Consultations
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Many people read the chapters at the
site, especially the Last Resort and the 60 Day Program
and get new hope that their incurable conditions might
not be quite as hopeless as they thought. For those in
California, the in-office consult is available, in
which a complete medical history and lifestyle analysis
is coupled with a specifically detailed application of
the 60 Day Program.
For those who can't make it in, they can do almost as
well with the one hour phone consult. Specializing in
difficult, confusing, incurable and hopeless cases,
these consults are for those who believe they've 'tried
everything." News flash: they haven't, because they're
still sick. When your doctor tells you there's nothing
more he can do for you, he's telling the truth. Your
misfortune is that he didn't tell you sooner.
See
website for details of both types of consult.
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Upcoming Seminars
15 May Waterbury CT- The Vaccine/Nutrition seminar
22 May Palm Springs CA- The Vaccine/Nutrition seminar
12 Jun LAX- Nutrition seminar
16 Jun- Dead Chiropractors Society Lecture Newport Beach CA
The Vaccine/Nutrition seminar is a survey course which
covers important highlights from the full day seminars on
each of the two subjects.
A few of the topics covered:
Swine flu
History of vaccines
Germ Theory
68 vaccines for children
2010 Mandated Schedule of vaccines
Ingredients of vaccines
Safety and efficacy science
Attenuated agents
Mercury, aluminum, formalin
Exemption laws in every state
Autism connection controversy
Discussion of individual vaccines
Future vaccines
The new GM foods global industry
Enzymes: natural foods vs processed
Xenobiotics: the need for detox
Mineral nutrition
Colon immunobiology
Arterial detox/ heart drugs
Oral chelation
The healthiest people on earth
Weston A Price
The 60 Day Program
Complete patient nutrition materials
Antioxidants and free radicals
Collagen
Chiropractic and nutrition
Cost: 12 hours CE $169
General public: $99
To register please call 408 298 1800 mwf or email
doc@thedoctorwithin.com
More details see
www.thedoctorwithin.com
Both seminars now available on DVD sets. Updated versions.
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New
Collagen Chapter
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This is a complete rewrite of the new chapter
because we just upgraded to an even more bioavailable and
effective new collagen. It's only 10 pages. Please read if
you have any interest in your skin, hair, muscles, bones, or
organs!
Click here to read new collagen chapter.
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Peptide
Globules
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The new collagen may sometimes contain small
clumps. Some patients have called in thinking this was some
kind of problem or they got a defective jar or something.
The clumps are simply peptide globules seen in the new
product that are the result of 2 improvements:
- smaller particle size
- the 3 added amino acids
The clumping has no effect on solubility: the instant you
spoon the collagen into any liquid it all dissolves
immediately. That is one characteristic of high
bioavailability of course: how fast it dissolves.
These peptide globules are one result from going to the new
low molecular weight of 2000 daltons. In addition the
supplemental glycine, carnitine, and glucosamine you see on
the label may attract the smaller particles of the collagen,
sometimes resulting in small clumps throughout the sample.
This didn't happen in the earlier product because the extra
aminos were about the same size as the larger particle
collagen.
So relax and just realize that the peptide globules are not
the result of sloppy processing or damaged merchandise. We
know all about it and they are actually a good thing.
The new particle size represents an unprecedented advance in
the global collagen industry. Consequently, during the past
few months the demand for the new low molecular weight blend
has gone through the roof. Manufacturers are struggling to
meet the demands and have told us that there may be some
delays in production during the summer. This may result in
back-orders that may last a few weeks. The good news
however is that once the production problems are smoothed
out, we will be able to obtain all we need and there will be
no further delays in delivery.
We had a chance to buy some inferior collagen to tide us
over during the interim, but have decided to wait until we
can only provide the high end collagen. Quality is always
worth waiting for. People must have confidence that
anything they buy here will be the highest quality available
anywhere. No idle boast, as anyone can see from the
testimonial section on the site.
Please click here to read the new re-write of the Collagen
chapter.
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More
Proposed Changes to Continuing Education for California DCs
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Just when you
thought it was safe to go back in the water...
For the 4th time in the past
few years the Board has drafted a new version of proposed
changes in continuing education. The main areas include
changes in allowable course material, increasing to 24 hours
annually, making a 12 hour seminar last 14 hours, and
allowing immediate dismissal of any Provider for unspecified
reasons.
You are encouraged to send
in your comments, whatever they may be. Supposedly all
input will be reviewed. My opinion is expressed in the
letter below. These sentiments are shared by a great number
of educators and doctors within our profession. If everyone
is sleeping, these extreme changes may soon become law.
Once that happens it will be virtually impossible to change
it back.
So read the letter below.
You can go on the Board's website and see the actual text of
the proposed changes. Then send your comments without delay
to:
To: Dixie Van Allen
2525 Natomas Pk Dr. #260
Sacramento, CA 95833
dixie.vanallen@chiro.ca.gov
Doesn't have to be a long letter. It just has to be like,
in the next few days.
Here's my two cents:
To: Dixie Van Allen
2 May 10
2525 Natomas Pk Dr #260
Sacramento CA 95833
dixie.vanallen@chiro.ca.gov
chiro.info@chiro.ca.gov
To: Offce of Administrative Law
Attn: April Alameda
300 Capitol Mall, Suite 1250,
Sacramento, California 95814-4339
cc: Dynamic Chiropractic
ICA
CCA
Governor's Office, Sacramento
Sent by email and certified mail
Response to proposed changes in CE regulations
The Trojan Horse?
Doctors responding to proposed CE changes now for the 4th
time in the past 2
years can marvel at how the profession
has survived without any changes at
all. Few significant
changes in CE regs have been made during the past 15
or 20
years. The profession has muddled through somehow: doctors
attended
CE classes, renewed their licenses, paid their
fees, and acquired some
modicum of useful information from
the seminars.
The drafters of the new proposals seemed to have learned
about the legal
criteria for changing existing regs mainly
from the comments received from
us, the respondents to the
past 2 or 3 versions of Proposed Changes. While
their
previous versions were rough drafts that showed almost no
familiarity
with statutory requirements for changing regs,
the current proposals now pay
some lip service to those
criteria. But it’s still very superficial.
So once again,
let us look at yet another draft of Proposed Changes to CE
regs:
On p. 1 The drafters cite the prime criterion for changes to
existing regs from the original Chiropractic Initiative:
'... the board may make changes, the standard being
-...for the protection
of the public.'
That’s the statutory bar that must be met for any change.
Then they proceed to forget that standard for the rest of
the proposal.
P1 continues:
'the purpose of these additions, changes and
amendments is to increase the
amount of CE hours while
providing a broader range of courses available for credit,
clarify CE
requirements, establish application and renewal
fees, and establish an
appeal Process for denial or
withdrawal of CE providers.'
This statement of purpose already oversteps the Board's
statutory limitations by not meeting the
criterion that the
changes they make must be for the protection of the public.
How is the public protected by the Board adding fees? How
is the public protected by replacing the current rules for
denying a course with over-elaborate new procedures?
Clarifying CE requirements? They were already clear. What
they are proposing here is an entire new system.
This will be a continuing theme in this response: that
none of the proposed
new changes protects the public any
better than with the current system,
which has been
protecting the public just fine for the last 30 years.
Is there another agenda afoot, masqued by this burning
desire to 'protect
the public'? Is there some Trojan Horse
we should be watching for?
This allegation of 50% of board complaints being related to
areas of proposed mandatory
new CE courses is so general,
so overbroad that it has no meaning. That same standard
could apply to virtually any area of practice. Also it
assumes facts that are not in evidence. There’s no proof.
The unnamed authors simply state it.
First of all, the time period for the alleged complaints is
very short: 6 months.
Second of all---these are ALLEGED violations - including the
famous
‘anonymous tip’ cases. In such a system, the
accusee is guilty until proven
innocent. So this is quite
a different statistic from actual violations. The
importance and number is obviously being exaggerated here.
Why? What are they selling?
The solution to the imaginary problem makes little sense:
'the proposal will replace the three category system with
two categories - mandatory and approved ... including work
comp courses or courses from any other branch of healing
arts.
What a non-sequitur. I thought we were talking about
protecting the public. Weren’t they just talking about
protecting the public? How is re-categorizing CE courses
into arbitrary and actually more
restrictive categories
going to protect the public one iota? Quite a leap.
How is accrediting a course from a dentist or naturopath
without even reviewing it or asking for a syllabus going to
protect the public??? Please.
Already on the second page we are far afield from any
logical progression of
ideas.
With respect to the increase in fees, the question is the
same: how does
that fall within the standard of protecting
the public? The board may only
make changes in the
long-standing time-honored initiative act - changes that
further protect the public. With the further criteria of
Clarity,
Consistency, and Necessity. Remember?
The argument that increasing CE hours will create
new businesses and new
jobs - even if it were true is pretty fatuous, not
to mention utterly
beyond the scope of a Board such as
this. Shocking they would even try to
rationalize
something so completely outside the original purview of the
state board. Using board powers to increase fees to create
jobs --- such
altruism is more than suspicious, even if
they had the authority, assuming
powers that are simply not
provided in any existing regulatory code. A
slippery
slope indeed, if this precedent gets established. One
shudders to
imagine the platform for quid pro quo such a
radical new power would invite
between private ventures and
the board members of the future. Analogy: the
well-documented sweetheart deals between the drug companies
and the FDA
Advisory Committee. This idea should be kept
in mind as we read fur ther
here.
Effect on small business? Why is this subject even brought
up at all in such a proposal?
It’s bizarre enough that it’s
mentioned, - why would the Board even concern
itself with
such matters, or imagine it has the power?
With respect to the specific proposals:
Article 6:
The new Sec. 360: Provider application fees and biennial
provider fee:
These fees are unnecessary new changes. The only reason
offered for them
was to help new businesses, which is a
nonsensical notion at best, utterly
beyond the scope of a
simple professional regulatory board. So now the
chiropractic Board feels it’s their job to jump-start the
state’s economy?
Imagine what would follow if every state
board in any area adopted the same
attitude. What
credentials in economics, let alone authority, does this
Board pretend it has?
Obviously the $50 course application fee should remain as
it has been for
these many years. No other change is
necessary.
New Sec 361 a Course Content CE, new version
Except for the few little changes below, this entire
section should be
expunged from the new proposals.
The proposal requires 2 hours mandatory from its paragraph
11, which
includes truth in advertising, law, ethics, abuse
issues, etc. These areas
are fine, but should be included
in the ‘additional’ courses which may be
taught.
The issue here is that this arbitrary list suddenly makes
these special types of
courses absolutely mandatory for
every single re-licensing seminar. While
these subjects
may have some redeeming academic value if they are taught
well, they certainly do not necessarily reduce the number
of would-be lawbreakers, and therefore certainly cannot
guarantee to protect the public any better than the public
is protected now,
considering the enormous regulatory load a
DC is subject today. The claimed improvement is an
illusion.
The problem is that such courses being mandatory wastes
course time that a very
conscientious DC should be spending
on other more valuable subjects, which
should be the focus
of CE, if there is to be only 12 hours of classroom time
annually.
With new Sec. 361 (a) 6,
would someone please explain to me what chiropractic
manipulation is, and
why it is offered as a substitute for
adjusting? Speaking of protecting the
public ...
Beyond that, the 4 hour requirement for subheadings 3, 5,
and 10 is fine
because it actually expands the number of
courses for that slot.
So once again, the 2 hours under subheading 11 should be
included together
with the other 6 hours, which would make
it a total of 8 hours drawn from
all these areas. This
actually would be an expansion of the present system
and
would be a slight improvement. Though to go to all this
trouble writing
up a new regulation just for these minor
changes seems really unnecessary.
Section 361 (b) 2
I have an issue with the proposal to allow unmonitored,
blanket approval of
any course already accredited by any
other ‘healing arts board or bureau’ without any
scrutiny
whatsoever. During the past 10 years, my courses have been
CE approved for
nurses, naturopaths, acupuncturists, and
dentists. I can testify that none
of these professions
extends the same presumption of validity to us as this
present new
proposal would offer them. Coming from a body
already overwhelmingly
restrictive in every area possible,
such magnanimity seems suspect, and
suggests some
underlying agenda. What new quid pro quo’s may fall into
place if this proposal is whisked through? At the very
least, it’s a bad
idea.
Under this proposal, we’re adding a huge amount of detailed
new restrictions
to a DC applying for course approval, but
if a course in Swedish massage is
approved by the board of
massage for example, it is welcomed with open arms
and
automatically approved for chiropractic CE. No scrutiny, no
syllabus
review, no cv check, nothing. Anyone see what
we’re doing here?
New section 362 Provider Approval Duties,
Responsibilities
Now we get to the heart of the matter.
Comparing the old crossed out paragraph # 356.5 (a)
our
prime contention here is that what has been crossed out was
working fine, for decades.
It should remain unchanged.
Beginning with the first new paragraph, the new agenda
begins to emerge.
The obsessively complex description of an
extravagant new denial and appeal
process is very
disturbing at face value.
First off, it blithely assumes that the time-tested version
of how providers are accepted or denied was not working, or
is no longer good enough. What would make that so? What is
the
unspoken plan here?
What unwritten policy change would necessitate a written
change?
In (a) why is it necessary to spell out in painstaking,
meticulous detail
an applicant’s recourses for appealing a
denied seminar? Why all this ink?
If the seminar’s subject
matter does not fall into the
specified categories, reject
it. If it does, approve it. Just like
always. If some
violation is committed, pull the seminar. Just like
always. What is this elaborate prolixity about? What is the
plan? It
broadcasts like a mad scrambling to cover all the
bases in preparation for a
rash of appeals to seminars
about to be denied. If that seems paranoid,
then the new
proposals are that much less necessary.
The proposed new Sec 362 c ---biannual renewal for all
Providers
It is not the proposed $50 biannual renewal fee for
Providers that is problematic, but
rather the idea of an
unprecedented new policy suddenly requiring Providers
to
renew at all, just pronounced out of the blue, without the
slightest attempt
at offering any rationale for its
necessity.
WHY IT IS NOT NECESSARY: First of all, renewing all the
hundreds of
Providers every 2 years would create a mountain
of applications, responses, and corrections, etc.
and open a
whole Pandora's box of administrative and clerical issues
that would further
tax the limited time resources of an
already overstressed board staff. There is no way the
new
fees taken in would make up for all that new paperwork,
which would perpetuate itself, every 2 years. It would be a
net financial loss.
No necessity for changing the current system has been
shown. This is a frivolous and whimsical
notion. Why
would someone who has been an instructor for 10 years need
to file a new
application? For what? Not only is it
insulting to those who have made
careers out of being
providers, it also devalues the Board’s own original efforts
at qualifying the Provider in the first place.
Secondly, this new proposal is NOT CONSISTENT with the
long-established 5 year mentor/apprentice program which has
worked so well these past decades.
The new proposal would do away with that time-tested
system. Having personally gone through the 5 year
apprenticeship, I can say it was invaluable to me. It has
proven itself an excellent system for introducing a new
instructor into the complexities of CE regs.
By the time someone has been a seminar Provider for say 10
years that
Provider has learned the system extremely well.
Why on earth would someone
like that need to re-apply every
year? No new training is involved. The
idea is
ill-conceived, and certainly doesn't merit serious
consideration as
a permanent change to state law. The only
hidden agenda suggested is that it
would give some future
irresponsible Board more power to deny Providership
for
vague, arbitrary, personal, or frivolous reasons.
We should leave the current 5 year apprenticeship in
place. Replacing this
valuable time-proven system with the
litany of specific threats contained in
the new sec 362 (f)
is unreasonable, cumbersome, impractical, and
practically
begs for a smothering amount of burdensome litigation
which
would drag on for years unresolved, and waste the state’s
resources
in prosecuting its case.
Leaving the current system intact generates no new body of
unnecessary
paperwork and expense to maintain.
The new Sec. 362 e
# 1-6
are repetitive and already in place now. Essentially the
same as existing
regs. No necessity for change.
New Section 362 (f) - withdrawing approval of CE courses
The new proposed Section 362 (f) where it goes on and on
about denials and
appeals for a seminar application is a
serious red flag indicating
the probable consequences
foreseen by the drafters of this radical new
proposal. The
way it is written, it's as though they're expecting a whole
flood of appeals from a large number of applications they
are preparing to
reject, and the drafters seem to want to
have these statutory safeguards in
place to protect their
new decisions, no matter how unreasonable. The
imprudent
pathway upon which they would now have the State embark is a
radical detour in policy that would make CE course approval
a very
subjective affair indeed, inviting a brave new world
of prejudicial
decisions based on the whims and values of a
very few people. It is a
fundamental shift from the
current traditional approval policy, whereby
approval is
basically an administrative clerical matter: as long as the
course work falls within general parameters of common sense
and academic
value to the attendees, it meets the
requirements.
This simple policy has served the profession well for
decades in providing
doctors with a wide range of course
material from which to choose. Courses that are badly
presented or ill-researched are soon eliminated very
naturally, by the vote
of the number of DCs who either deem
the subject material valuable or
not. They either show up
or they do not, and a seminar rises or falls based
on that
attendance.
What change do we see here? Under the new proposals, the
suggestion is made
that a couple of people should now have
that power to choose exactly what courses will ever see the
light of day.
It should not escape the reader’s notice that those making
such a decision
are not necessarily themselves educators or
Providers, nor do they need to
have any credentials
whatsoever. Yet they would have total power to reject
a
seminar prepared by an academic career professional, that
had been
successfully attended for years by the DCs who
chose it.
Such a decision for acceptance or rejection is going to be
made by a 5
minute review of a course syllabus in which one
or two sentences summarizes
an hour of material? With the
wide range of course material that is
currently approved,
much of it very technical and detailed
and meticulously
researched by years of study, are we really going to
pretend that one individual of unspecified credentials has
the intelligence
and wisdom to make yes or no decisions in
all these fields, without ever
actually attending the
seminar itself to learn what it was truly about?
This is precisely what we are being asked to buy here. And
again, once this
new provision is passed into law, it will
be almost impossible to root it
out. We must consider these
implications very carefully before passing it
into law.
Clarity is a prime criterion in considering making changes
to laws already
on the books, because of the possibility of
misinterpretation by some future
Board.
The language itself in (f) seems almost deliberately
unclear, and is a
walking target for litigation:
“The Executive Officer may withdraw approval of any CE
provider for good cause..”
What precisely is good cause? According to whom? We see
what it may include, but it’s an undefined, open notion, in
this context. It invites subjective interpretation, even
personal vendetta, and flagrant abuse.
What are the criteria for the Officer to make this
unilateral, sudden, and
abrupt decision? Under precisely
what circumstances? Anonymous letters? Signed letters
kept
secret? All this intrigue is possible the way this
proposal is written.
And then the time limit is absurd: 180 days! Suspended
for no proven reason, the seminar would be immediately
suspended for a year until it is
'resolved'?
What if the charge proves to be groundless? What if some
future Executive Officer makes something
up because of a
personal dislike of a Provider who is following all the
regs? All this and more is possible if this ill-contrived
proposal is passed. These strange specifics seem to
indicate a plan, an intention to protect some unprecedented
agenda about to unfold.
What could that possibly be? --
In short, this section (f) is extravagant, dangerous and
almost begs for
future abuse. In itself it is no
improvement to the present system and by
no stretch of the
imagination could it be said to protect the public better
than the existing law.
The way it is written, Section 362 (f) may well put the
Board itself in harm's way
from a legal aspect, exposing
them to an enormous number of lawsuits.
We therefore propose
that Section 362 (f) should be stricken and expunged
from
this proposal.
New section 363 (b)
Here again is the reiteration of the exact same ideas as in
362 (f)
immediately above. Why the repetition? What is it
the author wants to make
certain gets protected? If this
is just bad typing, it is insulting to the
reader who has
just been made to read the exact same paragraph.
New section 363 (c) 2:
We saw this in the previous rough drafts - this bizarre
idea about the 50 minute academic hour.
As before, Section 363 (c) 2 regarding the 10 minute break
is unprecedented and without
merit. This proposal is a
radical, extreme departure in long-standing
policy with
absolutely no reason or foundation even offered.
Every doctor in this state received a license and an
undergraduate degree based on the 50
minute academic hour.
None of us had to stay after school to make up for
the 10
minute breaks throughout the day, did we? The 50 minute
academic
hour has been the standard not only within our
profession since the time of
BJ Palmer, but in every
university and center of higher learning both in the US and
abroad since the time of Chaucer. The way this proposal is
written would effectively extend a 12 hour seminar to 14
hours!
It is difficult to grasp the intent of such a new idea
being introduced as
law.
This section should be deleted and never mentioned again.
It is an
embarrassment to our profession that it was even
suggested and it shows how
far afield these proposed
policies are separated from the academic
regulations of any
other legitimate profession, healing or
otherwise,
throughout all of Western civilization.
In a professional gathering such as a CE seminar, the topic
of break times
is not a subject requiring the drafting of
any legislation, but rather one
of common sense. Our
profession has got along well for the past century
without
addressing it; it seems reasonable to continue with the
present
traditions regarding it.
New section 363 (e) is unnecessary self evident and should
be deleted.
Here we see in 363 (f) the same exact paragraph regarding
cancelling and
denying courses that has already appeared
twice before! What is the meaning of this?
All 3 of them
should be deleted.
New Section 363.1 The matter of distance learning.
Though well established throughout the majority of colleges
in the US today,
it is clear this drafters of the new
proposals have little experience with
distance learning.
My coursework has been accredited for distance learning in
many
states for some years. It does not involve mailing
DVDs and other materials
to the student. How could any
security be maintained in that situation?
The companies with online courses that have been CE
accredited for DCs in 35
states for years follow standard
accepted protocols for security and
completion. Aligning
oneself with these established organizations will be a far
higher
standard that the Board’s uninformed
reinvent-the-wheel suggestions here.
All that needs to be stated is that distance learning is
now approved for 12
hours from any accredited online
source. Period.
New section 366
The very last paragraph in this section regarding the Board
enlisting
attendees of a seminar as spies in order get
information about the course is certainly unworthy of
this
type of proposal, and not something that needs to be written
into state
law. The Board is free to call anyone it wishes
at the present time, so why
waste time writing a law that
lets them do what they can already do now?
The proposal has
a kind of KGB feel to it and is another embarrassing part
of the new proposals.
New proposal 372. As it is written it is doubletalk,
completely
self-cancelling and redundant. It certainly is
not necessary as a new
regulation.
On behalf of the profession, I for one would like to
apologize to anyone who
has had to wade through this morass
of repetitive, arbitrary, generally
unnecessary proposals
for the past 2 years to change a perfectly good code
of
regulations. It seems reckless and intemperate to ignore a
track record
of success evidenced by the current set of
rules, which has served so well
these many decades, and to
replace it with trendy, ill-considered whims
which will
certainly not stand the test of time.
Earlier drafts of these proposals during the last 2 years
have exposed us
Responders to some exotic suggestions by
this same Board. It is clear our suggestions had
some
effect, saving the profession from some truly baroque
interpretations of CE
course requirements, as well as of
the Board’s imagined scope. Although
some of the current
suggestions are at least now within reason, with the
above
exceptions, there is no compelling evidence whatsoever that
the
current Category topics for CE need any revision. At
all.
Aside from these repeated proposals for change, the current
Board has done a
fine job, which is all the legacy any
Board needs. This imagined imperative
to leave its mark -
any mark at any cost - will certainly have the opposite
effect than the one wished for, if this problem-riddled
final draft is
indeed the heritage they will leave.
The current regulations have set a high standard for
chiropractic CE in this
state for decades, and should
continue to do. No need for change has been
shown. After
reading the long-winded new proposals carefully, no
reasonable person could defend that the essential
requirements for Clarity,
Consistency, and Necessity for any
changes have been satisfied.
At present our beleaguered profession certainly has more
pressing issues to
attend to than these mysterious
amendments. To persist in draft after
draft of these
short-sighted, confused proposals being submitted would be a
continued waste of time for all involved, in my opinion.
Let’s put it to
rest right here.
Respectfully submitted,
Tim O'Shea DC
What a strange profession we have – look what we spend our
time on, while the world is in desperate need of
chiropractic care.
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