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<p>Not trying to impose anything but trying to explain why this is
something fundamentally wrong and why IP Leasing is not a valid
justification for a resourse holder to keep their IP space. Me and
other people already explained why IP Leasing is wrong but it
seems you don't wish to accept it. Bottom line is that if that is
the staff understanding there is nothing you or other members that
have interest in leasing can do other than try to adjust the rules
using the current rules to allow that which would be something
really difficult to happen.<br>
</p>
<p>It is interesting that some same people who engaged in the last
tentative of Transfer Policy Discussion that would allow legacy
resource holders to retain their legacy status are now defending
that IP Leasing it something normal and acceptable. What a
coincidence !<br>
</p>
<p>Regards<br>
Fernando<br>
</p>
<div class="moz-cite-prefix">On 03/07/2021 01:22, Ibeanusi Elvis
wrote:<br>
</div>
<blockquote type="cite"
cite="mid:CANanHiyLPUG1PV1bE=xMXGDL-FPDxC5WRCQife_fMXNDROAmkw@mail.gmail.com">
<meta http-equiv="content-type" content="text/html; charset=UTF-8">
<div>
<div dir="auto">Hello Fernando</div>
<div dir="auto"><br>
</div>
<div dir="auto">I don’t think you’re addressing my questions,
rather, you have your set of belief (and we do have our way of
thinking, which is fine, but we shouldn’t try to impose our
thoughts on others when your say is a “point of view” rather
than “a fact”) that IP leasing is wrong while overlooking that
the fact that there is never a body that prohibits it. I mean,
the CPM doesn’t - the law doesn’t - never really does except
some sort of people simply “do not agree” because they think
its “wrong”. </div>
<div dir="auto"><br>
</div>
<div dir="auto">The CPM doesn’t - </div>
<div dir="auto">“If you don't see in the CPM and with the
different explanations that have been given here in the
discussion I am sorry you failed to understand (maybe because
you or other do not wish to understand it). Perhaps you are
expecting some specific set of words in the CPM that are not
there, but the important part is staff to interpret that IP
Leasing means the current resource holder is using the
addresses in a different way from what they have been
justified initially and resources may be subject to
revocation. “ - if the CPM really does, then it shouldn’t be
an “interpretation” or “explanation” but rather a clear and
precise definition that “IP leasing” is not allowed. In fact
what is the actual case is that the CPM, when it’s written,
never take into account the situation of IP leasing. It’s just
like people are trying to use Victorian laws to interpret
modern matters, when the Victorians don’t even have that thing
in mind. If I follow your logic, that we keep “interpretating”
the CPM, then I’m sure 100 people will have 100 ways of
interpretation. What is at stake here is that we don’t try to
label opinions as facts.</div>
<div dir="auto"><br>
</div>
<div dir="auto">Additionally, it’s been quite obvious that <span
style="border-color:rgb(0,0,0)">a number of “senior”
community members have the tendency to think what they say
is right, but that’s really not the case. The purpose of
this community is to give people the ability to express
their various opinions and not to dictate or impose their
opinions as “right” on others. </span></div>
<div dir="auto"><span style="border-color:rgb(0,0,0)"><br>
</span></div>
<div dir="auto"><span style="border-color:rgb(0,0,0)">Elvis </span></div>
</div>
<div><br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Sat, Jul 3, 2021 at 7:30
Fernando Frediani <<a href="mailto:fhfrediani@gmail.com"
moz-do-not-send="true">fhfrediani@gmail.com</a>> wrote:<br>
</div>
<blockquote class="gmail_quote" style="margin:0px 0px 0px
0.8ex;border-left-width:1px;border-left-style:solid;padding-left:1ex;border-left-color:rgb(204,204,204)">
<div>
<p>Some people seem to try to justify that IP Leasing as
something normal "because they need or depend on that"
or "because it earns money leasing addresses to other
organizations" or "because it is a functional way to
bypass the current exhaustion phases of some RIRs". None
of that is a justification for something that keeps
being wrong. It is not because it works well for some
that it has to be something acceptable by the current
rules. Depending on IP Leasing does not make it right or
acceptable in terms of justification.</p>
<p>If you don't see in the CPM and with the different
explanations that have been given here in the discussion
I am sorry you failed to understand (maybe because you
or other do not wish to understand it). Perhaps you are
expecting some specific set of words in the CPM that are
not there, but the important part is staff to interpret
that IP Leasing means the current resource holder is
using the addresses in a different way from what they
have been justified initially and resources may be
subject to revocation. Can you justify resources saying
you need them because you intend to lease them ? No you
can't.</p>
</div>
<div>
<p><br>
</p>
<p>Fernando<br>
</p>
<div>On 02/07/2021 18:49, Ibeanusi Elvis wrote:<br>
</div>
<blockquote type="cite">
<div dir="auto">Hello Fernando, </div>
<div dir="auto"><br>
</div>
<div dir="auto">In your previous email, you outlined
“relying on the WRONG OPTION”. Again, like you’ve been
asked, what are you criteria or justification for what
constitutes a “wrong option”. Also, I don’t see where
the CPM prohibits IP Leasing and based on what you
said earlier, what about the consequences of the end
user losing connectivity?. </div>
<div dir="auto"><br>
</div>
<div dir="auto">Elvis. </div>
<div><br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Sat, Jul 3,
2021 at 5:28 Fernando Frediani <<a
href="mailto:fhfrediani@gmail.com"
target="_blank" moz-do-not-send="true">fhfrediani@gmail.com</a>>
wrote:<br>
</div>
<blockquote class="gmail_quote" style="margin:0px
0px 0px
0.8ex;border-left-width:1px;border-left-style:solid;padding-left:1ex;border-left-color:rgb(204,204,204)">
<div>
<p>Perhaps you may not be used with the way
numbering resources are allocated and must be
used. This is not a simple internal network
usage thing that any company can decide at
will.<br>
Anyone holding these resources MUST use them
in according to the current rules and MUST
justify and *keep justifying that usage*
permanently in order to be able to keep
holding those resources - which by the way is
not something the belongs to the organization.</p>
<p>Bizarre is to get resources form the RIR, not
use them for what they have been justified
originally and bypass that justification
giving them to allow someone to bypass the
current rules of a RIR.<br>
If any organization is holding resources which
it doesn't justify anymore it either gives it
back to AfriNic or transfer to another
organization who have usage and justify for
that.<br>
IP Leasing is a clear way to show the RIR and
Community that resource holder doesn't justify
to keep that IP space to anymore.</p>
</div>
<div>
<p><br>
</p>
<p>Fernando<br>
</p>
<div>On 02/07/2021 15:45, Mimi dy wrote:<br>
</div>
<blockquote type="cite">
<div dir="ltr">Hi Fernando,<span> </span><br>
<br>
I am wondering what basis do you use to
define “a wrong option”? And who gave you,
or me or the community the right to
determine how networks are used? Does the
CPM entitle us the right to tell a certain
company; “you have the option to use Inter
RIR transfer policy”? I may have missed
that, but please point out to me where the
CPM gives us the right to intervene with
others and their networks just because we do
not like it.<br>
<div>That is just bizarre. </div>
<div><br>
</div>
<div>Best,</div>
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">Le ven. 2
juil. 2021 à 18:39, Fernando Frediani <<a
href="mailto:fhfrediani@gmail.com"
target="_blank" moz-do-not-send="true">fhfrediani@gmail.com</a>>
a écrit :<br>
</div>
<blockquote class="gmail_quote"
style="margin:0px 0px 0px
0.8ex;border-left-width:1px;border-left-style:solid;padding-left:1ex;border-left-color:rgb(204,204,204)">
<div>
<p>So they are relying on a wrong option
which should never have relied. <br>
If they have needs for IPv4 (as
everybody else) and they cannot get
these addresses directly from the RIR
as per the current rules which apply
equally to everybody they have the
option to use Inter-RIR transfer
policy available on all other RIRs.<br>
<br>
If these organizations are from
outside Africa region then it is even
worst they grab unused addressed that
were assigned to a local company to
use somewhere else out of the region.</p>
<p>Not everything that is useful or
convenient to some is correct and as
such should e stimulated and IP
leasing mean the current holder
doesn't justify for those addresses
anymore, so either it gives it back to
AfriNic or transfer them definitely.</p>
<p>Regards<br>
Fernando<br>
</p>
<div>On 02/07/2021 14:29, Mimi dy wrote:<br>
</div>
<blockquote type="cite">
<div dir="ltr">
<div dir="ltr">Hello Fernando, </div>
<div dir="ltr"><br>
</div>
<div dir="ltr">
<div>Many organizations rely on IP
Leasing in order to acquire
number resources quickly and
affordably to meet their current
and future needs. It is totally
legit, especially during the
IPv4 exhaustion phase, where
resource scarcity represents a
real issue for ISPs and
network-holders in AFRINIC's
service area.</div>
<div>I find it absurd that you are
arguing against IP leasing when
it is a legal and accurate way
to obtain IPs. Indeed, there are
some malicious organizations out
there misusing leased IPs, but
that is certainly not the case
for everyone, so no need to
generalize. Consequently, you
cannot really dismiss IP leasing
using weak arguments as such. </div>
<div><br>
</div>
<div>Since IP leasing is very
helpful to numerous entities in
the period of shortage of
available IP addresses, and is
certainly legal, I fail to
understand why you are
advocating against it. </div>
<div><br>
</div>
<div><br>
</div>
<div>Best,</div>
<div><span
style="font-size:16px;font-family:Gotham,Arial,Helvetica,sans-serif;color:rgb(0,0,0)"></span></div>
<div><span
style="font-size:16px;font-family:Gotham,Arial,Helvetica,sans-serif;color:rgb(0,0,0)"><br>
</span></div>
<div><br>
</div>
<div><span
style="font-size:16px;font-family:Gotham,Arial,Helvetica,sans-serif;color:rgb(0,0,0)"><br>
</span></div>
<div><span
style="font-size:16px;font-family:Gotham,Arial,Helvetica,sans-serif;color:rgb(0,0,0)"><br>
</span></div>
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">Le ven.
2 juil. 2021 à 16:48, Fernando
Frediani <<a
href="mailto:fhfrediani@gmail.com"
target="_blank"
moz-do-not-send="true">fhfrediani@gmail.com</a>>
a écrit :<br>
</div>
<blockquote class="gmail_quote"
style="margin:0px 0px 0px
0.8ex;border-left-width:1px;border-left-style:solid;padding-left:1ex;border-left-color:rgb(204,204,204)">Well,
like it or not but having a
customer that is in the leasing
<br>
business may effectively change
our opinion about some subject,
even if <br>
personally you wish it may not
to.<br>
<br>
Trying to find an exact 'ipsis
literis' word in the CPM that
fulfill or <br>
not your expectations may not
always work. There is always
room for some <br>
interpretation and staff is the
one responsible to do that in
this context.<br>
For the absurd leasing
possibility is very simple: if
leasing proposes <br>
cannot be used as a
justification to receive a new
block from the RIR <br>
why would it be after you
receive it and missuse it for
different <br>
proposes other than bring
connectivity to your customers.
In that sense <br>
I really hope staff stand strong
in revoking resources that are
being <br>
used for leasing proposes,
different from what they have
been justified <br>
originally and if necessary
fight in courts of Mauritius to
have that <br>
decision preserved.<br>
<br>
For out of the region usage
there have been multiple people
who showed <br>
that is not currently permitted.
Maybe you don't agree with that
but <br>
bottom line is that is what
staff has been interpreting from
the current <br>
rules backed by what some of us
have put here based in previous
messages.<br>
<br>
Want to use AfriNic resources in
a different region ? Simply
transfer <br>
them permanently using the
soon-to-come Inter-RIR transfer
policy and <br>
bound to the rules of the new
RIR.<br>
<br>
Regards<br>
Fernando<br>
<br>
On 02/07/2021 04:46, Owen DeLong
via RPD wrote:<br>
> Full disclosure: I don’t
personally have a dog in this
fight. I am personally<br>
> agnostic as to whether
leasing should or should not be
permitted in a<br>
> newly developed policy.<br>
><br>
> I do have a client that I
consult for which is in the
leasing business. It is my<br>
> opinion that their leasing
business is 100% compliant with
policy as it is<br>
> written and that if the
community doesn’t like that
fact, the community can<br>
> and should certainly amend
the policy to rectify the
situation.<br>
><br>
>> On Jun 29, 2021, at
03:08 , Frank Habicht <<a
href="mailto:geier@geier.ne.tz"
target="_blank"
moz-do-not-send="true">geier@geier.ne.tz</a>>
wrote:<br>
>><br>
>> Hi,<br>
>><br>
>> On 29/06/2021 12:01,
Owen DeLong via RPD wrote:<br>
>>> nectivity customers
or use out of the region as
something "normal and<br>
>>> acceptable".<br>
>>><br>
>>> Regardless of who
does and does not benefit, the
reality is that short<br>
>>> of an actual
government with the ability to
enforce its rules using<br>
>>> guns and prisons,
people who can make a profit are
going to do what<br>
>>> they are going to
do.<br>
>> I need to break this
down.<br>
>> I'm working in my
$dayjob for one of those
companies that are after<br>
>> $profit. What this
company _did_ is subscribe to
the methods and rules<br>
>> of a Mauritius company
called AfriNIC, in order to get
Internet<br>
>> Numbering Resources.
And I think many of the AfriNIC
members formally<br>
>> subscribed to these
rules. (And the rules are
subject to change<br>
>> according to PDP)<br>
>><br>
>> These INR are provided
to members per need and
justification. Relatively<br>
>> recently additional
rules came into force that
limited each allocation<br>
>> to maximum /22 - this
is how rules can change.<br>
>><br>
>> INR are delegated to
members that need them
themselves, and AfriNIC<br>
>> calls these members
"End-User" members. They are
also delegated to<br>
>> members that provide
internet access to respective
customers, and<br>
>> AfriNIC calls these
members "LIR" members.<br>
> You are close, but the term
used in the bylaws is “open
system protocol<br>
> network services”. I am not
sure why such awkward and broad
language<br>
> was chosen, but that’s a
much broader definition than
“internet access”.<br>
><br>
> In the CPM, LIR is defined
as “An IR that receives
allocations from an RIR and
primarily<br>
> assigns address space to
'end-users’. LIRs are generally
ISPs. Their customers are other<br>
> ISPs and possibly
end-users. LIRs must be members
of AFRINIC.”<br>
><br>
> Again, there’s not a single
word in that definition that
ties it to connectivity<br>
> services or internet
access.<br>
><br>
>> I believe in all
justifications for IPv4, LIR
members request/require<br>
>> the addresses to
address customers, or servers,
or VMs that get<br>
>> connectivity services
from the LIR member. And there
is no problem with<br>
>> that. LIR is in the
business of making profit,
providing connectivity,<br>
>> hosting servers,
services, needs IPs, gets IPs.<br>
> Certainly this is the
prevalent model, whether or not
it is 100% pervasive<br>
> I am not sure.<br>
><br>
>> There is a big
difference to the case where an
LIR member<br>
>> - has IPv4 address
space,<br>
>> - is not using it
themselves,<br>
>> - not for connectivity
(or hosting) customers<br>
>> and has the IPv4 space
used by "customers" that are
only getting the<br>
>> IPv4 space as a service
- sold or leased.<br>
> Is there? So long as the
customers in question are
justifying the space to the<br>
> same standards that an
end-user applying to the RIR
would have to or to the<br>
> same standard that would be
required if they were also
getting connectivity<br>
> from the LIR, then what
exactly is the difference?<br>
><br>
> What if the LIR in question
did announce the covering
aggregates of space<br>
> they leased and provided
some minimal connectivity to the
customer in question?<br>
> Now they meet the
definition you’ve provided
above, but they’re not actually<br>
> moving packets because the
more-specific being announced to
the customer’s<br>
> higher bandwidth providers
will win vs. the aggregate.<br>
><br>
> Does removing this
connectivity fig leaf really
change the nature of the<br>
> assignment in a meaningful
way?<br>
><br>
>> Is that the purpose for
which the IPv4 space was
obtained and justified?<br>
> Since I don’t have access
to anyone’s IPv4 justifications
to AFRINIC in a<br>
> manner which would allow me
to comment publicly, I’m going
to skip this<br>
> question. Suffice it to
say, I can imagine a number of
ways in which this<br>
> is possible.<br>
><br>
>> There are "rules" that
say an LIR should notify when
use of an IP block<br>
>> changes.<br>
> Yes. The rules are,
however, ambiguous at best and
it’s not clear at what<br>
> level of detail a “change”
is constituted nor is it clear
whether an update<br>
> to whois is adequate
notification in most
circumstances.<br>
><br>
>> I see a big difference
between changes *within an LIR*
and changes to<br>
>> *use the IP space
outside the AfriNIC member LIR*.<br>
> So if I have space that was
allocated to my LIR and I
assigned it to<br>
> customer A who is using the
space in their network
(technically outside<br>
> of my LIR), but then they
return the space when they get
their own<br>
> block and become a BYOA
customer, my assigning that
space to customer<br>
> B for their use on their
network (also outside my LIR)
becomes a problem<br>
> or change in the usage
exactly why?<br>
><br>
>> With the first, I
consider it generally accepted
that justification remains.<br>
>> With the latter, I
believe that the *LIR that
subscribed to AfriNIC<br>
>> rules* has shown to no
longer have the justification
for these IPs for<br>
>> connectivity and
hosting, including "PA"
customers.<br>
> What if the justification
in question was not
“connectivity and hosting”?<br>
><br>
> What if the justification
was “Numbering hosts on customer
networks”?<br>
><br>
>> The reason for doing
the latter is obviously $profit,
and yes - some "<br>
>> are going to do what
they are going to do ".<br>
> The reason for the former
was obviously profit, too.
Nobody is in business<br>
> to subsidize the benefits
of others without making a
profit.<br>
><br>
>> And what this community
allows them to get away with.<br>
> It’s not so much a question
of “get away with” as “what the
rules actually<br>
> say” from my perspective.
You may wish to argue that the
intent or even<br>
> the clear intent of the
community is something else, but
in reality, for rules to be<br>
> useful, one must consider
what the rules actually say, and
not the current<br>
> popular interpretation of
intent around the rules.<br>
><br>
> Making it up as we go along
has become somewhat of an
AFRINIC tradition<br>
> at this point, seemingly
both in the staff actions and in
the board, PDWG,<br>
> community, and various
committees.<br>
><br>
> There’s also a pretty
strong history of doing so being
the source of a great<br>
> many problems, so I
continue to hope that we can
learn from those mistakes<br>
> and start actually
following the rules as they are
written and making the<br>
> changes necessary through
the proper processes when the
rules do not<br>
> meet the perceived needs of
the current situation.<br>
><br>
>> To be Frank: I simply
don't believe that<br>
>> AS212552
"BitCommand" in Armenia gets IP
connectivity services from<br>
>> ... you know who.<br>
> Honestly, I don’t know who,
but it’s easy enough to look up:<br>
><br>
> <a
href="https://bgp.he.net/AS212552#_irr"
rel="noreferrer"
target="_blank"
moz-do-not-send="true">https://bgp.he.net/AS212552#_irr</a><br>
><br>
> Says that they get apparent
transit from AS64515 and
AS24940.<br>
><br>
> This seems to be borne out
by <a
href="https://bgp.he.net/AS212552#_graph4"
rel="noreferrer"
target="_blank"
moz-do-not-send="true">https://bgp.he.net/AS212552#_graph4</a><br>
><br>
>> In other continents /
RIRs the IPv4 space is finished.
Noone has any<br>
>> hope of justifying any
with the RIR. Some have more
than they need -<br>
>> give or sell it to
others that have "a need" and
the market can probably<br>
>> regulate that.<br>
> ARIN is still issuing /24s
under NRPM section 4.10, so
that’s not entirely<br>
> correct.<br>
><br>
>> But AfriNIC still has
and is distributing IPv4 -
should it do so by<br>
>> "whoever pays most" or
"everyone according to their
need [upto a /22<br>
>> ;-)]". Has it given
IPv4 resources to members
according to their<br>
>> respective (perceived)
needs???<br>
>><br>
>> Wasn't one of the rules
that the LIR was to use the IPs
for the<br>
>> connectivity (or
hosting) services?<br>
> I’ve reviewed the bylaws,
the RSA, and the CPM pretty
carefully. I couldn’t<br>
> find a connectivity
requirement other than one that
calls for the numbers<br>
> to be “routed on the
internet” (which, btw, is a
unique requirement in<br>
> AFRINIC not present in
other RIRs).<br>
><br>
>> Are the rules still
applicable?<br>
> The rules still apply as
written, but that’s the real
sticking point. Do we<br>
> want to focus on the common
perception of what we think the
rules<br>
> say (as you have done
above) or do we want to review
the rules as<br>
> they are written and call
for the enforcement of those
rules according<br>
> to a plain text
interpretation of their actual
content?<br>
><br>
>> bit more below...<br>
>><br>
>>> I’m not
particularly happy about this
reality, but I do recognize that<br>
>>> it is, in fact,
reality and I’m not in favor of
giving RIRs guns or<br>
>>> the ability to
incarcerate people. Contracts
only get you so far and<br>
>>> clever people can
always find ways to comply with
the letter of a<br>
>>> contract while
circumventing the other party's
intent if they want to<br>
>>> try hard enough.<br>
>>><br>
>>> So no, these are
not “nice words”, they are the
recognition of<br>
>>> unpleasant and
inconvenient truths that like it
or not, we are faced<br>
>>> with new realities,
economic, technical, and legal.<br>
>> Is one of these
realities that an LIR got
resources from AfriNIC for<br>
>> providing connectivity
(or hosting) services, and now
these are no<br>
>> longer in place?<br>
> I have no knowledge of such
a situation, but in truth I have
not read<br>
> the original justification
for the space issued to the LIR
I think you<br>
> are referring to.<br>
><br>
>>> In many countries
legal frameworks the lack of a
transfer policy<br>
>>> allowing
registrants to monetize the
transfer of their registrations<br>
>>> could be considered
either restraint of trade or an<br>
>>>
anti-trust/anti-competitive
matter.<br>
>> the fact is that these
numbers should be unique and
centrally managed.<br>
>> These anti-trust
lawyers can send a better
proposal for managing them.<br>
> The ability to sell one’s
registration to another does not
in any way impinge<br>
> the central management of
numbers for uniqueness.<br>
><br>
>> The question is whether
"according to need" or
"according to whoever<br>
>> offers more $$".<br>
> This assumes that monetized
transfers and/or leasing cannot
be done<br>
> on the basis of need, which
is a false premise. To the best
of my knowledge,<br>
> Larus is quite scrupulous
and detailed in collecting need
justification from<br>
> customers prior to issuing
addresses to them. That is
certainly the written<br>
> company policy and has been
the case with each and every
recipient<br>
> case I have been involved
with in my consulting for them.<br>
><br>
>> Should I be allowed to
"buy" a /16 from AfriNIC, put it
in a safe, sell<br>
>> it 3 years later for
$profit ???<br>
> No. The rules prohibit you
putting it in a safe and not
routing it. Also, you<br>
> aren’t buying the /16, you
are paying a fee for the service
of recording and<br>
> maintaining the
registration of the space. You
can’t sell the integers, but<br>
> selling the registration of
the integers has become common
practice<br>
> worldwide whether you like
it or not.<br>
><br>
>> Is that the purpose for
which AfriNIC got the /8's from
IANA?<br>
> Things have changed since
the IANA was issuing /8s. The
world has changed.<br>
> Many of the /8s were issued
by the IANA in order to support
Email, FTP, and<br>
> NNTP. I suspect there are
very few servers running FTP or
NNTP these days,<br>
> and while EMAIL is still a
pervasive technology (for better
or worse), it is not<br>
> a significant fraction of
internet traffic.<br>
><br>
> Very few of the /8s issued
by IANA were issued during a
time when streaming<br>
> video could have been
considered as a purpose for
issuing them, yet today<br>
> it is probably the largest
consumer of bandwidth on the
internet by far.<br>
><br>
> Should we require all of
the RIRs that have issued space
to Netflix after<br>
> IANA runout to reclaim and
return that space to IANA and
rejustify it because<br>
> streaming video was not the
purpose for which it was issued?<br>
><br>
> I think not.<br>
><br>
>> PS: all or most
questions are serious. answers
will help.<br>
> All of the answers were
serious as well. I’d expect
nothing less from<br>
> someone of your stature in
the community.<br>
><br>
> I hope the answers are
helpful.<br>
><br>
> Owen<br>
><br>
><br>
>
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