To what extent does the historical development of ‘la cause’ and ‘consideration’ coincide or differ from each other, and what are their implications?

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Introduction

With the absence of either cause or consideration an agreement will be denied legal effect, even if the parties had intended for it to be legally binding.[1]  Within this essay, La cause, a doctrine in the French civil law system will be compared to its equivalent in the English common law system, consideration. Both doctrines have an extended historical development.

On the one hand, the French doctrine seems to have originated from Roman Law and Canonist Law – for instance, the word ‘cause’ stems from the Roman word causa’. There have been several attempts at trying to define the notion of causa and therefore the French doctrine la cause. In Roman Law, causa had several interpretations; however, the meaning taken by the Civil Code was that it was “a legal ground or recognised title”.[2] While the Civil Code does not actually give a definition for the doctrine, the jurist Baudry-Lacantinerie in the 20th century defined it as “the immediate, hence the essential, purpose on account of which the contract is made”.[3] On the other hand, the English doctrine seems to have come to light in the 16th century. In 1557, in Joscelin v Shelton,[4] consideration was defined as the “motivation behind the giving of a promise”.[5] The modern definition of consideration is found in Misa v Currie,[6] where it was held that for something to be valuable consideration it “may consist either in some profit or benefit accruing to the one party, or some detriment, loss suffered by the other”.[7]

The historical emergence of both doctrines was quite different.[8] La cause was the product of “a prolonged moral and philosophical pre-occupation with the human will”[9]; whereas the concept of consideration was “devised by commercially-minded lawyers at a time when they were anxious to escape from their formalistic medieval laws and expand their law of contracts”.[10]

The purpose of this essay is to identify the extent to which the historical development, of both the French and English doctrines, has played a role in creating the contrasting aspects between the two concepts. This will result in a better comprehension on how two doctrines with the same purpose have become different.

In order to achieve this, the doctrines will be compared through a chronological argument. Firstly, the origins of la cause and consideration will be discussed. Secondly, the introductions of la cause in the civil law system and consideration in the common law system will be comparatively analysed. Finally, the modern state of the French and English doctrines will be examined.

Part I: The origins of ‘la cause’ and consideration’

The notion of ‘causa’ from Roman Law and Canonist Law

The supporters of the modern doctrine of la cause often link the doctrine back to Roman Law.[11] Gaius, a Roman jurist, used the word ‘causa’ in the expression

varie causarum figurae’. This, taken in its literal sense, could be interpreted to mean the source of the obligation. However, under French law, the expression ‘cause de l’obligation’ is taken differently; it is not the reason why the promisor was obliged, but why he consented to the obligation that matters.[12] Moreover, according to Lorenzen, any declaration of will in Roman Law could be avoided through an exception and action if the presupposition (causa) under which such declaration was apparently made, did not exist.[13] This could be linked back to the notion of cause, where, as stated in article 1131 of the Civil Code, “an obligation without cause […] can have no effect”.[14] When comparing ‘causa’ to what the cause of a contract is, there are clear similarities that can explain how the doctrine of ‘la cause’ developed into what it is today.

Jean Domat, a 17th century French jurist, was at the origin of the introduction of the doctrine of la cause in the Civil Code of 1804.[15] In order to formulate the doctrine of cause, Domat cited texts in the Corpus Juris Civilis of Justinian, the largest compilation of ancient Roman Law.[16] Nonetheless, whilst there are some similarities, there can be no certainty that the doctrine has a historical connection to the Roman Law’s notion of ‘causa’. Marcel Planiol, a professor of French Law in 20th century, argued that “Domat’s innovation consists in attaching decisive importance to ‘causa’, while the Romans gave it none”.[17] This statement mirrors the opinion of modern opponents of the doctrine of cause; that in Roman Law of contracts, ‘causa’

“meant nothing more than any foundation of the action”.[18] While it has been demonstrated that there is a link between the notions of ‘causa’ in Roman Law and cause in French law, there are still some commentators that argue that, in reality, there was no theory of cause or consideration under Roman Law.[19] For instance, Buckland and McNair have argued that in Roman Law to give validity to a contract, there was no requirement of ‘causa’ or anything that resembled it.[20]

A historical reconciliation can be demonstrated through the argument that, in fact, the doctrine originates from a mixture of Roman Law and Canonist Law. In the 13th century, the necessity of the abstract cause as a condition of validity of the contract was established in Canonist Law.[21] This condition required that each obligation needed the correlative obligation of the other party to be its cause.[22] Under French Law, the doctrine of la cause has two different categories: objective cause and subjective cause. It could be said that the subjective cause resembles the Canonist tradition, where it entails the subjective reasons why the parties entered into the contract. However, the objective cause resembles the Roman tradition. The objective cause in French law is the abstract goal of the contract.[23] Evidently, the French doctrine has historical roots both in Roman Law and Canonist Law.

The origins of the concept of ‘consideration’

It has been argued that the doctrine of consideration was a modification of the Roman concept of ‘causa’. For a short period of time England was part of the Roman 

Empire and ultimately was influenced by Roman Law. Due to the shortness of that period, the influence was not as strong in England as in the rest of the Roman Empire.[24] Nonetheless, the courts have evidently borrowed the Roman law phrase ‘ex nude pact non oritur actio’.[25] This phrase signifies “no action arises from a nude contract” and designates agreements which are unenforceable due to the lack of consideration.[26] In Smith,[27] the court applied the Roman maxim, and held that the contract was invalid due to the unlawfulness of its object and that there was a want of “sufficient consideration”.[28] Therefore, akin to the doctrine of la cause in French law, the doctrine of consideration could be said to have originated from Roman Law.[29] Moreover, in the case Sidenham,[30] the court established cause and consideration as equivalents, where it used the phrase “cause or consideration” on a number of occasions.[31] This case was fundamental in the historical development of the doctrine of consideration, as it is where the doctrine was firmly established as a rule of the common law.[32] Finally, as Hodsworth states, while the notion of ‘causa’ was “highly influential in the development of the doctrine […] it was never adopted by the common law”.[33]

By the year 1535, three contractual remedies seem to have emerged in the royal courts; these were the actions of covenant, debt and case.[34] The aim of these remedies was to enforce contractual claims.[35] However, there were shortcomings to these actions resulting to their gradual replacement during the 15th and 16th centuries with the action of assumpsit. It wasn’t until the 16th century that the action of assumpsit became “clearly established in substance”. It is believed that the doctrine of consideration has roots in the action of assumpsit; as J.B Ames states: “assumpsit developed out of case in the form of deceit [suggesting] that consideration came from the allegation in that writ”.[36] The word consideration first appeared around the year 1557.[37] Joscelin v Shelton[38] is the first case that documents the presence of consideration in the action of assumpsit.[39] Under the action of assumpsit, consideration was defined as the “motivation behind the giving of a promise”.[40] It could be said that this form of consideration very much resembles the subjective cause of a contract in French law. Both notions look at the motivation for the promise made in the contract.

However, the doctrine of consideration throughout the centuries went through many alterations to become its modern self. In the 19th century, the case Misa v Currie[41] established that consideration involved a benefit and detriment relationship between the parties. The benefit was linked to the notion of quid pro quo and the detriment was linked to the tortious origin of the action of the assumpsit.[42] The notion of quid-pro-quo means ‘something for something’ and can be traced back to the 16th century from the action of debt.[43] The interesting point to draw from this notion is that, at the time of the action of assumpsit, the Roman term ‘causa’ often competed with the term ‘consideration’ as a way of expressing a required element to enforce a promise.[44] Evidently, important aspects of the doctrine of consideration were derived from the action of assumpsit and can be linked back to the doctrine of la cause in French law.

Part II: The establishment of ‘la cause’ and ‘consideration’ in the civil and common law systems

The establishment of the doctrine of ‘la cause’ through its introduction in the Napoleonic Civil Code of 1804

Robert Joseph Pothier enabled the work of Domat to be introduced into the Napoleonic Civil Code in 1804. The views of Domat, in regards to the notion of causa, were accepted by Pothier, resulting in a majority of his work being incorporated into the French Civil Code.[45] The principle that was inscribed into the Civil Code was that “the cause of obligation is the immediate end which the party has in view”.[46] For both Domat and Pothier, the only cause that was essential to the formation of a contract was the abstract cause of the obligation.[47] In the modern view of the doctrine of la cause, this would be labelled as the ‘objective cause’. As far as one can tell the modern orthodox views of la cause were derived from the 17th and the 18th centuries through the works of Domat and Pothier.

The French Civil Code was introduced in 1804 by Napoleon. Articles 1131 and 1133 reformulate the works of Domat and Pothier.[48] Additionally, Article 1108 is important in the establishment of the doctrine as it identifies the doctrine as one of the four essential requisites for an agreement to be valid.[49] Article 1131 establishes how the doctrine works in the law of contracts in France, where “a contract without cause or a false or illicit cause will be considered as invalid”.[50] Consequently, a contract will not have a ‘cause’ where the parties did not have a serious intent to enter into a binding legal relationship.[51] Moreover, an obligation will have a false ‘cause’ where the parties believed the promise had a certain legal foundation, when in reality it did not.[52] Following Article 1131, Article 1133 states: “the ‘cause’ is unlawful when it is prohibited by law, when it is contrary to good morals, or is against the public interests”.[53] Therefore, Articles 1131 and 1133 impose the limits and functions of the doctrine. Although the Civil Code does not actually provide a definition for the doctrine, through Articles 1108, 1131 and 1133, it highlights the role the doctrine plays in the French law of contracts.

The doctrine of la cause will differ through the different types of contracts. French law differs, in this area, to English law as it recognises gratuitous contracts as enforceable contracts. The cause of a promise is the purpose for which it is made.[54] Therefore, a promise is made either in exchange for a counter-benefit or from a desire to confer a gratuitous benefit.[55] This can be identified in Article 1382 of the Civil Code, which states: “every human act whatsoever which causes damage to another obliges him by whose fault it has happened to compensate for”.[56]

Accordingly, where an individual has relied on a statement or action by another and incurred a detriment, he/she can enforce the promise that was made to him/her. That said, under French law, an informal promise of a gratuitous service may be binding.[57] Finally, when looking at the French doctrine in gratuitous contracts, the objective cause is identified as “the unfettered intention to provide something without demanding anything in return”.[58] In this instance, there would be no consideration under English law.

The establishment of the doctrine of consideration in common law

While Joscelin[59] is the first case in which a notion of consideration first appeared, the case Hunt v Bate[60] was vital in the evolution of the doctrine. In the latter case, the court through its decision led to the emergence of the consideration test in common law.[61] Consideration was used to mean motive or reason, highlighting a similarity with the notion of the subjective cause in French law.[62]  While throughout the 16th century there was evidence of something similar to the doctrine of consideration and the presence of the word ‘consideration’, there were still uncertainties as to its establishment in common law throughout the 18th century. In the case Pillans v Van Mierop,[63] Lord Mansfield stated that “the ancient notion about the want of consideration was for the sake of evidence only”.[64] It is evident that Lord Mansfield did not recognize the doctrine of consideration; providing the reason that the obligation of a contract should be deduced from the lawful intention of the party, not from something objective to give it substance and meaning.[65] However, in Rann v Hughes,[66] the House of Lords disagreed with Lord Mansfield when it held: “the laws of the country supply no mean, nor afford any remedy, to compel the performance of an agreement made without sufficient consideration”.[67] In the subsequent case Eastwood v Kenyon,[68] the need for consideration, in order to validate agreements, was reaffirmed.[69] Evidently, it was not until the 19th century that that these uncertainties were settled and that the modern doctrine of consideration was fully incorporated into common law.

During the 18th and 19th centuries, there was also a debate in regards to identifying moral consideration as part of the English doctrine. Some earlier cases, such as Dutton v Poole,[70] show the common law courts considering love and affection as valid consideration for a promise.[71] In addition, it was held that a donative promise became enforceable in ‘affective’ relationships.[72] Such argument was supported by Lord Mansfield in Hawkes v Saunders[73] where he said, “[w]here a man is under a moral obligation…and promises, the honesty and rectitude of the thing is consideration”.[74] The decision of this was significant as it became known as the ‘Hawkes rule’, and incorporated the use of love and affection as consideration.[75] These cases demonstrate strong similarities between the doctrines of consideration and la cause, as both identified promises that did not involve a bargain or promise in exchange as enforceable. Moral consideration in England was the equivalent to gratuitous promises in France. However, in the case Eastwood v Kenyon[76] it was held that moral consideration could no longer be an operative doctrine.[77] This case demonstrates a clear distancing of the English doctrine from the French doctrine.[78] The modern French law doctrine includes psychological motivations, making it a subjective concept, whereas the modern English law doctrine is described as essentially an objective concept.[79] The 19th century led to the accepted notion that “moral consideration is no consideration”.[80] As it has been shown, the notion of consideration went through a significant amount of changes in order to become the modern doctrine.

Part III: The modern doctrines of la cause and consideration

The 2016 Reform: the consequent disappearance of la cause in the French Civil Code

The classic theory of la cause has been severely attacked throughout the centuries.[81] Marcel Planiol was seen to have vehemently criticised the doctrine of la cause at the end of the 19th century.[82]  Anti-causalists based themselves off Planiol’s work and denounced the doctrine as unnecessary and false.[83] This led to an anti-causalist movement in France during the 20th century.[84] Modern French writers have identified the requirement of la cause as a source of confusion and thus does not serve a useful purpose in French law.[85] Throughout the early 21st century there was a movement towards a reform of the Civil Code. In July 2008, a draft by the Ministry of Justice included the abolishment of the concept of ‘cause’ and replaced it with the concept of ‘interest’.[86] The new concept was in fact very similar to the doctrine of la cause.[87] The result of the uncertainty that would come with this new concept led to the abandonment of its introduction and the reignition of the movement aiming to remove the doctrine of la cause from French law of contracts.[88] The reform of the French Civil Code happened in 2016. There were three reasons that led to this reform. Firstly, there was an outdated and incomplete section of the Civil Code, which meant there was a lack of a clear and precise picture of French law concerning contracts.[89] Secondly, the Civil Code had lost its international influence.[90] Finally, French law was unattractive to international businesses where it was no longer the governing law for international contracts.[91] As a consequence to the 2016 Reform, the doctrine of la cause was removed from the Civil Code.

Whilst the doctrine was in fact removed, there are still traces of it in French contract law. Firstly, a condition that came with its removal was that any contracts that were concluded prior to the 1st October 2016, the reform would not apply.[92] Therefore, French judges can still make the use of old articles that mention the doctrine of la cause.[93] Example of this is the case Delay in crediting accounts.[94] This case demonstrated how the objective cause can be applied subsequently to the reform in modern transactions.[95] While the doctrine of la cause has been taken out of the Civil Code, as Solène Rowan affirms: “it has been replaced with clearer and more defined rules”, providing the courts with a way to reach similar solutions.[96]

The development of the modern doctrine of consideration

Unlike the doctrine of la cause, the modern conception of consideration requires an exchange of mutual promises or the exchange of a performance in return for a promise.[97] This modern conception has been the law for centuries.[98] However,

the law has gone through modern developments, as demonstrated in Rose and Frank v Crompton.[99] In this case, another requirement was added to the doctrine, where it was held that the promise must be intended to create legal relations.[100] The modern doctrine of consideration operates in a way to distinguish between generally unenforceable gratuitous promises and enforceable promises.[101] While this seems to be a clear concept, the law is, in reality, unclear on the doctrine of consideration. The lack of clarity is due to the courts’ inconsistency in their application of the rule, due to their unwillingness to enforce it strictly in all cases.[102]

As of today, many scholars and judges argue that the doctrine of consideration is an unnecessary obstacle to the enforcement of what would otherwise be valid contractual agreements.[103] The doctrine of consideration has faced attacks since the 1970s with the discussion of its continued ‘usefulness’.[104] These criticisms have led to some advocating for it complete removal.[105] For example, Mark B. Wessman has argued that the complete removal of the doctrine is very realistic. He argues that the functions performed by the doctrine could be successfully performed by other doctrines.[106] There has also been criticism on an international level. For example, the UNIDROIT Principles of International Commercial Contracts demonstrate that doctrines, such as consideration, are unnecessary and even problematic in commercial circumstances which demand the use of international contracts.[107] While the doctrine has been under a lot of pressure and has almost been removed from common law, as of today, the doctrine is still an essential part of the law of contracts in England and Wales. To conclude, it has been widely acknowledged that consideration should not perhaps be removed, however, it has been argued that it should nonetheless be reformed.[108]

Conclusion

In light of the historical development that both doctrines endured to become their modern selves, it has been demonstrated that while they incorporate the same purpose in the law of contracts, they differ in many ways. Although it is still unclear whether or not the doctrines did in fact both originate from Roman law, it seems that at moments in history the two doctrines were almost identical. However, through their evolutions they differed as one became an objective notion and the other one of a mixture of both subjective and objective notions.

Several conclusions may be drawn from the historical development of both doctrines. Firstly, there is clear evidence that the French doctrine originated from the Roman Law’s notion of ‘causa’. However, in regards to the English doctrine, it is simply believed that the doctrine may have originated from the same Roman notion. Nonetheless, it is evident that while it may have not originated from ‘causa’, the modern doctrine of consideration was vaguely influenced by it. Secondly, the English doctrine evolved throughout the centuries facing continuous changes visible in case law; whilst the French doctrine was firmly established in 1804. Nonetheless, the two doctrines were ‘reunited’ in the 18th century when moral consideration was accepted and therefore meant that gratuitous promises were enforceable under both doctrines. However, with Eastwood v Kenyon the clear resemblance between the two doctrines came to an end.[109] Finally, while the two modern doctrines are very much dissimilar, they still suffered similar critiques. Both doctrines were said to be useless and therefore unnecessary under common law and civil law. In 2016, this led to the removal of the doctrine of la cause from the Civil Code, whereas consideration is still fully incorporated in English law. Thus, it could be questioned whether the English doctrine is soon set to meet the same fate as its French counterpart.

Based on the above arguments, it can be confirmed that the historical development of a doctrine is vital in understanding the reasons as to why its modern self is constructed as such. Conclusively, the study of both doctrines, side by side, has been enlightening as it has provided a clearer illustration as to how identical notions, in two different legal systems, came to become contrasting doctrines.


[1] Robert L Henry, ‘Cause in the Civil Law and Consideration in the Common: Much Ado About Nothing’ (1941) 29 Ky LJ 369 p 370.

[2] F P Walton, ‘Cause and Consideration in Contracts’ (1925) 41 L Q Rev 306.

[3] Ernest G Lorenzen, ‘Causa and Consideration in the Law of Contracts’ (1919) 28 Yale Law Journal 621 p 632.

[4] [1557] 1 WLUK 6, 74 E.R. 503 (Court of King’s Bench).

[5] Charlotte Mary Boardman, ‘Considering Consideration: A Critical and Comparative Analysis of the Doctrine of Consideration in the Anglo-Canadian Common Law’ (LLB thesis, University of Kent 2011) p 56.

[6] (1876) 1 App. Cas. 554 (House of Lords).

[7] ibid.

[8] B.S Markesinis, ‘Cause and Consideration: A Study in Parallel’ (1978) 37(1) The Cambridge Law Journal <https://www.jstor.org/stable/4506061> accessed 24 February 2020.

[9] ibid, p 55.

[10] ibid.

[11] Lorenzen (n 3) p 625.

[12] Henri Leon ET Jean, ‘La Cause En Droit Francais’ (1956) 3 McGill L J 6 p 10.  

[13] Lorenzen (n 3)  p 630.

[14] Abram Glaser, ‘Doctrine of Consideration and the Civil Law Principle of Cause’ (1941) 46 Dick L Rev 12 p 17.

[15] Henry (n 1) p 371.

[16] ibid.

[17] ibid, p 372.

[18] Lorenzen (n 3)  p 624.

[19] Henry (n 1) p 372.

[20] W W Buckland and Arnold D. McNair, Roman Law and Common Law (2nd edn, Cambridge University Press 1952).

[21] Leon ET Jean (n 12) p 10.

[22] ibid, p 9.

[23] Hugh Beale (et al), Cases, Material and Text on Contract Law (2nd edn, Hart Publishing 2019).

[24] Boardman (n 5) p 50.

[25] Glaser (n 14)  p 22.

[26] ibid, p 20.

[27] Smith and Smith [1583] 1 WLUK 62, 74 E.R. 559 (Court of King’s Bench).

[28] Henry (n 1) p 389.

[29] Lorenzen (n 3).

[30] Sidenham and Worlington’s [1584] 1 WLUK 86, 74 E.R. 497 (Court of King’s Bench).

[31] Henry (n 1)  p 389.

[32] ibid, p 387.

[33] Boardman (n 5)  p 59.

[34] Edward Jenks, The History of the Doctrine of Consideration in English law (C. J. Clay and Sons 1892) 161.

[35] ibid, p 161.

[36] Henry (n 1)  p 380.

[37] Glaser (n 14)  p 20.

[38] [1557] 1 WLUK 6, 74 E.R. 503 (Court of King’s Bench).

[39] Boardman (n 5) p 56.

[40] ibid.

[41] Currie (n 6).

[42] A T Denning, ‘Recent Developments in the Doctrine of Consideration’ (1952) 15 The Modern Law Review 1 p 2.

[43] Boardman (n 5)  p 52.

[44] Charles Calleros, ‘Cause, Consideration, Promissory Estoppel, and Promises under Deed: What Our Students Should Know about Enforcement of Promises in a Historical and International Context’ (2013) 13 Chi-Kent J Int’l & Comp L 83 p 98.

[45] Lorenzen (n 3)  p 632.

[46] Glaser (n 14)  p 17.

[47] Leon ET Jean (n 12).

[48] ibid, p 10.

[49] Code Civil, art 1108.

[50] Code Civil, art 1131.

[51] Lorenzen (n 3)  p 633.

[52] ibid, p 632.

[53] Code Civil, art 1133.

[54] Malcom S Mason, ‘The Utility of Consideration – A Comparative’ (1941) 41(5) Columbia Law Rev Association, Inc. <https://www.jstor.org/stable/1117841> accessed 6 February 2020 p 3.

[55] ibid.

[56] Code Civil, art 1382.

[57] Mason (n 54)p 14.

[58] Beale (n 23).

[59] Joscelin (n 38).

[60] [1567] 1 WLUK 38, 73 E.R. 605 (Court of King’s Bench).

[61] Henry (n 1) p 386.

[62] ibid, p 391.

[63] [1765] 4 WLUK 4, 97 E.R. 1035 (Court of King’s Bench).

[64] Glaser (n 14)  p 23.

[65] ibid, p 21.

[66]  [1778] 1 WLUK 2, 101 E.R. 1014 (Court of King’s Bench).

[67] Glaser (n 14) p 23.

[68] [1840] 1 WLUK 317, 113 E.R. 482 (Court of Queen’s Bench).

[69] Glaser (n 14)  p 23.

[70] [1678] 1 WLUK 145, 86. E.R. 215 (Court of King’s Bench).

[71] Mark K Moller, ‘Sympathy, Community and Promising: Adam Smith’s Case for Reviving Moral Consideration’ (1999) 66 University of Chicago Law Review 213.

[72] ibid, p 214.

[73] [1782] 1 WLUK 37, 98 E.R. 1091 (Court of King’s Bench).

[74] Moller (n 71) p 214.

[75] ibid.

[76] Eastwood (n 68)

[77] Moller (n 71)p 214.

[78] ibid.

[79] Beale (n 23).

[80] ibid, p 350.

[81]  Leon ET Jean (n 12)6.

[82] Beale (n 23).

[83]  Leon ET Jean.

[84]  ibid.

[85]  Lorenzen (n 3) p 634.

[86] Beale (n 23).

[87] ibid.

[88] ibid.

[89] Solene Rowan, ‘The New French Law of Contract’ (2017) International & Comparative Law Quarterly <http://eprints.lse.ac.uk/75815/> accessed 9 February 2020 p 2.

[90] ibid, p 3.

[91] ibid, p 4.

[92] Beale (n 23).

[93] ibid.

[94] Cass com, 6 April 1993.II.22062 (delay in crediting accounts).

[95] Beale (n 23).

[96] Rowan (n 89)p 1.

[97] Calleros (n 44) p 98.

[98] Denning (n 42).

[99] [1924] 12 WLUK 20, A C 445.

[100] Denning (n 42).

[101] Calleros (n 44) p 98.

[102] Clarence D Ashley, ‘Doctrine of Consideration’ (1912-1913) 26 Harv L Rev 429.

[103] Boardman (n 5)p 17.

[104]  ibid, p 74.

[105]  ibid.

[106] Mark B. Wessman, ‘Should we Fire the Gatekeeper: An Examination of the Doctrine of Consideration’, (1993) 48(1) University of Miami L Rev 45.

[107] Boardman (n 5)  p 191.

[108]  ibid, p 189.

[109] Eastwood (n 68).

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