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                     Solicitor-Client Privilege

              By H. Martin Kay, Q.C. and Brenda Johnson

This booklet is intended as a basic guide to solicitor-client privilege. It
is not to be regarded as a substitute for specific legal advice. Persons
who require legal advice should consult with legal counsel.

                           September 2007

                 Solicitor-Client Privilege

Legal professional or solicitor-client privilege is considered a substantive
rule of law, and part of the law of evidence: Descôteaux v. Mierzwinski
(1982, S.C.C.). By successfully invoking privilege, a person is entitled
to resist the disclosure of information or the production of documents
to which an opposing litigant would otherwise be entitled.

Solicitor-client privilege trumps all other claims to evidence. As
recently as 1996 a member of the English House of Lords commented
that legal professional privilege was “the predominant public interest”.
That court has declined to sanction any test which requires a balancing
of interests where privilege applies. The Federal Court of Appeal stated
in 2004 that privilege is not just a rule of evidence but a “fundamental
rule of law”. Its importance is such that opposing counsel who obtain
copies of their opponents’ privileged documents may be disqualified
from acting further: Celanese Canada v. Murray Demolition (2006,

Notwithstanding its importance, however, the principles governing this
significant doctrine remain uncertain in a number of material respects.
Some Canadian courts had not been able to resist the temptation to
suggest the need for some balancing of interests where privilege is
invoked, although the Supreme Court now seems to have rejected this
idea. In making a determination about releasing information subject
to solicitor-client privilege, a judge should order release only when it is
‘absolutely necessary’: Goodis v. Ontario (2006, S.C.C.).

Anglo-Canadian law generally recognizes two categories of legal
professional/solicitor client privilege. Although the same protection
of evidence applies to each and they can overlap, the two categories
operate quite separately: Opron Construction. Co. v. Alberta (1989, Alta.
C.A.). Decisions, including Canadian court decisions, sometimes fail
to distinguish between the two categories of privilege and may even
suggest the requirements of one as necessary to the other; for example
that contemplation of litigation is essential for any claim to privilege
(which it was, several centuries ago).

Two distinct types of privilege apply to legal advice and legal matters:
solicitor-client communication privilege (generally referred to as “legal
advice privilege”) and litigation privilege.

(1) Legal Advice Privilege

The requirements of Legal Advice Privilege are:

1.   the communication must be between the lawyer and client (written
     or oral);

2.   the communication must be connected to obtaining legal, not
     business or other non-legal, advice;

3.   the communication must be confidential (i.e. no strangers present);

4.   there must have been no waiver of confidentiality (i.e. subsequent
     disclosure to strangers).

Lawyers sometimes casually and incorrectly assume that any
communication between a solicitor and a client is privileged. The
privilege is confined, as its title indicates, to legal advice.

The relevant communication or document need not contain legal
advice, provided it forms part of an exchange for that purpose.
Unsolicited legal advice is also protected, provided there is a solicitor-
client relationship. The privilege does not include instructions given to
a solicitor or requests for mere factual information. The key is that the
communication must concern legal advice.

Of particular interest to counsel involved in multi-jurisdictional
transactions is the ability to claim privilege under this category where
the advice sought concerns the laws of another jurisdiction in which
the lawyer is not qualified to practice, say a Canadian lawyer advising
a client on a matter of English or American law. Some Canadian cases
denied legal advice privilege in such circumstances.
(2) Litigation Privilege

The requirements for Litigation Privilege are:

1.   there must have been current litigation or a reasonable
     contemplation of litigation at the time of the communication;

2.   the dominant purpose for the creation of the document must
     have been its intended use in actual or reasonably contemplated

3.   the communication must have been confidential; and

4.   there must not have been any waiver of confidentiality.

The “dominant purpose” test has now been generally accepted in Canada
and it or variants of it have been the source of many of the disputes
over privilege. Many documents have several purposes. Preparation for
litigation must be more than a substantial purpose but it need not be
the sole purpose. The entire communication is either privileged or not
under this heading, and generally cannot be dissected.

This test can, of course, be varied by legislation. In Ontario it has been
varied by the Rules of Court in its application to expert reports, which
enjoy privilege there only if their purpose is use in actual or reasonably
anticipated litigation.

(3) Features/Differences

The principal difference between legal advice privilege and
litigation privilege is that with litigation privilege, fact
gathering and communications with third parties are protected. With
legal advice privilege, the communication must generally be between
the solicitor and the client. Even litigation privilege does not protect
the historical facts themselves, but it should protect all reports and
other documents generated during the investigation process.

There is some dispute as to whether internal exchanges within a
corporate client for the purpose of obtaining legal advice will be
privileged generally or only if the dominant purpose is for contemplated
litigation. The better view is that even an internal client request for
legal advice will generate legal advice privilege.

The requirements of litigation privilege can be altered by legislation.
Rules of court pertaining to expert reports may require that their
preparation be for the sole purpose of litigation, as in Ontario—see
above. However, a significant restriction of the doctrine could raise a
Charter of Rights and Freedoms challenge.

It will be readily apparent that a particular communication might
be privileged under both categories. There is some academic debate
whether the two categories really can overlap or whether litigation
privilege is confined to third party communications (since legal advice
privilege already protects communications between solicitor and
client). The result should be the same, however.

Both categories of privilege require an element of confidentiality in the
communication. There are several aspects to this.

First, confidentiality requires that the persons concerned intend to
maintain the communication as confidential. Privilege can be lost
–waived– if one fails to maintain confidentiality. Not all inadvertent
acts of disclosure will constitute a waiver of privilege, though there
does not have to be a clear intent to waive privilege before it can be

Second, one cannot maintain privilege over something which is not
confidential in nature. For example, if a lawyer is involved in the
execution of documents or is present at meetings with other parties,
there is no privilege with respect to those facts.

Privilege can, however, attach to non-confidential documents which
are assembled for the purposes of litigation, at least with respect to the
copies of such documents in the hands of the lawyer or party preparing
for litigation. This has, in the past, been called the “solicitor’s work-
product” or “barrister’s brief ” privilege: see B (9) below.
                     B. SCOPE OF PROTECTION

(1) All Communications

The privilege, if established, extends to all forms of communication
including faxes, voice mail, email and other information stored on
computers. Even statements of account rendered by a law firm can
be privileged, to the extent that they disclose the litigation work
undertaken or the legal advice sought or given.

(2) Lawyers’ Role

Legal advice or solicitor/client privilege requires that a lawyer be
involved and generally that no others be involved. If others are present
during the conversation, one may lose privilege. Parties with a common
legal interest in the advice, even if not the actual client, can be present.
They must also respect the confidentiality of the communication.
Others giving legal advice to date, such as patent agents, have not been
recognized as akin to lawyers for the purpose of legal advice privilege.

Litigation privilege, on the other hand, does not require the involvement
of lawyers at all. The key is that the communications or other activities
were for the predominant purpose of preparing for litigation, either
existing or anticipated.

While the above seems to be the law, there are cases which imply that
counsel must be involved in order to successfully assert this privilege.
Those cases exhibit some confusion regarding the two categories of

(3) Accident Investigations

Probably the single most contentious aspect of privilege concerns the
investigation of accidents and similar incidents, such as suspected
environmental contamination. Accident reports, investigators’ reports
and similar exchanges most often raise the question whether they were
prepared primarily with litigation in mind. The dominant purpose
must be preparation for litigation, tested at the time of the creation
of the report or other material. However, while the issue is usually
litigation privilege, it may also be appropriate to claim legal advice
privilege, depending upon the circumstances. Legal advice privilege
seems less strict in its test of the document’s purpose, but is more
strict against the involvement of third parties: SNC-Lavalin v. Citadel
General Assurance (2003, Ont. M.).

While each case, the courts emphasize, is fact specific, a reasonable
guide is provided by the rationale for litigation privilege: Ernst &
Young v. Central Guaranty Trust (1998, Alta. Q.B.). The purpose of the
privilege is to protect from disclosure the statements and documents
which are obtained or created particularly to prepare one’s case for
litigation or anticipated litigation. It is intended to permit a party
to investigate freely the facts at issue and determine the best way to
prepare and present the case for litigation. For that reason, at the time
of the document’s creation, preparation for litigation must have been
the dominant purpose.

Courts have said that the dominant purpose is not to be determined by
reference to subsequent developments. If litigation later materializes
it does not retroactively characterize the report, etc. as having been
prepared for the dominant purpose of litigation.

The involvement of in-house counsel in such investigations adds to the
complexity of the analysis. In-house counsel may in that event be more
readily seen as having a separate, non-legal role, as an investigator and
not a lawyer: College of Physicians v. B.C. (2002, B.C.C.A.). However,
when a lawyer is involved those portions of communications containing
advice on legal matters should be protected, even if the investigation
itself is not found to be for the predominant purpose of litigation.

(4) Dissemination Within a Corporation

Otherwise privileged communications do not lose their confidentiality
within a corporation merely by being shared with non-management
employees. Nor are they excluded from privilege merely because they
are between non-management employees.
There was a theory in American law at one time that such
communications had to be with a senior level of management. This has
never been the case in Canadian law and may have been abandoned
in American law as well. As long as the corporation does not lose
confidentiality by disclosure beyond the corporation, wide spread
dissemination among employees ought not to destroy the privilege.

However, wider dissemination greatly increases the risk that persons
will disclose the information or that it will otherwise be seen to have
lost its confidential character. Further, the corporation has to be
careful to ensure that the persons receiving the information have an
interest in obtaining it. If the distribution is to persons who have no
apparent need to know, a court is more likely to find that the necessary
confidentiality was not maintained.

As a practical matter, distribution should be limited to those who need
to know and the number of copies should be limited. Both to ensure
that the confidentiality is not lost and to avoid inadvertent disclosure
which could be harmful, internal copies can be labeled with a warning
that they are privileged and confidential and are not to be copied or
discussed with others except those shown on the distribution list. If
some recipients do not need to keep their copy, the better course is to
take it back or destroy it.

(5) Once Privileged, Always Privileged?

This statement is certainly true about legal advice privilege. It is
qualified in the case of litigation privilege. Because the dominant
purpose has to be for use in litigation, the privilege may be lost after
the litigation which was contemplated is over. Evidence privileged as
preparation for lawsuit #1 will not be privileged against disclosure in
lawsuit #2, unless the latter is a “closely related proceeding”: Blank v.
Canada (2006, S.C.C.).

(6) Extra-Territorial Application

Privilege had been treated as a doctrine of procedural law, not
substantive law, such that it had no application in foreign proceedings.
This aspect is changing as the Supreme Court has stated that privilege
is a substantive rule and not a mere rule of evidence. If it is part of the
substantive law of Canadian common law jurisdictions, it should under
Canadian conflict of law rules be applied by any foreign court applying
the law of such Canadian jurisdictions. Whether or not a foreign court
would accept this characterization of the law of privilege is not clear.

Even if it is still regarded as a procedural rule, foreign courts may
nonetheless be receptive to respecting privilege as understood in
Canadian law, particularly with respect to documents retained in
Canada. That is, though, primarily a matter for the foreign court to

(7) Fraud

No privilege will protect communications in furtherance of a crime
or fraud, whether the lawyer was aware of this or not. This loss of
privilege applies only to crime or fraud. It does not apply to actions
which are merely unlawful, such as torts or breaches of contract.

(8) Not Applicable to All Proceedings

Legal professional privilege, and especially litigation privilege, may not
apply to all proceedings, only those of a judicial or quasi-judicial nature.
For example, it was held in an Alberta case that litigation privilege did
not apply to preparations for proceedings before the Municipal Tax
Assessment Review Board: Alberta v. Ghermezian (1999).

(9) Work Product/Lawyer’s Brief

There is a subset of litigation privilege or legal advice privilege known
as lawyer’s work product or lawyer’s brief privilege. Two aspects are
significant. First, a package of documents assembled by counsel for
litigation may be privileged even though the individual documents are
not. The collection could disclose a strategy or argument. Second, the
need to show strict confidentiality in discussions with, or statements
from, witnesses is relaxed: Strass v. Goldsack (1975, Alta. C.A.).

The privilege which attaches to settlement negotiations and without
prejudice exchanges operates separately from legal advice and litigation
privilege. Some of these communications may also be protected against
disclosure by implied contract between the parties.

Legitimate settlement negotiations are protected from disclosure. The
policy behind conferring privilege here is to encourage settlement and
to avoid or limit litigation where possible.

Documents do not need to be labeled “Without Prejudice” to create
the privilege but it does help to establish a party’s intentions, upon
which the privilege rests. The courts also recognize that some persons
sprinkle these words on documents without much consideration as to
whether it is appropriate. The courts will look behind the label.

The privilege does not apply where there is a dispute whether or not
an agreement was reached or as to the terms of such an agreement.
Whether strangers to the settlement can obtain production of the
correspondence or agreement is in the discretion of the court.


Both categories of privilege should apply equally to the advice and
activities of in-house counsel as they do to independent practitioners.
In R. v. Campbell (1999), the Supreme Court expressly endorsed the
right of in-house counsel to claim privilege. The in-house designation
did not affect “the creation or character of the privilege”. This position
was confirmed more recently in Pritchard v. Ontario (Human Rights
Commission) (2004, S.C.C).

The qualification, which applies to all lawyers, is that in respect of
legal advice privilege in particular the lawyer must have been acting
in his/her capacity as a legal advisor. Even a lawyer in private practice
cannot assert privilege over, say, investment advice given to a client,
or any other non-legal advice. This requirement was reaffirmed by
the Supreme Court in Campbell. The Court noted that government
lawyers, with whom the case was concerned, might be called upon
for policy advice that had nothing to do with legal matters. The court
recognized that a comparable range of functions existed for salaried
corporate counsel. However, where the purpose is to provide legal
services, legal advice privilege can be claimed: Mutual Life Assurance
Co. v. Canada (1988, Ont. H.C.), Homestake Mining v. Texas Gulf
Potash (1976, Sask. Q.B.).

Although there are statements of this principle from the highest courts,
the law here gets murky in its application to particular facts. There are
some cases that seem to say in-house counsel may only assert litigation
privilege, e.g. Gainers v. Canadian Pacific (1993, Alta. Q.B.). That
really would not differentiate in-house counsel from anyone else in the
corporation. As noted above, anyone may assert litigation privilege if
the requirements are met. Even some decisions that agree in-house
counsel may assert either category of privilege reflect an unhappy
inclination to conclude that the work carried out by in-house lawyers is
not legal in nature. While the analysis should be the same for in-house
and outside lawyers, the courts are more likely to find that in-house
counsel is acting in a non-legal capacity if he/she also acts on occasion
in an executive or other capacity for his/her employer.

(1) How to Best Retain Privilege

Recognizing this tendency, one recommended counter measure, which
may not always be practical, is to segregate non-legal work from legal
work. If in-house counsel is involved, say, in business evaluations, it
would be preferable to have these filed separately.

Problems frequently arise over litigation privilege, where the
predominant purpose must be to address anticipated or existing
litigation. The courts seem to be more inclined to find an investigation
under the direction of in-house counsel to be a normal course event
and not subject to litigation privilege. Because of this, corporations
frequently engage outside counsel early after explosions and similar
incidents, and funnel all reports through them to improve the chance
of maintaining privilege. Engaging outside counsel does not ensure
that privilege will be maintained but it does seem to improve the

(2)    Disclosure in           Corporate        Minutes       and      to

(a) Minutes and Similar Records

Legal advice and other privileged information contained in, say, the
minutes from a board of directors meeting are subject to privilege:
CKUA Radio Foundation v. Hinchliffe (1999, Alta. Q.B.). That portion
which contains the privileged communication should for production
purposes be deleted from the producible document (minutes).

Privilege does not protect evidence on collateral matters, such as the
process whereby the advice was given, or the client’s actions as a result
of the advice. Further, where minutes record an action taken upon
legal advice, that is a fact rather than evidence of the advice, and it is
not likely privileged.

(b) Shareholder Access

Perhaps surprising to some, shareholders may have a right of access to a
corporation’s privileged information on occasion. This happens where
the shareholder is pursuing a claim in which it has a common interest
with the corporation, such as a derivative action. This appears to be
an aspect of common property privilege. Where the corporation and
shareholder are adverse in interest, this common property privilege
ought not to apply, at least where the adversity existed at the date of
the communication in question.

There is little case law on this, the leading case being an old English
decision, Gouraud v. Edison Bell Gower Tel. Co. (1888, Ch. D.), but the
principle seems to still be generally accepted by legal writers.

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These same rights of shareholders under American law seem to be
predicated on a fiduciary relationship and they appear to entitle a
shareholder to greater access than under Canadian law.

(3) Disclosure to Interested Third Parties

Commercial arrangements between several parties, such as joint
ventures, may raise “common interest” privilege. This allows parties
similarly situated to exchange legal advice and views among themselves
without losing privilege. Privilege would be lost on the shared
information as among the parties, but should not be lost to outside
persons. Care must be taken, though, to ensure that the sharing parties
do indeed have a common interest and are not just getting along for the
moment. Analysis which demonstrates that there are different interests
will defeat the “common interest” privilege.

The same principle applies whether the disclosure is to an arms length
third party, such as co-venturers in a project, or to those in an affiliate
corporation. In the case of in-house counsel representing both parent
and subsidiary corporations, a Canadian court could well conclude,
as a U.S. court has, that the parties are jointly represented by the in-
house counsel, but this requires an understanding of the scope of the
in-house counsel’s role in the event of conflict between the parent and
subsidiary corporation: Teleglobe Communications Corporation v. BCE
Inc. (2007, U.S. Court of Appeals, 3rd Cir.).

(4) Waiver of Privilege

A party is generally free to waive either legal advice privilege or
litigation privilege. Waiver of without prejudice privilege may require
consensus. The decision to waive is that of the client, not the lawyer.
Waiver generally requires that the client be aware of the privilege and
that he intend to give up the benefit. However, privilege can be lost
through carelessness.

There is a concept of limited waiver, which was recently applied to
protect disclosure to a corporation’s auditors. The waiver only extended
to the auditors: Philip Services v. O.S.C. (2005, Ont. S.C.J., Div. Ct.).

                                                Bennett	Jones	LLP	 13
It frequently happens that, for what seem to be good tactical reasons
at the time, a party chooses to disclose to an opposing litigant a
portion of a privileged communication. Disclosure of part, though,
may automatically result in loss of privilege over the whole document,
whatever the disclosing party intended. When you selectively disclose
portions of a document that are beneficial to you, you have no assurance
that privilege will not be lost on those portions that you intended to
keep confidential.

While the courts now seem to be more accommodating of partial
disclosure, care should still be taken. If the court finds that the other
party may have been misled by partial disclosure, privilege over the
whole document will likely be lost.


While not part of privilege, there are situations in which parties
assume or agree to obligations not to disclose or use documents
outside a particular proceeding. An obvious example is the implied
undertaking which attaches to all documents and information
provided on discovery in civil proceedings. These obligations operate
on very different principles and disclosure is usually at the discretion
of the court to whom the undertaking is deemed to have been given.
However, an undertaking or agreement not to disclose may result in a
party being denied the ability to introduce evidence of a conversation
or document in evidence, much as privilege operates.


As noted at the outset, no other profession enjoys a privilege comparable
to legal advice privilege, nor is there another privilege comparable to
litigation privilege. There are, however, other instances of privilege,
which are just as absolute. Documents in the possession of senior

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government officials, for example, may be privileged under section 34
of the Evidence Act of Alberta.

                     G. KEY CONSIDERATIONS

One cannot masquerade as privileged that which is not, but there are
precautions to best ensure the claim of privilege where it applies:

Identify privilege issues early on. Litigation privilege, for example, is
determined by the predominant intent at the time the document is
created, not by subsequent events.

Apply self-serving labels judiciously. Labeling documents “privileged
and confidential” and memorializing the intent to conduct an
investigation or undertake other activities in preparation for litigation
will assist, though not guarantee, a successful claim of privilege.
The label will also serve as a reminder to others to take care how the
documents are later used or disseminated.

Ensure where possible that communications flow through a lawyer.
This is essential for legal advice privilege and assists in the ability to
assert litigation privilege. If investigations are needed, have counsel
order them. When the reports are to be discussed in-house, have
counsel present them for comment.

Where any lawyer engages in non-legal functions, whether in-house
counsel or in private practice, steps should be taken to segregate those
files or to otherwise differentiate that which is undertaken in a legal
capacity from that done in other capacities.

Manage the dissemination of documents in respect of which privilege
may be asserted, both to ensure that the necessary element of
confidentiality is not lost and to avoid inadvertent disclosure which
could be damaging.

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                           H. CASE STUDIES

The following case studies are intended as a further guide to the nature
and operation of the law of privilege.

      Pritchard v. Ontario (Human Rights Commission) (2004, SCC)
      Legal Advice Privilege

The Supreme Court held that solicitor-client privilege protects
communications between an administrative board and its in-house
counsel, to the same extent as communications with corporate counsel
in the private sector.

Ms. Pritchard had sought production of a legal opinion prepared by
the staff lawyer for the OHRC about her sexual harassment complaint.
She had argued that, as a human rights complainant, she shared a
“common interest” with the Commission in the legal opinion. The
Supreme Court’s most recent commentary on this issue makes clear
the high status given to solicitor-client privilege:

•   the privilege covers “any consultation for legal advice, whether
    litigious or not”;
•   once established, the privilege is “considerably broad and all
•   it attaches to “all communications made within the framework of
    the solicitor-client relationship”;
•   the necessary relationship “arises as soon as the potential client
    takes the first steps.”
The privilege does not extend to communications

(1) where legal advice is not sought or offered;

(2) where it is not intended to be confidential; or

(3) that have the purpose of furthering unlawful conduct.”

•     the privilege is “jealously guarded and should only be set aside in

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     the most unusual circumstances”;
•    the privilege “must be nearly absolute… exceptions to it will be
•    once established, an assessment of the privilege “does not involve
     a balancing of interests on a case-by-case basis.”

     Blank v. Canada (2006, S.C.C.) Legal Advice Privilege and
     Litigation Privilege

Mr. Blank, as a director of a corporation (Gateway), was charged
with many offences under the Fisheries Act. After those proceedings
were stayed, Blank sued the government for conspiracy, perjury and
abuse of its prosecutorial powers. He applied under the federal Access to
Information Act for government records, some of which were refused on
the basis of solicitor-client privilege.

The Supreme Court of Canada held that reference to “solicitor-client
privilege” as an exception to disclosure under the federal Access to
Information Act (s. 23) included both “legal advice” and “litigation”
privileges, as the section incorporated the common law of privilege.
Thus, the decision informs the common law of privilege also.

The Court also held that, although legal advice privilege is not limited
in time, litigation privilege is extinguished when the litigation which
gave rise to it ends, unless the subsequent proceedings are “closely related
proceedings.” “Closely related” is likely to be narrowly interpreted,
meaning separate proceedings with the same or related parties, arising
from the same or a related cause of action, or proceedings that raise
common issues and that share the same purpose.

                                                Bennett	Jones	LLP	 17
    Husky v. MacKimmie Mathews (1999, Alta. Q.B.) Waiver of
    Privilege and Scope of Legal Advice

Various documents were sought in litigation between Husky and a law

(1) Legal opinions given to Husky by their in-house counsel

•   not producible as there was no compelling reason of “fundamental
    adjudicative fairness” to override solicitor-client privilege
(2) Legal opinions summarized in other documents already produced
    (i.e. waiver of privilege)

•   not producible as no express mention of the legal opinion in
    documents so no waiver
(3) “Without prejudice” communications between Husky and another
    party, P.C., in a prior action

•   not producible unless other party, P.C., consents, which they did
(4) Legal opinion prepared by lawyer “C” hired as a landman

•   producible as “C” was not employed as in-house counsel

    Three Rivers District Council v. Bank of England (No. 6) (2004,
    H.L.) Legal Advice Privilege

The House of Lords considered a claim of legal advice privilege made
by the Bank relating to documents prepared for the Bingham Inquiry
in 1991.

The House of Lords allowed the Bank to claim privilege over certain
communications between the Inquiry, three Bank officials and their
outside counsel (Freshfields).

All communications between solicitor and client relating to a
transaction in which the solicitor has been instructed for the purpose
of providing legal advice are privileged, even where they do not contain
advice on matters of law, so long as they are directly related to the
solicitor’s performance of his professional duty as legal advisor to the

Types of communications held to be privileged included advice
concerning the evidence a client will give at an inquiry (“presentational

                                              Bennett	Jones	LLP	 19
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