Felicia Sullivan https://www.feliciasullivan.com Around Here, It's ALWAYS 4/20! Sun, 18 Feb 2018 15:02:32 +0000 en-US hourly 1 https://wordpress.org/?v=4.9.4 What’s On Your Label, Part 2: California Cannabis Packaging and Labeling for “New” Products https://www.feliciasullivan.com/2018/02/18/whats-on-your-label-part-2-california-cannabis-packaging-and-labeling-for-new-products/ https://www.feliciasullivan.com/2018/02/18/whats-on-your-label-part-2-california-cannabis-packaging-and-labeling-for-new-products/#respond Sun, 18 Feb 2018 15:02:32 +0000 https://www.feliciasullivan.com/?p=554 California marijuana packaging and labeling
What are the packaging and labeling requirements for new marijuana products?

California is just starting to get its cannabis packaging and labeling regulations right under MAUCRSA. The state has a mandated transition period from January 1 to July 1, 2018, during which time adult use and medical marijuana licensees can do business with each other, and temporary and annual state licensees can transport and sell cannabis products already in their possession in the newly regulated market. This means there are two packaging and labeling standards during this transition period: one for products that licensees bring into the marketplace from before January 1, 2018 and another for products cultivated or made on or after January 1, 2018. I covered transition period product packaging and labeling in a previous post. This post will cover the packaging and labeling requirements for those products made or cultivated on or after January 1, 2018 (collectively, “New Products”).

Retailers

For New Products, retailers won’t package or label anything. Instead, all New Products will come to retailers already packaged and labeled by either cultivators, processors, manufacturers, or distributors. The only packaging requirement retailers have for New Products is exit packaging. Specifically, per section 5413 of the Bureau of Cannabis Control Emergency MAUCRSA rules, “[c]annabis goods purchased by a customer shall not leave the retailer’s premises unless

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California marijuana packaging and labeling
What are the packaging and labeling requirements for new marijuana products?

California is just starting to get its cannabis packaging and labeling regulations right under MAUCRSA. The state has a mandated transition period from January 1 to July 1, 2018, during which time adult use and medical marijuana licensees can do business with each other, and temporary and annual state licensees can transport and sell cannabis products already in their possession in the newly regulated market. This means there are two packaging and labeling standards during this transition period: one for products that licensees bring into the marketplace from before January 1, 2018 and another for products cultivated or made on or after January 1, 2018. I covered transition period product packaging and labeling in a previous post. This post will cover the packaging and labeling requirements for those products made or cultivated on or after January 1, 2018 (collectively, “New Products”).

Retailers

For New Products, retailers won’t package or label anything. Instead, all New Products will come to retailers already packaged and labeled by either cultivators, processors, manufacturers, or distributors. The only packaging requirement retailers have for New Products is exit packaging. Specifically, per section 5413 of the Bureau of Cannabis Control Emergency MAUCRSA rules, “[c]annabis goods purchased by a customer shall not leave the retailer’s premises unless

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Will California Protect Off-Work Medical Marijuana Use? https://www.feliciasullivan.com/2018/02/17/will-california-protect-off-work-medical-marijuana-use/ https://www.feliciasullivan.com/2018/02/17/will-california-protect-off-work-medical-marijuana-use/#respond Sat, 17 Feb 2018 15:10:04 +0000 https://www.feliciasullivan.com/?p=552 marijuana employment cannabis
This might not be true in California anymore.

Thirty states and the District of Columbia have laws that legalize marijuana for adult recreational use and/or medical use. Many of those states also protect employees’ off-work use of medical marijuana. However, some of those states, including California, Oregon and Washington, have statutes or case law allowing employers to terminate employees for off-work use of marijuana– even employees legally using it under the state’s medical marijuana laws. Oregon recently tried to pass legislation protecting off-work use of marijuana, but the bill failed to gain traction and fizzled at the committee level. California is the latest state to attempt to pass legislation to protect employee’s off-work use of medical marijuana. Let’s hope it happens!

California Assembly Bill 2069 (AB 2069), introduced last week, proposes to protect medical marijuana patients’ off-work use of marijuana. AB 2069 would amend California’s anti-discrimination statute by expanding the list of protected classes to include medical marijuana patients. This means that if an employer discovered that an employee or potential employee was a medical marijuana patient, or that the employee had tested positive for marijuana, it would be illegal for the employer to:

“refuse to hire or refuse to select the person for a training program leading to employment, or to bar or to discharge the person from employment …

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marijuana employment cannabis
This might not be true in California anymore.

Thirty states and the District of Columbia have laws that legalize marijuana for adult recreational use and/or medical use. Many of those states also protect employees’ off-work use of medical marijuana. However, some of those states, including California, Oregon and Washington, have statutes or case law allowing employers to terminate employees for off-work use of marijuana– even employees legally using it under the state’s medical marijuana laws. Oregon recently tried to pass legislation protecting off-work use of marijuana, but the bill failed to gain traction and fizzled at the committee level. California is the latest state to attempt to pass legislation to protect employee’s off-work use of medical marijuana. Let’s hope it happens!

California Assembly Bill 2069 (AB 2069), introduced last week, proposes to protect medical marijuana patients’ off-work use of marijuana. AB 2069 would amend California’s anti-discrimination statute by expanding the list of protected classes to include medical marijuana patients. This means that if an employer discovered that an employee or potential employee was a medical marijuana patient, or that the employee had tested positive for marijuana, it would be illegal for the employer to:

“refuse to hire or refuse to select the person for a training program leading to employment, or to bar or to discharge the person from employment …

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Marijuana News and Culture Recap: Winter 2017-2018 https://www.feliciasullivan.com/2018/02/16/marijuana-news-and-culture-recap-winter-2017-2018/ https://www.feliciasullivan.com/2018/02/16/marijuana-news-and-culture-recap-winter-2017-2018/#respond Fri, 16 Feb 2018 20:15:36 +0000 https://www.feliciasullivan.com/?p=550 This winter has been a whirlwind of cannabis news, culture and industry progress across the United States. With so much going on, we realize it can be a little difficult to stay up to date on all the industry happenings. To help you get up to speed, we’re back at it with another quarterly blog roundup.

Below, we’ve highlighted some of our top posts over the past quarter. Whether you’re looking to stay informed on recent cannabis industry news and culture or just would like to re-read some of your favorite posts, this article is full of great information for every cannabis enthusiast to enjoy.

To view our fall 2017 recap, click here.

Top Marijuana News and Culture

The cannabis industry is ever-evolving, bringing with it new trends, opportunities and ideas. Check out some of our favorite stories from this past quarter:

Winterization vs. De-Waxing: Which Method is Best?

De-wax vs. Winterization
Removing waxes and lipids from cannabis concentrates is a popular industry practice.

Concentrate popularity is on the rise, taking a hefty portion of market share away from flower sales. With such a dramatic increase in popularity, we’re also seeing a wide assortment of new products hitting the market. From wax, shatter, live resin, distillate and more, it seems a new product becomes a fan favorite every month – leaving …

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This winter has been a whirlwind of cannabis news, culture and industry progress across the United States. With so much going on, we realize it can be a little difficult to stay up to date on all the industry happenings. To help you get up to speed, we’re back at it with another quarterly blog roundup.

Below, we’ve highlighted some of our top posts over the past quarter. Whether you’re looking to stay informed on recent cannabis industry news and culture or just would like to re-read some of your favorite posts, this article is full of great information for every cannabis enthusiast to enjoy.

To view our fall 2017 recap, click here.

Top Marijuana News and Culture

The cannabis industry is ever-evolving, bringing with it new trends, opportunities and ideas. Check out some of our favorite stories from this past quarter:

Winterization vs. De-Waxing: Which Method is Best?

De-wax vs. Winterization
Removing waxes and lipids from cannabis concentrates is a popular industry practice.

Concentrate popularity is on the rise, taking a hefty portion of market share away from flower sales. With such a dramatic increase in popularity, we’re also seeing a wide assortment of new products hitting the market. From wax, shatter, live resin, distillate and more, it seems a new product becomes a fan favorite every month – leaving …

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Cannabis Startups 101: Raising Funds Under Rule 506(c) https://www.feliciasullivan.com/2018/02/16/cannabis-startups-101-raising-funds-under-rule-506c/ https://www.feliciasullivan.com/2018/02/16/cannabis-startups-101-raising-funds-under-rule-506c/#respond Fri, 16 Feb 2018 15:10:36 +0000 https://www.feliciasullivan.com/?p=548 A growing number of startups in the cannabis space are engaging brokers and online platforms to assist in their fundraising. This makes sense: as we’ve written previously, most investors (particularly institutional capital) are staying on the sidelines and taking a wait-and-see approach to the cannabis industry. Thus, cannabis startups will always target a smaller, more dispersed, more specialized investor base, and going through experts is a logical way to reach them. Note that 506(c) is one of the relatively new options for company financing, implemented as part of the JOBS Act of 2012. It allows for companies to engage in a more public “general solicitation”—but with strings attached, as we’ll detail below.

From a securities law perspective, the engagement of a broker-dealer or online platform converts the offering exemption from the ever-popular 506(b) offering to a 506(c) offering – changing this one letter has a number of significant consequences:

1 – You must ensure that the broker-dealer is registered, or else.

Section 3(a)(4)(A) of the Securities Act generally defines a “broker” broadly as “any person engaged in the business of effecting transactions in securities for the account of others.” This broad definition includes any “finder,” “fundraising consultant,” or anyone else receiving any transaction-based bonus or commission in return for introducing or engaging an investor. You should always consult your …

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A growing number of startups in the cannabis space are engaging brokers and online platforms to assist in their fundraising. This makes sense: as we’ve written previously, most investors (particularly institutional capital) are staying on the sidelines and taking a wait-and-see approach to the cannabis industry. Thus, cannabis startups will always target a smaller, more dispersed, more specialized investor base, and going through experts is a logical way to reach them. Note that 506(c) is one of the relatively new options for company financing, implemented as part of the JOBS Act of 2012. It allows for companies to engage in a more public “general solicitation”—but with strings attached, as we’ll detail below.

From a securities law perspective, the engagement of a broker-dealer or online platform converts the offering exemption from the ever-popular 506(b) offering to a 506(c) offering – changing this one letter has a number of significant consequences:

1 – You must ensure that the broker-dealer is registered, or else.

Section 3(a)(4)(A) of the Securities Act generally defines a “broker” broadly as “any person engaged in the business of effecting transactions in securities for the account of others.” This broad definition includes any “finder,” “fundraising consultant,” or anyone else receiving any transaction-based bonus or commission in return for introducing or engaging an investor. You should always consult your …

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What Is the Best Cannabis for Sleep? https://www.feliciasullivan.com/2018/02/16/what-is-the-best-cannabis-for-sleep/ https://www.feliciasullivan.com/2018/02/16/what-is-the-best-cannabis-for-sleep/#respond Fri, 16 Feb 2018 14:09:30 +0000 https://www.feliciasullivan.com/?p=546 What-Is-the-Best-Cannabis-for-Sleep---compressor.jpg

An estimated 3.3 million Canadians suffer from insomnia, which is about one in every seven people. Insomnia is defined as having difficulty falling asleep or staying asleep, even when you have the chance to do so. Because of this, people who have insomnia can experience fatigue, low energy, difficulty concentrating, and mood disturbances. 


Source: http://www.medicinalmarijuanaassociation.com/medical-marijuana-blog/what-is-the-best-cannabis-for-sleep…

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What-Is-the-Best-Cannabis-for-Sleep---compressor.jpg

An estimated 3.3 million Canadians suffer from insomnia, which is about one in every seven people. Insomnia is defined as having difficulty falling asleep or staying asleep, even when you have the chance to do so. Because of this, people who have insomnia can experience fatigue, low energy, difficulty concentrating, and mood disturbances. 


Source: http://www.medicinalmarijuanaassociation.com/medical-marijuana-blog/what-is-the-best-cannabis-for-sleep…

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Products to enhance microbial soil life https://www.feliciasullivan.com/2018/02/16/products-to-enhance-microbial-soil-life/ https://www.feliciasullivan.com/2018/02/16/products-to-enhance-microbial-soil-life/#respond Fri, 16 Feb 2018 09:31:35 +0000 https://www.feliciasullivan.com/?p=544 Feeding the soil

The nutrition of cannabis plants is a key factor that to a huge extent will determine the success of the harvest. Naturally, achieving a high yield of flowers is one of the principal objectives of every gardener, and a good way to measure the success of the grow. As a result the use of fertilisers in cannabis cultivation is pretty much ubiquitous, although there are still many growers unaware of the benefits of a healthy and active microbial life in the substrate.

To faithfully reproduce and accentuate the organoleptic characteristics (the aromas and flavours) of the cultivated variety, and to achieve a high cannabinoid content in the trichomes, are good indicators of a successful cannabis grow, and to achieve this, proper nutrition is absolutely indispensable.

All substrates can benefit from microbes

All growing media needs microbial life for healthy plant development

Therefore, the type of fertiliser that we use, in addition to encouraging flower production, will also have a significant influence other aspects such as the quality and final aroma of the flowers, their cannabinoid content and even the speed of flowering and maturity.

It has been demonstrated that when cultivating cannabis with natural or organic fertilisers instead of chemical or mineral fertilisers (minerals) the plants will produce better quality buds, giving excellent results in terms of flavour and aroma as …

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Feeding the soil

The nutrition of cannabis plants is a key factor that to a huge extent will determine the success of the harvest. Naturally, achieving a high yield of flowers is one of the principal objectives of every gardener, and a good way to measure the success of the grow. As a result the use of fertilisers in cannabis cultivation is pretty much ubiquitous, although there are still many growers unaware of the benefits of a healthy and active microbial life in the substrate.

To faithfully reproduce and accentuate the organoleptic characteristics (the aromas and flavours) of the cultivated variety, and to achieve a high cannabinoid content in the trichomes, are good indicators of a successful cannabis grow, and to achieve this, proper nutrition is absolutely indispensable.

All substrates can benefit from microbes

All growing media needs microbial life for healthy plant development

Therefore, the type of fertiliser that we use, in addition to encouraging flower production, will also have a significant influence other aspects such as the quality and final aroma of the flowers, their cannabinoid content and even the speed of flowering and maturity.

It has been demonstrated that when cultivating cannabis with natural or organic fertilisers instead of chemical or mineral fertilisers (minerals) the plants will produce better quality buds, giving excellent results in terms of flavour and aroma as …

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Blockchain and California Cannabis: From Seed to Sale https://www.feliciasullivan.com/2018/02/15/blockchain-and-california-cannabis-from-seed-to-sale/ https://www.feliciasullivan.com/2018/02/15/blockchain-and-california-cannabis-from-seed-to-sale/#respond Thu, 15 Feb 2018 19:10:19 +0000 https://www.feliciasullivan.com/?p=542 blockchain cannabis california

We have previously discussed blockchain technology and the effect it can have on the cannabis industry here and here. This post serves as a more detailed analysis of how blockchain can and may disrupt the tracking of cannabis from seed to sale, specifically within the new California adult use market.

Currently, cannabis businesses are spending significant amounts of money to implement track and trace systems compatible with Franwell’s Metrc. Metrc is a government-designed software that many states have elected to use, including California, that allows regulators to ensure that cannabis products are not being diverted to illegal markets. Cannabis products are given a radio frequency identification (“RFID”) tag, which licensees along the supply chain must input into their systems. This allows regulators to track the chain of custody of marijuana products. Under this system, however, licensees and regulators spend significant time ensuring compliant transfers.

Enter blockchain. In its simplest form, blockchain is a dispersed ledger. Transactions, or “blocks,” are added in a linear fashion, or “chain”, after they have been verified by other members of the blockchain as valid. All transactions on the chain are trackable to the initial entry. A blockchain platform can have various levels of supply chain information gathering, such as record keeping, tracking, assigning verifications, linking products together and sharing information.

Using blockchain technology, …

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blockchain cannabis california

We have previously discussed blockchain technology and the effect it can have on the cannabis industry here and here. This post serves as a more detailed analysis of how blockchain can and may disrupt the tracking of cannabis from seed to sale, specifically within the new California adult use market.

Currently, cannabis businesses are spending significant amounts of money to implement track and trace systems compatible with Franwell’s Metrc. Metrc is a government-designed software that many states have elected to use, including California, that allows regulators to ensure that cannabis products are not being diverted to illegal markets. Cannabis products are given a radio frequency identification (“RFID”) tag, which licensees along the supply chain must input into their systems. This allows regulators to track the chain of custody of marijuana products. Under this system, however, licensees and regulators spend significant time ensuring compliant transfers.

Enter blockchain. In its simplest form, blockchain is a dispersed ledger. Transactions, or “blocks,” are added in a linear fashion, or “chain”, after they have been verified by other members of the blockchain as valid. All transactions on the chain are trackable to the initial entry. A blockchain platform can have various levels of supply chain information gathering, such as record keeping, tracking, assigning verifications, linking products together and sharing information.

Using blockchain technology, …

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How to Make Cannabis-Infused Gummies https://www.feliciasullivan.com/2018/02/15/how-to-make-cannabis-infused-gummies/ https://www.feliciasullivan.com/2018/02/15/how-to-make-cannabis-infused-gummies/#respond Thu, 15 Feb 2018 17:40:06 +0000 https://www.feliciasullivan.com/?p=540 Gummy bears are perhaps my favorite candy. There’s something about those sweet little teddy bears that makes me want to kick back and relax or just slow down for a bit. And when you add weed to these gummies — well, let’s just say that’s one great way to make a favorite treat even better. But there’s a lot more to love about marijuana-infused gummy bears than a little stoner nostalgia; cannabis gummies are a great way to medicate. Here’s why:

Reasons to Love Cannabis Gummies

Store bought gummy bears are chalk-full of artificial sugars, flavors and additives that aren’t necessarily healthy. But homemade gummy snacks can be an excellent way get the health benefits of fresh fruit alongside the therapeutic benefits of cannabis.

Gummy Bears
Infused gummies are a great way to enjoy cannabis effectively. photo credit

Easy storage is another great reason to learn to make your own weed gummies. Just toss them in a bit of sugar when done to keep them from sticking together then store them in the fridge until ready to consume. Medicated gummies also make dosing more manageable as a single gummy or two should be a sufficient amount (though you’ll only know for sure through experimentation).

But perhaps the best reason to love marijuana gummies is because they’re a more efficient way

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Gummy bears are perhaps my favorite candy. There’s something about those sweet little teddy bears that makes me want to kick back and relax or just slow down for a bit. And when you add weed to these gummies — well, let’s just say that’s one great way to make a favorite treat even better. But there’s a lot more to love about marijuana-infused gummy bears than a little stoner nostalgia; cannabis gummies are a great way to medicate. Here’s why:

Reasons to Love Cannabis Gummies

Store bought gummy bears are chalk-full of artificial sugars, flavors and additives that aren’t necessarily healthy. But homemade gummy snacks can be an excellent way get the health benefits of fresh fruit alongside the therapeutic benefits of cannabis.

Gummy Bears
Infused gummies are a great way to enjoy cannabis effectively. photo credit

Easy storage is another great reason to learn to make your own weed gummies. Just toss them in a bit of sugar when done to keep them from sticking together then store them in the fridge until ready to consume. Medicated gummies also make dosing more manageable as a single gummy or two should be a sufficient amount (though you’ll only know for sure through experimentation).

But perhaps the best reason to love marijuana gummies is because they’re a more efficient way

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Oregon Cannabis: OLCC Clarifies Shared Processing Arrangements https://www.feliciasullivan.com/2018/02/15/oregon-cannabis-olcc-clarifies-shared-processing-arrangements/ https://www.feliciasullivan.com/2018/02/15/oregon-cannabis-olcc-clarifies-shared-processing-arrangements/#respond Thu, 15 Feb 2018 15:05:43 +0000 https://www.feliciasullivan.com/?p=538 oregon cannabis processor
Licensees and employees only: them’s the rules!

Our Oregon marijuana processor clients often approach us with requests to draft agreements that will allow third-parties to process cannabis in the client’s licensed premises. Typically, the processor is not operating at capacity and would like to supplement income by charging fees to keep the premises open around the clock. Previously, we have explained that this arrangement only really works if the third-party is also a licensed OLCC processor, pursuant to Oregon’s new alternating proprietor rules (OAR 845-025-3255). However, we are most often approached with proposals to have non-licensee third-parties enter the kitchen and physically create cannabis products that will be owned and sold by the licensee.

Here is a more concrete example: Kelly’s Kitchen is an Oregon Liquor Control Commission (OLCC) licensed processor. Kelly meets Cindy, who has developed a recipe, labels, and packaging. Cindy doesn’t want to go through the OLCC application process, she just wants to make her Bud Brownies. Kelly invites Cindy to personally make her brownies on Kelly’s property, and Kelly agrees pay Cindy for each unit sold. The prevalence of these arrangements suggests that the industry has been treating this as a grey area. However, we recently reached out to the OLCC and received confirmation that this is black and white: The OLCC will view …

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oregon cannabis processor
Licensees and employees only: them’s the rules!

Our Oregon marijuana processor clients often approach us with requests to draft agreements that will allow third-parties to process cannabis in the client’s licensed premises. Typically, the processor is not operating at capacity and would like to supplement income by charging fees to keep the premises open around the clock. Previously, we have explained that this arrangement only really works if the third-party is also a licensed OLCC processor, pursuant to Oregon’s new alternating proprietor rules (OAR 845-025-3255). However, we are most often approached with proposals to have non-licensee third-parties enter the kitchen and physically create cannabis products that will be owned and sold by the licensee.

Here is a more concrete example: Kelly’s Kitchen is an Oregon Liquor Control Commission (OLCC) licensed processor. Kelly meets Cindy, who has developed a recipe, labels, and packaging. Cindy doesn’t want to go through the OLCC application process, she just wants to make her Bud Brownies. Kelly invites Cindy to personally make her brownies on Kelly’s property, and Kelly agrees pay Cindy for each unit sold. The prevalence of these arrangements suggests that the industry has been treating this as a grey area. However, we recently reached out to the OLCC and received confirmation that this is black and white: The OLCC will view …

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What Are You Smoking Episode 26: Exercising With Cannabis https://www.feliciasullivan.com/2018/02/15/what-are-you-smoking-episode-26-exercising-with-cannabis/ https://www.feliciasullivan.com/2018/02/15/what-are-you-smoking-episode-26-exercising-with-cannabis/#respond Thu, 15 Feb 2018 01:31:27 +0000 https://www.feliciasullivan.com/?p=536 This week, Will is joined by Rebecca and Hannah to talk about exercising while high. The ladies share their favorite products and consumption methods to pair with a good sweat sesh.

The post What Are You Smoking Episode 26: Exercising With Cannabis appeared first on Leafly.

Source: https://www.leafly.com/news/podcasts/what-are-you-smoking-26-exercise…

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This week, Will is joined by Rebecca and Hannah to talk about exercising while high. The ladies share their favorite products and consumption methods to pair with a good sweat sesh.

The post What Are You Smoking Episode 26: Exercising With Cannabis appeared first on Leafly.

Source: https://www.leafly.com/news/podcasts/what-are-you-smoking-26-exercise…

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