There are 7 comments (sorted by their types, and the section they are about).
substantive comments
Comment LC-2819 : Introduction editorial comments
Commenter: Duff Johnson <duff@duff-johnson.com> (archived message ) Context: 1. Introduction This Working Draft provides informative gui...
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Comment :Introduction Paragraph 2:
"This document is intended to help clarify how to use WCAG 2.0"
- Remove the world "help". Either the document does or does not "clarify".
"the needs of people with accessibility requirements due to aging."
- This isn't clearly put. Perhaps "…the needs of people who benefit from accessibility technology due to the effects of aging." or some such.
Intro paragraph 3:
"While WCAG 2.0 was designed to be technology-neutral, it assumes the presence of a “user agent” such as a browser, media player, or assistive technology as a means to access web content."
- You should go on to mention at least some of the other web-specific assumptions (like HTTP) in WCAG 2.0, since they are both directly relevant to the application of WCAG2 to non-web ICT and a proximate cause of confusion over the applicability of WCAG2 to non-web ICT.
"…different contexts of use…"
- Go ahead and say: "non-web technologies".
Related issues: (space separated ids)
WG Notes:
Resolution: REGARDING YOUR SUGGESTION
Introduction Paragraph 2:
"This document is intended to help clarify how to use WCAG 2.0"
- Remove the world "help". Either the document does or does not "clarify".
RESPONSE:
To say that this document alone is all that is needed to clarify would mean that there is no role for Understanding WCAG 2.0, nor for any other consultants or experts in the area. This is a tool - but some people who are not expert may need others to help them understand.
Conclusion: Not Accept.
REGARDING YOUR SUGGESTION
"the needs of people with accessibility requirements due to aging."
- This isn't clearly put. Perhaps "…the needs of people who benefit from accessibility technology due to the effects of aging." or some such.
RESPONSE:
Good suggestion: Accepted
Text is changed to
"…the needs of people with accessibility requirements due to the effects of aging."
REGARDING YOUR SUGGESTION
Intro (para 3):
"While WCAG 2.0 was designed to be technology-neutral, it assumes the presence of a “user agent” such as a browser, media player, or assistive technology as a means to access web content."
- You should go on to mention at least some of the other web-specific assumptions (like HTTP) in WCAG 2.0, since they are both directly relevant to the application of WCAG2 to non-web ICT and a proximate cause of confusion over the applicability of WCAG2 to non-web ICT.
RESPONSE:
We mention this specific aspect because it relates to our comment and guidance. We do not see what the HTTP has to do with the specific guidance we provide. For example, whether a document is accessed via http:// or via file:/// doesn’t seem to make a big difference between rules -- but whether it was via a browser did.
Conclusion: Not Accept.
REGARDING YOUR SUGGESTION
"…different contexts of use…"
- Go ahead and say: "non-web technologies".
RESPONSE:
"Contexts of use" is a different domain than what technologies are used.
Conclusion: Not Accept (Please make sure the resolution is adapted for public consumption)
Comment LC-2820 : Intro reference to ISO standards
Commenter: Duff Johnson <duff@duff-johnson.com> (archived message ) Context: 1. Introduction This Working Draft provides informative gui...
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Comment :Intro paragraph 2:
Regarding "Authors and developers are encouraged to seek relevant advice about current best practices…"
- I don't understand why this document avoids mentioning other relevant normative standards for non-Web ICT. There are several such that directly address key areas WCAG2ICT intends to cover, but this draft of WCAG2ICT doesn't even acknowledge their existence. JTC 1, SWG-A should be mentioned here, as should PDF/UA (ISO 14289); both should be added to the References section. PDF/UA should be referenced in the text specifically when discussing documents. I suspect there are other examples as well.
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WG Notes:
Resolution: The task force was not charged with analyzing and commenting on the appropriateness or application of other standards group's work - - and W3C is not in a position, and does not usually comment on, the appropriateness or application of standards from other standard setting bodies. If another standard is cited as a normative part of a W3C standard - then it would be cited - but only with respect to how it would relate to a specific provision in this standard. In this case - WCAG does not normatively refer to other standards, so the task force does not either.
Conclusion: Not Accept (Please make sure the resolution is adapted for public consumption)
Comment LC-2821 : Set of documents confusing
Commenter: Duff Johnson <duff@duff-johnson.com> (archived message ) Context: 2.4. Set of Documents The term Set of documents, as used in...
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Comment :2.4 Set of Documents:
Why are "sets of documents" that are organized by means other than referring to each other or linking not included? I can think of many cases that I don't know how to address based on the definition provided. Some examples that pop immediately to mind...
- A single PDF in which many individual documents have been collated. The sub-documents (if we want to call them that) aren't referenced or linked, but (contra Note 1) they do have semantic significance as a "set" nonetheless because they exist as specific, identifiable, individually targetable (i.e., navigable) pages in a given file. Navigation could occur via bookmarks, scripts, actions, "pages" view (thumbnails)… things not mentioned in WCAG2ICT.
- A PDF with 5 attachments. The attachments are not referenced in the text, nor is a link provided. Is this a "set"? If not, why not? Most UIs would present it as such.
- Multiple PDF files in which bookmarks or actions (not textual references or link annotations) are used to connect one PDF to another (in UI terms).
- An HTML page with links to multiple PDF files - is this an example of a "set of documents"? Does it differ from a set of PDFs deployed together in some other way?
- A PDF in which additional documents (pages or attachments, or rich media annotations) are exposed to the user based on scripting functionality (as opposed to links).
- I take qualifying "set of documents" and republish (bundle) them together into a super-set, thus meeting the conditions for Note 1. Does this mean WCAG2ICT should not apply? Or, does it continue to apply only within each element of the super-set, and not to the super-set itself? Does it matter whether or not the super-set is a "publication" or not?
Related issues: (space separated ids)
WG Notes: These are treated together since the answers are all related
Resolution: QUESTION: Why are "sets of documents" that are organized by means other than referring to each other or linking not included? I can think of many cases that I don't know how to address based on the definition provided. Some examples that pop immediately to mind..."
RESPONSE TO YOUR QUESTION
The definition of SET was carefully crafted to both capture the same sense of the term as intended or equivalent to the use of the term in WCAG -- and to create a clear definition that can be applied in this case. *This is not an attempt to generically define the term "set of applications" or "set of software".* A set of web pages on a website is a (sub)set of content created by a single author, who designed those pages to be collected together in a set. Our definition is meant ONLY to be "the way that 'set of documents/software' should be interpreted when using it to try to apply this success criterion to non-web documents (or software), and our definition carries forward that "designed to be together" concept to non-web documents (and likewise non-web software). With this in mind - the question is not whether there can't be other definitions for the term "set" but whether this success criterion should be enforced for this group of documents or software.
So the comments below are not whether someone (in some general or dictionary context) might consider this a set, but whether a group of documents (or software) should be considered as a set when interpreting the way success WCAG 2.0 criteria would be applied to non-web ICT. That is, which groups of documents (or software) should be subject to the WCAG 2.0 success criteria that refer to sets.
A second issue is whether there is any ambiguity in the WCAG2ICT definition. In your examples, the only ambiguity we find, is where you do not provide any information about the groups of documents (or software).
Finally comments are provided on why we drew the line so that some collections of documents fall intentionally fall outside of the set.
NOTE: Your questions, though not directed to our definition of DOCUMENT, did highlight that our definition of document should be examined.
Answers to your questions and a proposed edit to the definition of "document" are provided below.
QUESTION:
- A single PDF in which many individual documents have been collated. The sub-documents (if we want to call them that) aren't referenced or linked, but (contra Note 1) they do have semantic significance as a "set" nonetheless because they exist as specific, identifiable, individually targetable (i.e., navigable) pages in a given file. Navigation could occur via bookmarks, scripts, actions, "pages" view (thumbnails)… things not mentioned in WCAG2ICT.
RESPONSE
True a single file (a zip, a pst, or a PDF) could contain multiple documents. Our definition of Set of Documents makes is clear that such a collection would not count as a set unless someone 'published them together and linked them all to each other'. This was done specifically to avoid having any random collection of convenience be considered a set and be subject to the WCAG 2.0 success criteria related to sets. People should be able to create collections and release them without having to treat them as if they were an intentional set of things rather than just a collection.
Your comment does raise an interesting question about our definition of document. There is no mention of publishing -- so any hard drive, email program file, or even an email with multiple attachments, would itself meet our definition of 'document'. We are therefore changing the definition BY ADDING THE FOLLOWING PHRASE:
"THAT FUNCTIONS AS A SINGLE ITEM RATHER THAN A COLLECTION,"
so that it reads
<begin definition>
document (as used in WCAG2ICT)
assembly of content, such as a file, set of files, or streamed media THAT FUNCTIONS AS A SINGLE ITEM RATHER THAN A COLLECTION, that is not part of software, and that does not include its own user agent
Note 1: A document always requires a user agent to present its content to the user.
Note 2: Letters, spreadsheets, emails, books, pictures, presentations, and movies are examples of documents.
Note 3: Software configuration and storage files such as databases and virus definitions, as well as computer instruction files such as source code, batch/script files, and firmware, are examples of files that function as part of software and thus are not examples of documents. If and where software retrieves “information and sensory experience to be communicated to the user” from such files, it is just another part of the content that occurs in software and is covered by WCAG2ICT like any other parts of the software. Where such files contain one or more embedded documents, the embedded documents remain documents under this definition.
Note 4: A collection of files zipped together into an archive, stored within a single virtual hard drive file, or stored in a single encrypted file system file, do not constitute a single document when so collected together. The software that archives/encrypts those files or manages the contents of the virtual hard drive does not function as a user agent for the individually collected files in that collection because that software is not providing a non-fully functioning presentation of that content.
Note 5: Anything that can present its own content without involving a user agent, such as a self playing book, is not a document but is software.
Note 6: A single document may be composed of multiple files such as the video content, closed caption text, etc. This fact is not usually apparent to the end-user consuming the document / content. This is similar to how a single web page can be composed of content from multiple URIs (e.g. the page text, images, the JavaScript, a CSS file etc.).
Example: An assembly of files that represented the video, audio, captions and timing files for a movie would be a document.
CounterExample: A binder file used to bind together the various exhibits for a legal case would not be a document.
<end definition>
QUESTION:
- A PDF with 5 attachments. The attachments are not referenced in the text, nor is a link provided. Is this a "set"?
RESPONSE:
See revised definition above.
If the PDF is meant to function as a single entity it would be a document.
If the PDF and the attachments are meant to be a set with the PDF (say a Manual consisting of an introduction and 5 attached policy documents that all interlink with the Introduction) then they would be a set.
If the PDF was an introduction to 5 separate policy documents that happen to be gathered together with the introduction PDF linking to them (one way), then it would be a collection, but not a purpose build set -- according to the WCAG2ICT definition.
These three cases can be (now that we have changed the definition of 'document' thank you ) unambiguously determined by applying the definitions.
The reason why it is defined this way is:
a) If it was an email with its attachments captured as PDF - it should not be considered a set -- because the authors of the documents that are attached could not possibly meet all of the success criteria talk about 'sets of documents' when they had no idea that their documents would later become part of a set; and
b) the author of the email would often not have permission to edit the attachments -- so they could not make them meet the criteria for a set; and
c) we did not want (a) and (b) to combine and make it impossible for anyone to attach things to their email and have them meet the guidelines -- since there is in fact to accessibility issue.
It is not reasonable to expect every collection of docs to meet the success criteria. Most user interfaces would present a collection as a collection; as a group. But they would not DEFINE them as a "set" and WCAG2ICT does not either.
QUESTION:
- Multiple PDF files in which bookmarks or actions (not textual references or link annotations) are used to connect one PDF to another (in UI terms).
RESPONSE:
Again - this might nor might not qualify depending on whether they met all of the conditions in the definition. Each of the parts of the definition of "set" is essential in order to limit the groups or collections of documents (software) that would fall within scope of the success criteria that deal with 'sets' (and are not designed to apply to any random groups or collections).
The definitions were designed such that when a person asked "should this group of documents (or software) in front me have to meet these success criteria that talk about "set of non-web documents" or (set of software)" the answer is YES only when it is important for accessibility for that group to meet those success criteria.
QUESTION:
- An HTML page with links to multiple PDF files - is this an example of a "set of documents"?
RESPONSE:
We are presuming you are talking about an HTML page that is not on the web - or else it would not be a WCAG2ICT issue.
So assuming you mean an HTML page - not on the web...
Again - Not enough information is provided to tell if the HTML page meets the definition. If it meets the definition then yes. If not, then no, for the reasons cited above.
This question appears to be the same as the questions above, just changing the form (technology) of one of the documents. But WCAG and thus WCAG2ICT are technology neutral, so changing the technology of one of the pages will not change the answer.
QUESTION:
- A PDF in which additional documents (pages or attachments, or rich media annotations) are exposed to the user based on scripting functionality (as opposed to links).
RESPONSE:
Only if they are exposed in a manner that meets the definition.
Why do we limit it this way? Because they might be documents created by a different author -- and this author is just linking to them. So they are a collection -- but the authors of those individual docs should not be expected to make their documents work together with other arbitrary documents that this person happens to link to along with theirs.
QUESTION:
- I take [a] qualifying "set of documents" and republish (bundle) them together into a super-set, thus meeting the conditions for Note 1. Does this mean WCAG2ICT should not apply? Or, does it continue to apply only within each element of the super-set, and not to the super-set itself? Does it matter whether or not the super-set is a "publication" or not?
RESPONSE:
WCAG2ICT is not a standard -- so it never applies or doesn’t apply.
But to speak to the general question you ask. If you have a "set of documents" as defined by WCAG2ICT, and you add other documents or "sets" to create a larger collection, the original sets remain sets (as long as you don't break them up) but the larger collection does not become a set. It is a collection of sets and documents.
It does not matter whether you publish them or not. The only way the larger collection would become a set - is if it met the definition of a set itself. To determine that, apply the different parts of the definition. If they are all true, then it would meet the definition of 'set' as it is used in WCAG2ICT.
Note: documents (or software), if deployed separately and later brought together - are usually a group or collection rather than a set.
Also note, If they are a set and are separated, they are no longer a set and do not need to meet the definition of set. (Please make sure the resolution is adapted for public consumption)
Comment LC-2822 : Set of software confusing / narrow
Commenter: Duff Johnson <duff@duff-johnson.com> (archived message ) Context: 2.5. Set of Software The term Set of software, as used in W...
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Comment :2.5 Set of Software:
This section appears to have been sculpted in an attempt to (very narrowly) avoid current implementations of popular document authoring products (such as Microsoft Office). Maybe it snags Apache Open Office (because OO can open one app from another without opening an existing document) - I'm not sure. The details about how to construe a "set" seem ambiguous and arbitrary… and most importantly, I cannot determine how the distinctions offered are substantially relevant to accessibility in any nontrivial sense.
Perhaps one way to make this point is to ask: what sets of real-world software *does* this definition include? Is there an example? And if not, then what is the point of such a definition in the first place?
Or, am I to take away the impression that if Microsoft were to be so foolish as to add a feature that would provide for opening Excel from Word without going to the Start menu then all of a sudden their Office suite meets the definition of "set" in WCAG2ICT… and this is worth highlighting? I just don't get it.
Presumably, the practical effect of such a definition will be to cause implementers to avoid X, Y or Z features that might threaten to appear as "a set" while still delivering "suites" (not "sets") of software to users. I read through the usage of "set of software" in the Notes for various Success Criteria and I'm left fairly confused. The text feels very over-engineered. There appear to be nuances and shades of meaning that simply hint at ways to get into trouble. I got very little enhancement to my own understanding from all the sloshing about.
- Counterexamples, 2nd bullet is missing the words "is to" before "open a document".
- Counterexamples, 3rd bullet. How can it possibly matter how the software is *sold*? Isn't it more a question (I guess) of the installation rather than the procurement?
Related issues: (space separated ids)
WG Notes:
Resolution: RESPONSE:
"Set of Software" was not defined to include or exclude any particular package. Rather it was, in fact, carefully crafted to include software that is a set while excluding collections of software or any groupings of software. MS Office is a collection of programs that are sold separately, and are also sold in an number of different collections, with different combinations of programs included in each. There is no "office" collection that would constitute a set but there are many collections. (Note: the fact that a company only releases one collection does not make it a set either. It must meet the definition)
And yes - a company might package or outfit their program to make it technically fall outside of the definition. However, that would only get them out of the couple of success criteria that deal with "sets" of software. These success criteria just relate to ways to move between the parts, and getting out of these provisions would not change things very much for the author or the user. In fact we note that true 'sets' of software are rare. Mostly we see an integrated software package or a collection of software - where users move between them like they would move between any other software.
REGARDING YOUR QUESTION: - Counterexamples, 2nd bullet is missing the words "is to" before "open a document".
RESPONSE
Accepted - good suggestion. We will add the words.
REGARDING YOUR QUESTION:- Counterexamples, 3rd bullet. How can it possibly matter how the software is *sold*? Isn't it more a question (I guess) of the installation rather than the procurement?
RESPONSE
An example is not definitive - it is an example. The word "sold" does not appear in the definition so it is not a required part. In this example we were pointing out that even though they were sold together, that did not make them a set. Being sold together is not a determining feature. Many things are bundled that are not sets. (Please make sure the resolution is adapted for public consumption)
Comment LC-2823 : Conformance clarifications
Commenter: Duff Johnson <duff@duff-johnson.com> (archived message ) Context: 5. Comments on Conformance WCAG2ICT is not a standard, so i...
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Comment :In general the first two paragraphs are very hard to understand. What's the real value here? Why not state it clearly? I would rewrite the first two paras into one, as follows:
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WCAG2ICT is not a standard, so it is not possible to conform to WCAG2ICT. However, some entities may wish to use the information in WCAG2ICT to help establish standards or regulations regarding accessibility in ICT that are based on WCAG 2.0. While such standards or regulations will need to address matters of conformance themselves, the following notes may be of assistance to those wishing to draft their own requirements:
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Item 1 in the list - Would it not be better to refer to 'levels of compliance" rather than "conformance requirements"? It would seem more in keeping with WCAG 2.0, IMO. Also in the 2nd sentence… change "was" to "is".
Item 2. Is this really necessary? What value does it add?
Item 3 in the list. It's unfortunate that the "i.e." here refers to a web-page - that's precisely what we don't (in principle) need WCAG2ICT to understand. Why not refer to an ATM machine, or a keypad, or whatever?
Item 4 in the list - similar problem to that raised with Item 3 in the parentheticals. C'mon, use a PDF or an ATM machine as an example! Also, the 2nd sentence should begin: "Conformance with WCAG 2.0 requires…."
Item 5 I admire this point - good thinking.
Last paragraph. This is a reasonable re-statement, but I think you should go further to point out that you do not intend a result that would characterize software with a broad brush. After all, if popular product X is fantastically accessible for things that 97% of people care about, but also includes some fancy features used by 3%… maybe those features are non-conforming, but that doesn't really mean the whole application deserves to be tarred and feathered with "Fails WCAG 2.0 (as read via WCAG2ICT)".
Related issues: (space separated ids)
WG Notes:
Resolution: REGARDING YOUR COMMENT:
In general the first two paragraphs are very hard to understand. What's the real value here? Why not state it clearly? I would rewrite the first two paras into one, as follows:
" WCAG2ICT is not a standard, so it is not possible to conform to WCAG2ICT. However, some entities may wish to use the information in WCAG2ICT to help establish standards or regulations regarding accessibility in ICT that are based on WCAG 2.0. While such standards or regulations will need to address matters of conformance themselves, the following notes may be of assistance to those wishing to draft their own requirements:"
RESPONSE:
Accept. Thank you for your suggestion. We will be replacing the first two paragraphs with the paragraph you proposed to make it clearer and more concise.
REGARDING YOUR SUGGESTION:
Item 1 in the list - Would it not be better to refer to 'levels of compliance" rather than "conformance requirements"? It would seem more in keeping with WCAG 2.0, IMO.
RESPONSE:
"Compliance" is not a term that is defined or used in WCAG. So conforming would be more in keeping with WCAG.
Conclusion: Not Accept.
REGARDING YOUR SUGGESTION:
Also in the 2nd sentence… change "was" to "is".
RESPONSE:
RE "was" vs "is": The sentence is talking about what the WCAG Working Group did when the WCAG was created. Specifically it refers to the Working Group's decisions with regard to what level they put specific success criteria into. Since this was done in the past, the term "was" is the correct term.
REGARDING YOUR QUESTION:
Item 2. Is this really necessary? What value does it add?
RESPONSE:
The answer is Yes. This is a very important point in the design of WCAG -- and the wording of the success criteria requires this understanding. Otherwise a document that has no video could not meet the captioning requirement. They meet WCAG because of this understanding - since conformance does not say 'all applicable' provisions, it says 'all provisions'
REGARDING YOUR QUESTION:
Item 3 in the list. It's unfortunate that the "i.e." here refers to a web-page - that's precisely what we don't (in principle) need WCAG2ICT to understand. Why not refer to an ATM machine, or a keypad, or whatever?
RESPONSE:
The answer is that these are observations about the WCAG and its conformance. The WCAG does not apply to those technologies - so we could not include them in this list.
REGARDING YOUR SUGGESTION:
Item 4 in the list - similar problem to that raised with Item 3 in the parentheticals. C'mon, use a PDF or an ATM machine as an example!
RESPONSE:
(same answer as immediately above)
REGARDING YOUR SUGGESTION:
Also, the 2nd sentence should begin: "Conformance with WCAG 2.0 requires…."
RESPONSE:
Accept - Good suggestion. Making that change -- and correcting the typo ("approacheD used IS" should be "approacheS used ARE")
gives us a replacement sentence that reads:
"That is, conformance with WCAG 2.0 requires that the approaches used are supported by assistive technologies.
REGARDING YOUR SUGGESTION:
Item 5 I admire this point - good thinking.
RESPONSE:
Thank you. We will pass the complement on to the WCAG WG.
REGARDING YOUR SUGGESTION:
Last paragraph. This is a reasonable re-statement, but I think you should go further to point out that you do not intend a result that would characterize software with a broad brush. After all, if popular product X is fantastically accessible for things that 97% of people care about, but also includes some fancy features used by 3%… maybe those features are non-conforming, but that doesn't really mean the whole application deserves to be tarred and feathered with "Fails WCAG 2.0 (as read via WCAG2ICT)".
RESPONSE:
Partially agree.
We believe that when something fails it is useful to provide specifics about where it fails. But WCAG2ICT is not something you can conform to and we have not been asked to make comments about what the conformance model for other (non WCAG) standards. So we have said what we could in a way that others can usefully draw conclusions. (Please make sure the resolution is adapted for public consumption)
editorial comments
Comment LC-2827 : High Level Summary
Commenter: No Name <acmpolicyoffice@gmail.com> on behalf of ACM Public Policy Ofc. (archived message ) Context: Document as a whole
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Comment :Re: WC3 Guidance on Applying WCAG 2.0 to Non-Web ICT: Final Draft
Thank you for the opportunity to provide feedback on the Final Draft. We
appreciate the dedicated hard work of the WCAG2ICT Task Force to develop
this document.
To help make this document more useful to a broader audience, we suggest
the addition of a high-level, easy-to-use summary targeted at users who
have little familiarity with WCAG 2.0 requirements and non-web ICT.
We appreciate your consideration of our suggestion.
U.S. Public Policy Council of the Association for Computing Machinery
(USACM)
acmpo@acm.org
http://usacm.acm.org
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WG Notes:
Resolution: The document is a technical one in nature. We attempted to provide the high level summary in the introduction - where we provide a simple statement of the purpose, and an overview of our findings.
Under each success criterion we the provide a simple one or two sentence guidance. Since this document is about how to apply the WCAG 2.0, it is not possible to provide much more high level overview that would not require some knowledge of the document that we are talking about applying.
Once completed we will have an overview page on the W3C WAI site that will contain a high level intro to the WCAG2ICT.
Hopefully these combined will address your need. (Please make sure the resolution is adapted for public consumption)
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