Admen watch out: health Bannism is back

April 16, 2012

It’s been a while since the medical profession got onto its high horse about banning the promotion of fast-food and soft-drinks brands.

But now, sensing the increasing vulnerability of the Coalition Government, it’s charging straight for the breach.

The militant assault comes from the Academy of Medical Royal Colleges, an umbrella organisation which can count on the (at least passive) support of 200,000 doctors. It’s being directed by the academy’s vice-president Professor Terence Stephenson, something of a zealot in these matters.

Specifically, Stephenson wants:

  • A ban on brands like Coca-Cola and McDonald’s sponsoring major sporting events such as the Olympics. Carling, sponsor of the Carling Cup, also comes in for some harsh words;
  • Prohibition on the use of celebrities or cartoon figures in promoting “unhealthy” food and drink to children;
  • A safe area around schools, free from fast-food outlets;
  • “Fat taxes”, as in Scandinavia, levied on such foods;
  • Much clearer labelling on the calories, salt, sugar and fat contained therein.

Same old, same old, you may say. And you would be right. This is the “Bannist Tendency” making a not-very veiled attack on the Government’s proclaimed policy of collaborating with industry via so-called “responsibility deals”, which emphasise self-regulatory restraint rather than expensive-to-police and often-ineffectual red-tape.

When I say “ineffectual”, I should qualify that. In the short term, the proposed bans might well have a debilitating effect on commerce without achieving concomitant success in combatting national obesity. Longer term the strategy is tried and tested, however. It amounts to demonising fast-food and soft drinks in the same way the medical profession has managed to demonise smoking. At this very moment health secretary Andrew Lansley, the arch-proponent of industry “responsibility deals”, is contemplating stripping the last vestiges of marketing support from the tobacco industry with a ban on branded packaging. That’s what, in a generation’s time perhaps, the medical profession would like to see happening to Big Food brands.

Reducing the amount of salt, fat and sugar in our diet is of course a commendable aim, and it is right that the medical profession – of all special interest groups – should embrace it. But is it also right to equate the variable impact of HSSFs on our health with the addictive and truly pernicious effects of smoking? There is a matter of degree here, which does not seem to be adequately reflected in the uncompromising messianic fervour of the medical profession. Or, rather, some of the zealots who seem to have hijacked it.

Stephenson himself is a case in point. He may be an eminent paediatrician, but he also harbours some eccentric views. Among them, that second hand smoke (from tobacco) is a significant contributor to cot-deaths. He is also someone who clearly lives in a bubble blissfully sequestered from the inconvenient realities of commercial life. Here he is on the subject of football sponsorship:

“For adults, beer is a source of calories. I like going to a football match and drinking beer, but it’s the high-profile sponsorship that means that every time we mention this trophy, we mention in the same words Carling Cup.” So, let’s ban it, eh? Personally, I’m all the way with Stephenson on renaming it the “English Football League”. Period. But I do wonder where all the extra money is going to come from if we prohibit the likes of Carling, Coca-Cola and (heavy heart, here) McDonald’s from investing in sports events.

Surely, a little more personal responsibility exercised over how many HSSFs we ingest at any one time, not to mention how much exercise we take, are more salutary – and certainly less puritanical – solutions to the national obesity problem?

And, if we’re going to consider banning any advertising at all, what about reviewing the wall of money Big Pharma spends on targeting the medical profession?

Now there’s an unhealthy relationship.


The way back to La Dolce Vita – ‘legality menus’ served without Mafia topping

January 8, 2012

Regular readers of this blog may recall me recounting the heroic exploits of Libera Terra, an organisation dedicated to freeing the Italian food industry from the baneful influence of the Mafia.

Now I have fresh news to report. Scrupulous gourmands can be assured that not only their pizza, pasta, olive oil, breadsticks and Sicilian wine are untainted by organised crime: the restaurant in which they might aspire to eat them is now also being managed with a clean pair of hands.

Not any old upmarket restaurant either. We’re talking here of Rome’s most famous eaterie, the Café de Paris in the via Veneto – which once played centre-stage in Fellini’s La Dolce Vita. Of late it had fallen on evil times. In place of jet-setters, diplomats and businessmen, its core clientele had become mobsters. Something closely related, no doubt, to the fact that leading ‘Ndrangheta clan the Alvaro family (for which read Calabrian mob) had taken an unhealthy interest in the place.

A criminal investigation launched in 2009 led to the restaurant being put into administration, under legislation that empowers the Italian state to confiscate property owned by mobsters and to restore it to legitimate ownership through such entrepreneurial organisations as Libera.

For long-suffering restaurant manager Marcello Scofano the change of ownership comes as a huge relief. “We went through tough times. Because we rely a lot on foreign customers, the negative reputation abroad had a negative impact on our revenues,” he is reported as saying in La Stampa.

To celebrate a new era, and cement an ethically-cleansed alliance, Scofano has launched what he calls a “legality menu”. And guess what? It consists of dishes exclusively prepared from food grown on Libera’s confiscated estates.

As I said previously: Libera, it’s the ultimate Fairtrade kitemark.


Brands get the better deal out of alcohol responsibility

March 15, 2011
The 6 health public interest organisations which abruptly withdrew from the government’s “responsibility deal” on alcohol appear to have thought they were pulling the rug from under health secretary Andrew Lansley’s love-in with industry. That’s certainly the implication of the timing of their announcement, which came 24 hours before Lansley unveiled pledges by 170 brands to support responsible drinking, eating, behaviour at work and in the home.

If that was their intention, they are sorely deceived; at least, in the short term. These public interest groups comprise sober-minded people: The Royal College of Physicians, the British Liver Trust, the British Association for the Study of the Liver, the Institute of Alcohol Studies, the British Medical Association and Alcohol Concern. Yet they have acted like children, throwing their toys out of the pram because they cannot get what they want.

Worse, the gesture politics have actually back-fired. They have left Lansley’s new brand buddies looking adult, mature, responsible (albeit ever so slightly smug). Achieving clear unit labelling on more than 80% per cent of alcoholic drinks by 2013 may seem a fairly nugatory achievement in the wider public health battle against binge drinking and youthful alcoholism. But at least it’s a positive headline.

Whereas, the strategy of the breakaway NGOs is simply dumbfounding. Either they were extremely naive, or extremely cynical, in subscribing to the “responsibility deal” in the first place. Naive if they thought Lansley was going to do anything other than sign a concordat with industry – in lieu of (as he himself expresses it) expensive and time-consuming legislative restrictions. Or cynical, if they knowingly signed up for a project in which they had no confidence, merely to scupper it at a politically sensitive moment.

Professor Sir Ian Gilmore, formerly president of the Royal College of Physicians – and one of the defectors’ most articulate spokesmen – put his finger on their dilemma nearly 6 months ago. He signed up to the alcohol responsibility deal network even though he was sceptical of a “meaningful convergence between the interests of the industry and public health, since the priority of the drinks industry was to make money for shareholders, while public health demanded a cut in consumption… On alcohol, there is undoubtedly a need for regulation on price, availability and marketing – and there is a risk that discussions will be deflected away from regulation that is likely to be effective but would affect sales.”

In fact, Lansley had made it clear right from the start that he wanted a voluntary, not a regulatory, approach; and that the pricing of alcohol as a regulatory consumption mechanism was not part of the deal’s terms of reference.

Quizzed yesterday on why the 6 had pulled out, Gilmore observed: “It is not acceptable for the drinks industry to drive the pace and direction that […] public health policy takes.”

That may seem like pique (and indeed it is), but it shrewdly hints at a wider problem facing Lansley and the Department of Health. In the short term, cosying up to industry during these times of austerity might seem a smart and pragmatic thing to do. In the longer run, however, the DoH cannot afford to alienate its core constituency, the medical profession.

As one industry insider put it: “The health lobby is now screaming from the sidelines with placards on its chest. That doesn’t serve the public health interest; and it doesn’t serve ours, either. To paraphrase President Johnson, we’d rather have them inside the tent than outside it.”


Phil Rumbol lays his reputation for creativity on the line

September 8, 2010

For months it has been an open secret that Phil Rumbol, former Cadbury marketing director, was plotting to set up an advertising agency. The trouble was, most of us were on the wrong scent; the idea being he was going to head the London arm of Omnicom’s creative boutique, Goodby Silverstein & Partners.

At the same time, there were ominous rumblings of discontent at Fallon, the creative outpost of SSF, which also runs Saatchi & Saatchi London. Fallon – once highly praised for its Sony Bravia and Cadbury work – has latterly been dubbed “Fallen” by industry wags who, no doubt, have in mind the successive loss of the £70m Asda account, Sony, and the transfer of the £100m Cadbury account to Saatchi after some controversial Flake work went awry. The talk was of a possible management buyout. In the event, it is chairman Laurence Green and creative director Richard Flintham, rather than the agency, who have walked.

What we had failed to do was mix these two things together and make an explosive compound. All the more so since the story – broken by my colleague Sonoo Singh, editor of Pitch – has self-detonated in the very week that Saatchi & Saatchi celebrates 40 years of success in its party of the decade.

Details remain sketchy. We don’t, for example, know what the breakaway agency is to be called, nor whether it has any business. Kerry Foods has popped into the frame, specifically the Wall’s sausage brand. If so, it must be a gift from Saatchi.

Whether that’s the case or not, what’s really interesting about this start-up is the key role being played by a former client. Rumbol, so far as I can make out, has never worked in an agency himself, but he has had a distinguished career as a client, which has resulted in some memorable advertising. Boddington’s Cream of Manchester campaign was one of his early achievements, he was the Stella client (need I say more), and the commissioning force behind Cadbury’s Gorilla and Eyebrows campaign, not to mention the more controversial launch campaign for Trident chewing gum.

Rare is the client with such a creative pedigree. Possible examples: David Patton, patron of the Sony Bravia “Colour like no other” campaign; Simon Thompson, long-time sponsor of Honda ads such as ‘”Cog” and “Grr” ; and – long ago – Tony Simonds-Gooding, who tore up some unsupportive research and gave Lowe Howard-Spink the go-ahead with ‘Heineken refreshes the parts other beers can’t reach’. Rarer still is the client who is physically involved in a start-up and prepared to put his reputation, and possibly career, on the line; as rare in fact as hens’ teeth. It’s said that Rumbol earlier got close to signing a deal with Goodby, but that the stumbling block was the creative process, which would be shipped out to HQ in San Francisco. I can well believe it. Here’s someone who clearly has the courage of his convictions.

POSTSCRIPT: Spookily, Fallon has just conjured a new chief executive out of the hat, after a 6-month search. She is Gail Gallie, who was responsible for the BBC becoming Fallon’s first client in 1998.

PPS. It has been pointed out to me that the nearest precedent to Rumbol is the revered John Bartle. Oddly enough, Bartle himself was a Cadbury client. He worked at the confectionery and food company for eight years and, among other things, fostered Boase Massimi Pollitt’s celebrated Smash campaign. The significant difference with Rumbol is that Bartle then spent nine years in an advertising agency, TBWA, before forming the breakaway group that set up Bartle Bogle Hegarty in 1982.

UPDATE 24/12/10: The new agency is to be called 101 (not, thankfully, Room 101). The name has nothing to do with the agency’s official opening day, 10/1/11 – I’m told by a reliable source. We have yet to learn whether it has landed a big fish.


Food Standards Agency to be shorn of powers – it’s official

July 20, 2010

Some enlightenment on the vexed future of the Food Standards Agency has just come my way. It will stay, but be shorn of many of its powers. Here’s today’s ministerial statement on the subject:

Food Standards Agency in England. The Government recognises the important role of the Food Standards Agency in England, which will continue to be responsible for food safety. The Food Standards Agency will remain a non-ministerial department reporting to Parliament through Health ministers.

In England, nutrition policy will become a responsibility of the Secretary of State for Health. Food labelling and food composition policy, where not related to food safety, will become a responsibility of the Secretary of State for Environment, Food and Rural Affairs.

In effect, these changes will disembowel the FSA. Expect substantial cuts in its £135m annual budget and its 2,000-strong staff.


Abolition of FSA will give food industry more shout

July 12, 2010

Come on, we all knew a Tory government was going to abolish the FSA. It’s just we got the wrong one in our sights. How devious of them to lead us up the garden path like that!

While the incompetent Financial Services Authority (a watchdog steeped up to its dewlaps in responsibility for the banking crisis) has got off lightly with a root-and-branch reform instead of threatened abolition, the other FSA, the Food Standards Agency, which was threatened with root-and-branch reform but not abolition, is the one that is actually going to get the chop. Health secretary Andrew Lansley, we are told, will shortly announce that the organisation set up in 2000 in the wake of the BSE crisis will have its regulatory remit (safety and hygiene in the food chain) devolved to the Department for Environment, Food and Rural Affairs (Defra), and its responsibilities for advising on public health and diet (primarily the obesity debate) given to the Department of Health (DoH).

The immediate aim is to save about £1bn by breaking up a department with 2,000 people and a budget of £135m. However, commentators on both sides of the food divide have been quick to discern a not-very-hidden ideological agenda.

Nannyism: Out of fashion

With one stroke, Lansley has struck a lethal blow at the heart of nannyism. Even the food industry seems a little taken aback by the suddenness of the blow. And yet it is entirely consistent with Lansley’s promise – implicit in his decision last week to give industry a bigger role in Change4Life – to substitute “nudge” (persuasive technique) for cumbersome and expensive legislative coercion.

A happy by-product of this policy, so far as the food, soft drinks and alcohol companies are concerned, is that it puts them more firmly in the driving seat. We will hear no more of “traffic lights”, the simplistic but consumer-friendly food labelling system which the FSA has espoused with such zeal, much to the annoyance of Big Food. Similarly, I imagine the threat of a TV advertising watershed imposed on certain food and alcohol categories is definitively a thing of the past; and the medical caucus will – for now – be more hesitant about calling for an outright ban on the consumption of alcohol.

Critics of Lansley’s plan will no doubt point to the conflict of interest inherent in placing regulatory control within a department, Defra, which is also responsible for the supply side. One of the reasons for the FSA’s foundation as an independent body was the perceived inadequacy of MAFF (Ministry of Agriculture, Fisheries and Food) – Defra’s predecessor – in dealing with the BSE crisis, thanks to its cosiness with farmers. But that’s one for the critics. For the food and alcohol sectors, the FSA’s abolition marks a famous victory, not least in the communications war.

UPDATE: Some furious back-pedalling by Andrew Lansley’s special adviser has led to the following terse statement being issued on the DoH website this afternoon: “No decision has been taken over the Food Standards Agency (FSA). All Arms Length Bodies will be subject to a review.” Meaning? The electric chair will have to wait, but it’s definitely (or should that be indefinitely?) Death Row for the FSA. Emasculation by innuendo. NICE next?


Changed4Life – policy U-turn puts advertisers in the driving seat

July 8, 2010

For the health lobbyists, it was a rout; for advertisers – and especially those in the food, soft drinks and alcohol sectors – a triumph and an indisputable turning point.

Lansley: A Mars a day may help you work, rest and play

Yesterday’s landmark speech by health secretary Andrew Lansley left not a shadow of a doubt about the government’s future stance on the obesity debate. Nannying – in the sense of strict legislative curbs – is out and “nudge” – the employment of persuasion techniques to mould consumer behaviour – is definitively in.

In practice it means that a fiscally-challenged Government intends to withdraw some public funding from the 3-year Change4Life programme, leaving business to take up the financial slack. Almost without saying, this puts the members of the Business4Life initiative in an unprecedentedly powerful position.

As if to underline the point more graphically, Lansley made specific reference to some of the main consortium members in his redefinition of government policy:

“It is perfectly possible to eat a Mars bar, or a bag of crisps or have a carbonated drink if you do it in moderation, understanding your overall diet and lifestyle. Then you can begin to take responsibility for it and the companies who are selling you those things can be part of that responsibility too.” Companies which include Mars, Coca-Cola and Pepsi Cola (owner of Walkers Crisps).

What this means for the health lobby was bleakly summed up by Tam Fry, the feisty leading-edge of the National Obesity Forum. “NOF is horror-struck at Mr Lansley’s remarks. It sees them as nothing other than a bare-faced request for cash from a rich food and drink industry to bail out a cash-starved Department of Health campaign, ” he says. I might scruple at the “nothing other” bit, but find it hard to disagree with his argument, as far as it goes.

Lansley’s new concordat is at once an opportunity and a trap for the food and drink industry. It’s an opportunity to exercise more responsibility in what it sells, and how it sells it, to an increasingly wary consumer. As Fry points out, many food manufacturers continue to sell products whose salt, sugar, and fat content is well in excess of Food Standards Agency guidelines. There are signs of greater self-restaint, particularly in the area of trans fats, but it is slow and grudging. The science surrounding obesity meanwhile moves on, and with it – if diffusely and haphazardly – the consumer perception of what is acceptably healthy and what is not. Only this week, for example, a study found that children who are obese tend to exercise less, because they are already overweight; rather than because their lack of exercise causes them to put on weight. In other words, from the complex miasma of obesity’s causes – among them poor education, lack of exercise and poverty  – junk food has once more emerged as an all-too-visible spectre.

So, when Lansley advises Business4Life to reach for the till, it should reach for the till. But its members must also remember that what they are doing will lack all public credibility if it is unaccompanied by measurable changes in the behaviour of the food and drink companies themselves. This is not an opportunity for coasting.


NICE oversteps the mark in ‘last hurrah’ against Big Food

June 22, 2010

If I were the chief executive of the National Institute for Health and Clinical Excellence, I would be very careful where I trod right now. Quangos are looking highly dispensable in the forthcoming Exchequer purge of the public sector.

So what does NICE do? It plays the turkey voting for Christmas. Twice in the past month it has come out with a series of recommendations that are not only – arguably – beyond its remit but are also like a red rag to the new blue-and-yellow striped government.

First, it called for a watershed ban on advertising alcohol, when the government has already ruled that out. Now, in the process of advocating a total ban on so-called trans fats and a general assault on salty foods, it has not only recommended another watershed ad ban (see above) but proposed the introduction of the “traffic light” colour coded food warning system only days after it was rejected by the European Union.

NICE’s raison d’être is to save lives by improving the quality of healthcare (and by implication reduce the heavy financial burden associated with it). There’s no doubting that trans fatty acid is a nasty substance that can cause heart disease by promoting “bad” cholesterol at the expense of “good”; and that it’s also a suspect in other disorders, such as Alzheimer’s, cancer, diabetes and infertility. Nor that it has, in the past, been widely used by the processed food industry as a shortening agent (eg in biscuits) and as a substitute for butter (for instance, in margarine). But it’s definitely on the way out. Some countries – among them Denmark, Switzerland, Australia and parts of the United States – have already prohibited it. Britain has not got that far yet, but since 2006 our supermarkets have employed a self-denying ordinance, and the food manufacturers have been quietly phasing it out.

NICE’s determination to rid us of this noxious substance is not as disinterested as the organisation would have us believe. Behind it seems to lie an agenda: a crusade aimed at the food industry in general, and its freedom of commercial expression in particular.

Of course, in the longer run NICE is right to flag up the trans fat issue. Sooner or later its harmful effects – like those of tobacco – are going to become big business for lawyers in the States. For NICE, though, there may not be a longer run, if it goes on behaving the way it is. Government ministers are likely to conclude it is an organisation out of control. And we know what that could mean in these austere times.


Bavaria beats up Bud in World Cup beer putsch

June 20, 2010

Despite its transcendent dullness to date, this year’s World Cup has managed to produce a few results of startling clarity, mostly of the negative kind. There’s England’s lacklustre performance, of course, and ITV’s stunning series of own-goals. But it’s the aggregate performance of the official sponsors I’m going to address here – and their need to get real; especially with FIFA, the organising body behind the tournament.

Exhibit One, a piece of market research carried out by Lightspeed, on behalf of our rival publication. Conducted at the time of the England v US match, it showed that only 8% of respondents thought sponsorship had a positive effect on their view of the brands involved. That, mind you, depended on whether they could identify those brands in the first place. Many could not. Quite a few, for example, reckoned Mastercard was a “partner” (30%), when it is not; only 37% gave the correct answer: Visa. A further 29% were highly impressed with Nike’s performance as a sponsor – except that, notoriously, it is not. The answer should be Adidas. Only Coca-Cola hit the button: a high correlation between correct identification and strong awareness; 65% of respondents got it right.

There is, by the way, nothing anomalous or even unusual in these results. Marketing Week has conducted similar surveys over the years, and come up with pretty similar conclusions. Coke scores well, and all the other sponsors are way down the league table; Nike scores too, but it’s offside.

Exhibit Two, the beer brand Bavaria. If you really want to make a name for yourself, don’t bother with official sponsorship (which would be difficult to afford anyway). Try causing a stir by breaking the silly FIFA-inspired anti-ambush laws and watch your brand awareness ratings shoot up.

Personally, I find the whole Bavaria brand proposition muddled. Orange lederhosen? Is it a German brand trying to cash in on a Dutch pedigree, or a Dutch brand trying to associate itself with the annual beerfest in Munich? In fact, the latter. There’s no denying the value of its stunt marketing, however. Those 36 Dutch female fans dressed in Orange miniskirts, whose presence cost ITV’s Robbie Earle his job, are likely to remain on our minds for years to come. More practically, bavaria.com –  whose web traffic was previously undetectable – has been translated into the fifth most visited beer website in the UK. And, according to Bavaria’s UK marketing manager, there has been explosive interest on Twitter and other social media.

Just a stunt whose effects will quickly fade away, you say? I disagree. Thanks to FIFA, Bavaria can now put into play a long-term brand strategy based around “Operation Martyr”.

Handily, the great clunking fist of FIFA has just landed a civil action on the brewer, guaranteeing it the oxygen of publicity for a long time to come. Better still – if not for Ms Barbara Castelein and Ms Minte Niewpoort – is the arrest of the two “ringleaders”, and the preferring of criminal charges against them by the South African police. A  show trial, followed by a custodial sentence could not be better calculated to vilify FIFA and curry favour for the beleaguered beer brand. And what about the subsequent “Free the Bavaria Babes” campaign? Plenty of potential there, I think.  It’s going to make the official sponsors, particularly Budweiser, appear rather stupid (those few we can remember, that is).

So why do the official sponsors bother? Good question, to which there is no convincing answer. We know why Coke does it. It has a long and consistent association with sport that makes the other sponsors look like dilettantes. As for the rest, who knows? Collective delusion? Brand vanity?


If oil’s the next tobacco, watch out Big Food and Big Booze

June 17, 2010

General Mills, the food giant that owns Cheerios, Häagen Daz and Green Giant, is breathing a sigh of relief after it suppressed a press release suggesting the US government was about to mount a full-scale investigation into its supply chain. The release was a hoax, but General Mills has no room for complacency. The threat of political interference in the food business could be very real if we extrapolate what the government has been doing to BP.

I owe the originality of this insight to the Financial Times’ John Gapper. Gapper’s argument, laid out in a column this week, is as follows. “Slick Willy” Sutton, the infamous armed robber, once observed that he raided banks because – that’s where the money is. In the same manner, US politicians – aware that they have to address a yawning budget deficit if they are to be re-elected – are casting around for easy money to plug the gap. Voters, impoverished by Wall Street’s scandalous behavioiur, don’t have it. But dividend-rich companies, like BP, do.

BP, of course, had it coming to it. Its behaviour in the Gulf of Mexico can be described as neither caring nor competent. That, however, is not the point. It is the ease with which Congress and Obama have been able to extract $20bn – none of which is ever likely to be returned to the company – that should be worrying shareholders everywhere. There is no fixed liability associated with this sum and – like blackmailers the world over – politicians will come back for more if they think they can get away with it.

To Gapper, the BP concession has echoes of the 1998 tobacco settlement, in which the industry paid $246bn to various states following legal action by their attorney generals. It’s worth quoting him more fully here: “Only 5% of tha money was spent on tobacco-related initiatives with Virginia, for example, investing in higher education, fibre optic cables and research into energy.”

Now let me see, which other big-dividend paying companies could land themselves in a pickle with the state over litigation liability? Gapper thinks the list is comprehensive and cites energy providers, drugs companies and consumer goods companies. I think two on his list stand out particularly prominently: the food and alcoholic drinks companies.

Imagine, for example, what might happen if scientific evidence conclusively proved that many of the big food companies had been slowly poisoning us to death through the use of (now largely discontinued) hydrogenated fats? Or what about excessive sugar and salt in cereals directly leading to premature cardio-vascular impairment? The legal fall-out, through class actions, could be stupendous. And lining up behind the lawyers would be the politicians waiting for a big, fat hand-out, or else. After all, it could be argued, a massive amount of taxpayers’ money has, historically, been funnelled into dealing with the collateral medical issues: time for industry to pay back the “subsidy”.

All the more could these arguments be applied to the side-effects of excessive alcohol consumption. The history of the tobacco industry suggests that free will and individual responsibility weigh little in the balance once these matters come to court.

And where the US leads, little Britain surely cannot be far behind.


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