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Kieran P. Cotter (Trainer) Appeal – Prohibited Substance Referral Dundalk 20th January

The Appeals Body (Division 1), Mr. Justice Nial Fennelly, (in the chair), Mr. John Murphy and Mr. Robert Dore convened in the Offices at the Irish Horseracing Regulatory Board on Friday, 1st July 2022 to consider the appeal of Mr. Kieran Cotter (Trainer) against the decision of the Referrals Committee on 16th May 2022.

On the day, the Referrals Committee found that Mr. Cotter was in  breach of Rule 96(a) and made an order disqualifying the winner, Slade Runner, from first place, the result to be amended accordingly and that both the stake and prize money be forfeited. The Committee imposed a fine of €2,500 in respect of that matter. They also found Mr. Cotter in breach of Rule 148(i) in that the Trainer is responsible for everything connected with the welfare, training and running of all Horses under the care of that Trainer and that Slade Runner had been administered cobalt the day before the race and fined him €5,000 in this regard. They also found Mr. Cotter in breach of Rule 148(iii) in that in that he had failed to maintain his Medicines Register, failed to ensure that he and each of his staff having access to medicines were fully conversant with the rules and regulations relating to Prohibited Substances and that he had failed to be responsible for the safe keeping and administration of medicines having failed to securely lock the medicines cabinet and fined him €20,000 in this regard. The committee also ordered costs of €7,500 to be paid by Mr. Cotter.

The grounds of appeal lodged by Mr. Cotter was the severity of the sanction imposed.

At the Appeal, submissions were made by Mr. Richard Wixted, BL, instructed by Mr. Seamus Ward of James A. Boyle and Co Solicitors, on behalf of Mr. Cotter and by Mr. Louis Weston, Barrister, instructed by Ms. Béibhinn Murphy, BL, on behalf of the Irish Horseracing Regulatory Board.

The Appeals Body reserved their judgement on 16th May 2022 and their written judgement is attached to this press release.

Having considered the evidence, the Appeals Body, increased the fine for breach of Rule 96 to €5,000, removed the fine of €5,000 for breach of Rule 148, unaltered the fine of €20,000 for breach of Rule 148 and dismissed the appeal in respect of the order that Mr. Cotter pay €7,500 toward the costs of the IHRB.




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Delivered 14th July 2022


Appeals Body Members:          

Mr. Justice Nial Fennelly (Chairman),

Mr. John Murphy

Mr. Robert Dore

Parties:                         Mr. Kieran Cotter (the Appellant)

                                    Represented by Mr. Seamus Boyle, James A Boyle & Co

                                    Mr. Richard Wixted B.L.



Irish Horseracing Regulatory Board (IHRB). (Respondent)         

Represented by Ms. Cliodhna Guy, Head of Licensing Legal & Compliance, IHRB

Mr. Louis Weston B.L. & Ms. Bébhinn Murphy B.L.


HEARING OF APPEAL:   Offices of the IHRB on 1st July 2022


  1. This decision relates to the appeal of Mr. Kieran Cotter, Racehorse Trainer, from the decision of the Referrals Committee made on 16th May 2022. The Committee was composed of Mr. Justice Raymond Groarke (Chair), Mr. Peter Allen and Mr. Anthony Byrne. The Appeal was heard on 1st July 2022.

  2. The decision of the Committee arose from two distinct events:
  • The finding of cobalt in excess of the permitted level in the horse, Slade Runner, in a urine sample taken following his winning at Dundalk on the on the 20th of January 2021

  • Findings made on the occasion of an unannounced inspection of Mr. Cotter’s training establishment on Wednesday 3rd February 2021.

  1. The decision of the Referrals Committee, which is the subject of this Appeal, was, in summary:


  • To disqualify Slade Runner from winning the Dundalk race and to forfeit both the stake and the prizemoney. The Committee, in addition, fined Mr. Cotter €2,500 in respect of that matter.

  • To impose a fine of €5,000 in respect of a breach of Rule 148(i), in particular, in that Mr. Cotter administered cobalt in the form of a cobalt drench to Slade Runner;

  • To impose a fine of €20,000 in respect of what it described as “management matters under Rule 148”. In particular this concerned Mr. Cotter’s failure to keep and maintain a Medicines Register as required by Rule 148(iii)(b) but also encompassed a number of acts of breaches of Mr. Cotter’s duties and obligations under the rules, as a trainer.


  1. Cotter submitted an Appeal Form, dated 20th May 2022. He limits his appeal to the severity of the penalties imposed on him, which, he says, are “not proportionate to the misconduct found proved on [his] part, namely the primary breach being that of Rule 148.” In particular he says that the level of penalty imposed, was “unprecedented in the context of a breach of Rule 148(iii)(b).” He also complains of failure to take account of:


  • His evidence that he followed the guidelines for administration of a supplement;

  • His explanation for his oversight in the management of the medicines register:

  • Mitigating circumstances such as his honesty from the start of the IHRB investigation.

  • His difficult financial circumstances.

  1. He also complains of the severity of the decision to require him to bear the costs of IHRB legal representation.

The Appeals Body notes that Mr. Cotter, initially, at any rate, made no   

particular complaint about the fine of €2,500 imposed on him for breach of Rule 96 in respect of the fact that Slade Runner was found, having won at Dundalk, to have an excessive quantity of cobalt in his urine.

  1. The focus is, therefore, virtually entirely on the fine or fines totalling €25,000 imposed in respect of breaches of Rule 148.

  2. It is, in the first instance, necessary to give an account of the facts, which led, firstly, to the disqualification of Slade Runner from the Dundalk race and, secondly, which were disclosed on the occasion of the unannounced inspection of Mr. Cotter’s premises on 3rd February 2021.

  3. A routine urine sample was taken from Slade Runner after his win at Dundalk on 20th On 29thJanuary, the LGC Laboratory notified the IHRB of a positive screening finding for cobalt in that it was present at a level of 119 ng/ml. This meant that the concentration of cobalt exceeded the permitted threshold of 100 The relevant Certificate of Analysis was provided to the IHRB on 3rd February. Mr. Cotter was advised by email on 4th February that the screening finding for cobalt had been confirmed. Following Mr. Cotter’s request for the right to have the B portion of the sample analysed, this was performed by the LCH laboratory in France, which confirmed the positive finding, though at 115 ng/ml.

  4. Cobalt is an essential micronutrient needed for vitamin B 12 syntheses in the equine caecum and colon. Adult horses usually obtain sufficient cobalt from their diet to meet their daily demand. By reason of certain evidence regarding possible effect on performance, as explained by Dr. Lynn Hillyer, Chief Veterinary Officer for the IHRB, in her evidence, Cobalt is regulated in horseracing in Ireland. Dr. Hillyer said that concern can arise when cobalt is administered in large quantities or amounts to exceed the physiological capability of the body and it can have quite severe toxic effects in horses. Thus, Cobalt is a prohibited substance, if present above specified thresholds in urine on race day under Rule 20(v) and Regulation 14 of the Rules. The threshold is 100 ng/ml., expressed as “0.1 microgram total cobalt per millilitre in urine…” This Appeals Body has no function to pass judgment on the justification for this regulation. So far as we are concerned, the threshold is a given and, where it is exceeded in a horse on race day, there is a breach of the Rule.

  5. Following notification of the adverse analytical finding of cobalt in the urine of Slade Runner on 4th February 2021, Dr. Hillyer asked Mr. Cotter to outline the supplements, feeds and medicines to which the horse had been exposed in the week preceding the race. He reported that the horse had had a hind-gut condition accompanied by foul-smelling faeces. He consulted the representative of a company called Natural Nutrition Ltd, who recommended use of a Cobalt Copper Solution, which it supplied, at his request. He said he had administered a dose of 30 mls, by mouth via a dosing syringe on the Monday and Tuesday preceding the Wednesday race day in Dundalk. He later amended his position and said that the dose had been 20 mls. Mr. Cotter took no veterinary advice and did not even inform the company representative that the horse would be running within two days of the doses.


  1. Secondly, it is necessary to return to the unannounced inspection on 3rd Dr. Hillyer explained in evidence that the finding of cobalt in Slade Runner following the Dundalk Race gave rise to concern.

Early in the morning of 3rd February 2021, four officers of the IHRB led by Dr. Hillyer and three officers of the Department of Agriculture, Food and the Marine, (DAFM), led by Mr K. Devlin attended at Mr. Cotter’s premises. They explained the nature of their inspection to Mr. Cotter. Mr. Danny Murphy, Mr. Cotter’s assistant, and two other members of his staff who were present.

  1. All horses on the premises were identified and sampled. The DAFM team carried out an inspection of the premises extending to all buildings. A log was compiled documenting the medications, supplements, topical treatments or veterinary paraphernalia that were found. The Medicines Register was examined, and copies taken of relevant pages.

  2. Numerous used and unused needles and syringes were found in two places on the premises, some in an open cabinet in a wooden shed by the main barn being used as a tack room, and a general store and more syringes and needles in the garage near to the house. Numerous products containing cobalt and/or vitamin B 12 were identified such as “Copper Cobalt Solution,” “TransRight Superplus+,” and “Equine Energiser Solution.” All these were manufactured by Natural Nutrition Ltd. There was also a number of other products.

  3. Laboratory analysis was conducted by LGC. One syringe had clear yellow blood-tinged residue. One had blood in the hub of the syringe.

  4. The Medicines Register was examined both on the day of the inspection and later, following interview of Mr. Cotter. There were no entries relating to Slade Runner on either occasion. The Register was examined by reference to a number of individual horses and found to lack a considerable number of entries. Prescriptions obtained by DAFM and passed on to IHRB indicated that several treatments had been administered to horses in the yard but not recorded in the Medicines Register.
  5. The Appeal Body notes the decision of the Referrals Committee.

         Its ruling stated, at page 103:

“These refer to the management matters under Rule 148 and we are satisfied that Mr. Cotter has been in breach and indeed in serious breach of a number of the provisions under Rule 148. Not least of these is the failure by Mr. Cotter to maintain a Medicines Register as is required by the rule. It is an extremely aggravating aspect of this case that no Medicines Register was maintained for a number of years prior to February 2021…….”

“The evidence in regard to the Medicines Register establishes beyond all reasonable doubt, not just on the balance of probabilities, which we are to be guided by, that the duties and obligations placed on Mr. Cotter have been entirely ignored by him.”


  1. A lengthy passage at page 104 of the Decision details a number of other matters arising from the inspection of 3rd February:

“That this may be the result of a slovenly attitude in complying with the obligations is a benign interpretation given the plethora of other evidence relating to the management and use of medicinal products in the yard. For instance, used syringes and needles were left lying in a number of locations on the premises. Mr. Cotter doesn't believe that these were there. He doesn't know where they came from and he says he never used them; the presence also of a large number of unused syringes and needles in the barn; the apparent general use of veterinary medicines other than under veterinary supervision, effectively Mr. Cotter was self-medicating some of the horses in his care; the administration of intravenous injection contrary to proper procedures; reckless disregard to the potential effects or consequences of administering the cobalt drench to Slade Runner in particular. These are but a selection of the matters of which the IHRB have complaint and we find these complaints are substantiated.”


  1. While, notably, the Committee did not make any finding adverse to Mr. Cotter of breach of Rule 273(xiii), it seems clear that The Committee considered Mr. Cotter to have been in breach of the provisions of Rule 148 on a very broad scale. There was no question, in its view but that “the conduct of Mr. Cotter was of a most serious kind...”


  1. Apart from Rule 96 (the presence of excess Cobalt in Slade Runner at Dundalk) the Committee made a separate finding exclusively under Rule 148, presumably under Rule 148(i):

“...the Committee proposes to deal with the breaches of section 148 as one, and to impose a fine which is reflective of the seriousness with which we view this case and that is a fine of €25,000.”

  1. The subsequent modification of this figure, following intervention by counsel for IHRB, was also exclusively by reference to Rule 148.
  2. In summary, the Referrals Committee imposed penalties on Mr. Cotter as follows:

  3. In respect of the presence of excess cobalt in Slade Runner in the Dundalk Race, it made an order, under Rule 96(a), disqualifying the horse and that both the stake and prize money be forfeited. It also imposed a fine of €2,500;

  4. A fine of €5,000 for administering cobalt contrary to Rule 148;

  5. A fine of €20,000 for various breaches of Rule 148, in particular the failure to maintain the Medicines Register and the unexplained presence of a number of used syringes and needles, which had been left lying in a number of locations on the premises.

  6. Justice Groarke, on behalf of the Committee, said, at first, that the Committee proposed to treat “the breaches of section 148 as one” and to impose “a fine which is reflective of the seriousness of the case.” He proceeded to pronounce that the fine would be €25,000. Counsel for the Board intervened to point out that the fining power of the Committee is limited pursuant to Rule 19A.8(ii) to €20,000. Mr. Justice Groarke then said that the Committee proposed to break down the fine and said that there would be a fine of €5,000 in respect of Rule 148 “in that Mr. Cotter administered the cobalt….without veterinary oversight….” He said that “the fine of €20,000 is in respect of the balance of the matters to which I have referred as breaches of section 148 of the rules.”

  7. The Committee separately ordered Mr. Cotter to pay the sum of €7,500 in respects of the legal costs.
  8. Counsel for Mr. Cotter accepted the findings, which had been made against him by the Referrals Committee.  He complained, however, of one passage in the decision, where the Committee referred to the presence, as found on inspection, of a large number of unused syringes and needles in the barn and in a store and appeared to conclude that this showed an “apparent general use of veterinary medicines other than under veterinary supervision, effectively Mr. Cotter was self-medicating some of the horses in his care...”  Counsel said that this was an inference which the Committee was not entitled to draw. He made two particular points. Firstly, he said that the IHRB, Dr. Hillyer in particular, had accepted that the excess presence of cobalt found in Slade Runner at Dundalk was explained by Mr Cotter’s admitted dosages of the cattle drench from Natural Proteins on the two preceding days. Secondly, counsel said that the other horses, when tested, were found to be negative for the presence of excess cobalt.


  1. Cotter accepts the findings made against him, save for one point concerning inferences drawn from the finding of syringes and needles on the premises. His appeal is limited to complaint about the severity of the penalties imposed on him by the Referrals Committee.

  2. The appeal is taken by virtue of Rule 256 of the Rules, which provides:

“(i) An appeal against any decision of the Referrals Committee…in respect of any person or any other matter may be made to the Appeals Body within 7 days of the original Committee decision. Notice of appeal accompanied by a deposit of €500 and giving the specific reasons for the appeal must be lodged with the Keeper of the Match Book or the Registrar of the I.N.H.S. Committee. Such appeal will be determined by the Appeals Body on the basis of a written or electronically recorded transcript of the hearing. When the Appeals Body are so determining the appellant is entitled to legal representation.
(ii) Where the interests of justice so demand the Appeals Body on the hearing of any appeal (a) either on the application of any party or (b) on their own initiative hear such further oral evidence as they may decide and subject to such terms and conditions as they in their absolute discretion may determine.”

  1. The scope and nature of appeals pursuant to Rule 256 were helpfully considered in two comprehensive written decisions of the Appeals Body in two joined cases of The Turf Club v Edward O’Connell delivered on 16th and 24th July 2014. Each of the decisions was written by Mr. Justice Joseph Finnegan. In the first of those decisions on 16th July, the Appeals Body decided that such appeals to the Appeals Body “should be analogous to that afforded by the Supreme Court on an appeal from the High Court whereby the oral evidence given at the first instance is considered in documentary form.”  On 24th July 2014, the Appeals Body considered the nature of the appeal in detail. It referred to a number of reported decisions of the courts. In view of the limited scope of the present appeal, it will be sufficient to refer to the power of an appeal body to alter or vary conclusions of the tribunal of first instance based on inferences of fact drawn from proven facts.

  2. Generally, courts or tribunals of appeal will not review or amend findings of fact made by courts or tribunals of first instance. This general principle is qualified where the appeal body is asked to overrule or reverse an inference which has been drawn by that body from primary facts as found or agreed. In such a case, it is often considered that the appeal body is in as good a position to determine whether the inference should be drawn as was the tribunal of first instance. The law is well established.

  3. In SS Gairloch [1899] 2 I.R. 1 at page 18 Holmes L.J. said:

“It often happens………………that the decisive finding  is  a  deduction  from  facts  hardly  disputed  or  easily ascertained.  In such a case the appellate tribunal is in as good a position for arriving  at  a  correct  conclusion  as the  judge  appealed  from,  and  it would  be an  undue  restriction  on  the  functions  of  the  former  if  it  were  to hold itself bound by what had been found by the latter.”

  1. To similar effect, in Northern Bank  Finance Company  Ltd  v  Charlton [1979 I.R. 149 at 179 O’Higgins C.J. stated the proposition as follows:

“However, if the finding in question depends on the judge’s view of the evidence  or  on  inferences  he  draws  from  such  evidence,  then  the court  of  appeal,  while  respecting  this  view,  will  nevertheless  disagree if another view or a different inference be the proper one.”

  1. Most pertinently, McCarthy J, in his judgment in what has become the leading modern authority on the subject, namely Hay v O’Grady [1992] 1 I.R. 210 said:

“Inferences of fact are drawn in most trials; it is said that an

appellate court is in as good a position as the trial judge to draw

inferences of fact.  I do not accept that this is always necessarily

  1. It may be that the demeanour of a witness in giving evidence

will, itself, lead to an appropriate inference which an appellate

court would not draw.  In my judgement, an appellate court should

be slow to substitute its own inference of fact where such depends

on oral evidence or recollection of fact and a different inference

has been drawn by the trial judge.  In the drawing of inferences

from circumstantial evidence, an appellate tribunal is in as good a

position as the trial judge.”

  1. In application of these principles to the present case, we are of opinion that the finding of a significant number of needles and syringes in various places on Mr. Cotter’s training establishment was an objective and undisputed fact. It was also unexplained. Mr. Cotter was unable to provide any explanation other than the suggestion that they might have been left behind by a veterinary surgeon, for which there was no evidence. In all the circumstances, this Appeal Body, is in a position to consider the inferences drawn by the Referrals Committee and, if it disagrees, to review them. It might be added that Mr. Cotter did not include this matter in his grounds of appeal. On the other hand, counsel for the IHRB has not objected to our considering this matter. In the event, we are unable to think of any inference from the unexplained finding of the numerous used needles and syringes in two locations on Mr. Cotter’s premises other than that drawn by the Referrals Committee and certainly none which is favourable to the appellant. The finding of so many used needles and syringes is evidence of deplorable carelessness in the management of medicines.
  2. In these circumstances, we turn to consider the contention that the penalties imposed by the Referrals Committee were unduly severe.
  3. We say, without hesitation, that the appellant cannot plausibly complain about the fine of €2,500 imposed in respect of the finding of an excessive level of cobalt in the urine of Slade Runner when he ran and won at Dundalk on 20th January 2021. The minimum fine specified in Rule 96(a) is €1,000. While cobalt is not a substance which is prohibited per se, the threshold or maximum permitted is clearly laid down by Rule 20(v) read with R14. It was the duty of Mr Cotter, like every trainer, to be aware of these provisions including the thresholds. Rule 148 provides that every trainer is to be “responsible………for everything connected with the welfare, training and running of Horses” under his care. An aggravating feature is that Mr. Cotter administered the cobalt drench to the horse, without any veterinary advice on two days immediately before he was due to run at Dundalk. He did not even inform the representative of Natural Protein, from whom he obtained the product, of this fact. In our view a fine of €2,500 was amply within the range of permissible penalty. Indeed, in our view it was unduly moderate. Rule 19C gives power to the Appeals Body to increase any penalty imposed by the Referrals Committee. We believe that the fine should be increased to €5,000 and we so decide.
  4. Having regard to the history of the matter and how the Referrals Committee reached its decision, we propose to consider the other two fines together. Clearly, the principal penalty was the fine of €20,000. There were two elements in the reasoning of the Committee: firstly, the failure of Mr. Cotter to keep and maintain the Medicines Register; secondly, what is referred to, at one point, as “management matters under Rule 148” and elsewhere as “the plethora of other evidence,” and “the balance of the matters….referred to as breaches of section 148.”These appear to arise especially from the unexplained finding of used syringes and needles at various places on the premises.

  5. The Committee clearly took a most serious view of the very general, perhaps not quite total but approximating to total, failure to maintain a Medicines Register. It found that “the duties and obligations placed on M.r Cotter [had] been entirely ignored by him.”

  6. Rule 1(ii) contains a detailed definition of the Medicines Register. Rule 148(iii) provides:

“Each Trainer must keep a completed Medicines Register in the manner prescribed in respect of each training establishment and must ensure that the use of all medicines is carefully recorded in the Medicines Register, including the date and method of administration, treatment or substance administered, amount administered (if applicable) duration of treatment and name and signature of person administering and must be kept up to date at all times…”

  1. On the occasion of the inspection on 3rd February, it was noted that there were numerous examples of the Register not being up to date. There were no entries relating to the administration of cobalt products to any horse. Prescriptions later received by DAFM and passed to the IHRB indicated that treatments administered to several other horses had not been recorded in the Register.

  2. The seriousness of the fundamental failure to maintain the Medicines Register was treated as one by the Committee with the “plethora” of other evidence of breaches of Rule 148 and led it to impose a combined penalty of €20,000. It is difficult to dispute the gravity of these findings. We note, however, that we have very little guidance concerning the previous practice of the Referrals Committee in imposing fines for failure to maintain the Medicines Register.

  3. At this point, we should advert to the simultaneous imposition of the fine of €5,000 for a separate breach of Rule 148 in that “Mr. Cotter administered the cobalt...” Counsel for Mr. Cotter does not object to this finding per se.


  1. Nonetheless, there is a certain degree of ambiguity or inconsistency regarding the imposition of the two separate fines.

  2. As the Referrals Committee firstly pronounced them, they amounted to a single sum of €25,000. The Committee originally intended to treat all the breaches of Rule 148 “as one.” The separate fines arose from the fact that counsel for the IHRB intervened to draw the Committee’s attention to the €20,000 limit. Mr. Justice Groarke responded that the Committee proposed to “break it down.”

  3. Secondly, Mr. Justice Groarke, said there would be “a fine of €5,000 in respect of a breach of section – of Rule—148 in that Mr. Cotter administered the cobalt.” Cotter had already been separately fined for the fact that cobalt was present in Slade Runner’s urine when running at Dundalk and it is not clear that a separate charge had been made against Mr. Cotter of merely administering cobalt. After all, the administration of cobalt to a horse is not an offence per se. The infringement of the rules occurs, as it did in this case, when a finding is made that the threshold has been exceeded.

  4. We must also advert to the mitigating circumstances advanced on behalf of Mr. Cotter. It is principally contended that Mr. Cotter at all times cooperated with the inquiry conducted by the IHRB, that he answered questions put to him at interview and that he admitted or did not contest his breach of the rules. He claimed repeatedly that he had “put his hands up.” These points are contested to a degree. It is pointed out that, at the outset of the hearing before the Referrals Committee, counsel on Mr. Cotter’s behalf sought to have the charges dismissed. This was, in our view, an entirely unmeritorious application. It failed completely. It qualifies Mr. Cotter’s mitigation arguments but, we think, to a very limited degree. On the other hand, it must be said that Mr. Cotter had little possibility of disputing the findings either in relation to Slade Runner’s excess Cobalt, his abject failure to keep the Medicines Register or the discovery of the used syringes and needles. The Referrals Committee clearly took a very serious view of these breaches and were right to do so. In the end of the day, Mr. Cotter is entitled to some limited mitigation.

  5. Similarly, we take note of Mr. Cotter’s admittedly difficult financial circumstances. Such circumstances cannot seriously qualify the power and duty of the racing authorities to impose appropriate penalties for clear breaches of the rules. They could not, for example, qualify in any way the duty of every trainer to maintain the Medicines Register to an appropriate level. No doubt the performance of this duty necessitates the employment of competent clerical staff. But that requirement is inherent in the duty to keep proper records. Impecuniosity cannot mitigate the obligation of a trainer of horses to observe the rules.
  6. In all the circumstances, the Appeals Body has come to the conclusion that it should consider the two fines together. In all the circumstances, it concludes the appropriate fine should be €20,000.  The that will replace the two fines of €5,000 and €20,000.
  7. We do not propose to alter the award of costs. The Referrals Committee has power to award costs and/or expenses pursuant to Rule 267. IHRB requested a sum of €10,000. It was reasonable to award €7,500.
  8. In the result, we decide:          
  • To increase the fine for breach of Rule 96 to €5,000;

  • To remove the fine of €5,000 for breach of Rule 148;

  • To leave unaltered the fine of €20,000 for breach of Rule 148;


  • To dismiss the appeal in respect of the order that Mr. Cotter pay €7,500 toward the costs of the IHRB.

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