Anti–Electoral College forces achieved a significant victory today. The state senate in elector-rich California has voted to join the controversial National Popular Vote movement. Bill advocates in the state senate plan to send the bill to the assembly immediately; they hope that NPV can be re-approved there and forwarded to the governor, perhaps by the end of the day. (The assembly already approved the measure, but needs to re-approve it due to minor senate amendments.) Gov. Jerry Brown is expected to sign the bill and make California the ninth entity to join NPV.
To date, seven states plus D.C. (for a total of 77 electors) have agreed to NPV’s plan. California’s participation would provide a giant boost, bringing the new total to 132 electors — nearly halfway to the 270 electors needed to essentially eliminate the Electoral College.
NPV strived for the appearance of bipartisanship in California. They worked particularly hard to get Republicans on board, and initially obtained a few Republican co-sponsors for the legislation. Ultimately, however, the senate Republican co-authors had their names removed from the bill and voted “no,” along with one Democrat and every other Republican senator (except one, who abstained). Even in the assembly, Republican enthusiasm for the bill waned over time. In the end, only four Republican assemblymen voted for the measure.
The NPV campaign rests on two assumptions: First, that “only swing states” matter under the Electoral College system; second, that a direct-election system will eliminate this focus and ensure that voters everywhere are considered in presidential campaigns.
The first assumption is questionable, at best, and the second is simply wrong.
An honest assessment of American history shows that no state is permanently “safe” or “swing.” California is often viewed as irreversibly Democratic, but Republican candidates such as George H. W. Bush, Ronald Reagan, Richard Nixon, and Gerald Ford might disagree. Each won the state. Indeed, even the George W. Bush campaign spent time in California in 2000, thinking that it might be able to win. History shows that political parties don’t (and can’t!) ignore any state for too long without feeling the ramifications at the polls.
Moreover, despite NPV’s rhetoric, presidential candidates won’t suddenly begin visiting every single precinct in every corner of the country if a direct election system is implemented. Candidates have limited time and resources, and they must be more pragmatic. They will strategize. Since their goal would be “the most” individual votes, they will rationally go where the most individuals are: Urban areas. Rural areas (yes, even in a big state such as California) will suffer.
California legislators wanted to pretend that they’ve helped Republicans and Democrats alike by approving NPV’s radical proposal. Their plan is non-partisan, alright. It hurts voters of every political party, nationwide.
— Tara Ross is the author of Enlightened Democracy: The Case for the Electoral College.
One critical issue invariably overlooked in the NPV debate is vote count accuracy and precision, and provision for verification and recount. Will there be national standards for how votes are cast, counted and certified? How close must the vote be before there is a recount? Who pays for the recount and how is it conducted? There have been numerous catastrophes regarding state-wide vote certification since 2000. (Florida, Minnesota, Washington, etc.) How will this play out in 50 States simultaneously and with no controlling legislation?
Reply to this commentLinkReport AbuseThe U.S. Constitution specifically permits diversity of election laws among the states because it explicitly gives the states control over the conduct of presidential elections (article II). The fact is that the Founding Fathers and the U.S. Constitution permits states to conduct elections in varied ways. The National Popular Vote compact is patterned directly after existing federal law and requires each state to treat as "conclusive" each other state's "final determination" of its vote for President.
Current federal law (Title 3, chapter 1, section 6 of the United States Code) requires the states to report the November popular vote numbers (the "canvas") in what is called a "Certificate of Ascertainment." They list the electors and the number of votes cast for each. The Congress meets in joint session to count the electoral votes reported in the Certificates of Ascertainment. You can see the Certificates of Ascertainment for all 50 states and the District of Columbia containing the official count of the popular vote at the NARA web site at External Link
Recounts are far more likely in the current system of state-by-state winner-take-all methods.
The possibility of recounts should not even be a consideration in debating the merits of a national popular vote. No one has ever suggested that the possibility of a recount constitutes a valid reason why state governors or U.S. Senators, for example, should not be elected by a popular vote.
The question of recounts comes to mind in connection with presidential elections only because the current system so frequently creates artificial crises and unnecessary disputes.
A nationwide recount would not happen. We do and would vote state by state. Each state manages its own election and recount. The state-by-state winner-take-all system is not a firewall, but instead causes unnecessary fires.
Given that there is a recount only once in about 160 statewide elections, and given there is a presidential election once every four years, one would expect a recount about once in 640 years under the National Popular Vote approach. The actual probability of a close national election would be even less than that because recounts are less likely with larger pools of votes.
The average change in the margin of victory as a result of a statewide recount was a mere 296 votes in a 10-year study of 2,884 elections.
No recount would have been warranted in any of the nation’s 56 previous presidential elections if the outcome had been based on the nationwide count.
The common nationwide date for meeting of the Electoral College has been set by federal law as the first Monday after the second Wednesday in December. Under both the current system and the National Popular Vote approach, all counting, recounting, and judicial proceedings must be conducted so as to reach a "final determination" prior to the meeting of the Electoral College. In particular, the U.S. Supreme Court has made it clear that the states are expected to make their "final determination" six days before the Electoral College meets.
Reply to this commentLinkReport AbuseSo the idea here is that voters from the other 45 States would have no recourse if they felt that organized vote fraud in 5 States accounted for sufficient fraudulent votes being tallied for the popular vote winner to exceeded the margin between the two candidates?
Reply to this commentLinkReport AbuseNeither the current system nor the National Popular Vote compact permits any state to get involved in judging the election returns of other states. Existing federal law (the "safe harbor" provision in section 5 of title 3 of the United States Code) specifies that a state's "final determination" of its presidential election returns is "conclusive"(if done in a timely manner and in accordance with laws that existed prior to Election Day).
The National Popular Vote compact is patterned directly after existing federal law and requires each state to treat as "conclusive" each other state's "final determination" of its vote for President. No state has any power to examine or judge the presidential election returns of any other state under the National Popular Vote compact.
Reply to this commentLinkReport AbuseSo no matter how badly another state cheats, the other states have no say in the result.
NPV manages to combine the worst features of both the electoral college and popular voting.
Reply to this commentLinkReport AbuseThe National Popular Vote bill would guarantee the Presidency to the candidate who receives the most popular votes in all 50 states (and DC).
The National Popular Vote bill is a state-based approach. It preserves the Electoral College and state control of elections. It changes the way electoral votes are awarded in the Electoral College. It assures that every vote is equal and that every voter will matter in every state in every presidential election, as in virtually every other election in the country.
Under the National Popular Vote bill, all the electoral votes from all the states that have enacted the bill would be awarded, as a bloc, to the presidential candidate who receives the most popular votes in all 50 states and the District of Columbia. The bill would take effect only when enacted by states possessing a majority of the electoral votes -- that is, enough electoral votes to elect a President (270 of 538).
Every vote, everywhere, would be politically relevant and equal in presidential elections. Elections wouldn't be about winning states. No more distorting and divisive red and blue state maps. Every vote, everywhere would be counted for and directly assist the candidate for whom it was cast. Candidates would need to care about voters across the nation, not just undecided voters in a handful of swing states.
In the 2012 election, pundits and campaign operatives already agree that, only 7-14 states and their voters will matter under the current winner-take-all laws (i.e., awarding all of a state’s electoral votes to the candidate who receives the most popular votes in each state) used by 48 of the 50 states. Candidates will not care about at least 72% of the voters-- voters in 19 of the 22 lowest population and medium-small states, and in 16 medium and big states like CA, GA, NY, and TX. None of the 10 most rural states will matter, as usual. 2012 campaigning would be even more obscenely exclusive than 2008 and 2004. In 2008, candidates concentrated over 2/3rds of their campaign events and ad money in just 6 states, and 98% in just 15 states (CO, FL, IN, IA, MI, MN, MO, NV, NH, NM, NC, OH, PA, VA, and WI). Over half (57%) of the events were in just 4 states (OH, FL, PA, and VA). Candidates have no reason to poll, visit, advertise, organize, campaign, or care about the voter concerns in the dozens of states where they are safely ahead or hopelessly behind.
Now, policies important to the citizens of ‘flyover’ states are not as highly prioritized as policies important to ‘battleground’ states when it comes to governing, too.
Charlie Cook reported in 2004:
“Senior Bush campaign strategist Matthew Dowd pointed out yesterday that the Bush campaign hadn’t taken a national poll in almost two years; instead, it has been polling 18 battleground states.”
Former White House Press Secretary Ari Fleischer acknowledging the reality in the Washington Post on June 21, 2009 said:
“If people don’t like it, they can move from a safe state to a swing state.”
The Electoral College that we have today was not designed, anticipated, or favored by the Founding Fathers but, instead, is the product of decades of evolutionary change precipitated by the emergence of political parties and enactment by 48 states of winner-take-all laws, not mentioned, much less endorsed, in the Constitution.
States have the responsibility to make their voters relevant in every presidential election. The bill uses the power given to each state by the Founding Fathers in the Constitution to change how they award their electoral votes for president. It does not abolish the Electoral College.
Reply to this commentLinkReport AbuseIt might make states relevant, but it makes anything other than the two major parties completely irrelevant. Such a provision effectively enshrines Duverger's Law as the governing strategy of American politics.
Protest movements and third-parties would be more or less impossible to mount, as it effectively cements the (currently asinine) logic of "if you don't vote with your natural party, you're voting against them".
Party drift will more or less cease to exist, as giving the reins of national electoral parties to two and only two parties will result in independents likely having no choice left but to side permanently with a major party, lest their issues be completely abandoned.
Under such a scenario, say you're a Republican living in northern California or a Democrat living in the outskirts of Atlanta... good luck ever seeing candidates of your preferred party in your area ever again, even if your state is ostensibly competitive - strategy dictates that the two parties now are best off rallying the troops in as large of numbers as possible, effectively turning traditional logic on its head. Now no longer would politicians go to swing states specifically, but in party strongholds to gin up as many votes as is humanly possible.
Finally, such a system would give the two major parties more or less unlimited power to dictate the political agenda, as the lack of an ability to form a protest movement (short of possessing hundreds of millions, if not billions, of dollars and extensive media coverage) results in the RNC and DNC effectively obtaining the right to impose their candidates on the American people, whether they like them or not.
If anything, a National Popular Vote regime is a crippling imposition on the Republic, not its salvation, and would likely amplify the partisan nature of electoral politics to a degree that many would find completely unpalatable.
Reply to this commentLinkReport AbuseNational Popular Vote did not invent popular elections. Having election results determined by the candidate getting the most individual votes is not some scary, untested idea loaded with unintended consequences. It gives a voice to the minority party in those states where elections are seen as a foregone conclusion.
It adds up votes of all voters and the candidate with the most popular votes wins, as in virtually every other election in the country.
The National Popular Vote bill simply guarantees that the presidential candidate who receives the most votes in all 50 states will win the Presidency.
Reply to this commentLinkReport AbuseBut that's not the intention of the Presidential Election. Everyone votes in their state to influence how their state will vote for President in the Electoral College. The President is elected by the states, not the people. This isn't a Democracy, thank God.
Reply to this commentLinkReport AbuseThat Southern California secession movement is looking better and better by the day.
Reply to this commentLinkReport AbuseLet me get this straight--most of the NPV states are blue states. So the only thing this could possibly do is result in a Republican landslide. If a Dem wins the pop vote, guaranteed that the blue states went blue. But if a Republican wins the pop vote, then the blue NPV states will have to go red regardless...and NPV will be repealed in the very next assembly.
Reply to this commentLinkReport AbuseThe underlying problem is not whether a popular vote should replace the Electoral College, either constitutionally or de facto.
Rather, the problem has to do with moving goalposts. Let us say that in the next election, the Republican party candidate wins the popular vote, but not electorally. Do you think those states will abide by their own agreement, or not? I can easily envision the California lawsuit against its own pact, when it doesn't get the result it wanted.
Now, to something more likely: Suppose that the popular and electoral votes go different ways, and a state that is part of the agreement decides to renege, using the Electoral College instead, because that provides the result it wants. Precisely how would the remaining pact states enforce the agreement? What venue? What law?
Or, would the remaining pact states grudgingly accept the result, and boycott the state that reneged? What if it were a state that was hard to boycott because of its unique resources?
Reply to this commentLinkReport AbuseAny attempt by a state to pull out of the compact in violation of its terms would violate the Impairments Clause of the U.S. Constitution and would be void. Such an attempt would also violate existing federal law. Compliance would be enforced by Federal court action
The bill says: "Any member state may withdraw from this agreement, except that a withdrawal occurring six months or less before the end of a President’s term shall not become effective until a President or Vice President shall have been qualified to serve the next term."
The National Popular Vote compact is, first of all, a state law. It is a state law that would govern the manner of choosing presidential electors. A Secretary of State may not ignore or override the National Popular Vote law any more than he or she may ignore or override the winner-take-all method that is currently the law in 48 states.
There has never been a court decision allowing a state to withdraw from an interstate compact without following the procedure for withdrawal specified by the compact. Indeed, courts have consistently rebuffed the occasional (sometimes creative) attempts by states to evade their obligations under interstate compacts.
Reply to this commentLinkReport AbuseThe constitution also says that no state may enter into a pact with another state without congress's permission.
Since this pact is unconstitutional, it's enforcement mechanism is of no value, the federal courts do not enforce unconstitutional laws.
Even if it were, there is still no practical enforcement mechanism. The constitution specifically permits each state to determine how they will if assign their delegates. If the state wants to renege on the compact, there is no mechanism by which the courts can force them to stop.
Reply to this commentLinkReport AbuseCongressional consent is not required for the National Popular Vote compact under prevailing U.S. Supreme Court rulings. However, because there would undoubtedly be time-consuming litigation about this aspect of the compact, National Popular Vote is working to introduce a bill in Congress for congressional consent.
The U.S. Constitution provides:
"No state shall, without the consent of Congress,… enter into any agreement or compact with another state…."
Although this language may seem straight forward, the U.S. Supreme Court has method, in 1893 and again in 1978, that the Compacts Clause can "not be read literally." In deciding the 1978 case of U.S. Steel Corporation v. Multistate Tax Commission, the Court wrote:
"Read literally, the Compact Clause would require the States to obtain congressional approval before entering into any agreement among themselves, irrespective of form, subject, duration, or interest to the United States.
"The difficulties with such an interpretation were identified by Mr. Justice Field in his opinion for the Court in [the 1893 case] Virginia v. Tennessee. His conclusion [was] that the Clause could not be read literally [and this 1893 conclusion has been] approved in subsequent dicta."
Specifically, the Court's 1893 ruling in Virginia v. Tennessee stated:
"Looking at the clause in which the terms 'compact' or 'agreement' appear, it is evident that the prohibition is directed to the formation of any combination tending to the increase of political power in the states, which may encroach upon or interfere with the just supremacy of the United States."
The state power involved in the National Popular Vote compact is specified in Article II, Section 1, Clause 2 the U.S. Constitution:
"Each State shall appoint, in such Manner as the Legislature thereof may direct, a Number of Electors…."
In the 1892 case of McPherson v. Blacker (146 U.S. 1), the Court wrote:
"The appointment and mode of appointment of electors belong exclusively to the states under the constitution of the United States"
The National Popular Vote compact would not "encroach upon or interfere with the just supremacy of the United States" because there is simply no federal power -- much less federal supremacy -- in the area of awarding of electoral votes in the first place.
Any attempt by a state to pull out of the compact in violation of its terms would violate the Impairments Clause of the U.S. Constitution and would be void. Such an attempt would also violate existing federal law. Compliance would be enforced by Federal court action
The bill says: "Any member state may withdraw from this agreement, except that a withdrawal occurring six months or less before the end of a President’s term shall not become effective until a President or Vice President shall have been qualified to serve the next term."
The National Popular Vote compact is, first of all, a state law. It is a state law that would govern the manner of choosing presidential electors. A Secretary of State may not ignore or override the National Popular Vote law any more than he or she may ignore or override the winner-take-all method that is currently the law in 48 states.
There has never been a court decision allowing a state to withdraw from an interstate compact without following the procedure for withdrawal specified by the compact. Indeed, courts have consistently rebuffed the occasional (sometimes creative) attempts by states to evade their obligations under interstate compacts.
In 1976, the U.S. District Court for the District of Maryland stated in Hellmuth and Associates v. Washington Metropolitan Area Transit Authority:
“When enacted, a compact constitutes not only law, but a contract which may not be amended, modified, or otherwise altered without the consent of all parties.”
In 1999, the Commonwealth Court of Pennsylvania stated in Aveline v. Pennsylvania Board of Probation and Parole:
“A compact takes precedence over the subsequent statutes of signatory states and, as such, a state may not unilaterally nullify, revoke, or amend one of its compacts if the compact does not so provide.”
In 1952, the U.S. Supreme Court very succinctly addressed the issue in Petty v. Tennessee-Missouri Bridge Commission:
“A compact is, after all, a contract.”
The important point is that an interstate compact is not a mere “handshake” agreement. If a state wants to rely on the goodwill and graciousness of other states to follow certain policies, it can simply enact its own state law and hope that other states decide to act in an identical manner. If a state wants a legally binding and enforceable mechanism by which it agrees to undertake certain specified actions only if other states agree to take other specified actions, it enters into an interstate compact.
Interstate compacts are supported by over two centuries of settled law guaranteeing enforceability. Interstate compacts exist because the states are sovereign. If there were no Compacts Clause in the U.S. Constitution, a state would have no way to enter into a legally binding contract with another state. The Compacts Clause, supported by the Impairments Clause, provides a way for a state to enter into a contract with other states and be assured of the enforceability of the obligations undertaken by its sister states. The enforceability of interstate compacts under the Impairments Clause is precisely the reason why sovereign states enter into interstate compacts. Without the Compacts Clause and the Impairments Clause, any contractual agreement among the states would be, in fact, no more than a handshake.
Reply to this commentLinkReport AbuseBut what is to stop a renege state from challenging the compact in a federal court in its own terrain, and having a sympathetic judge rule that the compact, and all its enforcement terms, is unconstitutional?
It might be helpful for that judge to conduct a "trial" in which "witnesses" provide "testimony" over a long period of time. Meanwhile, potential appellate judges might discover that their kids are more likely to get into Harvard if the right result is obtained.
Or, declare that any opponent has no standing.
Think that couldn't happen? Think California Prop 8, and DOMA.
Going back to the 2000 election: At that time, I lived in California, but was preparing to retire to Florida. I was in Florida at the time (but not yet voting there). As the result went to the Supreme Court, I got the feeling that among non-partisans in both states (the only kind with whom I associate) there was little sentiment either way. Bush, Gore, whatever.
There is a better way: Remove the President's veto power, and provide a better mechanism for appointing Supreme Court justices (possibly limited terms rather than pre-screening by activists). This requires a new Constitution, of course. Instead of veto power, allow the executive branch to have two voting (or non-voting) appointed representatives and one appointed senator. These appointees would be able to express the administration's opinion regarding any bill. A wise administration would appoint persons who were economic experts, and have them focus on costs of legislation.
Then, the President could be chosen based on administrative competence rather than the ability to over-ride Congress. Let's face it, "limited government" and "checks and balances" are in shambles.
Reply to this commentLinkReport AbuseSorry, but in the US, constitutional law is determined by the constitution, not by the Court. You write that "the Court wrote..." The Court ruled in favor of one party and against another. The rest is just dictum. Do not quote case dictum as constitutional law. Dictum only indicates what that particular justice believes is a good reason for the ruling. Furthermore, the Court cited difficulties and wasted time and energy as evidence that we should not follow the passage literally, yet the Framers meant for government to be difficult so that change would be difficult. Your argument and his only support the literal reading.
Reply to this commentLinkReport AbuseThe population of the top five cities (New York, Los Angeles, Chicago, Houston and Philadelphia) is only 6% of the population of the United States and the population of the top 50 cities (going as obscurely far down as Arlington, TX) is only 19% of the population of the United States.
Suburbs and exurbs often vote Republican.
Evidence as to how a nationwide presidential campaign would be run, can be found by examining the way presidential candidates campaign to win the electoral votes of closely divided battleground states, such as in Ohio and Florida, under the state-by-state winner-take-all methods. The big cities in those battleground states do not receive all the attention, much less control the outcome. Cleveland and Miami certainly did not receive all the attention or control the outcome in Ohio and Florida in 2000 and 2004.
Because every vote is equal inside Ohio or Florida, presidential candidates avidly seek out voters in small, medium, and large towns. The itineraries of presidential candidates in battleground states (and their allocation of other campaign resources in battleground states) reflect the political reality that every gubernatorial or senatorial candidate in Ohio and Florida already knows–namely that when every vote is equal, the campaign must be run in every part of the state.
Even in California state-wide elections, candidates for governor or U.S. Senate don't campaign just in Los Angeles and San Francisco, and those places don't control the outcome (otherwise California wouldn't have recently had Republican governors Reagan, Dukemejian, Wilson, and Schwarzenegger). A vote in rural Alpine county is just an important as a vote in Los Angeles. If Los Angeles cannot control statewide elections in California, it can hardly control a nationwide election.
In fact, Los Angeles, San Francisco, San Jose, and Oakland together cannot control a statewide election in California.
Similarly, Republicans dominate Texas politics without carrying big cities such as Dallas and Houston.
There are numerous other examples of Republicans who won races for governor and U.S. Senator in other states that have big cities (e.g., New York, Illinois, Michigan, Pennsylvania, and Massachusetts) without ever carrying the big cities of their respective states. It is certainly true that the biggest cities in those states typically vote Democratic. However, the suburbs, exurbs, small towns, and rural parts of the states often voted Republican. If big cities controlled the outcome of elections, the governors and U.S. Senators would be Democratic in virtually every state with a significant city.
Under a national popular vote, every vote everywhere will be equally important politically. There will be nothing special about a vote cast in a big city or big state. When every vote is equal, candidates of both parties will seek out voters in small, medium, and large towns throughout the states in order to win. A vote cast in a big city or state will be equal to a vote cast in a small state, town, or rural area.
Reply to this commentLinkReport AbuseHalf the nation's population lives in the 40 largest urban areas--that's from the Census Bureau. NPV would shift power to urban areas, that much is obvious. (A shift that would likely be most dramatic within the Democratic Party, but it's difficult to predict the eventual results of such a massive shift in political incentives.)
Reply to this commentLinkReport AbuseThe population of the top 50 cities (going as obscurely far down as Arlington, TX) is only 19% of the population of the United States.
Suburbs and exurbs often vote Republican.
Evidence as to how a nationwide presidential campaign would be run, can be found by examining the way presidential candidates campaign to win the electoral votes of closely divided battleground states, such as in Ohio and Florida, under the state-by-state winner-take-all methods. The big cities in those battleground states do not receive all the attention, much less control the outcome. Cleveland and Miami certainly did not receive all the attention or control the outcome in Ohio and Florida in 2000 and 2004.
Because every vote is equal inside Ohio or Florida, presidential candidates avidly seek out voters in small, medium, and large towns. The itineraries of presidential candidates in battleground states (and their allocation of other campaign resources in battleground states) reflect the political reality that every gubernatorial or senatorial candidate in Ohio and Florida already knows–namely that when every vote is equal, the campaign must be run in every part of the state.
Even in California state-wide elections, candidates for governor or U.S. Senate don't campaign just in Los Angeles and San Francisco, and those places don't control the outcome (otherwise California wouldn't have recently had Republican governors Reagan, Dukemejian, Wilson, and Schwarzenegger). A vote in rural Alpine county is just an important as a vote in Los Angeles. If Los Angeles cannot control statewide elections in California, it can hardly control a nationwide election.
In fact, Los Angeles, San Francisco, San Jose, and Oakland together cannot control a statewide election in California.
Similarly, Republicans dominate Texas politics without carrying big cities such as Dallas and Houston.
There are numerous other examples of Republicans who won races for governor and U.S. Senator in other states that have big cities (e.g., New York, Illinois, Michigan, Pennsylvania, and Massachusetts) without ever carrying the big cities of their respective states. It is certainly true that the biggest cities in those states typically vote Democratic. However, the suburbs, exurbs, small towns, and rural parts of the states often voted Republican. If big cities controlled the outcome of elections, the governors and U.S. Senators would be Democratic in virtually every state with a significant city.
Under a national popular vote, every vote everywhere will be equally important politically. There will be nothing special about a vote cast in a big city or big state. When every vote is equal, candidates of both parties will seek out voters in small, medium, and large towns throughout the states in order to win. A vote cast in a big city or state will be equal to a vote cast in a small state, town, or rural area.
Further evidence of the way a nationwide presidential campaign would be run comes from the way that national advertisers conduct nationwide sales campaigns. National advertisers seek out customers in small, medium, and large towns of every small, medium, and large state. National advertisers do not advertise only in big cities. Instead, they go after every single possible customer, regardless of where the customer is located. National advertisers do not write off Indiana or Illinois merely because their competitor has an 8% lead in sales in those states. And, a national advertiser with an 8%-edge over its competitor does not stop trying to make additional sales in Indiana or Illinois merely because they are in the lead.
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