Ukraine - The real story behind the crisis
Since the breakup of the Soviet Union, Ukraine has been at a crossroads between East and West. Civil war, the annexation of Crimea and Covid-19 has taken its toll on the country.
I
f you were to assimilate the usual corporate media fodder, you would be left in no doubt that Russia is the boggy man, with president Vladimir Putin - former head of the KGB - evil incarnate. So, is Russia is playing devils advocate with the simmering Ukraine crisis?
The bread basket of Europe
H
istorically, Ukraine was known as the breadbasket of Europe due to its vast tracts of fertile soil. Ukraine was important agriculturally during the era of the Soviet Union. Now its resources are being recognised by the west and in particular US agricultural corporations.
Ukraine has some of the most fertile soils in the world, due to minimal impacts of the industrial farming model that is much more extensive in the west. This has made Ukraine an attractive proposition for Global agricultural interests. Investment is relatively inexpensive.
However outright ownership of Ukrainian land is restricted due to a moratorium on land sales. According to the law, foreign nationals and legal persons (private corporations) may lease land, but they are not allowed to own agricultural land. Essentially the main owners of land in Ukraine are traditional farmers (see below).
A full background on the moratorium can be found in a 2014 report published by the Food and Agriculture Organization of the UN, Attitudes toward the Lifting of the Moratorium on Land Sales and the Development of Land Markets in Ukraine.
The Political Climate
I
n order to make sense of the ongoing crisis in Ukraine, we have to turn the clock back 15 years and examine what happened during the so-called ‘Orange Revolution’.
Prior to the elections in 2004, Ukraine had gone the way of other post Soviet regimes, with corruption and malpractice seeping into politics and the economy. This affected the 2004 elections, which were rigged and forced a re-vote.
Viktor Yanukovych was the candidate seeking to maintain the status quo. His support came from the predominantly Russian east and south of the country. Contesting was the pro-western Viktor Yushchenko. After the electoral re-run, Yanukovych was sent packing and a new regime, supported by the people, took charge .
This article from the Washington Post, by Nadia Diuk reflects on what happened. But there is a caveat footnote in the article. Diuk is the ‘director, Europe and Eurasia, at the National Endowment for Democracy, a congressionally funded foundation that has supported nongovernmental democracy-building efforts in Ukraine since 1988’ (emphasis added).
The NED is well known for its influential engagement in US foreign policy issues and the organisation is open about its role in funding initiatives in Ukraine, listed on its website. These range from media outlets such as Crimean Community Radio to academic institutions such as the Kyiv School of Economics.
The two biggest expenditures, amounting to almost $1million are $519,377, allocated to the Center for International Private Enterprise (CIPE), coming under the heading ‘Sparking Economic Transformation’. And $475,000 for the National Democratic Institute for International Affairs (NDI) for ‘Improving Political Party Communication With Members And Citizens’.
The list suggests more than just ‘nongovernmental democracy-building efforts’. So, what is the NED?
Late journalist and author William Blum outlines the NED’s origins. It is a CIA cutout, created to divert attention away from the CIA’s tarnished image:
“We should not have to do this kind of work covertly,” said Carl Gershman in 1986, while he was president of the Endowment. “It would be terrible for democratic groups around the world to be seen as subsidized by the C.I.A. We saw that in the 60’s, and that’s why it has been discontinued. We have not had the capability of doing this, and that’s why the endowment was created.”
And Allen Weinstein, who helped draft the legislation establishing NED, declared in 1991: “A lot of what we do today was done covertly 25 years ago by the CIA.”
In effect, the CIA has been laundering money through NED.
In short, the NED interferes in other countries affairs. And being bankrolled by the US Government, there is nothing nongovernmental about its activities.
T
he book, The Colour Revolutions in the Former Soviet Republics, goes into some background behind the events of 2004.
Following the chaos of the collapse of the Soviet Union, Ukraine, along with the newly formed Russian Federation and other former Soviet countries, succumbed to the opportunism of a small group of wealthy businessmen. These ‘oligarchs’ as they were known became a major influence within politics. Some of them became involved within Ukrainian political parties. During the 1990’s, corruption was widespread.
However, given the nature of the situation, it was everyone for themselves. The result was a lack of continuity within the ranks of the oligarchs and who they should support in the coming election. Eventually it boiled down to an emerging discord with a corrupt and discredited ‘old guard’ and it was this that galvanised a new opposition to the reigning regime. Yanukovych became the face of the old establishment.
Needless to say, there were external interests in the election. Although the outcome was determined by domestic issues, as noted above, vested interests weren’t going to ignore proceedings.
For Russia, it was absolutely vital that Ukraine remained within its geopolitical orbit. Ukraine was a vital economic asset during the Soviet era. Maintaining relations with Ukraine would act as a buffer against western influence. Yanukovych then was the obvious choice for Russian support.
Russia offered a few economic carrots to Ukraine in the run up to the vote:
it reduced the gas debt from US$2.2 billion to US$1.4 billion …and abolished quotas for Ukrainian steel pipes. These measures came on top of the heavily subsidized energy that it already supplied to Ukraine.
According to the book, Russia also took advantage of corruption within the system by allowing vote rigging and other anomalies to influence the vote. But Russia’s mistake was to underestimate the rising strength of the people in the emerging ‘orange revolution.’
As for the west, the US unsurprisingly had an interest in proceedings and pulled no punches in its condemnation in the way the election was initially conducted. This was backed up by election observer organisation the Organization for Security and Co-operation in Europe (OSCE).
The EU had a vested interest from two angles, the ‘western’ components of the bloc and the former Soviet satellites from Eastern Europe who had recently joined the EU. These latter countries in particular were suspicious of Russian influence, favouring closer ties with Ukraine within Europe. Western countries tended to be more cautious.
The Security Service of Ukraine (SBU) helped to push Yushchenko to power. According the New York Times, they plotted to prevent the ascension of Yanukovych. However the SBU were split on the issue and generally remained politically neural. But the SBU was aware of Yanukovych’s links with corruption:
Several SBU officers said the premier, who was once convicted of robbery and assault and has close links to the corrupt eastern businessmen who have acquired much of Ukraine’s material wealth, was a man they preferred not to serve, especially if he were to take office by fraud.
The Yanukovych campaign was bugged and placed under surveillance, which underlined the corruption that was rife within the ruling party.
Yushchenko’s popularity was short lived following a power struggle between the two men. In 2010, Yanukovych returned to prominence winning the 2010 presidential election. However it wasn’t long before he became the focus of controversy again over an agreement with the EU and Ukraine:
On 30 March 2012 senior officials of Ukraine and the European Union initialed in Brussels the texts of an Association Agreement (AA) between the EU and Ukraine, and also the Deep and Comprehensive Free trade Agreement (DCFTA) as an integral part of the package.
‘‘Initialing’ signifies that the negotiations over the text have been concluded and agreed. However thus far there is no binding commitment. With signing there is a political commitment, but only after ratification is it legally binding.
Again, Ukraine found itself heading in an uncertain political direction. The crunch came in March 2014, when Russia annexed Crimea following the coup (or ‘revolution’ as billed by west ) that took place a month before.
Russia’s annexation of Crimea was technically illegal under Ukrainian constitutional law (see below), but the coup that took place and the removal of Yanukovych was also illegal, perpetuated directly by US interference.
Russia was effectively pushed into Crimea, as a Counterpunch article points out:
NATO missiles on the adjacent Ukraine border aimed directly at Russia would make that country extremely vulnerable to Western goals and destabilization efforts while threatening Russia’s only water access to its naval fleet in Crimean peninsula, the Balkans, the Mediterranean Sea and the Middle East – and not the least of which would allow world economic dominance by the US, the European Union, the IMF, World Bank and international financiers all of whom had already brought staggering suffering to millions around the globe.
The real instigators in the crisis were neo-Nazis, supported by Washington. Victoria Nuland, Assistant US Secretary of State for Europe and Eurasia, was the go-between. She had negotiated directly with fascist elements in opposition to Yanukovych’s Government. Evidence of these meetings surfaced in a ‘taped conversation with U.S. Ambassador to Ukraine Geoffrey Pyatt discussing their calculations of who’s in and who’s out to replace Yanukovych.’ As far as the EU was concerned, Nuland’s position was ‘fuck the EU.’ It was also clear from the conversation that then Vice President Joe Biden was supportive of the initiative.
So what precisely was the legal implications of the annexation of Crimea? A paper published in the American Journal of International Law unpacks the legal background.
As noted above, the move didn’t comply with Ukrainian law. But as the paper notes:
international law does not categorically forbid the emergence of a new state against the legal order of an existing state.
This was based on an advisory ruling from the International Court of Justice in 2010 based on the unilateral declaration of independence by Kosovo. It concluded that:
the declaration of independence of Kosovo adopted on 17 February 2008 did not violate international law.
However, its more complex than that in the case of Crimea. As such there is no provision in law to justify Russia’s action in seceding Crimea from Ukraine. Russia’s framing centred around the will of the people. And certainly there was an overwhelming consensus in the mainly Russian population to join the Russian Federation in the Referendum that took place. The case effectively falls into the extralegal zone when it comes to interpretation of the law.
There is one other dimension though that has gone largely unnoticed in the west. Ukraine was originally part of Russia up until 1954, when the Soviet Union transferred Crimea over to Ukraine. A paper published in the journal Russian Politics & Law covers the background of the transfer.
The reason cited for the transfer decision was to symbolically mark the 300th anniversary of Ukraine becoming a part of the Tsardom of Russia in 1654.
Prior to the transfer, Crimea had the status of an Oblast within the Russian Soviet Federated Socialist Republic (RSFSR). The legal status of the transfer remains controversial to this day and has been disputed.
The idea behind the move is generally credited to Nikita Khrushchev. However the final decision rested with the the Presidium of the CPSU Central Committee (forerunner of the Politburo) as Khrushchev was not yet full leader of the USSR yet.
The controversy relates to the Soviet Constitution and the actual meeting of the Presidium, which was only partially represented when the decision was made:
according to Article 18 of the Soviet Constitution of 1936, which was then still in effect, the territory of republics could not be changed without their consent. Such consent on the part of both republics was embodied in resolutions of the Presidiums of their Supreme Soviets. However, the list of powers of the Presidium of the Supreme Soviet of the RSFSR contained in Article 33 of the Constitution of the RSFSR did not include the power to change the borders of the RSFSR—not to mention the fact that only fifteen of the twenty-seven members of the Presidium were present at the session on February 5, 1954, where this question was decided.
Indeed in a section from the book “Frozen conflicts" in Europe on Crimea and the Ukrainian-Russian conflict, author Anton Bebler states:
The transfer of Crimea was said to has been prompted by the need to bring from Ukraine a large labor force and also water for irrigation. The decree however clearly violated Art. 14 and 18 of the then valid “Stalin’s” constitution of the Soviet Union, which required a formal agreement between Soviet Socialist Republics to border changes. The Supreme Soviet of the USSR (and not the Presidium) could only confirm such an agreement, but not by itself pass a federal law and a constitutional amendment to this effect. In the case of Crimea no such parliamentary procedure was initiated and duly carried out in the two parliaments, no relevant parliamentary sessions were held, no debates took place, no votes were taken and no agreement was adopted and signed. Moreover, the Crimean population was deprived of its right to give or deny its consent to the major status change. The transfer of Crimea to Ukraine was thus illegal even in Soviet terms, unconstitutional and clearly illegitimate.
Then came the dissolution of the Soviet Union. In a referendum on Ukraine independence in 1991:
the population of the Autonomous Republic of Crimea was not consulted on whether it desired to remain in Ukraine after the dissolution of the USSR or alternatively to rejoin the Russian Federation.
Boris Yeltsin, who was Russian leader at the time, failed to follow through on the return of Crimea to Russia. Since then there has been tension within the Crimea and other predominantly Russian regions in the east of Ukraine.
Crimea was pushing for independence, with the aim of a closer relationship with Russia. But this was blocked by Ukraine in 1995, with the removal of the acting president Yuriy Meshkov, who was ‘charged with anti-state activities and with promoting Crimea’s secession from Ukraine and its integration with the Russian Federation.’
The decision in 2008 to admit Ukraine to NATO at some point, was probably the tipping point as far as Russia was concerned. There was also the question of Sevastopol, which didn’t ratify the original transfer and had been under mainly Russian control. This was formalised in June 1993 when a resolution designating Sevastopol as a Russian city was adopted. With Yanukovych at the helm in Ukraine, Russia had no worries. But with his removal from power and the ensuing conflict that emerged, Russia was ready to act.
The referendum was a rushed affair and didn’t really leave time for a wider debate. But the desired outcome was reached from a Russian perspective.
As for the legal context on the annexation and referendum, the article makes this point:
the Russian-speaking majority in Crimea has relatively peacefully expressed and exercised this right, in conformity with principle 8 of the Helsinki Final Act. The two sizeable minority communities (Ukrainians and Tatars) apparently acquiesced to the desire of the Russian-speaking majority. These facts confer a measure of legitimacy to Crimea’s secession and to its reunification with the Russian Federation.
Refilling the Breadbasket
As the US and EU apply sanctions on Russia over its annexation of Crimea, JP Sottile reveals the corporate annexation of Ukraine. For Cargill, Chevron, Monsanto, there’s a gold mine of profits to be made from agri-business and energy exploitation.
A
n article from The Ecologist, Ukraine — the corporate annexation, looks at how US based corporations, mainly agri companies, have made inroads into Ukrainian agricultural interests.
First off the starting blocks was Cargill. It took advantage of post Soviet opportunities back in the early nineties. Since then it has consolidated significant parts the grain and animal feed market.
Cargill, is one of the biggest agri-corporations in the world and the largest privately held corporation in the United States in terms of revenue. They also have their tarnished history. In particular, they were targeted by Greenpeace over deforestation, resulting the development of soya plantations in the Brazilian Amazon.
It appears that Cargill was not put off by the crisis in Ukraine. Just as the storm of protests began, Cargill bought a 5% stake in UkrLandFarming, the world’s eighth-largest land cultivator. Prior to that — as The Ecologist notes:
On 13th December 2013, Cargill announced the purchase of a stake in a Black Sea grain terminal at Novorossiysk on Russia’s Black Sea coast.
The port — to the east of Russia’s strategically and historically important Crimean naval base — gives them a major entry-point to Russian markets and adds them to the list of Big Ag companies investing in ports around the Black Sea, both in Russia and Ukraine.
Meanwhile — hovering patiently in the background — is the US-Ukraine Business Council (USUBC), which sports Big Ag luminaries: Melissa Agustin, Director, International Government Affairs & Trade for Monsanto and Cargill’s Van A. Yeutter — amongst others. So lets take a closer look at the USUBC and its current president, Morgan Williams.
The US embassy in Ukraine has an interesting insight into US — Ukraine relations:
U.S. Commercial Service Ukraine: The U.S. Commercial Service offers valuable assistance to help U.S. business export goods and services to markets worldwide. We can help you pursue your business goals in Ukraine with a wide range of services to meet your needs. Whether you are looking for trading partners or joint venture partners, or if you need the advocacy of the U.S. Embassy to help level the playing field, our highly regarded trade professionals are ready to work with you to achieve your business objectives’. It also goes out of its way to mention that ‘The U.S.-Ukraine Business Council (USUBC) is a private, non-profit trade association representing the interests of US businesses active in Ukraine (emphases added).
Following the successful installment of Ukraine’s new president, the USUBC was quick to offer its congratulations. In a statement, the USUBC ‘congratulates the new President of Ukraine Petro Poroshenko and looks forward to a Comprehensive Dialog Between the Government of Ukraine and International Investors to ENHANCE prosperity and the European integration of Ukraine’.
(The USUBC links above accessed in 2014 appears to have been deleted).
As for Morgan Williams, his CV is explored by Liberty Voice:
Ukraine business council leader, Morgan Williams, is a U.S. agricultural industry MVP. Williams is the CEO and president of the joint U.S.-Ukraine Business Council (USUBC) and has supported the vital interests of U.S. companies like Monsanto and Cargill in Ukraine’s agricultural resources.
Liberty quotes from an interview with International Business Times about U.S. corporate involvement in Ukraine’s agriculture business. Williams states that the opportunity’s in Ukraine represents a ‘gold mine’:
Williams was asked what he would do to transform Ukraine’s business climate if he were elected the country’s president. His remark about his wish to “center around getting the government out of business, set fair and transparent rules, an honest legal system and drastically reduce opportunities for bribes and corruption,” contrasts his support of companies like Monsanto who do not abide by any of the codes Williams declares as integral to a fair economy and government. Williams’ tactical leadership position at the U.S.-Ukraine Business Council is the reason why he is the U.S. agricultural industry’s MVP.
Liberty goes on to note that:
Morgan Williams’ market opinions about the Ukraine are biased and nonobjective, because he represents Monsanto and Cargill. Williams exposed his questionable intentions when he proposed that the Ukrainian government should stay out of big business.
He apparently forgot that he represents several of the corporate parties that dabble in trading their former employees with the United States Environmental Protection Agency and Food and Drug Administration. Williams is the MVP of the U.S. agricultural industry because his leadership position in the U.S.-Ukraine Business Council gives legitimacy to Monsanto and Cargill’s suspicious growing investments in Ukraine.
Enter stage east former bio-tech leviathan Monsanto. Monsanto announced at the time that it will invest $140m in a non-GM corn seed plant. Reuters notes that ‘Ukrainian laws bar local farmers from growing genetically modified crops’. Vitaliy Fedchuk, representing Monsanto was asked whether Monsanto expected changes in regulations. He said: “Indeed, in Ukraine only conventional seeds are allowed for production and importation, thus we will be working with conventional seeds only.”
Given Monsanto’s reputation though, their website offered a slightly different perspective. But since the Beyer takeover, Monsanto’s history has largely disappeared into the ether.
However, one of the commitments that Monsanto had stressed was the expansion of non GM crops in Ukraine, with a statement with an ominous measure of doublespeak:
I also want to stress the importance of creating a favorable environment that encourages innovation and fosters the continued development of agriculture. Ukraine has the opportunity to further develop the potential of conventional crops, which is where we are currently concentrating our efforts. We also hope that at some point biotechnology is a tool that will be available to Ukrainian farmers in the future (emphasis added).
The program offers rural Ukrainians the opportunity to apply for a grant of up to $25,000 to help them develop a program that provides educational opportunities, community empowerment, or small business development.
But then came a twist. The Ecologist reported on a report from the Oakland Institute, which revealed that:
the World Bank and the International Monetary Fund (IMF), under terms of their $17 billion loan to Ukraine, would open that country to genetically-modified (GM) crops and genetically-modified organisms (GMOs) in agriculture.
It revolved around the EU agreement in which a clause stipulated that ‘both parties will cooperate to extend the use of biotechnologies’, which was forbidden by law in Ukraine.
The evidence pointed to Monsanto working behind the scenes to push the narrative towards changing the law and allowing the cultivation of GM crops. Indeed the release of a series of cables by Wikileaks, collated by Food & Water Watch, indicated that the US State Department has:
"lobbied foreign governments to adopt pro-agricultural biotechnology policies and laws, operated a rigorous public relations campaign to improve the image of biotechnology, and challenged commonsense biotechnology safeguards and rules - even including opposing laws requiring the labeling of genetically-engineered (GE) foods."
The article exposes the role of Morgan Williams and the USUBC:
According to consortiumnews.com (March 16, 2014), Morgan Williams is at "the nexus of Big Ag's alliance with US foreign policy."
Besides being president and CEO of the US-Ukraine Business Council, Williams is Director of Government Affairs at private equity firm SigmaBleyzer, which touts Williams' work with "various agencies of the US government, members of Congress, congressional committees, the Embassy of Ukraine to the US, international financial institutions, think tanks and other organizations on US-Ukraine business, trade, investment and economic development issues."
The US-Ukraine Business Council's 16-member Executive Committee is packed with US agribusiness companies, including representatives from Monsanto, John Deere, DuPont Pioneer, Eli Lilly, and Cargill.
Eventually Yanukovych went for a Russian aid package worth $15 billion, with a discount on Russian natural gas. That sealed his fate.
But the promise of US GM expansion never materialised. On the 24 October 2016, Ukraine voted in favour of a new moratorium on GM crops until 2023. And as it happened, Russia had recently outlawed the production of GMO’s. The Federal Law on Amending Legislative Acts of the Russian Federation in Regard to Improvement of State Control in the Field of Genetic Engineering was adopted on On June 29, 2016.
Foot on the gas
B
eneath Ukraine’s pristine soil there’s another ‘gold mine’ waiting to be exploited — shale gas. Chevron and Shell were poised to get in on the act.
The New York Times offered an overview of a 50 year deal that could see as much as $10 billion worth of investment.
Most of the gas used by Ukraine comes from Russia, leaving Ukraine:
highly dependent on Russia’s Gazprom, which cut off its supplies in 2006 and 2009 in pricing disputes. As a result, Ukraine pays exceptionally high prices for natural gas, making the economics of shale gas extraction even more attractive for companies like Chevron.
If the companies find and produce gas, “it would reduce dependency on foreign imports significantly,” said Menno Koch, a gas analyst at Lambert Energy Advisory in London. If Ukraine or other Eastern European countries became prolific producers, that “would be a game changer,” Mr. Koch said, by creating competition for the big suppliers to Europe, not only Russia but also Norway and Algeria.
Ironically from the Russian perspective:
Gazprom maintains that shale gas drilling inherently causes pollution and is more expensive than gas extracted from traditional deposits that are abundant in Russia. It also argues that shale gas wells are quickly depleted and that rising gas prices expected to accompany a European economic recovery will again make Gazprom’s long-term contracts appear competitive.
Clearly there is no doubt that Russia perceives a threat from the possibility of a shale gas boom in Ukraine. But that very much depends on whether Ukraine will endorse widespread fracking on its pleasant green fields and whether the potential for shale gas is as lucrative as chevron believes. However Russia is making contingency plans by constructing a pipeline route that bypasses Ukraine.
Since the deals with Shell and chevron were made, the ensuing conflict has pushed them both out. Ukraine’s shale revolution remains in limbo.
A
s for the current situation, Ukraine’s ties with Europe has grown closer. An Association Agreement, including a Deep and Comprehensive Free Trade Area (DCFTA) between the EU and Ukraine has now been in place since 1 September 2017. The EU has become Ukraine’s main partner in trade. As part of the agreement, a trade ban was imposed on Crimea following its annexation. The EU officially does not recognise the Russian Federation's illegal annexation of Crimea and Sevastopol. Additional measures have been imposed on the Russian Federation since the annexation. These were extended until 23 June 2020.
The EU relationship also threatens Ukraine’s agricultural traditions as the specter of neoliberal reform consolidates itself. A report from the Oakland institute, Driving dispossession: The global push to “unlock the economic potential of land”, outlines the changes. The World Bank and the European Bank for Reconstruction and Development (EBRD) had been pushing for such reforms since the IMF got its foot in the door.
In August 2019:
the World Bank approved a US$200 million loan for the restructuring of the agricultural market and the auctioning of state lands. The announcement of the loan was accompanied by President Zelensky’s pledge to move fast on lifting the moratorium [on the sale of land].
This followed a previous unexpected twist:
In August 2018, the European Court for Human Rights (ECHR) ruled that the moratorium violated the right to the protection of property under the European Convention on Human Rights. The ruling acknowledged that while Ukrainians can lease their land, being able to sell and “dispose of property [is] an essential element of ownership.”
Although not legally binding, the ruling may serve as another nail in the coffin. In the event, President Volodymyr Zelensky, who came to office in May 2019, is pushing to end the moratorium, but not without protests from the public against the reforms. This reform was successfully carried out in 2020 (see below).
Meanwhile the usual suspects have been hovering in the background:
In July 2019, Ukraine announced that it “attracted” two loans from Cargill Financial Services International for €100 million (US$112 million). In August 2019, Bayer (the group that now owns Monsanto), won an anti-monopoly suit in Ukraine’s Antimonopoly Committee – an antitrust body that already approved consolidation in the agribusiness sector, prompting questions regarding its consistency in applying antitrust laws.
Due to lockdown conditions imposed by the Covid-19 pandemic, the changes manged to get through without major protests taking place. The pandemic had rattled an already vulnerable Ukraine economy. That allowed global agencies like the IMF to swoop in and take advantage of the situation. As the report notes:
The IMF leveraging Ukraine’s desperate economic situation to create a land market illustrates how this crisis has already been used to advance the privatization of the commons. We cannot afford more structural adjustment programs that ignore the stakes of the climate crisis and move us in the wrong direction.
The IMF’s track record suggests major issues ahead for Ukraine’s farmers. As the report sums up:
The IMF is advancing an industrial agriculture model that remains environmentally untenable and disastrous for the majority of the country’s farmers.
The future of the country hangs in the balance then. Meanwhile, one of Ukraine’s demons is set to return to Government. Victoria Newland has been nominated for Undersecretary of State. An op-ed in Common Dreams by Codepink campaigners outlines why she should be kicked out.
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