, worthy of comment, discussion, and analysis? This is worse than the tail wagging the dog, it’s the meme wagging the cat wagging the tail that is wagging paid, professional law professors on whose skills, education, and dedication real life actually depends.

    Of course the courts have to respond to any suit brought before them, but the blogging community doesn’t need to make matters worse by treating everything as of equal importance. It’s not a matter of cancelling topics, it’s just making the choice to discuss things that truly matter. The VC blog doesn’t have to cover everything.

    Apologies in advance for ranting. But where does one have to go to find serious people talking about serious issues these days?

    1. Don’t come here Dave. Or at least skip over Kirkland.

  5. Apparently, the reason Democrats are upset about this is that they believe that their constituents are dumb enough to fall for it.

    1. They seem to agree with Mackey/Vaughn about that.

    2. There are dumb people in all voting categories.

      They also get to vote.

      1. If they are too stupid to not even understand HOW to vote, should they be voting? Where does personal responsibility for being an adult come into play here? Are we protecting these idiots for their entire adult lives now?

        1. Misleadable is not the same as not understanding a thing.

          1. Really? And where is the defining line?

            So if a person does not know HOW the voting process works and is misled from voting by a fucking meme on a twitter site that meme maker should go to jail for ten years?

            The twitter person has no responsibility in the civil process to exercise their civic responsibility by knowing how it is done? They are absolved of the responsibility of understanding because a meme on twitter told them so.

            Misleadable is not a real word for a reason.

            1. Fair enough.

              Gullible people get to vote.

      2. Of course they get to vote. By posting #Hillary to facebook or twitter.
        And their vote will be counted. Just by a different agency than my vote will be counted by.

  6. So is lying to poll watchers by telling then everyone is going home also a crime?
    Didn’t think so.

  7. I would have thought that no one was stupid enough to believe that they could vote by text. But then I looked at the news, and saw just how stupid many of my fellow citizens are. But there’s a bright side: anyone stupid enough to think he or she could vote by text was probably stupid enough to think he or she could also vote in person, so no actual votes would have been suppressed. No harm, no foul!

  8. There is a partisan slant to this because Hillary?

    Whatever your politics, your chances of seeing your candidate win a close election will depend in part on the votes of poorly-informed or partly-mentally-impaired (but like-minded!) political allies. Should the outcome of any such election depend on which side does the best job befuddling and then defrauding the vulnerable?

    The sneers are already in. Let’s hear the principled arguments to justify it.

    1. This was no doubt sleazy. But there is a big leap between sleazy and criminal.

      1. Usually there’s significant overlap.

    2. I am more concerned that there is selective prosecution involved, as well as the clear concern of parody and comedy being outlawed.

      On the first, I’ve heard people actually threaten to murder any Trump voters they find, but there has been no prosecution of any of them. Given some of the hateful attacks we’ve seen over the past 4 years, I don’t think all of these threats were mere hyperbole.

      On the second, you have this, a fairly obvious jest, being prosecuted as if it was a false polling station. Satire and Parody are clearly protected first amendment speech. Mocking stupid people is also one of the cores of comedy. This is the same issue as the prosecution of the Nazi pup in England, where an aspiring comedian videoed himself trying to convert his girlfriend’s dog into Nazism because it was too cute (his explicit reasoning). Somehow, this obvious mockery of evil people got him arrested, prosecuted, and convicted. This overzealous nonsense ends up hurting people who only wanted to make people laugh. That protects no one and hurts everyone.

      1. Ben,
        It was not funny. It was fraud aimed at stupid people.

        1. “It was fraud”

          No, it was a joke. As Joe says, its been around for decades. I’ve used it myself.

          1. Joke, schmoke. It is a fraud aimed at stupid people. Grow up.

            1. Once again: I discouraged stupid “patriots” (ego stroke) not to vote in GA because the election was “stolen by Chavista chi-com Raffensburger.”

              We all know how that turned out. Do I get an indictment?

              1. And if I may be clear, my intent was to discourage republicans from voting in the GA elections for senate.

              2. Well, encouraging people not to vote is not a crime. Tricking them into not voting might be.

                1. Granted, I didn’t use color of authority, but I did affect an inauthentic perspective based on (and echoing) assertions I knew to be false for a cynical purpose. So, partial credit?

            2. only a stupid person would think a joke equates to a fraud

        2. Please note: you do not find it funny. I find it in rather poor taste myself.
          However, it is clearly satire.

          This law was based around the idea of putting up a fake polling station to literally steal and discard votes or putting out believable billboards misstating polling places or times. Trying to apply it to a ridiculous premise like “you can vote by tweet” is absurd on its face. How ridiculous does it have to be in order to qualify? That’s for the courts to decide, but this clearly falls under the category of absurdist satire which is being prosecuted for political purposes.

          Yes, some people are stupid. There were those who honestly believed the Modest Proposal. That doesn’t mean Swift should have been arrested for promoting cannibalism.

          1. What you “say” in public” you are still accountable for. If there is any evidence that anyone responded then the credibility for some has been established. IF not, the prosecutor should walk away as the jury will not be convinced beyond a reasonable doubt.

          2. Further, those Irish babies are damn tasty!

      2. I have to agree. I don’t know if this was intended as comedy, but it clearly is indistinguishable from an attempt at comedy. Such a thing could easily have been seen on the Colbert Report or John Oliver.

      3. I’m not a lawyer, but presumably the prosecution is required to prove intent to defraud. The affidavit used to obtain an arrest warrant quotes the alleged conspirators discussing ways to make their communications more deceptive so intent seems pretty clear in this case.

        Your claim that the conspirators made “a fairly obvious jest,” combined with a reference to a British prosecution under a law that did not require proof of intent to defraud, is either an assertion that the prosecution cannot prove intent or that no proof of intent is required under American law. If it’s the latter, there are people better qualified than me to discuss the law who might chime in if you clarify that that’s the proposition you are arguing.

    3. A variation of this same message has been going around in every election since at least the late 1970’s.
      “The voting day for candidate A is tuesday, the voting day for candidate B is Wednesday” or some similar variation. only change is voting by text instead of instructions to vote on wrong day.

      both sides have been doing it, for at least 50 years

      So if there is a partisan slant – it is because it was aimed at Hillary voters.

  9. This has to fall into the; “You can’t fix stupid” file. I bet anyone that did this, had just put their check in the mail to that Billionaire Nigerian Prince.

    1. And yet Nigerian fraud is still a crime.

      (I once tried to report one case to the FBI. They had a form about various frauds, including one box labelled “Nigerian Fraud.” I sent in the form and never heard from them.)

      1. I sent in the form and never heard from them.

        Of course not, that’s not their style. I do hope you are smart enough to avoid the new guy in the coffee shop trying to be your friend and who is trying to convince you to commit those crimes ….

        1. I just avoid coffee shops!

      2. But at least Nigerian Prince fraud actually has the elements of fraud: an attempt to obtain something of value by deceit.

        They didn’t charge fraud in this case because the facts don’t supply the elements to charge fraud. The facts don’t supply the elements of voter intimidation either, but they probably thought they had a better chance because fraud case law has a much more extensive record defining a thing of value, and a vote is not a thing of value under that definition.

  10. Dr., would you expect that this case will make it to the Constitutional questions point, or is it more likely that the prosecution will quietly drop it?

  11. Eh voter fraud doesn’t happen. That is what Big Tech and media has told me. So I can’t believe anyone would have even thought that this was real.

    1. Jimmy, the quantities zero and less than 0.01% are so improbable that any such claims should be ignored. In the general election ~300.000 mail in ballots were disqualified in CA. That is 0.1% of the vote. In the primary 500,000 mail in ballots were disqualified.
      As with any other measurement, vote counts as a measure of the public will are subject to errors.
      If one loses by less than 0.1%, in law you lose, but in fact you many have been prefered by more voters than your opponent. Live with it.

      1. Did you bother to read what I wrote. Obviously election fraud does not happen AND even if it does then it does NOT matter at all. So I don’t know why the government is the least bit concerned about a guy who tweeted a very obvious fake way to vote. Why is this even a criminal case if any fraud is so inconsequential to the system that it is immaterial? Seems like we ought to be prosecuting white supremacists somewhere or people or take pictures with podiums.

        1. Of course I read what you wrote. Did you read what I wrote.
          In your text, your tongue is so deep in your cheek as to poke a hole through.

          1. Can you prove that the comment impacted the election?

            Isn’t that the only apparent crime involved with fraud?

        2. There’s a simpson’s meme that can explain the apparent discrepancy. Chief Wiggam tells the other two cops with names (unremembered) to cuff Marge and she protests. “But I thought you said the law was powerless!” “To help you,” the chief rejoins, “I said the law is powerless to help you, not *punish* you.”

    2. If you’ve paid any attention at all, you’d know that at least 10-20 voter-fraudsters DID attempt to do vote fraud in the 2020 election. We know because they got caught because it’s damn hard to get away with. They also mostly all voted for Scrump.

      1. Those stories didn’t make sense because Big Tech and the media all said election fraud did not happen. I’m sure it was just an old person confused on how to properly vote. I’m sure the local election board was able to sort it and out replaced their ballot with a real one.

        1. Right? Except that I read all those stories in mainstream press outlets. And in interviews with law enforcement they pretty much all admitted to frauding. Maybe your source for the MSM claiming there was no fraud is in error? Or, perhaps there were conditional statements that mitigated that claim, like: “there was no widespread, unchecked fraud in the 2020 election that would have swayed the results thereof?”
          Because it seems like people who know agree that’s true.

  12. “Can election lies simply be outlawed?”

    Surely, Professor, you understand that there are different kinds of lies. “Politicians lie” is a common trope, but typically that is about policy matters. “I have enacted a Muslim ban” is a political lie. “Mexico will pay for the wall” is a political lie. It is for the voters to decide whether to believe or not.

    This defendant lied about the mechanics of voting, in an (alleged) attempt to have voters waste their vote. That is a very different kind of lie. Much harder to say that the First Amendment protects that.

    (I am dubious whether this prosecution can be fit into the language of the statute. It is certainly a creative approach, which is frowned upon in criminal cases. I would expect a motion to dismiss at some point.)

    1. This seems right. Pretty sleazy, but not covered by the statute as quoted, IMO.

    2. The defendant should have lied about sex instead. Obviously, that can’t be punished.

    3. Fortunately, all those voters were probably in our of those areas that had 100% voter turnout so ultimately someone made certain they not only voted in a proper manner but that their vote was actually counted!

  13. Tablet?

    Newsweek and Gateway Pundit wouldn’t take it?

    1. Be nice, Arthur. 🙂

      1. That’s hilarious.

        1. This one may not be hilarious, but it is at least a chuckler.

          (Next, check the IUP marching band version.)

  14. Doesn’t there come a point where a lie becomes so stupidly implausible that it’s protected as parody?

    1. That’s the obvious defense. It was an attempt at humor. No one could reasonably believe this was true, so no disclaimer or explicit punchline was necessary.

      1. No on could believe? I guess that you have no idea of how many stupid people that there are.

        1. It doesn’t have to be impossible for the mentally impaired to believe, it should be sufficient that any person of ordinary intelligence would recognize it as a joke.

          1. Well, you’re wrong about your estimate. But that statement is empirically verifiable.

          2. The “average, ordinary, reasonable person standard” needle has moved quite a bit in the past couple of decades.

            1. In the wrong direction, that is.

    2. There was a theorist who noted that there is a point at which, the lie, no matter how implausible, actually becomes true through repetition. What was his name? Begins with a “G,” Deutch fellow…
      Not “Gobbles” that’s a turkey…

    3. You’ve identified a common Trump defense, actually used by Fox News to defend Tucker Carlson.

  15. My crime was better, and more than canceled out the effects of his crime. It reflects to the everlasting credit of Trump’s Justice Department that they forbore to prosecute me.

  16. Understanding the Supreme Court hasn’t resolved the specific issue, I don’t see why prosecution in this case would raise a First Amendment problem. The defendant is accused, not of advocating general false propositions, but of inducing people to engage in specific conduct in a deceitful way.

    I don’t see why inducing people to hand over their vote under false pretenses about the mechanics is different from inducing them to hand over their money.

    I see the situation as very different from, say, a politician who makes a false campaign promose.

    1. Indeed, the ad is fraudulent on its face and is election tampering.

  17. I bet I’d we changed the date to today and published this meme, people would vote for Hillary on Twitter.

    Sadly, the court won’t take on the even bigger question – should anyone dumb enough to think they can vote for president on Twitter because of this meme be able to choose the leader of the free world?

  18. This kind of fraudulent nonsense would be eliminated by required in-person voting except by signed request each time for a mail-in absentee ballot to be received on or before the close of polls on election day.

    1. Stop.Making.Sense. 🙂

    2. How? Presumably anyone who was taken in by this was taken in because they didn’t know what the actual rules were: I’m not sure why changing the rules would make much difference.

  19. “inducing people to hand over their vote under false pretenses… say, a politician who makes a false campaign prom[i]se.”

  20. On the parody issue, some here seem to think that it is required that the parody be so obvious that no one with an IQ above 75 would be fooled.

    I don’t think that is correct. To use an analogy from trademark law, generally a plaintiff has to show the defendant’s use will likely cause confusion or deceit. But in cases where a mark is used in an artistic or creative way, the courts have required a heightened showing due to First Amendment concerns.

    The leading case is Rogers v. Grimaldi, 875 F.2d 994 (2d Cir. 1989), which has been followed by many courts around the country, particularly the Ninth Circuit.

    Because overextension of Lanham Act restrictions in the area of titles might intrude on First Amendment values, we must construe the Act narrowly to avoid such a conflict. . . .

    We believe that in general the {lanham] Act should be construed to apply to artistic works only where the public interest in avoiding consumer confusion outweighs the public interest in free expression. In the context of allegedly misleading titles using a celebrity’s name, that balance will normally not support application of the Act unless the title has no artistic relevance to the underlying work whatsoever, or, if it has some artistic relevance, unless the title explicitly misleads as to the source or the content of the work.
    . . .
    This construction of the Lanham Act accommodates consumer and artistic interests. It insulates from restriction titles with at least minimal artistic relevance that are ambiguous or only implicitly misleading but leaves vulnerable to claims of deception titles that are explicitly misleading as to source or content, or that have no artistic relevance at all

    I do not know if this has ever been applied in a criminal case. But don’t see why it would not be.

    If the defendant here asserted he was engaged in parody or satire (perhaps mocking the stupidity of some voters), I think that there is room to say that even though some might be mislead, the First Amendment requires that such be tolerated.

    I would at least explore this argument were I this defendant’s lawyer.

  21. It seems people didn’t read Volokh’s full article. I found it to persuasively address most of the posts.

    1. Sadly, this is true of pretty much all the OPs and their articles. Cited to or referred to, but rarely read by us, the great unwashed masses.

  22. In PA, your ballot will be rejected if there is any identifying mark on the secrecy envelope. Would it be acceptable if a political campaign sent out fake “voter guides” to their opponents likely voters instructing them to sign the secrecy envelope and thus invalidating their ballots?

    1. …well, outside of 2020, sure. In 2020? Nah.

  23. The answer to all your questions is no.

    The fact that its even a point of debate is ridiculous.

  24. Can the government punish election workers who kick out election observers, refuse them entry, force them to stand too far away for meaningful observance, deceive election observers in saying counting is finished and then count ballots in their absence, cover up windows with cardboard to prevent observing, etc ?

    1. And if so – why don’t they?

    2. I know this one: courts in PA found that there’s NO LAW specifically requiring the presence of election observers, regardless of whether they stand 6 or 10 feet away. That 6 feet versus 10 feet question was also THE ONLY CASE in which the pro-Scrump “elite strike force” achieved a favorable ruling.

      1. That 6 feet versus 10 feet question was also THE ONLY CASE in which the pro-Scrump “elite strike force” achieved a favorable ruling.

        Actually, they only briefly did. The trial court ruled against them, the appellate court ruled in their favor, but then SCOPA ruled against them.

        But your summary is incorrect; PA law does require the presence of observers. Trump lost on the distance issue, not the presence issue.

        The one case where Trump’s legal team actually prevailed wasn’t that, but was about extending PA’s deadline for curing ID issues for late-arriving ballots. Here’s an article that described the issue:

        Those ballots were segregated and never tallied, and could not affect the results because their number was much smaller than the margin of victory.

    3. Can the government punished Internet commenters who repeat long-debunked lies about what happened?

      1. I’m going to say no, 1A generally protects that. A private entity, however, can pursue such person for defamation provided it can demonstrate malicious or negligent disregard for the truth and some specific harm from the published falsehood.

      2. Care to explain? I’m not sure if anyone was “kicked out” but reports seem to be that the rest of these things have indeed happened.

        Of course, these were isolated instances, with no indication it had an effect on votes or results — just like the OP.

        1. Well, for instance, the cardboarded up windows thing. It was not to keep people from seeing what was happening in the room. All observers of both parties — more than 100 — were already in the room. The windows were covered to keep people outside the room, who were not entitled to be there, from filming the ballots.

  25. It’s obviously satire, which is protected expression.

    Also, anyone dumb enough to fall for that clearly failed high school civics/government/whatever they’re calling it these days.

    1. Even if it is not “obviously” satire, if there is a reasonable doubt on that question, the jury has to acquit him. Given that a lot of people here think it is satire, it would seem there is at least reasonable doubt.

      1. That assumes that people here are raising the satire defense in good faith.

  26. DIsclaimer, I’m not a lawyer nor do I ply one on TV.

    My understanding of the statute is that successful prosecution requires a clear identification of the predicate right at issue and establishing the mens rea of the party attempting to infringe that right.

    The right to vote seems pretty clear cut for the first part, so I’d expect the case to turn on the intent. Like most of us here, it looks more like a dumb joke than an actual attempt to prevent voting, so I’m skeptical it rises to that bar. However, if the prosecution has some evidence that this was intended to deny people’s vote in actuality, I could see a successful prosecution.

    It would certainly be even dumber as a voter suppression attempt than as a dumb meme, but there is no idiot defense that I’m aware of.

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