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Group 4

COURSEWORK 1
Sim Registration in the Philippines
School of Electrical, Electronics, and Computer Engineering
Mapua University, Muralla St., Intramuros, Manila
October 2, 2019 | ECE70-B2

Abrasaldo, Aubrey Agatep, Errol Ace L. Alterado, Bryant A. Fernando, Bernadette


Mae B. Nicole H.
errolagatep@gmail.co bryant.alterado6@gm
aubreymaeabrasaldo m ail.com brndttfernando@gmai
@yahoo.com l.com

Montemayor, Ma. Niebres, Anna Pambid, Luis Daniel Pascual, Lance


Fatima Iriela A. Veronica D. A. Vincent V.

fatimamontemayor18 annaveroniebres@gm luispambid@gmail.co lancevpascual@gmail


@gmail.com ail.com m .com

Reyes, Carl Francis Valenzuela, John


John M. Renielle F.

reyescarlfrancisjohn jrreniellev@gmail.co
@gmail.com m
Abstract— Subscriber Identity Module (SIM) Card considerable information infrastructure that should
registration has been a major topic for law enforcement in be able to handle numerous sources of data. [6]
fighting crimes and mainly for anti-terrorism. This practice 3. Specter of Surveillance. In its 2014 State of
has been required in some countries. However, many Privacy report, Privacy International noted how
critics say that SIM card registration poses a major threat Zimbabwe’s SIM card registration law essentially
to the privacy of the subscriber. This paper discusses the rendered obsolete the potential for anonymity of
SIM card registration in the Philippines, the laws and bills communications, enabled location-tracking, and
related to it, its advantages and disadvantages, and also significantly simplified communications
some cases related to SIM card registration. surveillance and interception. [4]
4. Disenfranchising the Marginalized. In South
Keywords— subscriber, SIM card, Africa, two competing mobile operators
experienced drops in their customer bases following
I. INTRODUCTION the establishment of a mandatory SIM card
Today, SIM card registration is required in around 90 registration system. [7]
countries. Its purpose in law enforcement, especially when II. OBJECTIVES
fighting crimes and terrorism, is often use by propontents as
sufficient justification for its solid evidence. Furthermore, not In general, the objective of this research are as follows:
only is it costly and difficult to apply in the real world, it also ● To cite the different communication companies in
poses many risks to data protection and every individual’s the Philippines
right to privacy. ● To analyze the advantages and disadvantages of the
sim registration implementation in the Philippines.
The reason behind a mandatory SIM card registration ● To relate any, law, article, or bill regarding the said
system is its ability to prevent crimes and terrorisms in the topic
country. Nigeria's system was proven that unregulated ● To analyze the further improvement and generate
mobile phone use aided in undertaking of crimes such as suggestions about the sim registration in the
robberies, kidnappings, and internet fraud banking. [1] Also, Philippines.
In Ecuador, SIM Registration and mandatory IMEI
(International Mobile Equipment Identity) was implemented The goals of the study are to interpret and simplify the
to address specific crimes such as handset theft. [2] memorandum order, and to propose a version, in which the
objectives will be met.
For increasing public access to mobile-based government III. ARTICLES/LAWS/BILLS
services, proponents also like to cite its potential. In Egypt,
one study made a prototype mobile voting system through HOUSE BILL NO. 7233. An act requiring the registration
country's SIM card registration and it showed an increase in of all users of subscriber identity module cards be it enacted
engagement of citizens in the elections. The Government in by the Senate and House of Representatives of the
Pakistan is considering to use the National ID that features Philippines in Congress assembled:
validated biometric data from mobile registration for
providing access to e-government services. [3] Section 1. Short Title. This Act shall be known as the
“Subscriber Identity Module (SIM) Card Registration
And then there is the narrative that a SIM card registration Act.”
system improves the service delivery capacity of
telecommunications companies and mobile operators. For Section 2. Declaration of Policy. The State recognizes the
instance, the use of registered SIM user data in Nigeria for vital role of information and communications technology
targeted marketing activities is said to have led to an increase in nation building.
in the take-up of offers among customers. [3] A similar
phenomenon was reported to have occurred in Kenya. [4] The introduction of modern telecommunications
technology with the view of providing the wildest
Even though the system has many benefits, it also has information dissemination is greatly encouraged, but
criticisms and flaws and these are as follows: possession of the most modern technology with its
1. Crime-fighting Myth. In 2014, law enforcement tremendous responsibility. Thus, a mechanism must be
authorities there recovered SIM cards supposedly installed to maximize the benefits of modern
used by militants in a terrorist attack. The cards were telecommunications technology and to deter illegal or
eventually traced to unsuspecting individuals with malicious utilization of the same that benefit only a few.
no connection to the incident. [5]
2. Logistical Nightmare. SIM card registration also Towards this end, the State shall require the
poses many implementation challenges to mobile registration of all users of subscriber identity module
service providers and the concerned government (SIM) cards.
agencies. After all, such a system would require
Section 3. Definition of Terms. As used in this Act:
a.) Direct seller - refers to a person, natural or Except in cases where the PTE is the direct seller, the
juridical, who directly, dispenses or sells a SIM card accomplished registration form must be submitted by the
to an end user; direct seller to the concerned PTE within fifteen (15) days
from the date of sale. Failure on the part of the seller to
b.) End user - refers to any individual/subscriber comply under this Section shall constitute a violation of
who directly purchases a SIM card from a direct this Act.
seller;
Section 5. Coverage of Registration. All direct sellers are
c.) Postpaid subscription - refers to the subscription hereby mandated to register the following information in
wherein service is provided by virtue of a prior the SIM card registration form:
arrangement with a public telecommunications a.) Full name, date of birth, gender, and address of
entity, and the end user thereof is billed at the end of the end user appearing in a valid government-issued
the monthly billing cycle according to the user of identification document with photo, SIM card end
mobile service; users shall be required to present the original copy
of any of the following valid government
d.) Prepaid subscription - refers to the subscription identification documents (ID) with photo:
wherein credit is purchased in advance of service 1. Passport;
use. The purchased credit is used to pay for mobile 2. Digitized Social Security Service (SSS) ID;
phone services at the point the service is accessed or 3. Government Service Insurance System (GSIS)
consumed. If there is no available credit then access e-Card;
to the requested service is denied; 4. Driver’s license;
5. Firearms’ License to own and Possess (LTOP)
e.) Public Telecommunications Entity or PTE - ID;
refers to any person, natural or juridical, 6. Professional Regulation Commission (PRC)
government or private, engaged in the provision of ID;
telecommunications services to the public for 7. Integrated Bar of the Philippines (IBP) ID;
compensation; 8. Overseas Worker’s Welfare Administration
(OWWA) ID
f.) SIM - refers to the Subscriber Identity Module 9. Digitized Bureau of Internal Revenue (BIR)
which is an embedded circuit that securely stores the ID;
international mobile subscriber identity and related 10. Voter’s ID;
keys used to identify and authenticate subscribers on 11. Senior Citizen’s card;
mobile devices, such as mobile phones and 12. Person with Disabilities card; or
computers’ 13. Other government issued ID.

g.) SIM card - refers to a removable card into which In the absence of any of the above IDs, a
an electronic integrated circuit is embedded and is National Bureau of Investigation (NBI) clearance,
transferable between different mobile devices; Police clearance, or a Philippine Statistics
Authority (PSA) Certified Birth Certificate with an
h.) SIM card registration - refers to the process of ID picture taken within the last six (6) months prior
recording and verifying mobile phone number and to the purchase of a SIM card shall suffice. The
personal information of a subscriber, by a PTE or direct seller may make further inquiries or require
other direct seller, including the subscriber’s full the submission of additional identification, if
name, date of birth, gender, and address. necessary. The purchase of a SIM card may be
withheld pending submission of the additional
Section 4. Sale and Registration of SIM Cards. - Every requirements.
PTE or direct seller shall require the end user of a SIM
card to represent valid identification with photo to b.) Assigned cell phone number of SIM card(s) and
ascertain the latter’s identity. The PTE or direct seller its serial number.
shall further require the end user to accomplish and sign a In case of end users who are foreign nationals, they
control-numbered registration form issued by the shall register their full name, passport number, and
respective PTE of the SIM card purchased. The address in the SIM card registration form upon
registration form shall include an attestation by the end presentation of the following:
user that the person appearing before the direct seller is i.) For foreign nationals visiting as tourists for not
the same person who accomplished and signed the more than thirty (30) days:
registration form and that the identification documents 1. Passport;
presented are valid and correct. Failure of an end user to 2. Proof of address in the Philippines;
comply with the requirements under this Section shall be 3. Return ticket to own country of the tourist
aground for the PTE or direct seller to refuse the sale and or any other ticket showing the date and
issuance of a SIM card. time of departure from the Philippines; and
4. Any other information as may be required Act and to submit the same to the DICT every six (6)
by the Department of Information and months.
Communications Technology (DICT)
ii.) For foreign nationals staying for more than In case of loss of a SIM card or any change in the
thirty (30 ) days either as workers or students: information contained in the registration form after
1. Passport; purchase of the SIM card, the subscriber shall notify the
2. Full name as indicated in the passport; PTE within forty-eight (48) hours from such loss or
3. Proof of address in the Philippines; change in information. Within fifteen (15) days from
4. Alien Employment Permit issued by the receipt of notification from the subscriber, the concerned
Department of Labor and Employment PTE must notify the DICT of such loss or change in
(DOLE); school registration and ID for information.
students; and
5. Any other information as may be required `All PTEs are required to keep the data of their
by the Department of Information and subscribers and the DICT shall ensure that this data is kept
Communications Technology (DICT). with utmost confidentiality.

Section 6. Submission of Registration Form. The Section 11. Registration of Existing Prepaid Mobile
registration form shall be accomplished in triplicate, and Phone Subscribers. All existing mobile phone subscribers
forwarded by the direct seller to the concerned PTE. The with prepaid SIM cards are required to register with their
concerned PTE shall submit a copy of the duly respective PTE within one hundred eighty (180) days
accomplished registration form to the DICT within fifteen from the effectivity of this Act. An extension period of not
(15) days from the date of sale or receipt of such form longer than one hundred twenty (120) days shall be
from their respective direct sellers. The required allowed upon a valid written request to the DICT.
registration form and copies thereof shall be certified by
the direct seller or any other duly appointed officer of the Failure to register within the prescribed period shall
PTE. authorize the PTE to automatically deactivate its services
to the concerned prepaid SIM card subscriber.
Section 7. Submission of Verified List of Dealers or
Agents. The PTE shall submit to the DICT, within thirty Section 12. Penalties. The following penalties shall be
(30) days from the date of effectivity of this Act, a verified imposed for failure to comply with any of the provisions
list of their current authorized dealers/agents nationwide. of this Act:
The PTE shall submit to the DICT and National (a) If the offense is committed by a PTE, the President
Telecommunications Commission (NTC), every quarter and other executive officers shall be held liable, and the
of each year an updated list of the same. following penalties are imposed:
(1) First offense: a fine of Three hundred thousand
Section 8 Confidentiality Clause. Any information in the pesos (Php 300,000.00)
SIM card registration shall be treated as absolutely (2) Second offense: a fine of Five hundred thousand
confidential, unless access to information has been pesos (Php 500,000.00)
granted upon written consent of the subscriber: Provided, (3) Third offense and subsequent offenses: a fine of
That the waiver of absolute confidentiality shall not be One million pesos (Php 1,000,000.00) for every
made a condition for the approval of subscription offense.
agreements. The confidentiality clause in the SIM card (b) If the offense is committed by a direct seller, a penalty
registration shall take effect at the point of sale. of suspension of its operation and a fine of Five thousand
pesos (Php 5,000.00) to Fifty thousand pesos (Php
Section 9. Disclosure of Information.. Notwithstanding 50,000.00) shall be imposed.
the provisions of Section 8 hereof and in accordance with (c) If the offense is committed by an officer or employee
Sec. 12(e) of Republic Act No. 10173, otherwise known of an implementing agency under this Act, a penalty of
as the “Data Privacy Act of 2012”, the PTE or the DICT suspension or dismissal from service and a fine to be
shall be required to disclose the full name and address determined by the court shall be imposed without
contained in the SIM card registration, upon a duly issued prejudice to the filing of an appropriate criminal, civil
subpoena or order of a court upon a finding of probable and administrative case.
cause, or upon written request from a law enforcement
agency in relation to an ongoing investigation, that a Section 13. Implementing Rules and Regulations (IRR). –
particular number is used in the commission of a crime or Within ninety (90) days from the effectivity of this Act,
that it was used as a means to commit an unlawful act. DICT, in coordination with the NTC and other concerned
agencies, shall promulgate rules and regulations and other
Section 10. SIM Card Register. All PTEs are required to issuances as may be necessary to ensure the effective
maintain a SIM Card Register of their subscribers implementation of this Act.
containing information required under Section 5 of this
Section 14. Transitory Provision. Only direct sellers who - Globe Telecom, commonly shortened as Globe, is a major
have been duly authorized by the PTEs and the NTC, shall provider of telecommunications services in the Philippines. It
be allowed to sell prepaid SIM cards. Upon the effectivity operates one of the largest mobile, fixed line, and broadband
of this Act, all PTEs are mandated to recall all prepaid networks in the country. Globe Telecom's mobile subscriber
SIM cards for sale to the public by those establishments base reached 60.7 million as of end-December 2017, down
not authorized by it. Otherwise, they shall be imposed the 3% from the 62.8 million subscribers reported a year ago.
penalties prescribed in this Act.
- Smart Communications, Inc., commonly referred to as
Section. 15. Separability Clause. Should any part of this Smart, is a wholly owned wireless communication and digital
Act be declared unconstitutional or invalid, other services subsidiary of PLDT Inc., a telecommunications and
provisions hereof that are not affected thereby shall digital services provider based in the Philippines. The
continue to be in full force and effect. company has 58.3 million mobile subscribers on its GSM
network as of 2017 , under the brands Smart, Sun, and TNT.
Section 16. Repealing Clause. All laws, decrees, Smart’s wireless broadband subscribers number 3.8 million
executive orders, proclamations, rules and regulations, under the brands Smart Bro and Sun Wireless Broadband.
and issuances, or parts thereof which are inconsistent with
the provisions of this Act, are hereby repealed, amended, 3. SIM Replaceability. Sim registration comes together with
or modified accordingly. sim deactivation. In case of any loss or damage, it can be
requested for deactivation since it is named after you.
Section 17. Effectivity. This Act shall take effect fifteen Afterwards this request, it can be replaced with the same
(15) days after its publication in the Official Gazette or in number. By this condition, no more alibis can be made (in
any newspaper of general circulations.. case of investigations) since it can be replaced.

IV. ADVANTAGES AND DISADVANTAGES DISADVANTAGES

Sim card registration is already implemented in almost 1. More resources and manpower. Even though it is
90 of the countries in the world. Mainly, the reasons that were technically doable on our country, the process will be long,
analyzed for its implementation are the terrorist attacks and considering the number of prepaid subscribers in the
crimes in most cases. Recently last year, this bill has sprung Philippines. This requires telecommunication companies
after its final reading in the House of Representatives, named more resources and manpower since they will be handling the
the House Bill 7233 or the Subscriber Identity Module (SIM) process of registration and deactivation as well.
Card Registration Act. Of course, not only the sim card
subscribers can be affected by this but also the PTE or Public 2. Identity Falsification. Even though there is sim registration
Telecommunication Entity, the telecommunication services present, it is without doubt that there will still be people who
provider to the public. The sim registration will work by a will fake their identities by showing fake documents. The
sim card registration form and by presenting a government- solution for this is to base the data on a national ID system
issued document or ID with the holder’s photo. Providing a basis which is another topic to begin with.
lot of advantages also comes with a lot of disadvantages and
stated below are the pros and cons about the sim registration 3. Market Sales. As we all know, SIM cards can be purchased
in the Philippines. easily in stores and shops in our country but with the
implementation of sim card registration, the sales will be
ADVANTAGES handled by the telcos itself since there is a registration
required.
1. Proper Accountability. People will be more accountable of
his/her actions knowing that it can be traced to the owner’s 4. Market Numbers. With sim registration implemented,
name. This form of registration is like registering a vehicle there will be fewer numbers of activated SIM cards which is
and a formal ownership of the sim card. This is significant for the basis for subscriber figures in marketing. Also, going
the cases of threats, scam or defraud. By this way, it can back to the past system, when a SIM card is lost or damaged,
easily be traced and reported in case of any misconduct acted it still counts as one in the subscriber figure because it has a
by an anonymous number upon another. status of “activated” still even though it is not active already.
Since sim registration also proposes deactivation, the
2. Current Implementation. SIM registration is already subscriber figure in the market will be less than the usual and
ongoing in the Philippines but for only postpaid subscribers. affected.
This current event proves that it is technically doable in our
country, even for prepaid subscribers. As of now, there are Looking at the advantages and disadvantages of this house
already 2 million postpaid subscribers who had their SIM bill still proposes the further study and considerations before
cards already registered. Below are the top it can be passed. Opinions about this issue are still divided
telecommunication companies who provide SIM cards to the among the masses but as long as it will be helping the
subscribers. Philippines evolve to modernization and country security, it
must be well considered.
V. CASES The National Privacy Commission (NPC) has caused Globe
Telecom, Inc. to enforce more stringent subscriber
The following articles/ publication material depicting verification protocols to better protect its customers
committed crimes using cellular or mobile phones which following reports that one of its prepaid mobile customers
were classified as to whether it is an act of identity theft fell victim to identity theft, made possible through the
or cyber fraud. perpetrator that resulted in the unauthorized access to the
customer’s online banking account.

65 Charged for Globe Telecom theft, fraud In a move to bar cyber-thieves from exploiting mobile
Identity Theft/Cyber Fraud authentication as a backdoor for fraudulent transactions, the
NPC took Globe to task for security gaps in its SIM
In 2015, In an incident connected with Globe, a man fell replacement procedures.
victim to identity theft and almost lost P48,000 through
an online bank transfer. His Facebook post about the “A SIM card in the hands of a cyber thief makes mobile
experience has become viral. authentication meaningless, as it becomes almost like a
master key for committing all sorts of identity fraud. It
Ian Caballero, a Globe postpaid subscriber, reported on leaves the victim’s personal data vulnerable to all sorts of
July 2 that his SIM card did not have any signal and misuse and abuse, including access to email and Facebook
requested for a replacement. However, the Globe operator accounts, and unauthorized ATM and online bank
told him that someone had already processed a SIM withdrawals. As gatekeepers of mobile authentication, we
replacement a few hours before his call. are asking Telco providers to upgrade their security
measures,” said Privacy Commissioner and Chairman
Caballero immediately ordered the operator to cancel the Raymund Enriquez Liboro.
active SIM card since all his online accounts were
connected with the number. After recovering all his In processing SIM replacement requests, Globe said it shall
accounts, Caballero received an email from his bank require subscribers to present government-issued ID cards
informing him of P48,000 transfer to another local bank. as identity credential or the original SIM bed as proof of
Fortunately, the transfer was not cleared and Caballero ownership.
recovered the money.
According to Liboro, “We hope to see all telco operators in
Anton Bonifacio, vice president for information security at the country enforcing stringent measures to protect the
Globe, said they are looking at the case as a “targeted attack” privacy interests of their subscribers not just against mobile
since the perpetrator submitted all the necessary verification identity thieves but against all sorts of mobile fraudsters.
requirements to change SIM cards. Fraudsters thrive by being one step ahead of the game. Their
fertile criminal minds exploit gaps in processing systems to
execute their plan. We can beat them to it with more
“Nag-submit ng documents, may authorization letter, SSS ID proactive steps like this and reacting quickly to fraud,” he
ng subscriber namin, driver’s license so talagang nag- said.
request ng change SIM. So sinunod talaga 'yung verification
processes namin kasi meron siyang documents,” Bonifacio SIM swapping refers to the modus operandi where
said. fraudsters illegally obtain from a telco operator a
replacement SIM card not belonging to them and then use
(All documents were submitted, there was an authorization the number for fraudulent activities.
letter, the subscriber’s Social Security System ID, driver’s
license, so verification processes were really followed.) “Personal identity thieves and fraudsters start their schemes
by collecting as much data about you as possible. They
could be stalking your Facebook account, sending you
NBI investigators have already requested for the CCTV phishing emails, or posing as credit card agents asking very
footages from the store where the Caballero’s SIM card was detailed personal information. The risk these people pose is
replaced. very real: your name can carry real financial value. Once
these people commit crimes in your name, it can be very
difficult to recover. Let’s stop feeding these schemers.
Probers are still investigating how all the victim’s vital
Don’t share personal details on social media; transact only
information were obtained but have yet to release a statement
with privacy-compliant business agents who will seek your
regarding the case.
consent before asking for any personal data,” Liboro added.

VI. CASE RESOLUTION


NPC makes telco take measures against SIM-swap fraud;
public warned on identity theft
65 Charged for Globe Telecom theft, fraud
Identity Theft Identity Theft/Cyber Fraud
The problem focuses on an identity targeted attack to Ian VIII. REFERENCES
Caballero who is a Globe postpaid subscriber. As we [1] M2SYS Technology. (n.d.). Fingerprint Biometric Based
know, postpaid subscribers are registered to a SIM Card Registration System Deployed in Nigeria.
telecommunications company and are required to pass Retrieved from http://www.m2sys.com/blog/wp-
identity validations like IDs issued by the government, content/uploads/2015/07/Case-Study-SIM-Card-
and other required documents to avail a postpaid Registration-System-Deployed-in-Nigeria-BioPlugin.pdf.
subscription plan. However, the problem showcased a [2] GSMA. (2016, April). Mandatory registration of prepaid
breach in the system wherein the identity of a subscriber SIM cards: Addressing challenges through best practice.
has been compromised. Although this shows that Retrieved from https://www.gsma.com/publicpolicy/wp-
scenarios like this may arise if ever prepaid subscribers content/uploads/2016/04/GSMA2016_Report_MandatoryRe
register their identity to a system, there are ways to gistrationOfPrepaidSIMCards.pdf.
prevent this from happening. One mistake made by globe [3] GSMA. (2013, November). The Mandatory Registration
is that they did not verify the caller who requested for a of SIM Card Users: A White Paper. Retrieved from
sim transfer. They should always validate the identity of https://www.gsma.com/publicpolicy/wp-
their customers to prevent such cases from happening. On content/uploads/2013/11/GSMA_White-Paper_Mandatory-
the side of the customers, they should not share too much Registration-of-Prepaid-SIM-Users_32pgWEBv3.pdf.
of their personal information on social media and other [4] Donovan, K. P., & Martin, A. K. (2014, February 3). The
platforms. Rise of African SIM Registration: The Emerging Dynamics
of Regulatory Change. Retrieved from
https://firstmonday.org/ojs/index.php/fm/article/view/4351/
NPC makes telco take measures against SIM-swap fraud; 3820.
public warned on identity theft [5] Suman, V. (2014, December 19). Peshawar School
Identity Theft Attack: 4 Suspects Arrested In Bahawalpur, Pakistani
Taliban Used Woman’s SIM Card. Retrieved from
http://www.ibtimes.com/peshawar-school-attack-4-suspects-
Just like in the previous case, sim card registrations may
arrested-bahawalpur-pakistani-taliban-used-womans-
open up opportunities for identity fraud and other crimes
1763334.
involving the identity of a subscriber. To update their
[6] GSMA. (2013). The Mobile Economy 2013. Retrieved
security, telecommunication companies must require the
from https://www.gsma.com/newsroom/wp-
person requesting a replacement card for an affidavit
content/uploads/2013/12/GSMA-Mobile-Economy-
attesting to the truth of the loss of the SIM card. Also to
2013.pdf.
prevent sim swapping, people should stop oversharing
[7] Privacy International. (2014). The State of Privacy 2014.
personal information on social media as well as with people
Retrieved from
who they barely know. Continuing this improving security
https://privacyinternational.org/blog/1509/state-privacy-
on the postpaid side, we hope it will allow us to open up the
2014.
possibility of prepaid sim card registration in the future in
[8] Committee Report No. 621. (n.d.). Retrieved from
our country.
http://www.congress.gov.ph/legisdocs/first_17/CR00621.pd
f.

VII. CONCLUSION
Based from the information in this paper, the
implementation of SIM Card registration is somewhat hard
considering the number of subscribers in the Philippines and
some of those own many SIM cards unless all of the SIM
cards will be deactivated resulting to everyone having
registered before acquiring a SIM. It’s only a matter of time
when this law will be imposed because it’s already approved.
This law will have a great effect on our society as it can
prevent terrorism and make the subscribers more responsible.
However, it can also have a negative effect especially in
terms of privacy. Everything has its own advantages and
disadvantages, and in terms of SIM card registration, it’s only
in the matter of implementation if it will be successful in law
enforcement activities or it only paves way for criminals to
do harm using this technology.

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