Mutual Recognition Agreement (MRA) International Workshop 2009 … · 2009-08-17 · Mutual Recognition Agreement (MRA) International Workshop 2009 Tokyo, Japan Overview of FCC Requirements
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Mutual Recognition Agreement (MRA) International Workshop
2009 Tokyo, Japan
Overview of FCC Requirements
March 4, 2009
George TannahillFCC Lab - Technical Research Branch
george.tannahill@fcc.govOffice of Engineering and TechnologyFederal Communications Commission
1
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Overview
FCC Overview
FCC Regulations
Equipment Approval Process
– General information
– TCB information
– MRA information
Post Grant Surveillance
TCB Implementation/Operations
Information Sources
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Federal Communications Commission
Federal Communications Commission (FCC) regulates the private sector telecommunications industry, in the public interest
– Establishes technical regulations for transmitters and other equipment to minimize their potential for causing interference to radio services.
– Administers an authorization program to ensure that equipment reaching the market complies with the technical requirements
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FCC Organizational Chart
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OET Lab Principle Functions
Equipment Authorization including monitoring Telecommunication Certification Bodies (TCBs)
Ensure compliance through market surveillance and enforcement
Technical Studies supporting regulatory policies and rulemaking
Providing web-based comprehensive and timely clarification of technical standards and procedures
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FCC Regulations
Title 47 of the Code of Federal Regulations (47 CFR)
Transmitter specifications
Radio Services
EMC specifications
Telephone Terminal Equipment
Test Methods
Equipment Authorization Requirement
Marketing and Importation Rules
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FCC Regulations Overview
Administrative Rules– Contain general requirements applicable to all other rule sections• 47 CFR Parts 0, 1 and 2
– Examples: application filing process, general description of required tests, confidentiality, etc.
Radio Service Rules– Contain specific user licensing and equipment authorization testing requirements• 47 CFR Part 15, 18, 22, 24, etc.
– Examples: Line conducted and radiated emission limits for specific products, occupied bandwidth masks, etc.
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FCC Administrative Regulations
47 CFR Part 0– 0.457 & 0.459 Confidentiality
47 CFR Part 1– 1.1307 & 1.1310 – RF Exposure
47 CFR Part 2– Subpart I – Marketing
– Subpart J – Equipment Authorization
• 2.201-2.202 – Emission designators
• 2.902-2.907 Authorization Types
• 2.929 – 2.926 – ID Labels
• 2.1033 – Application for Certification
• 2.1043 – Permissive Changes
• 2.1046 – 2.1057 – General tests for licensed devices
– Subpart K – Importation of Devices
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Equipment Authorization Regulations
Administrative• Part 0: Commission organization
• Part 1: Practice and procedure
• Part 2: General rules and regulations
License Exempt Operation• Part 15: Radio frequency devices
• Part 18: Industrial, Scientific, and Medical Equipment
• Part 68: Telephone Terminal Equipment
Licensed Operation• Part 11: Emergency Alert Systems (EAS)
• Part 20: Commercial Mobile Radio Services
• Part 22: Public mobile services
• Part 24: Personal communication services
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Equipment Authorization Regulations (continued)
Licensed Operation (continued)• Part 25: Satellite communications
• Part 27: Miscellaneous wireless communication service
• Part 73: Radio broadcast services
• Part 74: Experimental, Auxiliary & Special broadcast services
• Part 80: Maritime services
• Part 87: Aviation services
• Part 90: Private land mobile radio service
• Part 95: Personal radio service
• Part 97: Amateur radio services
• Part 101: Fixed microwave services
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Measurement Techniques
What Measurement Techniques Should Be Used?– A number of measurement techniques have been identified
and can be found in: • FCC Rules
– Radio Service Rules
– Part 2 General Rules & Regulations
– Industry Standards Incorporated by Reference
• Text of the Report and Order
• Public Notice Issued by the Commission
• Knowledge Database
• Industry Standards
– Measurement Procedures Website
• http://www.fcc.gov/oet/ea/eameasurements.htm
– OET Website for Equipment Authorization General Information: http://www.fcc.gov/oet/ea/Welcome.html
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Verification(Self-approval)
Certification(Approved by FCC
or TCB)
DoC(Self-approval usingan accredited lab)
Equipment Authorization Program
The type of approval is specified in the
rulesfor the particular
type of device SDoC (Part 68)(Self-approval
Database by ACTA)
Minimum
Maximum
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FCC Authorization Requirements
Verification SDoC DoC Certification Most ISM
Equipment Cable System
Term. Device
TV & FM Receivers
PC’s & Peripherals PC’s & Peripherals1
All Other Digital Devices
Most Receivers Most Receivers
Pt-to-Pt Microwave
TV Interface Devices
TV Interface Devices
Broadcast Transmitters
Consumer ISM Equipment
Consumer ISM Equipment
Aux. Broadcast Transmitters
Telephone Equipment
Telephone Equipment1
INMARSAT Equipment
Most transmitters
406 MHz ELT Scanning Receivers
CATV Relay Transmitters
(1) The FCC Lab no longer certifies this equipment. However, this equipment may be certified by a TCB.
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Equipment Authorization Top Ten Certification Equipment Classes
02468
101214161820
DTS DXX DSS PCE JBP DSC TNB NII PCB 8CC
Percent vs Equipment Class
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Equipment Authorization Classifications
Category Description Percent Rules
DTS Digital Transmission System 16.1 15C
DXX Part 15 Low Power Communication Device Transmitter 13.9 15C
DSS Part 15 Spread Spectrum Transmitter 18.7 15C
JBP Part 15 Class B Computing Device Peripheral 11.4 15B
PCE PCS Licensed Transmitter held to ear 9 Licensed 24
DSC Part 15 Security/Remote Control Transmitter 4.5 15C
TNB Licensed Non-Broadcast Station Transmitter 4.4 Licensed 22
PCB PCS Licensed Transmitter 4.1 Licensed 24
NII Unlicensed National Information Infrastructure TX 3.6 15E
8CC Part 18 Consumer Device 1 18
Total 86.7
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General Equipment Types
License Exempt Devices – Parts 15 & 18
– Incidental Radiator - Parts 15.13 & 15.5(b)
– DC Motors & mechanical light switches
– Unintentional Radiator - Part 15 Subpart B
– Intentional Radiator - Part 15 Subpart C +
– Industrial, Scientific and Medical equipment – Part 18
Licensed Transmitters – Other Rule Parts
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License Exempt Unintentional Radiators
Part 15, Subpart B – Any device that intentionally generates RF energy, but does not intentionally radiate that energy
Examples:
– Digital devices (data processing equipment, computers, etc.)
– Radio receivers that tune between 30-960 MHz
– TV interface devices (VCRs, cable terminal devices, etc.)
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License Exempt Intentional Radiators
Part 15, Subpart C –Lists frequency bands and types of operation permitted.
Examples:
– Cordless Telephones
– Remote Switches, door controls, alarms
– Wireless Local Area Network (WLAN)
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Licensed Radio Services
Transmitters that require either an individual license or a blanket authorization are subject to requirements of a specific radio service.
– General Mobile Radio Services (non-cellular)
– Personal Mobile Services
– Broadcast Radio Services
– Microwave Radio Services
– Maritime and Aviation Radio Services
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Telephone Terminal Regulations
47 CFR Part 68 –Telephone Terminal Equipment (TTE)
– Public Switched Telephone Network (PSTN)
– Private Line Interfaces
– Analog Interfaces
– Digital Interfaces
– www.part68.org
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MRA Equipment Authorization Processes
Declaration of Conformity
– Approval using an accredited test lab
– MRA Phase I/Japan EMC Arrangement
Certification
– Approved by FCC or Telecommunication Certification Body (TCB)
– MRA Phase II/Japan MRA
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Application for Certification Information
2.1033(b)Part11,15,18– Name, address
– FCCID
– User/installation Manual
– Circuit Description
– Block Diagram
– Schematics (when required)
– Measurement Report
– Photos
• Internal, external, setup
2.1033(c) Other Parts– Name, address
– FCCID
– User/installation Manual
– Circuit Description
– Emission Type
– Frequency Range
– Power levels & max.
– Tune Up procedure
– Schematics
– Measurement Report
– Photos
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FCC/TCB Certifcation Process Comparison
Manufacturer’s Product
Pay for TCB
Services
Product is Tested
Questions and Answers
Grant is Issued
Grant is Issued
Product is entered into the FCC Database through
Form 731
Completes Form 731 Product is entered into the
FCC Database
Examiner Review
Engineer Review
Processing
FCC Fees
Support Information is uploaded
The review process is between 30 – 45 days
If no problems are found a Grant is issued.
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Equipment Authorization Certification Process Trends
0
2000
4000
6000
8000
10000
12000
2001
2002
2003
2004
2005
2006
2007
2008
Authorized byFCC
Authorized byTCBs
Total NewAuthorizations
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Why Use the Private Sector?
Speed at which technology is changing and shorter product life cycles require faster product approvals
The private sector has the technical expertise and ability to certify equipment.
Increase the resources performing conformity assessment
Efficiencies in designing and approving product in the same geographic location
Reduce uncertainty and delay in obtaining certification
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What is a TCB?
A Telecommunication Certification Body is a Certification Body that has been accredited to ISO/IEC Guide 65 and ISO/IEC Standard 17025 by a recognized Accrediting Organization and recognized by the FCC to approve equipment subject to certification.
A TCB has certain rights and responsibilities (e.g. equitable treatment of applicants, audit through sampling of equipment on market)
Foreign entities may become a TCB in accordance with the terms of a government-to-government Mutual Recognition Agreement/Arrangement.
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TCB Scope of Responsibility
TCB (see § 2.962 (e) and Public Notice, DA 99-1640) – Is empowered to certify products in accordance
with the FCC rules
– Must provide fair and equitable treatment
– Must accept test data from any source, subject to subcontracting clause in ISO Guide 65 and shall not unnecessarily repeat tests
– May assess fees for processing applications
– May rescind grant within 30 days
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MRA Introduction
Purpose of MRA -- To facilitate trade by allowing Conformity Assessment Bodies (CAB) in one economy to test (Phase I) and/or certify (Phase II) products to the Technical Regulations of another economy.
Participation in a MRA is voluntary -- however, if a economy agrees to participate in either Phase I and/or Phase II certain rights and obligations in accordance with the terms of the MRA apply.
Government to Government
Use of harmonized technical standards is not part of an MRA
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Benefits of MRAs
Products May be shipped directly to foreign countries without any further requirements for testing and/or certification thereby reduced costs and time to market
Facilitates trade by promoting market access and competition
Reduces and minimizes non-tariff trade barriers
Shortens time for manufacturers to introduce their products into the importing countries
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MRA Webpage
Organizes all FCC related MRA information in one location:
– www.fcc.gov/oet/ea/mra
• Links to agreements
• Implementation information
– Accredited CAB requirements
– Certification Body requirements
» TCB Guide 65 Checklist
» TCB Roles and Responsibilities
» Measure procedures
• Contact information for stakeholders
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Identification of US Players
Regulatory Authority (RA)
Federal Communications Commission (FCC)
www.fcc.gov
Designating Authority (DA)
National Institute of Standards and Technology (NIST)
www.nist.gov
Accreditation Body (Phase 1)
National Voluntary Lab Accreditation Program (NVLAP) & American Association of Lab Accreditation (A2LA)
www.nist.gov
www.a2la.org
AB (Phase 2) American National Standards Institute (ANSI)
American Association for Laboratory Accreditation (A2LA)
www.ansi.org
www.a2la.org
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United States and MRAs
The US Government has agreed to participate in
the following MRAs for conformity assessment:
European Union MRA
European Free Trade Association (EFTA) MRA
Asian Pacific Economic Co-operation Tel MRA (APEC)
Inter-American Commission for Telecommunications (CITEL MRA)
Japan MRA
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US – Japan Telecom MRA
Scope: Telecommunications terminal equipment and radio equipment
– Limited to radio and telecommunications equipment subject to certification
• Doesn’t include ISM and unintentional radiators.
– United States – FCC Rules (47 CFR)
– Japan – Telecom Business Law, Radio Law, related ordinances
– Regardless of location of the supplier or country of origin of the equipment
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US – Japan Telecom MRA
Entry into force– Signed February 16, 2007 in Washington, D.C. by
officials of the U.S. and Japan– Japan’s Parliament (Diet) approved the MRA; June 19,
2007– Arrangement on Electro-Magnetic Compatibility (EMC):
through Exchange of letters Exchange of diplomatic notes – December 2007• Official implementation date January 1, 2008
– Training/Workshops in 2009• Tokyo March 3-4, 2009.• Gaithersburg NIST May 4-8, 2009
Information on US-Japan MRA:– http://ts.nist.gov/Standards/Global/mra_rebuild_japan.cfm
– http://www.fcc.gov/oet/ea/mra/Japan.html
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MRA Implementation Process
Basic Requirements:
– Regulatory Authority
– Designating Authority
– CAB Accrediting Body
Modify laws to allow if necessary
– Laws must allow private sector testing and approval.
Establish:
– Procedures for recognizing foreign CABs
– Procedures for designating CABs
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Accreditation Requirements
MRA Phase I/EMC Arrangement– Regulatory Authority
– Designating Authority
– Accrediting Body
• ISO17011
– CAB
• ISO 17025
MRA Phase II/Japan MRA– Regulatory Authority
– Designating Authority
– Accrediting Body
• ISO17011
– CAB
• ISO 65
• ISO 17025
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MRA Phase I/EMC Arrangement -Accreditation of Test
LaboratoriesLaboratories outside the United States will be recognized by the FCC if one of the following two conditions are met:
– the laboratory has been designated by a foreign authority and recognized by the Commission under the terms of a government-to-government Mutual Recognition Agreement or Arrangement; or
– the laboratory has been accredited by an organization whose accreditations are recognized by the Commission.
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MRA Status – Phase I/EMC Arrangement
Phase I/EMC Arrangement (mutual acceptance of test data) is operational with the following countries:
• Australia
• Canada
• Chinese Taipei
• European Union
• Hong Kong, China
• Japan
– 60 recognized
• Korea
• Singapore
• Vietnam
Region Number of Labs
North America
91
Europe 47
Asia 125
Middle East
3
Total 266
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MRA Status – Phase II/Japan MRA
Phase II (mutual acceptance of approvals) is operational with the following countries:
• Canada
• European Union
• Hong Kong, China (pending development of procedures)
• Singapore
A total of 32 Telecommunication Certification Bodies (TCBs) have been recognized by the FCC.
• 17 domestic TCBs
• 15 foreign TCBs
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Process SummaryHow to become a Certification Body/TCB– Accreditation by FCC recognized accreditation body
– Apply to MIC for Designation to FCC
– Upon FCC recognition TCB may begin authorizing equipment.
After Recognition– TCB may authorize equipment in accordance with FCC Rule
– TCB may not make interpretations or waivers
– Keep up to date with FCC regulations
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Process Summary (continued)
How to authorize equipment:
– Log on to FCC Equipment Authorization Website:
• Go to www.fcc.gov
• Click on “e-filing” link
• Scroll to “OET TCB/Accreditor Electronic Filing” link and click on it and bookmark page that opens.
• Click TCB login and enter login and password.
• Complete Form 731 to issue grant.
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TCB TrainingMonthly conference calls with TCB Council– Phone in first Tuesday every month at 11 AM Washington
DC time.
TCB Meetings– TCB’s meet 2-3 times annually to discuss issues and
for training.
Other training opportunities– Scheduled as necessary
– May 5-7, 2009 NIST in Gaithersburg, MD USA
• http://ts.nist.gov/Standards/Conformity/mra/2009-MRA-Workshop.cfm
FCC Knowledge Database– www.fcc.gov/labhelp
Beta Test/Practice Website– https://selafoss.fcc.gov/tcb/index.html
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TCB/Accreditor Filing Webpage
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TCB Login Homepage
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Post Grant SurveillanceFCC– Reviews TCB Grants– Requests Samples from Grantees and TCB’s– Purchases Samples– Focused sampling projects
TCB– FCC requires each TCB to audit 5 % of products
they authorized annually• 1 % RF Exposure if applicable• www.fcc.gov/labhelp KDB 610077
– https://fjallfoss.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=20540&switch=P
Other– General public complaints/testing– Competitors complaints/testing
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Post Grant Audit Issues
FCC Actions– Non compliance issues:
– Require explanation
– Monetary fines
– Confiscate equipment
– Fix equipment
TCB Responsibilities– Required to report issues to FCC & Grantee
Applicant Issues– Non response
• Grantee code deferral
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Enforcement ActionsPROXIM WIRELESS CORPORATION. Notified of a $11,000 monetary forfeiture for marketing non-compliant wireless access points. Adopted: 01/29/2009 by NAL. (DA No. 09-146).– http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-
146A1.pdf
INTER TECH FM. Notified of a $7,000 forfeiture for marketing unauthorized equipment (47 USC 302(b); 47 CFR 2.803(a)(2)), and an $11,000 forfeiture for providing incorrect material factual information without a reasonable basis (47 CFR 1.17(a)(2).
Adopted: 01/29/2009 by NAL. (DA No. 09-147).– http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-
147A1.pdf
POWER 7 TECHNOLOGY CORPORATION. Issued a $25,000 proposed monetary forfeiture for marketing unauthorized radio frequency devices. Action by: Chief, Spectrum Enforcement Division, Enforcement Bureau. Adopted:02/17/2009 by NAL.(DA No. 09-253). EB– http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-
253A1.pdf
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Enforcement Actions Continued
HUMAX CO., LTD. Adopted a Consent Decree terminating an investigation into equipment marketing violations by Humax. Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER. (DA No. 09-214). EB $15,000http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-214A1.pdfAUDIOVOX CORPORATION. Adopted a Consent Decree terminating aninvestigation into possible equipment marketing violations by Audiovox.Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER.(DA No. 09-229). EB $5,000http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-229A1.pdfWISTRON NEWEB CORPORATION. Adopted a Consent Decree terminating aninvestigation into equipment marketing violations by Wistron NeWeb.Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER.(DA No. 09-215). EB $30,000http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-215A1.pdfKI RYUNG ELECTRONICS CO., LTD. Adopted a Consent Decree terminatingan investigation into whether certain satellite radio equipment manufactured and sold by KRI in Korea and China and imported and marketed in the United States by third parties comply with FCC Rules. Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER. (DA No. 09-226). EB $30,000http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-226A1.pdf
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SummaryFCC– Overview
– Regulations
– Equipment Authorization Process
TCB– Requirements & responsibilities
MRA– Overview
– Statistics
Post Grant Surveillance & Enforcement
Information sources
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Information On Line
Equipment Authorization Webpage
– Measurement techniques, explanation of EA programs, filing information, MRAs, TCBs, EA announcements, etc.: http://www.fcc.gov/oet/ea/
Procedures for information sharing and distribution
– Updated Interpretation Database & new contact desk for web based inquiries: http://www.fcc.gov/labhelp
OET Info on line (Orders, Public Notices, etc.)
– http://www.fcc.gov/oet/info/
FCC Rules and Regulations:
– http://www.fcc.gov/oet/info/rules
General FCC Information:
– http://www.fcc.gov
FCC MRA Webpage
– www.fcc.gov/oet/ea/mra
March 4, 2009MRA International Workshop
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Thanks!
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