Prosecution Insights
Last updated: April 19, 2026
Application No. 18/269,222

CELL TRAY

Non-Final OA §103
Filed
Jun 22, 2023
Examiner
KASS-MULLET, BENJAMIN ELI
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
LG Energy Solution, Ltd.
OA Round
1 (Non-Final)
64%
Grant Probability
Moderate
1-2
OA Rounds
3y 7m
To Grant
60%
With Interview

Examiner Intelligence

Grants 64% of resolved cases
64%
Career Allow Rate
9 granted / 14 resolved
-0.7% vs TC avg
Minimal -4% lift
Without
With
+-4.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
62 currently pending
Career history
76
Total Applications
across all art units

Statute-Specific Performance

§103
67.9%
+27.9% vs TC avg
§102
14.5%
-25.5% vs TC avg
§112
11.2%
-28.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 14 resolved cases

Office Action

§103
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 . Priority Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statement(s) (IDS) submitted on 6/22/2023, 9/10/2024, 4/2/2025, 6/10/2025, and 12/04/2025 have been considered by the examiner. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim(s) 1-6, 8, 11-13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Guerin (KR 20100100943 A) in view of Seol (US 20210028431 A1) and further in view of Ma (CN 210129536 U). Regarding claim 1, Guerin teaches the following elements: A cell tray, comprising: a tray body in which upper part is open and having an internal space; (“The tray 34 has an overall parallelepiped shape with an overall rectangular cross section. This train 34 is opened at the top in the manner described below and closed at the base by a flat lower horizontal wall 48.” Guerin [50]) partition walls dividing the internal space so that a plurality of cylindrical cells are each accommodated between the partition walls; (“The storage unit 20 has the same appearance. Each unit 20 thus has a cylindrical shape with a vertical axis. Each unit 20 is partitioned by an outer cylindrical surface 36 laterally and by an upper circular horizontal end surface 38 and a lower end circular horizontal end surface 40 in the vertical direction.” Guerin [49] PNG media_image1.png 285 335 media_image1.png Greyscale PNG media_image2.png 501 806 media_image2.png Greyscale Guerin is silent on the following elements of claim 1. Specifically, while Guerin teaches that each unit has an upper and lower connection terminal (“Each unit 20 has two electrical connection terminals 42. Each terminal 42 protrudes perpendicularly to the surface 38 and the surface 40, respectively.” Guerin [49]), Guerin is silent on a first connector pivotably installed on the upper part of the partition wall, a second connector between the partition walls in the tray body, and an electrical characteristic measurer connected to the first and second connector: a first connector pivotably installed on an upper part of a first partition wall of the partition walls, and pivoting toward the upper electrode tab to contact an upper electrode tab of a first cylindrical cell to the plurality of cylindrical cells; a second connector installed in the tray body between the partition walls and contacting a lower electrode tab of the first cylindrical cell; and an electrical characteristic measurer electrically connected to the first connector and the second connector to measure Seol teaches the following elements of claim 1 that are not found in Guerin. Specifically, Seol teaches a battery tray with a voltage detection implement that includes detection ends on both the upper ad lower portions of the cell block. The only thing Seol does not teach is the first connector being explicitly pivotably installed: a first connector pivotably installed on an upper part of a first partition wall of the partition walls, and pivoting toward the upper electrode tab to contact an upper electrode tab of a first cylindrical cell to the plurality of cylindrical cells; (“and a connection end on another end of the voltage detection lead and exposed at an upper end of the insulative body for connection with a circuit board on the cell block.” Seol [0010]) a second connector installed in the tray body between the partition walls and contacting a lower electrode tab of the first cylindrical cell; (“The voltage detection lead may include a detection end on an end of the voltage detection lead and exposed at a lower end of the insulative body to form a voltage detection position at a lower portion of the cell block;” Seol [0010]) and an electrical characteristic measurer electrically connected to the first connector and the second connector to measurecell. (“The detector 40 extends vertically in the lengthwise direction of the side cells C2, it may be efficient to measure the voltages of the lower ends 10b of the side cells C2 by using the detector 40, and it may be effective for obtaining a simple structure to measure the voltages of the upper ends 10a of the side cells C2 by using the connectors 105 that connect the upper ends 10a of the side cells C2” Seol [0085]. In this case, the voltage detector acts as the electrical characteristic measurer.) Seol and Guerin are considered to be analogous because they are both within the same field of battery trays/packs configured to secure a plurality of battery cells. Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the battery tray of Choi containing a plurality of battery cells separated by partition walls to include the voltage detection system utilizing an upper and lower connector, as taught by Seol, in order to be able to monitor the cell performance in real time and be aware of any potential malfunctions earlier than would otherwise be possible. It would additionally be obvious, when modifying the structure of Guerin to incorporate the voltage detection implement of Seol, to install the upper and lower connectors to be connected to the partition wall and be in contact with the upper and lower electrode tabs, as this would be the safest method of production. Seol is silent on the upper connector being pivotably attached on an upper part of the first partition wall. However, the teachings of Ma would give motivation for one skilled in the art to use a hinge shaft/pivotable structure to the upper portion of the tray, in order to provide further stability. See below for a comparison of the pivotable structure of Ma compared to the upper connector of the instant drawings. PNG media_image3.png 449 522 media_image3.png Greyscale PNG media_image4.png 127 202 media_image4.png Greyscale Ma and Seol are considered to be analogous because they are both relating to the storage of a plurality of battery cells within a battery tray. Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the upper connector of Seol to be pivotably attached to a hinge shaft, as taught by Ma, in order to provide additional security and stability within the battery tray (“the upper cover 7 the lower surface through the first hinge (15) is hinged with a pressing plate 16, upper surface of the pressing plate 16 is fixed with a second spring 18, a pressing plate 16 is fixed on the lower surface of the rubber pad 17. the pressing plate 16 and the second spring 18 can firmly fix the battery in the battery box, so as to prevent the battery from loosening phenomenon; lower end of the supporting base 13 fixed with a first spring 14, a support base 13 fixed to the two ends of slide 21 can move up and down along the sliding groove so as to have the protection function of the battery in the new energy electric motor car driving process, it prolongs the service life of the battery” Ma [31]). Examiner acknowledges that the hinged portion of Ma is not specifically a connector for a sensing assembly, and still asserts that the teachings of Ma would make obvious a modification to include a connector via a hinged/pivotable structure in order to obtain additional benefits. Regarding claim 2, Guerin teaches the following elements: The cell tray of claim 1, wherein the partition walls are formed in a lattice shape. (Guerin fig. 3 depicts its battery cells being separated by a lattice-shaped partition wall, analogous to that depicted in the instant drawings.) PNG media_image5.png 270 327 media_image5.png Greyscale PNG media_image6.png 411 534 media_image6.png Greyscale Regarding claim 3, Guerin teaches the following elements: The cell tray of claim 2, wherein the tray body comprises a bottom plate forming a lower part of the tray body, the partition walls being installed on the bottom plate, and an outer frame surrounding the partition walls and coupled to the bottom plate or integrally formed with the bottom plate. (Guerin figure 4 clearly depicts a bottom plate and partition walls being formed on the bottom plate, and an outer frame surrounding the cell units and partition walls) PNG media_image7.png 317 409 media_image7.png Greyscale Regarding claim 4, Guerin teaches the following elements: The cell tray of claim 3, wherein a height of the outer frame is greater than a combined height of the partition walls and a length of the first connector. (Given that the tray structure of Guerin comprises a housing/cover “There is a single housing 32, which constitutes a tray for receiving the unit 20. Thus, a single hollow portion is provided to form a receptacle 234 having a rectangular shape in the unit 20. Unit 20 is introduced laterally into receptacle 234.” Guerin [113], this limitation would be met even with the modifications via Seol and Ma. Specifically, if the height of the partition wall and first connector were greater than that of the outer frame, the outer frame/housing would not be able to perform is primary purpose of housing the interior components of the battery tray. Therefore, it would be obvious to anyone skilled in the art to make the outer frame large enough to house all of the components of the interior.) Regarding claim 5, modified Guerin teaches the following elements: The cell tray of claim 1, wherein a hinge frame is installed on the upper part of the first partition wall, and wherein the first connector has a hinge shaft hinged to the hinge frame. (By modifying the partition wall of Guerin to include the upper connector of Seol, provided with a hinge frame/shaft as taught by Ma, this limitation would be met without any further motivation or modification.) Regarding claim 6, Guerin teaches the following elements: The cell tray of claim 1, wherein the electrical characteristic measurer measures at least one of electrical resistance, voltage, and current of the first cylindrical cell. (“The detector 40 extends vertically in the lengthwise direction of the side cells C2, it may be efficient to measure the voltages of the lower ends 10b of the side cells C2 by using the detector 40, and it may be effective for obtaining a simple structure to measure the voltages of the upper ends 10a of the side cells C2 by using the connectors 105 that connect the upper ends 10a of the side cells C2” Seol [0085]. In this case, the voltage detector acts as the electrical characteristic measurer.) Regarding claim 8, Guerin teaches the following elements: The cell tray of claim 3, further comprising a cooling member for cooling the cylindrical cell on the bottom plate of the tray body. (“Advantageously, the outer surface 51 of the tray 34 is thermally connected to cooling means such as cooling air flow, heat pipes, or any suitable cooling means.” Guerin [104]) PNG media_image8.png 358 265 media_image8.png Greyscale Regarding claim 11, Guerin teaches the following elements: The cell tray of claim 1, further comprising a tray top coupled to the tray body to cover the upper part of the tray body. (“The cover 132 for closing the tray 34 constitutes a protective cover for the unit 20.” Guerin [128]) Regarding claim 12, Guerin teaches the following elements: The cell tray claim 11,wherein the tray top comprises an insulating member protruding downward at a position corresponding to the first cylindrical cell. (“As a variant, the trays and covers are made of thermally conductive and electrically insulating materials.” Guerin [172]) Regarding claim 13, modified Guerin teaches all the elements of claim 11, as shown above. Guerin is silent on the following elements of claim 13: The cell tray of claim 11, wherein the electrical characteristic measurer is installed either on the tray body or on the tray top. However, Seol teaches all of the elements of claim 13 that are not found in Guerin: The cell tray of claim 11, wherein the electrical characteristic measurer is installed either on the tray body or on the tray top. (Seol figure 1 depicts the voltage measuring device being installed on the interior of the tray body, thus meeting the limitations of claim 13.) PNG media_image9.png 269 451 media_image9.png Greyscale Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Guerin (KR 20100100943 A) in view of Seol (US 20210028431 A1), further in view of Ma (CN 210129536 U), and further in view of Capati (US 20190081372 A1). Regarding claim 7, modified Guerin teaches all the elements of claim 1, as shown above. Guerin is silent on the following elements of claim 7: The cell tray of claim 1, further comprising a wireless communication device connected to the electrical characteristic measurer and capable of transmitting an electrical characteristic value of the first cylindrical cell measured by the electrical characteristic measurer to outside the tray body. However, Capati teaches all of the elements of claim 7 that are not found in Guerin. Specifically, Capati teaches a similar voltage monitoring device that can explicitly comprise wireless communication to outside of the battery tray: The cell tray of claim 1, further comprising a wireless communication device connected to the electrical characteristic measurer and capable of transmitting an electrical characteristic value of the first cylindrical cell measured by the electrical characteristic measurer to outside the tray body. (“The BMU connectors 145, e.g., wires, wireless, or mechanical connectors, … The BMU connectors 145 can include signal paths or conductive paths having at least one second end coupled with a port (e.g., input port, output port) of the battery module 100, one or more battery blocks 105, one or more battery cells 110 and one or more cold plates 130 to receive signals from the battery monitoring unit 140 or to transmit signals (e.g., voltage signals, current signals, temperature signals, power signals, status signals) from the respective component to the battery monitoring unit 140.” Capati [0027]. In this case, the BMU is shown to be outside of the battery tray, thus teaching an electrical characteristic measurer within the battery tray which is capable of wireless communication to a device outside of the battery tray. Capati additionally teaches that the BMU can couple further with the battery pack via wireless communication, thus extending the transmission even further from the battery tray “The battery monitoring unit 140 can couple with a battery pack level monitoring system using a wiring harness or an alternative wireless form of communication.” Capati [0091]) Capati is considered to be analogous to Guerin because they are both within the same field of battery systems containing a plurality of cells in a tray, and having an electrical characteristic measurer within the tray. Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the electrical characteristic measurer of Guerin to include the ability to wirelessly communicate to a device outside of the battery tray, as this is taught by Capati to be a known method within the art, and additionally because it would allow for effective transmission of the collected data while requiring less materials/space in the battery tray in the form of wires. Claim(s) 9-10, is/are rejected under 35 U.S.C. 103 as being unpatentable over Guerin (KR 20100100943 A) in view of Seol (US 20210028431 A1), further in view of Ma (CN 210129536 U), and further in view of Stephens (US 20180337377 A1). Regarding claim 9, modified Guerin teaches all the elements of claim 8, as shown above. Guerin, Seol, and Ma are silent on the following elements of claim 9: The cell tray of claim 8, further comprising a cooling member accommodating groove in the bottom plate, wherein the cooling member is installed in the cooling member accommodating groove, and the second connector is installed on the cooling member. However, Stephens teaches all of the elements of claim 9 that are not found in the aforementioned references: The cell tray of claim 8, further comprising a cooling member accommodating groove in the bottom plate, wherein the cooling member is installed in the cooling member accommodating groove, and the second connector is installed on the cooling member. (“As shown in FIG. 9, the cold plate supports 145 have a height that is configured to place a cold plate or cooling element 147, such as a thermoelectric component or a liquid cooled component, against or in thermal engagement with the lower surface of the battery module 114.” Stephens [0069]. Figure 8 and 9 of Stephens clearly depict a cooling element formed in a groove on the bottom plate of the battery tray.) PNG media_image10.png 362 484 media_image10.png Greyscale PNG media_image11.png 324 652 media_image11.png Greyscale Stephens is considered to be analogous to Guerin because they are both within the same field of battery trays containing cooling devices. Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the cooling device of Guerin to be formed in a groove to have additional air circulation and support various structural designs of battery modules (“The battery supports 38 may elevate the lower surface of the battery modules 14 away from the floor portion 24 of the tub component for air circulation and to provide an intrusion distance that prevents damage to the battery modules 14 from impacts to the bottom or lower surface of the battery tray 10. The battery supports 38 may also have a height that is configured to support a cold plate or cooling element 47, such as a thermoelectric component or a liquid cooled component, against or in thermal engagement with the lower surface of the battery module 14, such as shown in FIG. 8. The battery supports in additional embodiments may have various structural designs to support the battery modules or other items.” Stephens [0054]). It would additionally be obvious to use a thermoelectric cooling component as Stephens demonstrates that this is a common method in the art, and therefore would only require a simple substitution of one cooling element for another, and the simple substitution of one known element for another is likely to be obvious when predictable results are achieved. (see MPEP § 2143, B.). No further modification or motivation would be required to meet the additional elements of claim 10. Regarding claim 10, modified Guerin teaches all the elements of claim 9, as shown above. Guerin, Seol, and Ma are silent on the following elements of claim 10: The cell tray of claim 9,wherein the cooling member is a thermoelectric module. However, Stephens teaches all of the elements of claim 10 that are not found in the aforementioned references: The cell tray of claim 9,wherein the cooling member is a thermoelectric module. (“As shown in FIG. 9, the cold plate supports 145 have a height that is configured to place a cold plate or cooling element 147, such as a thermoelectric component or a liquid cooled component, against or in thermal engagement with the lower surface of the battery module 114.” Stephens [0069].) Claim(s) 14-16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Guerin (KR 20100100943 A) in view of Seol (US 20210028431 A1), further in view of Ma (CN 210129536 U), and further in view of Biskup (US 20170047572 A1). Regarding claim 14, modified Guerin teaches all the elements of claim 5, as shown above. Guerin, Seol, and Ma are silent on the following elements of claim 14: The cell tray of claim 5, wherein further comprising a third connector hinged to the hinge frame, the third connector contacting an upper electrode tab of However, Biskup teaches all of the elements of claim 14 that are not found in the aforementioned references. Specifically, Biskup teaches a novel bus bar that connects numerous cells, therefore showing that it would be obvious to one skilled in the art to connect multiple cells from a single connection point: The cell tray of claim 5, wherein further comprising a third connector hinged to the hinge frame, the third connector contacting an upper electrode tab of (Biskup figure 11 depicts a bus bar which connects to a plurality of battery cells in a non-overlapping way. This demonstrates that one of ordinary skill in the art could take the modified hinge and connection use to meet the limitations of claim 5, and add in additional connectors to connect up to 4 or more cells to a single connector.) PNG media_image12.png 197 296 media_image12.png Greyscale Buskin and Guerin are considered to be analogous because they are both within the same field of battery trays configured to hold and connect a plurality of cells. Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the connection structure of Guerin, Seol, and Ma to connect to multiple cells from a single point, without overlap, in order to reduce cost associated with extra materials (“To simplify fabrication of the current distribution link while reducing cost and insuring performance, preferably link 1101 is fabricated from a single sheet of conductive material, for example a sheet of a metal such as a sheet of copper or aluminum. To form the symmetrical, equal length current pathways, a series of slots 1105 are formed in the link, for example using a stamping process, a laser cutting process, or another fabrication technique.” Buskin [0057] and “ the use of non-overlapping bus bars of alternating polarity provide a simplified configuration that yields reduced weight as well as reduced material and fabrication costs.” Buskin [0053] and “the present invention provides a current distribution link, also referred to herein as a current distribution interconnect. The purpose of this link is to evenly distribute the current among the parallel connected batteries, thereby eliminating the current imbalance that resulted from the prior art's assembly connections.” Buskin [0054]) By modifying the hinge shaft of Ma, used in the battery tray of Guerin, to include connections to multiple cells from one point, the additional limitations of claims 15 and 16 would be met without requiring any further modification or motivation. One skilled in the art would understand both that up to four cells could be connected from one point without overlap, and that in order to do so, the connections could be formed diagonally from a point located in between the four cells. Regarding claim 15, modified Guerin teaches all the elements of claim 5, as shown above. Guerin, Seol, and Ma are silent on the following elements of claim 15: The cell tray of claim 5,wherein the partition walls are formed in a lattice shape, and wherein the hinge frame has a third connector, a fourth connector and a fifth connector respectively contacting a second battery cell, a third battery cell and a fourth battery cell of the plurality of battery cells. However, by combining modified Guerin with the teachings of Biskup, as shown above regarding claim 14, the additional limitations of claim 15 would be met: The cell tray of claim 5,wherein the partition walls are formed in a lattice shape, and wherein the hinge frame has a third connector, a fourth connector and a fifth connector respectively contacting a second battery cell, a third battery cell and a fourth battery cell of the plurality of battery cells. (As shown in claim 14 above, Buskin teaches that it would be obvious to one of ordinary skill in the art to connect up to four [or more] cells from a single connection point. Therefore, it would additionally be obvious to include a fourth and fifth connector used to connect a third and fourth battery cell, in addition to a second.) Regarding claim 16, modified Guerin teaches all the elements of claim 15, as shown above. Guerin, Seol, and Ma are silent on the following elements of claim 16: The cell tray of claim 15, wherein the hinge frame is located at an intersection of the first partition wall and a second partition wall, and wherein each of the connectors extends diagonally from the intersection. However, by combining modified Guerin with the teachings of Biskup, as shown above regarding claims 14 and 15, the additional limitations of claim 16 would be met: The cell tray of claim 15, wherein the hinge frame is located at an intersection of the first partition wall and a second partition wall, and wherein each of the connectors extends diagonally from the intersection. (based on the combination of Biskup and modified Guerin, if the connectors were coming from a single point—the hinge frame—rather than a linear bus bar, it would be obvious to one skilled in the art to form the connections to the four surrounding cells diagonally, as there would be no other way to connect four cells from one frame without overlapping.) Conclusion The following pieces of prior art were considered to be relevant but were not used in the rejection: Choi (US 20180198102 A1) –teaches an battery tray very similar in appearance to instant invention with partition walls in between the plurality of battery cells Matthews (US 20180294657 A1) –teaches a clamping mechanism for a sensing assembly that is similar to the hinge shaft/pivotability of the instant claims Any inquiry concerning this communication or earlier communications from the examiner should be directed to BENJAMIN ELI KASS-MULLET whose telephone number is (571)272-0156. The examiner can normally be reached Monday-Friday 8:30am-6pm except for the first Friday of bi-week. 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, NICHOLAS SMITH can be reached at (571) 272-8760. 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. /BENJAMIN ELI KASS-MULLET/Examiner, Art Unit 1752 /NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
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Prosecution Timeline

Jun 22, 2023
Application Filed
Mar 16, 2026
Non-Final Rejection — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
64%
Grant Probability
60%
With Interview (-4.2%)
3y 7m
Median Time to Grant
Low
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