FAS 2021 UP11: Carbon steel fasteners
Notice of normal value review
Ottawa,
The Canada Border Services Agency (CBSA) has today initiated a normal value review (review) to determine the normal values and export prices applicable to certain carbon steel fasteners (fasteners) originating in or exported from the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei) by Honor Best Co., Ltd.
The review follows the receipt of a request for re-determination by an importer in Canada and is part of the CBSA’s enforcement of the Canadian International Trade Tribunal’s (CITT) order issued on September 2, 2020 in Expiry Review No. RR-2019-002, respecting the dumping of fasteners originating in or exported from the People’s Republic of China (China) and the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei) and the subsidizing of such goods, originating in or exported from China, excluding fasteners specifically designed for application in the automotive or aerospace industry, in accordance with the Special Import Measures Act (SIMA).
The product definition and the applicable tariff classification numbers of the goods subject to the CITT’s order are contained in Appendix 1 (subject goods).
Should the exporter decide to participate in this review, it is required to provide a complete and accurate response to the CBSA’s request for information (RFI) by December 13, 2021. The exporter will be considered cooperative if the requested information is complete, submitted on time and the exporter permits verification of the data.
If the exporter does not provide a complete response to the RFI by the deadline date, the normal values and export prices applicable to the subject goods will be determined pursuant to the ministerial specification.
Please be advised that exporters who are not the manufacturers of the subject goods should ensure that their suppliers/manufacturers have received the RFI and that they also provide a complete and accurate response to the RFI by December 13, 2021.
The schedule for this normal value review is now available. The CBSA will close the record for this review at any time during the proceeding, without advance notice, once it has been determined that sufficient information has been received to make a decision. Therefore, interested parties are encouraged to provide any and all information that they feel is relevant to this review to the CBSA as early as possible. The CBSA will update the website to announce that the record has been closed. Interested parties will have seven days from the close of the record to file case arguments concerning the review and 14 days from the close of the record to file reply submissions in respect of the case arguments.
The normal values and export prices determined as a result of this review will be applied to settle the request for re-determination on hand and may be applied to any requests for re-determination of importations of subject goods that have not been processed. The normal values and export prices determined for the exporter will also be effective for the subject goods released from the CBSA on or after the date of the conclusion of the review.
Where applicable, the normal values and export prices determined as a result of this review may be applied retroactively. Exporters with normal values are required to promptly inform the CBSA in writing of changes to domestic prices, costs, market conditions or terms of sale associated with the production and sales of the goods. All parties are cautioned that where there are increases in domestic prices, and/or costs as noted above, the export price for sales to Canada should be increased accordingly to ensure that any sale made to Canada is not only above the normal value but at or above selling prices and full costs and profit of the goods in the exporter’s domestic market. If exporters did not properly notify the CBSA of any such changes, did not adjust export prices accordingly, or did not provide the information required to make any necessary adjustments to normal values and export prices, retroactive assessments of anti-dumping duty may be warranted. Please refer to the CBSA’s re-investigation and normal value review policy Memorandum D14-1-8.
Any questions concerning the above should be directed to:
- Telephone:
- Paul Pomnikow: 343-553-1640
Email: simaregistry-depotlmsi@cbsa-asfc.gc.ca
Appendix 1—Product definition
Subject goods definition
“Certain carbon steel fasteners originating in or exported from the People’s Republic of China and the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei), excluding fasteners specifically designed for application in the automotive or aerospace industry.”
The following table is a list of subject products included in the Canadian International Trade Tribunal's (CITT) findings/orders for certain carbon steel fasteners.
Imperial | Metric | |||
---|---|---|---|---|
Diameter | Length | Diameter | Length | |
Wood screws | #4 to #24 (0.112" to 0.386") |
3/8 to 8 in. | M3 to M10 | 10 mm to 200 mm |
Square and hex lag screws | #14 to #24 (1/4" to 0.386") |
3/4 to 4 in. | M6 to M10 | 20 mm to 100 mm |
Sheet metal/tapping screws | #4 to #24 (0.112" to 0.386") |
3/8 to 8 in. | M3 to M10 | 10 mm to 200 mm |
Thread forming screws | #4 to #24 (0.112" to 0.386") |
3/8 to 3 in. | M3 to M10 | 10 mm to 75 mm |
Thread cutting screws | #4 to #24 (0.112" to 0.386") |
3/8 to 3 in. | M3 to M10 | 10 mm to 75 mm |
Thread rolling screws | #4 to #24 (0.112" to 0.386") |
3/8 to 3 in. | M3 to M10 | 10 mm to 75 mm |
Self-drilling tapping screws | #4 to #24 (0.112" to 0.386") |
3/8 to 3 in. | M3 to M10 | 10 mm to 75 mm |
Machine screws | #4 to 3/8 in (0.112" to 3/8") |
3/8 to 8 in. | M3 to M10 | 10 mm to 200 mm |
Flange screws | 1/4 to 5/8 in | 3/8 to 4 in. | M6 to M16 | 10 mm to 100 mm |
The following products are excluded by the CITT in Inquiry No. NQ-2004-005, in Expiry Reviews No. RR-2009-001 and RR-2014-001, and in Interim Reviews No. RD-2016-001 and RD-2016-003 and, therefore, are not subject to anti-dumping duty or countervailing duty.
- Acoustic lag screws
- Aster screws
- Chicago screws
- Collated screws
- Connector screws (kd)
- Decor screws
- Drawer handle screws
- Drive spikes RR
- Euro screws
- Hex socket cap screws
- Instrument screws
- Knurled head screws
- Machine screws with wings
- Optical screws
- Screw spikes RR
- Security screws
- Self-clinching studs
- Socket cap screws
- Socket set screws
- Square-head set screws
- Thumb screws
- U-drive screws
- Wing screws
- Screws imported under tariff item Nos. 9952.00.00, 9964.00.00, 9969.00.00, 9972.00.00 and 9973.00.00 for use in the manufacture of snowmobiles, all-terrain vehicles, personal watercraft and three-wheeled motorcycles
- R4(trademark) screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent numbers 2 267 572 and 2 198 832 and a Climatek(trademark) coating which is certified to meet the ICC Evaluation Service, Inc. (ICC-ES) "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- RSS(trademark) rugged structural screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent numbers 2 267 572 and 2 140 472 and a Climatek(trademark) coating which is certified to meet the ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- MSS(trademark) zip tip metal siding screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent numbers 2 267 572 and 2 478 635 and a Climatek(trademark) coating which is certified to meet the ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- MSS(trademark) drill tip metal siding screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent numbers 2 267 572 and 2 478 635 and a Climatek(trademark) coating which is certified to meet the ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- Pan(trademark) head screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- Cabinet(trademark) screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- FIN/Trim(trademark) head screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- White FIN/Trim(trademark) head screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- RT Composite(trademark) Trim(trademark) head screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- White RT Composite(trademark) Trim(trademark) head screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- Vinyl Window(trademark) screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- Caliburn(trademark) concrete screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- Kameleon(trademark) composite deck screws marketed by GRK Canada Limited which have the features and characteristics described in Canadian patent number 2 267 572 and a Climatek(trademark) coating which is certified to meet ICC-ES "Acceptance Criteria for Corrosion-resistant Fasteners and Evaluation of Corrosion Effects of Wood Treatment Chemicals" (AC257); or equivalent
- Sharp-pointed drywall screws with diameters ranging from #6 to #7, lengths ranging from 0.4375 in. to 2.25 in., with a coarse, fine or high-low thread, with a bugle, flat, pan, truss or wafer head, with a Phillips driver and a black phosphate or standard zinc finish
- Self-drilling drywall screws with diameters ranging from #6 to #7, lengths ranging from 0.4375 in. to 2.25 in., with a fine thread, with a bugle, flat, flat truss, pan, pancake, truss or wafer head, with a Phillips driver and a black phosphate or standard zinc finish
- TOPLoc(trademark) or Splitstop(trademark) composite decking fasteners for exclusive use in conjunction with TimberTech® composite material decking systems
- Titen HD(trademark) (THD) heavy-duty carbon steel screw anchors for concrete, manufactured for and imported by Simpson Strong-Tie, bearing Canadian trademark number TMA614622 and Canadian patent number CA2349358, with diameters of between 0.25 in. (1/4 in.) and 0.375 in. (3/8 in.), inclusive (i.e. between 6.35 mm and 9.525 mm, inclusive), and lengths of between 1.25 in. and 8.00 in., inclusive (i.e. between 31.75 mm and 203.2 mm, inclusive), tested or assessed in accordance with one or more of: ASTM E488 ("Standard Test Methods for Strength of Anchors in Concrete and Masonry Elements"); AC106 ("Acceptance Criteria for Predrilled Fasteners (Screw Anchors) in Masonry Elements"); AC193 ("Acceptance Criteria for Mechanical Anchors in Concrete Elements"); or ACI 355.2/ACI 355.2R ("Qualification of Post-Installed Mechanical Anchors in Concrete") as amended or replaced from time to time
- Shoulder bolts made of steel, grade 5, and zinc-plated, with a hexagonal head, an unthreaded cylindrical shoulder section ranging from 1/4 inch to 3/4 inch in diameter, and a threaded section that is smaller in diameter than the shoulder ranging from 3/8 inch to 7/8 inch in length and between 10-24 and 5/8-11 in common thread sizes
- Squeeeeek No More® square-drive wood screws, manufactured by or on behalf of O'Berry Enterprises Inc. under U.S. patent Nos. 5,371,992, 5,372,466 or 6,250,186, for use in wood flooring, with scoring above the threaded portion of the screw that allows the upper portion of the screw and head to be easily broken off, 3" or 3.5" in length, of a #8 or #9 diameter, threaded in part with 8 threads per inch and in part with 9 threads per inch, with the remainder unthreaded, and covered in a Gleitmo 615 lubricant coating (or equivalent coating) and imported in packages of 500 screws or less
The following products are excluded by the CITT's in Expiry Review No. RR-2019-002 and, therefore, are not subject to anti-dumping duty or countervailing duty.
- Screws designed by 1833236 Ontario Inc. d.b.a. U2 Fasteners and marketed under the trade name Construction Screw(trademark), which have the features and characteristics described in Canadian patent number 2 979 899, a U-Gold(trademark) coating, and are certified to comply with the most recent versions of the International Building Code® and the International Residential Code® and recognized for use in wood chemically treated with waterborne alkaline copper quaternary, type D (ACQ-D); or equivalent
- Screws designed by 1833236 Ontario Inc. d.b.a. U2 Fasteners and marketed under the trade name Vinyl Extrusion Screw(trademark), which have the features and characteristics described in Canadian patent number 2 979 899 and a proprietary coating; or equivalent
- Composite deck screws with a dual coarse thread design, a counter boring head, a #20 TORX® ttap® drive and in lengths of 2.5 in. or 3 in., packaged together with color matched plugs made from the same material as the deck boards, and a setting tool designed to drive the screw to the appropriate level below the surface of the board, as part of the Cortex® Hidden Fastening System for Decking; or equivalent
- PVC trim screws with a dual coarse thread design, a counter boring head, a #20 TORX® ttap® drive and in lengths of 2 in. or 2.75 in., packaged together with color matched plugs made from the same material as the PVC trim, and a setting tool designed to drive the screw to the appropriate level below the surface of the trim, as part of the Cortex® Hidden Fastening System for PVC Trim; or equivalent
- Fascia board screws with a coarse thread design, a flat head, a #20 TORX® ttap® drive and in a length of 1.75 in., packaged together with color matched plugs made from the same material as the fascia board, a counterbore tool designed to create a hole for the screw and plug, and a setting tool designed to drive the screw to the appropriate level below the surface of the board, as part of the Cortex® Hidden Fastening System for Fascia; or equivalent
- TrapEase® 3 composite deck screws with a dual coarse thread design, a color matched counter boring head, a #20 TORX® ttap® drive and in lengths of 2.5 in. or 3 in., packaged together with a driver bit; or equivalent
- TrapEase® FASCIA screws with a dual coarse thread design, a color matched flat head, a #20 TORX® ttap® drive and in a length of 1.75 in., packaged together with a counterbore tool designed to create a pilot hole for screw placement and a driver bit; or equivalent
- TimberLOK® heavy duty structural wood screws with a coarse thread design, a blank shank diameter of approximately 0.189 in., a countersinking hex washer head with a 5/16" drive and a head marking indicating overall length in inches, in various lengths, which are certified to comply with the most recent versions of the International Building Code® and the International Residential Code® and recognized for use in wood chemically treated with waterborne alkaline copper quaternary, type D (ACQ-D), packaged together with a driver bit; or equivalent
- HeadLOK® heavy duty structural wood screws with a coarse thread design, a blank shank diameter of approximately 0.191 in., a flat head with an 8 lobe SpiderDrive(trademark) and a head marking indicating overall length in inches, in various lengths, which are certified to comply with the most recent versions of the International Building Code® and the International Residential Code® and recognized for use in wood chemically treated with waterborne alkaline copper quaternary, type D (ACQ-D), packaged together with a driver bit; or equivalent
- FlatLOK® structural wood screws with a coarse thread design, a blank shank diameter of approximately 0.227 in., a flat head with a #40 TORX® ttap® drive and a head marking indicating overall length in inches, in various lengths, which are certified to comply with the National Building Code of Canada and recognized for use in wood chemically treated with waterborne alkaline copper quaternary (ACQ), packaged together with a driver bit; or equivalent
- LedgerLOK® structural wood screws with a coarse thread design, a blank shank diameter of approximately 0.228 in., a hex washer head with a 5/16" drive or a flat head with a #40 TORX® ttap® drive, and a head marking indicating overall length in inches, in lengths of 3.625 in. or 5 in., which are certified to comply with the most recent versions of the International Building Code® and the International Residential Code® and recognized for use in wood chemically treated with waterborne alkaline copper quaternary, type D (ACQ-D), packaged together with a driver bit; or equivalent
- ThruLOK® structural wood screws with a unique thread design, a Paddle Point(trademark) tip, a blank shank diameter of approximately 0.228 in., a hex washer head with a 5/16" drive and a head marking indicating overall length in inches, in various lengths, which are certified to comply with the most recent versions of the International Building Code® and the International Residential Code® and recognized for use in wood chemically treated with waterborne alkaline copper quaternary, type D (ACQ-D), packaged and used together with ThruLOK® washers and nuts; or equivalent
- KWIK HUS-EZ high-strength self-tapping/undercutting carbon steel screw anchors for cracked concrete, uncracked concrete, seismic, concrete over metal deck, and grouted masonry applications, with a hex washer head, bearing Canadian trademark number TMA1011376 and having the features and characteristics described in Canadian patent number CA2738182, with a diameter of 0.25 in. and lengths ranging from 1.875 in. to 4 in., tested or assessed in accordance with one or more of: ASTM E488 ("Standard Test Methods for Strength of Anchors in Concrete and Masonry Elements"); ICC-ES AC106 ("Acceptance Criteria for Predrilled Fasteners (Screw Anchors) in Masonry Elements"); ICC-ES AC193 ("Acceptance Criteria for Mechanical Anchors in Concrete Elements"); American Concrete Institute (ACI) 355.2 ("Qualification of Post-Installed Mechanical Anchors in Concrete"), or National Building Code of Canada (NBCC) requirement outlined in Canadian Standards Association (CSA) A23.3-14 Annex D as amended or replaced from time to time; or equivalent
- KWIK HUS-EZ P high-strength self-tapping/undercutting carbon steel screw anchors for cracked concrete, uncracked concrete, seismic, concrete over metal deck, and grouted masonry applications, with a pan washer head and Torx® drive, bearing Canadian trademark number TMA1011376 and having the features and characteristics described in Canadian patent number CA2738182, with a diameter of 0.25 in. and lengths of 1.875 in. or 2.625 in., tested or assessed in accordance with one or more of: ASTM E488 ("Standard Test Methods for Strength of Anchors in Concrete and Masonry Elements"); ICC-ES AC106 ("Acceptance Criteria for Predrilled Fasteners (Screw Anchors) in Masonry Elements"); ICC-ES AC193 ("Acceptance Criteria for Mechanical Anchors in Concrete Elements"); ACI 355.2 ("Qualification of Post-Installed Mechanical Anchors in Concrete"), or NBCC requirement outlined in CSA A23.3-14 Annex D as amended or replaced from time to time; or equivalent
- KWIK HUS-EZ E high-strength self-tapping/undercutting carbon steel screw anchors for cracked concrete, uncracked concrete, seismic and concrete over metal deck applications, with an externally threaded stud with hex washer head, bearing Canadian trademark number TMA1011376 and having the features and characteristics described in Canadian patent number CA2738182, with a diameter of 0.25 in. and a length of 1.625 in., tested or assessed in accordance with one or more of: ASTM E488 ("Standard Test Methods for Strength of Anchors in Concrete and Masonry Elements"); ICC-ES AC193 ("Acceptance Criteria for Mechanical Anchors in Concrete Elements"); ACI 355.2 ("Qualification of Post-Installed Mechanical Anchors in Concrete"), or NBCC requirement outlined in CSA A23.3-14 Annex D as amended or replaced from time to time; or equivalent
- KWIK HUS-EZ I high-strength self-tapping/undercutting carbon steel screw anchors for cracked concrete, uncracked concrete, seismic and concrete over metal deck applications, with an internally threaded hex washer head, bearing Canadian trademark number TMA1011376 and having the features and characteristics described in Canadian patent number CA2738182, with a diameter of 0.25 in. and lengths of 1.625 in. or 2.5 in., tested or assessed in accordance with one or more of: ASTM E488 ("Standard Test Methods for Strength of Anchors in Concrete and Masonry Elements"); ICC-ES AC193 ("Acceptance Criteria for Mechanical Anchors in Concrete Elements"); ACI 355.2 ("Qualification of Post-Installed Mechanical Anchors in Concrete"), or NBCC requirement outlined in CSA A23.3-14 Annex D as amended or replaced from time to time; or equivalent
- Hangermate® case hardened carbon steel screw anchors, produced from a single piece of steel, with type 17 gimlet or self-drilling points, diameters ranging from 3/16 in. to 5/16 in., lengths ranging from 1 in. to 4 in., and various heads with threaded rod coupler sizes ranging from 1/4 in. to 1/2 in. or acoustical ceiling eyelets, approved by FM Approvals or Underwriters Laboratory, coated with a zinc plating according to ASTM B633, SC1, Type III (Fe/Zn5), for vertical, horizontal, side or variable mounting in steel or wood and intended for use in hanging applications; or equivalent
- Hangermate®+ case hardened carbon steel screw anchors, produced from a single piece of steel, with diameters of 1/4 in. or 3/8 in., lengths ranging from 1.625 in. to 2.5 in., and internally or externally threaded heads with threaded rod coupler sizes ranging from 1/4 in. to 1/2 in., certified to comply with the most recent versions of the International Building Code® and the International Residential Code®, tested or assessed in accordance with ASTM E488 ("Standard Test Methods for Strength of Anchors in Concrete and Masonry Elements"), ICC-ES AC193 ("Acceptance Criteria for Mechanical Anchors in Concrete Elements"), and ACI 355.2 ("Qualification of Post-Installed Mechanical Anchors in Concrete"), evaluated and qualified by an accredited independent testing laboratory for recognition in cracked and uncracked concrete including seismic and wind loading and for reliability against brittle failure, approved by FM Approvals, coated with a zinc plating according to ASTM B633, SC1, Type III (Fe/Zn5), for vertical mounting in normal-weight concrete, sand-lightweight concrete and concrete over steel deck, and intended for use in hanging applications; or equivalent
- Screw-Bolt+(trademark) case hardened carbon steel anchors, produced from a single piece of steel, with diameters ranging from 1/4 in. to 5/8 in., lengths ranging from 1.25 in. to 8 in., and a hex washer head or a flat head, certified to comply with the most recent versions of the International Building Code® and the International Residential Code®, tested or assessed in accordance with ICC-ES AC193 ("Acceptance Criteria for Mechanical Anchors in Concrete Elements") and ACI 355.2 ("Qualification of Post-Installed Mechanical Anchors in Concrete"), evaluated and qualified by an accredited independent testing laboratory for recognition in cracked and uncracked concrete including seismic and wind loading and for reliability against brittle failure, coated with a zinc plating according to ASTM B633, SC1, Type III (Fe/Zn5) or a mechanically galvanized zinc plating according to ASTM B695, Class 55, for mounting in normal-weight concrete, lightweight concrete, concrete over steel deck, grouted concrete masonry and brick masonry; or equivalent
Additional product information
- Hex socket cap screws and socket cap screws are specifically excluded and hex cap screws as a whole are also excluded
- "Lag bolts" are in actuality considered to be subject lag screws
- There is a difference between wing screws and screws with wings, the former are excluded while the latter are, with the exception of machine screws with wings, included
- Some fasteners designated as "bolts" are in reality subject screws, namely: flange bolts, bin bolts, grain bin bolts, square and hex lag bolts, and stove bolts
Tariff classification numbers
The importation of the subject goods are usually classified under the following tariff classification numbers:
- 7318.11.00.00
- 7318.12.00.00
- 7318.14.00.00
- 7318.15.00.10
- 7318.15.00.49
This listing of tariff classification numbers is for convenience of reference only. Refer to the product definition for authoritative details regarding the subject goods.
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