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					                         NO. A-06-000748              DCI Z/w2DOI


                                                 NEBl8gJ~~S3~ ~P~~AtS
            IN THE NEBRASKA COURT OF APPEALS




                  MBNA AMERICA BANK, NA

                         Plaintiff-Appellee

                                vs.

                      PAUL JOHN HANSEN

                       Defendant-Appellant.




APPEAL FROM THE DISTRICT COURT OF DOUGLAS COUNTY, NEBRASKA

                   Honorable Gregory M. Schatz


  SUPPLEMENTAL BRIEF OF APPELLEE, MBNA AMERICA BANK, NA




                    Prepared and Submitted by:

                    Karl von Oldenburg #20228
                Brumbaugh & Quandahl, P.e., LLO
                                 th
                 4885 South I I 8 Street, Suite 100
                        Omaha, NE 68137
                           402-554-4400
                      Attorney for Appellee
                                 TABLE OF CONTENTS

                                                                                       Page

I.     STATEMENT OF THE FACTS                                                            I
II.    ARGUMENT                                                                           I
            A.    Introduction                                                            l

           B      The Federal Arbitration Act Preempts the Nebraska Uniform
                  Arbitration Act                                                        2

            C.    The Federal Arbitration Act is Applicable to the Parties Contract.     3

           D.     Confirmation of the Award in County Court is Proper                     4

           E.     Nebraska Statutes Confer Jurisdiction upon the County Courts           .5

VII.   CONCLUSION                                                                        6




                                           11
                                  TABLE OF AUTHORITIES


                                       STATE CASES

Cornhusker International Trucks, Inc. v. Thomas Built Buses, Inc.
     263 Neb. 10; 637 N.W. 2d 876 (2002)                             2

Mastrobuono v. Shearson Lehman Hutton Inc.,
      514 U.S. 57; 115 S. Ct. 1212 (1995)                            3

Kelley v. Benchmark Homes, Inc.,
       250 Neb 367; 550N.W. 2d 640 (1996)                           3,4

Dowd v. First Omaha Securities Corporation,
      242 Neb. 347, 495 N.W. 2d 36 (1993)                            .3

Southland Corp. v. Keating,
       465 U.S. 1; 104 S. Ct 852 (1984)                                  3

Smith Barney, Inc. v. Painters Local Union No.1 09 Pension Fund,
       254 Neb. 758, 762; 579 N.W. 2d 518, 521 (1998)                .3

MBNA Bank v. Straub,
     815 N.Y.S. 2d 450 (2006)                                        .4

A1BNA Bank v. Runyan,
      2007 WL776820 (Neb App.2007)                                   5


                                   FEDERAL STATUTES

9U.S.C. §1 etseq                                                      3

9 U.S.C. §9                                                          4


                                     STATE STATUTES

Neb. Rev. Stat. §25-2601 et seq                                          2


Neb. Rev. Stat. §24-517(5)(a)                                       5,6




                                               III
                                 I. STATEMENT OF THE FACTS

           Appellee incorporates its statement of facts included within Appellee's original brief.

For purposes of the limited questions raised by this Court Appellee states the following:

           The Appellant applied for an MBNA America Bank, N.A. credit card account (DCT27).

The credit card agreement involving the credit card account contained an arbitration provision.

The arbitration provision provided any claim or dispute by either party would be resolved by

binding arbitration before the National Arbitration Forum and would be governed by the Federal

Arbitration Act (DCT30 and 32).

           Appellee, as this COUlt has already decided, filed a claim in arbitration (DCT25) and

Appellee was issued a proper award through arbitration (DCT36). Pursuant to the language in

the Federal Arbitration Act ("FAA") Appellee sought to enforce the arbitration award. Appellee

filed its action to enforce the award in Douglas County Court (DCT 76-78).

           The complaint sought to enforce an arbitration award based on breach of contract for the

amount of $10,776.31 (DCT 36).            The compliant referenced enforcement of the award was

pursuant to the FAA. On March 2, 2006 the Douglas County COUlt entered summary judgment

against Appellant and in favor of Appellee in the amount of $10,776.31 plus court costs

(DCT21).

                                            II. ARGUMENT

                                     A.       INTRODUCTION

           The Court of Appeals permitted a re-hearing on this matter for the limited purpose to

decide if Nebraska County Courts are afforded the jurisdiction to confirm arbitration awards. In

the Court's order regarding the hearing, the COUlt presented the parties with four questions to

address.     The first three questions relate to and touch upon the statutory language of the
Nebraska Uniform Arbitration Act ("NOAA"). Neb. Rev. Stat. §25-2601 et seq. The fourth and

last question requests what effect, if any, the Federal Arbitration Act ("FAA"), U.S.C. §1 et seq.

has regarding conferring jurisdiction on the Nebraska County Courts,

        Appellee's main argument relates to the Court's fourth question. The FAA is controlling

and confers jurisdiction upon Nebraska County Courts. Second, the NOAA's reference to

district court is in name only. The Nebraska Legislature has codified that county courts shall

have concurrent original jurisdiction with the district court in all civil actions when the amount is

below a threshold amount. Neb. Rev. Stat. §24-517.

      B.      THE FEDERAL ARBITRATION ACT PREEMPTS THE NEBRASKA

                             UNIFORM ARBITRATION ACT.

       The Nebraska Supreme Court has long recognized the applicability ofthe FAA.

               We [The Nebraska Supreme Court] have acknowledged that the
               FAA created a body of federal substantive law which applies to
               any arbitration agreement within the coverage of the FAA. The
               FAA represents a liberal federal policy favoring arbitration
               agreements notwithstanding any state substantive or procedural
               policies to the contrary. The U.S. Supreme Court has held that
               the FAA not only declared a national policy favoring arbitration
               but withdrew power from the states to require a judicial forum for
               the resolution of claims which the contracting parties have agreed
               to resolve by arbitration. Cornhusker International Trucks, Inc.
               v. Thomas Built Buses, Inc. 263 Neb. 10, 18; 637 N.W. 2d 876,
               883 (2002)


       In Cornhusker International Trucks, IIIC., the Nebraska Supreme Court found that the

FAA preempted Nebraska's arbitration act and any Nebraska limitation to arbitration. The

Nebraska Supreme Court found the specific arbitration clause encompassed all disputes under

the contract, even if counter to Nebraska's laws. Specifically, the Court concluded "the FAA

applies to the agreement before us and that the FAA preempts Nebraska law which conflicts with

the FAA. Arbitration under the [FAA] is a matter of consent not coercion, and the parties are


                                                 2
generally free to structure their arbitration agreements as they see fit." Id @ Neb 19, quoting in

part from Mastrobuono v. Shearson Lehman Hutton Inc., 514 u.s. 57; 115 S. Ct. 1212 (1995).

        The supremacy clause of the U.S. Constitution dictates that state law, including state

constitutional law, is superseded to the extent that it conflicts with federal law. Id. See also

Kelley v. Benchmark Homes, Inc. 250 Neb 367, 373; 550 N.W. 2d 640, 643 (1996). Therefore,

the Nebraska Supreme Court has repeatedly allowed the FAA and its provisions to supercede the

NUAA.

        In Dowd v. First Omaha Securities Corporation, 242 Neb. 347,495 N.W. 2d 36 (1993),

the Nebraska Supreme Court reviewed Nebraska laws holding arbitration clauses void and

unenforceable. The Court in Dowd, in reversing Nebraska's ban on arbitration reviewed in depth

Southland Corp. v. Keating, 465 U.S. 1; 104 S. Ct 852 (1984).          The pivotal United States

Supreme COUtt case change Nebraska's prohibition against arbitration in total and on later cases

in which Nebraska law attempted to limit arbitration. See Cornhusker International, supra. The

basic tenant affirmed in Dowd is the recognition of Congress principal purpose of ensuring that

private arbitration agreements are enforced according to their terms and holding that FAA pre-

empts state laws. Dowd @ Neb. 355, citing Southland. supra.

                C.   THE FEDERAL ARBITRATION ACT IS APPLICABLE TO THE

                                    PARTIES CONTRACT.

       The Federal Arbitration Act, 9 U.S.C. §1, et seq. brings within its purview contracts

involving interstate commerce. Smith Barney, Inc. v. Painters Local Union No. 109 Pension

Fund, 254 Neb. 758, 762; 579 N.W. 2d 518, 521 (1998). The Arbitration Act [FAA] creates a

body of federal substantive law of arbitability, applicable to any arbitration agreement within the

converge of the act [FAA] which trumps any state substantive or procedural policies to the

contrary. !d.


                                                 3
       It is uncontroverted that the facts in this case establish the FAA is the applicable statute.

There is diversity jurisdiction Appellant, a Nebraska citizen and Appellee, a national bank

domiciled in Delaware. The contract at issue relates to and touches upon interstate commerce.

(See Kelley v. Benchmark Homes, 250 Neb. 367, 370; 550 N.W. 2d 640, _                        (1996)

(acknowledging interstate commerce as a threshold to invoke the FAA). See also MBNA Bank v.

Straub, 815 N.Y.S. 2d, 450, 455 (2006) (stating credit card contractual relationships are by their

nature interstate connnerce).   Further, the parties contractually agreed to arbitrate any disputes

pursuant to the FAA.

       Appellee argues that once it is found that the FAA is applicable then the FAA preempts

Nebraska laws with regard to the court ofjurisdiction to enforce.

      D.      CONFIRMATION OF THE AWARD IN COUNTY COURT IS PROPER.

       Pursuant to the FAA, once an arbitrator enters an award in favor of one of the parties, that

party may confirm the award in civil court. 9 U.S.C. §9. The FAA States:

               If the parties in their agreement have agreed that a judgment of
               the court shall be entered upon the award made pursuant to the
               arbitration, and shall specify the court, then at any time within
               one year after the award is made any party to the arbitration may
               apply to the court so specified for an order confirming the award,
               and thereupon the court must grant such order unless the award is
               vacated, modified, or corrected as prescribed in sections 10 and
               II of this title. If no court is specified in the agreement of the
               parties, then such application may be made to the United States
               court in and for the district within which such award was made.
               Notice of the application shall be served upon the adverse party,
               and thereupon the court shall have jurisdiction of such party as
               though he had appeared generally in the proceeding. If the
               adverse party is a resident of the district within which the award
               was made, such services shall be made upon the adverse party or
               his attorney as prescribed by law for service of the notice of
               motion in an action in the same court. If the adverse party shall
               be a nonresident, then the notice of the application shal1 be served
               by the marshal of any district within which the adverse party may
               be found in like manner as other process of court.



                                                 4
In the instant case, the parties contractually agreed to any COUlt with jurisdiction.   Since the

arbitration is a matter of civil contract law and the amount is under $55,000.00, Nebraska County

Courts have jurisdiction to hear FAA arbitration confirmations. This has been confirmed by this

COUlt in the case of MBNA Bank      1'.   Runyan, 2007 WL776820 (Neb App.) (attached to brief and

cited pursuant to Ct. R. of Pract. 2e(4». In MBNA v. Runyan, their Court confirmed an FAA

arbitration commenced in the County COUlt.

    E.     NEBRASKA STATUTES CONFER JURISDICTION UPON THE COUNTY

                                                COURTS.

         In addressing this Court's inquiry regarding if the NUAA confers original jurisdiction

only to Nebraska District Court, Appellee argues Nebraska by operation of law has expanded the

definition of "District Court."    The Nebraska legislature, aware of the NUAA, stated each

County Court shall have the following jurisdiction:

                Concurrent original jurisdiction with the district COUlt in all civil
                actions of any type when the amount in controversy is forty-five
               thousand dollars or less through June 30, 2005, and as set by the
               Supreme COUlt pursuant to subdivision (b) of this subdivision on
               and after July I, 2005.
               (a) When the pleadings or discovery proceedings in a civil action
               indicate that the amount in controversy is greater than the
               jurisdictional amount of subdivision (5) of this section, the county
               court shall, upon the request of any party, certify the proceedings
               to the district COUlt as provide in section 25-2706. An award of
               the county court which is greater than the jurisdictional amount of
               subdivision (5) of this section is not void or unenforceable
               because it is greater than such amount, however, if an award of
               the county COUlt is greater than the jurisdictional amount, the
               county court shall tax as additional costs the difference between
               the filing fee in district court and the filing fee in county court.
         Neb. Rev. Stat. §24-517(5)(a).

When the NUAA was originally adopted there may have been a larger difference between the

district and county courts. Since that date, however, the legislature has expanded the county




                                                    5
 courts jurisdiction.   The Nebraska Legislature has clearly expanded it to include arbitration

 confirmations.

                                         III. CONCLUSION

         This court has previously found that Appellee's arbitration award was true and proper.

TIlls Court further found the confirmation of the award was procedurally correct. On rehearing

this, the Court requested briefs to address the single issue of whether the County Court has the

jurisdiction to entertain confirmation of the award. The FAA conferred jurisdiction when the

parties agreed to confirm an award in any court with jurisdiction. Since this is a civil contractual

matter under $55,000.00, then the County Court did have jurisdiction.

         Similarly even under Nebraska law, the legislature expanded the jurisdiction of the

county court to be concurrent original jurisdiction on any civil matter.      Appellant was given

proper notice of Appellee's intent to confirm the arbitration. Appellant did not object to the

parties choice of forum, Finally, the matter was heard on the merits. At worst, the remedy

would be similar to §25-517 (5)(a) in which the county court shall tax as additional costs the

difference between the filing fee in the district court and the filing fee in county court and

transfer the action to district court for further proceedings.

Dated   this~4 day of October 2007.



                                                   Karl von Oldenburg #20228
                                                   Brumbaugh & g,uandahl, P.C., LLO
                                                   4885 South 118' Street, Suite 100
                                                   Omaha, NE 68137
                                                   402-554-4400
                                                   Attorney for Appellee




                                                   6
                             CERTIFICATE OF SERVICE

       The undersigned does hereby certify that on this ~ day of October 2007, a hue and
correct copy of the foregoing was sent via U.S. mail, first class, postage prepaid, to the
following:

Paul Hansen
1548 Nor1h 19th Street
Omaha, NE 68110
DEFENDANT




                                           7
· 2007 WL 776820                                                                              Page I of 4




  Not Reported in N.W.2d, 2007 WL 776820 (Neb.App.)

  Only the Westlaw citation is currently availabie.

  NOTICE: THIS OPINION IS NOT DESIGNATED FOR PERMANENT PUBLICATION AND MAY NOT BE
  CITED EXCEPT AS PROVIDED BY NEB. CT.R. OF PRACT. 2E.


                                       Court of Appeals of Nebraska.
                                             March 13, 2007.

 Appeal from the District Court for Valley County, Ronald D, Oiberding, Judge, on appeal thereto from
 the County Court for Valley County, Aian L. Bro_dbeck, Judge. Judgment of District Court affirmed.
 Phillip E. Runyan, pro se.

 Margaret A. McDevitt, of Brumbaugh & Quandahl, P.c., L.L.O., for appellee.


 IRWIN, CARLSON, and CASS1'L Judges.


                                              INTRODUCTION


 CARLSON, Judge.
 *1 Phillip E. Runyan appeals from an order of the district court for Valley County affirming the county
 court's order granting the motion of MBNA America Bank (MBNA) for summary judgment and ordering
 Runyan to pay MBNA the sum of $11,324.23.


                                               BACKGROUND

 In 2003, MBNA issued Runyan a credit card, and the terms and conditions of the credit card
 agreement provided for binding arbitration in the event of any dispute. MBNA alleged that after using
 the credit card and making payments on his account, Runyan defaulted, and on May 19, 2004, an
 arbitration award was entered against Runyan In the amount of $11,324.23.

 Subsequently, MBNA filed a motion for summary judgment, stating that no genuine Issue of material
 fact existed and seeking confirmation of the arbitration award. Runyan then flied a response to
 MBNA's motion, stating that summary judgment should not be granted because MBNA failed to
 produce both an original arbitration agreement containing his signature and an original credit card
 application signed by him. Runyan attached two documents to his response: his own affidavit and
 MBNA's responses to his requests for admissions.

A summary judgment hearing was held on November 21, 2005. At that hearing, MBNA entered into
evidence an affidavit by Gregory Canarp, a custodian of MBNA records. Canarp stated that Runyan
applied for a credit card with MBNA and that MBNA issued Runyan a credit card with a credit card
agreement which provided for binding arbitration in the event of any dispute. A copy of the credit
card agreement was attached to Canarp's affidavit.

Canarp testified that there is no written contract showing that Runyan agreed to pay the charges If
MBNA issued him a credit card. Rather, Canarp stated that when an appiication Is submitted by an
individual and accepted by MBNA, the Individual receives a credit card with terms and conditions
which constitute the "agreement" between the parties. Canarp stated that by the terms of the
appiication and the agreement, the individual's use of the credit card constitutes acceptance of the




http://web2.westlaw.com/l.esult/documenttext.aspx?1.Itdb=CLID DB4040823I O&docsam... 10/23/2007
 2007 WL 776820                                                                                    Page 2 of 4


  credit card and its terms and conditions.

  Canarp stated that after receiving the card, Runyan used the card and made payments on his
  account. Canarp stated that subsequently, Runyan stopped making payments and defaulted on the
  agreement, leaving an unpaid balance of $11,324.23. Canarp stated that arbitration proceedings then
  took piace before "the National Arbitration Forum" and that Runyan had the opportunity to present
  evidence and information to "the Arbitration Board." Canarp testified that on May 19, 2004, an
  arbitration award was entered against Runyan in the amount of $11,324.23 and Runyan was sent
  notice of the award.

  Runyan did not present or offer any evidence at the hearing.

  On December 8, 2005, the county court filed an order, finding that no genuine Issues of materlai fact
  existed and that MBNA was entitled to judgment as a matter of law. Accordingly, the court ordered
  Runyan to pay MBNA the sum of $11,324.23. Runyan then appealed to the district court, which
  affirmed the trial court's order.

  *2 Runyan appeals.


                                          ASSIGNMENTS OF ERROR

 On appeai, Runyan contends that the trial court erred by (1) ignoring certain aspects of Canarp's
 affidavit, (2) ignoring his unrebutted affidavit and his response to MBNA's motion for summary
 judgment, and (3) Ignoring MBNA's responses and answers to his discovery requests.


                                           STANDARD OF REVIEW

 Summary judgment is proper when the pleadings and evidence admitted at the hearing disclose that
 there is no genuine Issue as to any material fact or as to the ultimate inferences that may be drawn
 from those facts and that the moving party is entitled to judgment as a matter of law. In reviewing a
 summary judgment, an appellate court views the evidence in the light most favorable to the party
 against whom the judgment Is granted and gives such party the benefit of all reasonable inferences
 deducible from the evidence. The party moving for summary judgment has the burden to show that
 no genuine Issue of material fact exists and must produce sufficient evidence to demonstrate that the
 moving party is entitled to judgment as a matter of law. CernY Y. (Ql]g/i'y,]]O Neb. 706, 708 N.W.Z_Q
 219 (2005).


                                                  ANALYSIS

 Initially, we note that Runyan's assigned errors are not the same errors he argues in his brief. All
 three of Runyan's assigned errors are the errors Runyan stated in his appeal from county court to
 district court. Runyan only argues one of these errors in his brief to this court, specifically that the
 trial court overlooked certain deficiencies in Canarp's affidavit. In addition, Runyan raises two
 arguments in the Instant appeal that he did not raise in the district court: that the county court
 denied him the opportunity to rebut MBNA's arguments regarding binding arbitration and that the
 court overlooked the fact that MBNA failed to prove that the parties entered into an agreement to
 arbitrate any disputes.

To be considered by an appellate court, an alleged error must be both specifically assigned and
specifically argued in the brief of the party asserting the error. White Y. White, 271 Neb."}, 709
N.W.2d325 (2006). Similarly, in the absence of plain error, when an issue Is raised for the first time
in an appellate court, the Issue will be disregarded Inasmuch as the trial court cannot commit error
regarding an issue never presented and SUbmitted for disposition in the trial court. Sti'tte v. Molina,_
271 Neb. 488, 713 N.W.2d 412 (2006). While we recognize that Runyan represented himself
throughout these proceedings, we aiso recognize that a litigant proceeding on a pro se basis Is



http://web2.westlaw.com/result/documenttext.aspx?rltdb=CLID_DB40408231 O&docsalll... 10123/2007
 2007 WL 776820                                                                                 Page 3 of 4


  obligated to follow the same appellate rules and procedures applicable to counsei. Cole Y~J$/)erwoQrJ,
  :Z71Neb,.9S3,.716 N.W.2d 36j200Ji). Finding no plain error, we address Runyan's only allegation of
  error that was both assigned and discussed.

   Runyan argues that the trial court overlooked several deficiencies in Canarp's affidavit. In Canarp's
  affidavit, he testified that as the custodian of records at MBNA, he has the care, custody, and control
  of MBNA's business records pertaining to Runyan's account. Canarp testified that MBNA Issued
  Runyan a credit card, which Runyan used, and that after Runyan defaulted, Canarp examined
  MBNA's records reqardinq Runyan's account and gave Runyan credit for ali payments Runyan made
  and for any items for which credit was due. Canarp also stated that MBNA does not issue credit
  cards with a written contract, but, rather, an individual first fills out an application and submits it,
  and after it is accepted, the individual receives a credit card along with an agreement which specifies
  the terms and conditions of the card's use. Runyan stated that this agreement includes a provision
  for binding arbitration in the event of any dispute. Canarp testified that the indlvldual's use of the
  card is acceptance of the credit card aiong with its terms and conditions.

  *3 Canarp further' stated that after Runyan defaulted, arbitration proceedings took place in
 accordance with the credit card agreement and Runyan had the opportunity to present evidence.
 Canarp testified that on May 19, 2004, an arbitration award was entered against Runyan and Runyan
 was sent notice of the award. Canarp testified that Runyan failed to request vacation of the award or
 Its modification Within 90 days of the service of such award.

 Runyan points to Canarp's testimony and states that the trial court erred in accepting Canarp's
 statements as true, because Canarp failed to attach any proof to support his testimony. We disagree.
 Attached to Canarp's affidavit is an 18-page exhibit showing each and every detail of Runyan's credit
 card account with MBNA, including Runyan's charges, the payments Runyan made, and any credits
 Runyan received, in addition to a copy of the credit card agreement pertaining to Runyan's credit
 card account. A copy of the arbitration award was also attached to Canarp's affidavit. Runyan
 appears to argue that MBNA's summary judgment motion should not have been granted unless MBNA
 produced two written contracts signed by him, one shOWing that he requested a credit card from
 MBNA and the other showlnq that he agreed to arbitration In the event of a dispute.

 A movant for summary judgment makes a prima facie case by producing enough evidence to
  demonstrate that the movant Is entitled to a judgment if the evidence were uncontroverted at trial. At
 that point, the burden of producing evidence shifts to the party opposing the motion. (:J'irIlY v.
 Longley, 2JONeb. 706, 708 N.W.2~ 219 (20.0,'i). When MBNA placed into evidence Canarp's affidavit
 with the above statements, MBNA made a prima facie case by producing enough evidence to
 demonstrate that it would be entitled to a judgment If the evidence were uncontroverted at trial. At
 that point, the burden shifted to Runyan, who failed to put forth any evidence at the summary
 judgment hearing. Although Runyan attached his affidavit to his motion opposing summary judgment,
 Runyan failed to enter his affidavit into evidence at the hearing. For these reasons, Runyan's
 arguments are without merit.

 Runyan also mentions several other alleged deficiencies In Canarp's afftdavlt, including Canarp's
 posslbie use of a hand stamp to place his name on the afftdavtt and Canarp's failure to show his
 address or the city he resides In. Runyan also states that Canarp's signature is illegibie. We have
 reviewed Canarp's affidaVit and conclude that Canarp's affldavlt is not deficient for any of the reasons
 Runyan mentions. Therefore, we conclude that the county court did not err in finding that no genuine
 issue of materiai fact exists or in granting summary judgment in MBNA's favor.


                                              CONCLUSION

After reviewing the record, we conclude that the trial court did not err in granting MBNA's motion for
summary judgment and in ordering Runyan to pay MBNA the sum of $11,324.23. Therefore, the
district court's decision upholding the trial court's order is affirmed.

 *4 AFFIRMED.



http://web2.westlaw.com/result/documenttext.aspx?rltdb=CLID_DB40408231 O&docsam... 10/23/2007
 2007 WL 776820                                                                                 Page 4 of4



  Neb.App.,2007.
  MBNA America Bank, N.A. v. Runyan
  Not Reported in N.W.2d, 2007 WL 776820 (Neb.App.)

  END OF DOCUMENT

                                                      (C) 2007 Thomson/West. No Claim to Orig. US Gov. Works.




http://web2.westlaw.com/result/documenttext.aspx?rltdb=CLID_DB4040823I O&docsam... 10/23/2007

				
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