Prosecution Insights
Last updated: April 19, 2026
Application No. 18/235,764

SYSTEMS AND METHODS FOR SHARED ACCOUNTS

Final Rejection §101
Filed
Aug 18, 2023
Examiner
DUCK, BRANDON M
Art Unit
3693
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Wells Fargo Bank N A
OA Round
4 (Final)
64%
Grant Probability
Moderate
5-6
OA Rounds
2y 7m
To Grant
83%
With Interview

Examiner Intelligence

Grants 64% of resolved cases
64%
Career Allow Rate
214 granted / 332 resolved
+12.5% vs TC avg
Strong +19% interview lift
Without
With
+18.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
47 currently pending
Career history
379
Total Applications
across all art units

Statute-Specific Performance

§101
47.9%
+7.9% vs TC avg
§103
21.9%
-18.1% vs TC avg
§102
9.6%
-30.4% vs TC avg
§112
13.3%
-26.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 332 resolved cases

Office Action

§101
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Status of Claims This action is in reply to Applicant Response filed on 12/3/2025. Claims 1, 10 and 19 have been amended and are hereby entered. This action is made FINAL. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more. Under the broadest reasonable interpretation, the following claim terms are presumed to have their plain meaning consistent with the specification as it would be interpreted by one of ordinary skill in the art. MPEP § 2111. Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03) Claim 1 recites a process, which is a statutory category of invention (Step 1: YES). Claim 10 recites a system (system), which is a statutory category of invention (Step 1: YES). Claim 19 recites a product, which is a statutory category of invention (Step 1: YES). Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a)). Yes. The claims are analyzed to determine whether it is directed to a judicial exception. The following claims identify the limitations that recite additional elements in bold and the abstract idea without bold. Underlined claim limitations denote newly added claim limitations: Claims 1, 10, and 19 are abstract, and recite a method comprising: receiving, by a computing system of a first provider, a request from a first user device associated with a first member to form a shared account with one or more second members, the request including information identifying a first account of the first member, and a security parameter for the shared account, the security parameter including a physical interaction with the first user device to join the shared account, wherein the first account is stored in a database of the computing system; generating, by the computing system, the shared account including a first link between the shared account and the first account, wherein the generated shared account is stored in the database and includes a unique account number indicating the shared account is accessible by multiple members; transmitting, by the computing system, one or more messages to one or more second user devices associated with the one or more second members; receiving, by the computing system, from the first user device, an indication of one or more physical interactions between the one or more second user devices and the first user device; generating, by the computing system, one or more second links between one or more second accounts of the one or more second members and the shared account responsive to the one or more physical interactions, wherein generating the one or more second links comprises: determining, by the computing system and responsive to a first physical interaction with a respective user device of a second member of the one or more second members, that the second member does not have an account stored in the database: generating, by the computing system and responsive to determining that the second member does not have the account stored in the database, a user interface including a drop-down list of a plurality of providers; providing, by the computing system, the user interface to the respective user device of the second member; receiving, by the computing system and via a user input to the user interface, a selection of a second provider from the drop-down list; generating, by the computing system, responsive to receiving the selection of the second provider, and via a communication link between the computing system and a second computing system of the second provider, a second user interface including a log-in portal associated with the second provider; providing, by the computing system, the second user interface to the respective user device of the second member; and receiving, by the computing system and via a user input to the second user interface, log-in credentials and a selection of an external account of the second member; establishing, by the computing system, a value associated with the shared account; receiving, by the computing system, an input via the first user device indicating a selection to initiate an inbound transfer of a first amount from the first account to the shared account to increase the value associated with the shared account; detecting, by the computing system, that the value associated with the shared account satisfies a threshold criteria; identifying, by the computing system, an eligible member from among the first member and the second member responsive to the value satisfying the threshold criteria and according to at least one machine learning model that considers financial transaction information of each linked second member; transmitting, by the computing system, a notification to the user device of the eligible member, the notification indicating availability of an outbound transfer from the shared account to the account of the eligible member; receiving, by the computing system, a response from the user device, the response selecting to initiate the outbound transfer from the shared account to the account of the eligible member; and initiating, by the computing system, the outbound transfer in an amount specified in the response from the shared account to the account of the eligible member. These limitations, as drafted, under its broadest reasonable interpretation, covers performance via certain methods of organizing human activity, but for the recitation of generic computer components. Under human activity, the limitations are commercial interactions, specifically business relations. Also, the limitations are managing interactions between, specifically following instructions. Accordingly, the claim recites an abstract idea. The mere recitation of generic computer components in the claims do not necessarily preclude that claim from reciting an abstract idea. (Step 2A-Prong 1: Yes. The claims recite an abstract idea). Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)). No. The above judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of computing system of a first provider, first user device, database of the computing system, computing system, database, first link between the shared account and the first account, one or more second user devices, user device of the second member, one or more second links, communication link, machine learning model, second computing system, first database, second database, processing circuit, processors, memory, non-transitory computer readable medium storing instructions, processing system, network interface, user interface, second user interface, one or more messages, log-in portal, input via the first user device, an indication of one or more physical interactions between the one or more second user devices and the first user device, drop-down list of a plurality of providers, physical interaction with the first user device, notification to the user device of the eligible member, and response from the user device. The additional elements of a computing system of a first provider, first user device, database of the computing system, computing system, database, first link between the shared account and the first account, one or more second user devices, user device of the second member, one or more second links, communication link, machine learning model, second computing system, first database, second database, processing circuit, processors, memory, non-transitory computer readable medium storing instructions, processing system, are just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)). The additional elements of network interface, user interface, second user interface, one or more messages, log-in portal, input via the first user device, an indication of one or more physical interactions between the one or more second user devices and the first user device, drop-down list of a plurality of providers, notification to the user device of the eligible member, and response from the user device are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of Graphical User Interfaces (MPEP 2106.05(h)). The computer components are recited at such a high-level of generality (i.e. as a generic computer components) such that it amounts to no more than mere instructions to apply the exception using generic computer components, and the claims fail to recite technological detail as to how the step of the judicial exception is accomplished. Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea and are at a high level of generality. The abstract idea includes receiving an indication of a physical interaction (“physical interaction with the first user device”). A human analog equivalent could be, for example, a handshake between people. The use of generic devices to perform this interaction does not integrate the abstract idea into a practical application under Step 2A Prong 2. The physical interaction is implemented using generic technology because it merely recites the use of standard communication protocols or generic hardware to establish the physical interaction. This is merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f)). (Step 2A-Prong 2: NO. The judicial exception is not integrated into a practical application). Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05). No. The claims are next analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional elements of (computing system of a first provider, first user device, database of the computing system, computing system, database, first link between the shared account and the first account, one or more second user devices, user device of the second member, one or more second links, communication link, machine learning model, second computing system, first database, second database, processing circuit, processors, memory, non-transitory computer readable medium storing instructions, processing system, network interface, user interface, second user interface, one or more messages, log-in portal, input via the first user device, an indication of one or more physical interactions between the one or more second user devices and the first user device, drop-down list of a plurality of providers, physical interaction with the first user device, notification to the user device of the eligible member, and response from the user device) in the claims amount to no more than mere instructions to apply the exception using a generic computer component and generally linking the use of GUI’s to the judicial exception. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component and generally linking the use of GUI’s to the judicial exception cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. In addition to merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f)), the additional element of using the devices for physical interaction also does not go beyond what is well-understood, routine, and conventional activity in the field, as evidenced by two piece of prior that discuss NFC style “tapping” between devices (US 20140279479, Para 47 – “As a result of a conventional NFC-style "tap" of the wireless communication device 104 with the NFC POS terminal 102, the terminal 102 may perform a pairing handshake with the device 104 and set up the Bluetooth pairing between the wireless communication device 104 and any other Bluetooth-enabled device, such as a device in the retail environment including the NFC POS terminal 102, the Bluetooth terminal 110, and the like. The NFC POS terminal 102 may use the NFC protocols as a medium such as for exchange of device-to-device information to facilitate Bluetooth pairing via the Bluetooth terminal 110. In this way, traditional NFC POS terminal 102 tap-to-pay may be combined with Bluetooth pairing for fast electronic payment information transfer to the NFC POS terminal 102 and later delivery of payment confirmation (e.g. a payment receipt) via Bluetooth. In addition to exchange of device-to-device information for Bluetooth pairing, additional information, including security key information for securing data transferred over a Bluetooth link may be exchanged (e.g. encryption keys and/or signing keys). The information received by the NFC POS terminal 102 from the device 104 may be processed by the terminal 102 and/or may be forwarded to a central server, one or more of the Bluetooth terminals 110, to another NFC POS terminal, and the like for processing including handling of device paring, security key exchange and configuration, and the like, & US 20130304553, Para. 4, “Near Field Communication (NFC) is a proximity communication technology that can enable contactless device payment technologies and that is supported by the Global System for Mobile Communications (GSM) Association. Radio frequency identification (RFID) is another wireless communication technology that can be adapted to enable NFC contactless device payment technology. NFC communication generally is conducted in a range from about 3 to about 4 inches. Such short communication distances limit enable secure communication between close field proximity enabled devices. In operation of an NFC transaction, a user "taps" a contactless device, such as an NFC-enabled mobile phone, to a reader of a point of sale (POS) system. The reader recognizes the NFC-enabled device when the device is moved within range of the reader, establishes a secure communication channel with the device, and initiates a payment transaction between the reader and the device. NFC contactless payment devices can function as a credit card to enable purchases at the point-of-sale. During the conventional transaction, the device and the reader communicate to complete the predefined transaction”). Accordingly, a conclusion that the additional element of using the devices for physical interaction also does not go beyond what is well-understood, routine, and conventional activity in the field. Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claims do not amount to significantly more than the recited abstract idea (Step 2B: NO; The claims do not provide significantly more, and are not patent eligible). Claim 2 recites further comprising initiating, by the computing system, a second inbound transfer from the account of the eligible member in the amount to the shared account. These limitations are also part of the abstract idea identified in claim 1, and are similarly rejected under the same rationale as claim 1, supra. Claim 3 recites wherein the outbound transfer comprises a loan against the shared account, and wherein the second inbound transfer comprises a repayment of the loan. These limitations are also part of the abstract idea identified in claim 1, and are similarly rejected under the same rationale as claim 1, supra. Claim 4 recites further comprising determining, by the computing system, an access pattern of first user and the one or more second members, wherein the eligible member is identified according to the access pattern. These limitations are also part of the abstract idea identified in claim 1, and are similarly rejected under the same rationale as claim 1, supra. Claim 5 recites wherein the access pattern is determined by an analysis of at least one transaction within an account of the first member and an account of the second member. These limitations are also part of the abstract idea identified in claim 1, and are similarly rejected under the same rationale as claim 1, supra. Claim 6 recites wherein inbound transfer comprises a recurring inbound transfer from the first account to the shared account. These limitations are also part of the abstract idea identified in claim 1, and are similarly rejected under the same rationale as claim 1, supra. Claim 7 recites wherein the notification comprises a withdrawal allowance notification, and a user interface element allowing for the eligible member to defer the withdrawal to another user within the shared financial account. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of user interface element are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of graphical user interfaces (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished. Further, the additional element of user interface in the claim amounts to no more than mere instructions generally linking the use of graphical user interface to the judicial exception. The same analysis applies here in Step 2B, i.e., mere instructions generally linking the use of graphical user interface to judicial exception cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claims do not amount to significantly more than the recited abstract idea. Claim 8 recites wherein the notification comprises a withdrawal allowance notification, and a user interface element for receiving a selection of the amount to transfer via the outbound transfer. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of user interface element are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of graphical user interfaces (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished. Further, the additional element of user interface in the claim amounts to no more than mere instructions generally linking the use of graphical user interface to the judicial exception. The same analysis applies here in Step 2B, i.e., mere instructions generally linking the use of graphical user interface to judicial exception cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claims do not amount to significantly more than the recited abstract idea. Claim 9 recites wherein the first member is the eligible member responsive to the first portion associated with the first account exceeding a threshold value. These limitations are also part of the abstract idea identified in claim 1, and are similarly rejected under the same rationale as claim 1, supra. Claim 11 recites wherein the processing circuit is further configured to initiate a second inbound transfer from the account of the eligible member in the amount to the shared account. These limitations are also part of the abstract idea identified in claim 10, and are similarly rejected under the same rationale as claim 10, supra. Claim 12 recites wherein the outbound transfer comprises a loan against the shared account, and wherein the second inbound transfer comprises a repayment of the loan. These limitations are also part of the abstract idea identified in claim 10, and are similarly rejected under the same rationale as claim 10, supra. Claim 13 recites wherein the processing circuit is further configured to determine an access pattern of first user and the one or more second members, wherein the eligible member is identified according to the access pattern. These limitations are also part of the abstract idea identified in claim 10, and are similarly rejected under the same rationale as claim 10, supra. Claim 14 recites wherein the access pattern is determined by analysis of transactions within an account of the first member and an account of the second member. These limitations are also part of the abstract idea identified in claim 10, and are similarly rejected under the same rationale as claim 10, supra. Claim 15 recites wherein inbound transfer comprises a recurring inbound transfer from the first account to the shared account. These limitations are also part of the abstract idea identified in claim 10, and are similarly rejected under the same rationale as claim 10, supra. Claim 16 recites wherein the notification comprises a withdrawal allowance notification, and a user interface element allowing for the eligible member to defer the withdrawal to another user within the shared financial account. These limitations are also part of the abstract idea identified in claim 10, and the additional elements of user interface element are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of graphical user interfaces (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished. Further, the additional element of user interface in the claim amounts to no more than mere instructions generally linking the use of graphical user interface to the judicial exception. The same analysis applies here in Step 2B, i.e., mere instructions generally linking the use of graphical user interface to judicial exception cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claims do not amount to significantly more than the recited abstract idea. Claim 17 recites wherein the notification comprises a withdrawal allowance notification, and a user interface element for receiving a selection of the amount to transfer via the outbound transfer. These limitations are also part of the abstract idea identified in claim 10, and the additional elements of user interface element are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of graphical user interfaces (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished. Further, the additional element of user interface in the claim amounts to no more than mere instructions generally linking the use of graphical user interface to the judicial exception. The same analysis applies here in Step 2B, i.e., mere instructions generally linking the use of graphical user interface to judicial exception cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claims do not amount to significantly more than the recited abstract idea. Claim 18 recites wherein the first member is the eligible member responsive to the first portion associated with the first account exceeding a threshold value. These limitations are also part of the abstract idea identified in claim 10, and are similarly rejected under the same rationale as claim 10, supra. Claim 20 recites wherein the instructions further cause the processing system to perform operations comprising initiating a second inbound transfer from the account of the eligible member in the amount to the shared account, wherein the outbound transfer comprises a loan against the shared account, and wherein the second inbound transfer comprises a repayment of the loan. These limitations are also part of the abstract idea identified in claim 19, and are similarly rejected under the same rationale as claim 19, supra. Response to Arguments Applicant's arguments filed 12/3/2025 have been fully considered but they are not persuasive. Applicant argues that the currently recited claims are significant technical improvements (Applicant arguments, pg. 14). Examiner disagrees. The currently recited claims are a manual process with additional elements. Regarding the physical interaction of user devices, the currently recited claim limitations fail to recite how the interaction leads to any improvement or is specific in any nature. In other words, the claims fail to reveal anything unconventional with the interaction or security, for that matter, and the claims themselves only highlight the abstract idea (which is noted in the above 101 rejection). More specifically, applicant’s note that the device interaction is a non-conventional way of coupling users and a unique way to group users which may be required to touch their devices before joining. However, there is not an unconventional way that the devices interact or an unconventional way of touching their devices which allows them to be grouped, just that the grouping is unconventional. Thus, the improvement is in the abstract idea, and the technology is just used as a tool. Applicant argues that the currently recited claims are similar to Example 23 of the USPTO Subject Matter Guidelines. Examiner disagrees. In Example 23, the claim (Claim 4) was deemed eligible as it recited additional limitations that amounted to significantly more than the abstract idea, when viewing the computer limitations as an ordered combination. As noted in the guidelines: “The claim further recites te limitations of displaying a first and second window, detecting an overlap condition indicating the windows overlap such that textual information in the first window is obscured from view, determining the textual information is too large to fit in an unobstructed portion of the first window, scaling the textual information based upon the calculated scale factor, automatically relocating the scaled textual information to an unobstructed portion of the first window so that it is viewable by the user, and automatically returning the textual information to its original format when the overlap condition no longer exists.” In essence, the example noted that the claim limitations “improved the functioning of a basic display function of the compute itself.” The currently recited claim limitation do not involve scaling or relocating textual information in overlapping windows, as are not synonymous with Example 23. Also, the currently recited claims are not synonymous to Example 35 of the USPTO Subject Eligibility Guidelines as well. Example 35 dealt with an ATM providing an random code, mobile communication generating an image from encrypted code in response to the random code, and a determination of the transaction based on the analysis of the code. The currently recited claims do not involve encrypting or decrypting code, whatsoever. Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to BRANDON M DUCK whose telephone number is (469)295-9049. The examiner can normally be reached 8am - 5pm. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Michael Anderson can be reached at 571-270-0508. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /BRANDON M DUCK/Examiner, Art Unit 3693 /ELIZABETH H ROSEN/Primary Examiner, Art Unit 3693
Read full office action

Prosecution Timeline

Aug 18, 2023
Application Filed
Nov 06, 2024
Non-Final Rejection — §101
Jan 21, 2025
Interview Requested
Jan 28, 2025
Examiner Interview Summary
Jan 28, 2025
Applicant Interview (Telephonic)
Feb 11, 2025
Response Filed
May 05, 2025
Final Rejection — §101
Jun 24, 2025
Interview Requested
Jul 07, 2025
Examiner Interview Summary
Jul 07, 2025
Applicant Interview (Telephonic)
Jul 09, 2025
Response after Non-Final Action
Aug 11, 2025
Request for Continued Examination
Aug 13, 2025
Response after Non-Final Action
Aug 28, 2025
Non-Final Rejection — §101
Nov 13, 2025
Interview Requested
Nov 20, 2025
Examiner Interview Summary
Nov 20, 2025
Applicant Interview (Telephonic)
Dec 03, 2025
Response Filed
Feb 25, 2026
Final Rejection — §101 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
64%
Grant Probability
83%
With Interview (+18.9%)
2y 7m
Median Time to Grant
High
PTA Risk
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