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Preserving Citizens' Right to Not Know
A Survey of National Boundaries in the Internet Era

Dec. 4, 2001

Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media regardless of frontiers.
Universal Declaration of Human Rights, Article 19 (UN, 1998)
The Internet is a powerful and perhaps vital economic, educational and political resource, but it can also be a double-edged sword. All nations with an Internet presence, regardless of regime type, have identified negative consequences which are associated with the technology (Taubman, 1998).

Since well before the advent of the nation-state, governments have attempted to limit the free flow of information to their citizens through a variety of means. Prior to the development of modern communication technology, books and pamphlets could be effectively stopped at national borders. Radio presented a much greater challenge, one that was - and continues to be - exploited in the name of propaganda and communications warfare. In the past several decades, and particularly during the 1990s, the possibilities for citizens of any nation to receive information from any source have exploded with the development of satellite communications and the Internet. Many states are wrestling with various threats they perceive to their citizens and culture, from the availability of pornography to racist and hate material in the liberal Western nations, and from cultural or religious pollution to perceived threats to the ruling governments in authoritarian nations. In the West, the Internet, like short wave radio, has been touted as a tool for combating authoritarian regimes worldwide, and particularly in Asia and the Middle East.

In the U.S. and Europe, the debate of national sovereignty has often been couched more in commercial and security terms than in the language of freedom of information. The Aspen Institute's Communication and Society Program notes that as the Internet and other electronic technologies "fuel the globalization of national economics," they are drastically alter the ability of governments to control what takes place within their borders. Entirely new international bodies and legal regimes are taking control of many financial and economic matters (Bollier, 1997) Under these conditions, efforts have focused on preventing companies or individuals from outside the state from taking advantage of commercial products produced within the state. The U.S. government's attempt to prohibit exportation of strong encryption on the grounds that it would damage U.S. security is a well-known example. Since Sept. 11, 2001, the U.S. has moved rapidly to limit access from outside its borders to any information previously posted to the Internet - deemed potentially damaging - such as maps or descriptions of water resources, nuclear power plants and environmental information, thereby limiting access for its citizens as well (OMB Watch, 2001).

Do national borders still hold meaning in the age of the Internet? Can governments pursue economic development while limiting political discourse that may bring their legitimacy into question? This paper surveys four nations' approach to free expression on the Internet: Singapore, China, Saudi Arabia and Iran. Each government has a history of limiting the internal and external flow of information. Outside these four nations' borders, particularly in the West, computer culture has been anarchistic and anti-authority. Maximum free speech is seen as a positive value leading to social and intellectual progress, but none of the four have had a culture or history of freedom of speech; all have traditions of authoritarian or paternalistic government and a strong belief at both the governmental and social level of the power of ideas to destabilize society. Anti-colonial sentiments, particularly in Saudi Arabia and China, reverberate with traditions of limited free speech; outside ideas and information may be seen as imperialistic and computer culture may be viewed as an extreme symptom of this type of cultural or spiritual pollution. Despite these fears, all four nations have embraced the Internet as a necessary and even desirable technology, while actively working to maintain social and political control. The path each has taken to control free expression reflects the particular circumstance of their respective regimes.

Social Control and Self-Censorship in Singapore

In East Asia, a number of governments have embraced the Internet for its commercial potential, while actively seeking to limit political discourse and the free flow of ideas that might threaten governmental or societal stability. Singapore, an economically advanced, yet politically authoritarian and socially conservative nation, has been in the forefront of efforts to follow both paths. Garry Rodan (2000) argues that Singapore's commitment to a market economy has generally meant little substantive opening of the media. Both domestic and international media in all forms have readily practiced self-censorship. Companies including Dow Jones, and the over twenty satellite television broadcasters [1] that make Singapore a regional media center, tailor their programming toward media restrictions to maintain their good relationship with the government. Reporting has tended to focus increasingly on business issues and shy away from social or political stories. Rodan argues that the market economy has in fact softened the resolve of the international media organizations to report freely, rather than softening the government's resolve to control and obstruct.

Singapore has a long history of censorship as a means of maintaining a stable society, supported by both the government and a majority of its citizens. Irresponsible media reports of several inflammatory incidents in the recent past have caused racial and religious rioting, as well as negative views of Singapore abroad (Peng, 1995). In 1991, the quasi-governmental National Computer Board began a study on how computer technology could economically benefit the country and improve the lives of its citizens. At the same time, the Ministry of Information and the Arts undertook its decennial survey of censorship laws and standards across all media. When published, these two reports made it clear neither area could be considered in isolation.  Peng found widespread support for censorship within the citizenry, with Singaporeans favoring the most censorship in materials for children, news leading to racial conflicts, and racially offensive public expression.

In the recent past, Singapore has instituted various laws to encourage the use of advanced technology for business - such as satellite dishes for large companies - while the public has been limited to more easily controlled channels such as cable television (Kalathil, 2001). Peng (1995) notes that censorship in Singapore is likewise differentiated by situation, i.e. materials going into home are more heavily censored that those for commerce; materials for the young more than those for adults; materials for public consumption more than those for private consumption; and, finally, materials deemed as having artistic or educational merit are less heavily censored.

The Internet has posed a regulatory problem for Singapore because of its decentralized nature and potential to be a mass medium requiring hordes of censors from a variety of different agencies due to its convergent nature (combining several functions). To address this difficulty, Singapore chose to treat it as a broadcast service, rather than a telecommunications service or as computer service. Under the 1996 (rev. 1997) Singapore Broadcasting Service (SBA) Act, the Singapore Broadcasting Authority promulgated new regulations covering political, religious and pornographic materials "to ensure that nothing is included in any broadcasting service which is against public interest or order, national harmony or which offends against good taste or decency." The Act also required operators of Internet companies, including ISPs, cyber cafés, and organizations with sites that provide political or religious information about Singapore to register with the SBA (SBA Act, 1997).

In practice, the regulations meant Singapore's three licensed ISPs (later four) had to implement filtering technology to block access to "access denied" websites through the use of proxy servers (Seneviratne, 1999). The block list has been updated periodically, but Michael Bociurkiw (2000) noted that satellite television station CNBC Asia reported a year later that the Singaporean government's efforts had largely failed. Of the approximately 800,000 sites carried by Singapore's ISPs, government officials admitted that only 100 were actually blocked, mostly pornographic sites such as Computer culture being what it is, computer users were quick to circumvent even those token controls - a quick browse on Google revealed detailed instructions on setting up a separate proxy server that would bypass the filters (Richardson, 1999). The chairman of Singapore's National Internet Advisory Committee, Bernard Tan Tiong Gie, claimed that Singapore's speech restrictions were gradually being lifted, although it would be sometime before all restrictions on printed material would be repealed. "At the end of the day, blocking these sites really is a symbolic gesture."

Bruce Gale of Hong Kong-based Political and Economic Risk Consultancy noted that a technological and governmental infrastructure for controlling politically undesirable sites (and likewise for cable television) was still in place if the Net became seen as an alternative news source for Singaporeans (Bociurkiw, 2000). Amendments to the Newspapers and Printing Presses Act in 1986 gave the government power to limit the local circulation of international newspapers deemed to be 'engaging in the domestic politics of Singapore.' (Rodan, 2000). In 2001, Gale's analysis appeared to prove true as the government imposed additional Internet restrictions that banned political campaigning from non-official websites in a run-off election. At the end of November 2001, the government used the new regulations to crack down on Robert Ho Chong, a former journalist, who posted an opinion piece shortly before the Nov. 3 general elections accusing government officials of violating election laws by visiting polling places in the 1997 general elections (Ho, 2001). The government arrested him on charges of attempting to incite violence or disobedience to the law that was likely to lead to a breach of peace; Ho was forced to undergo psychiatric examination. He is currently out on bail and will be tried later in December (Singapore Prosecutes, 2001).

Even if the government's control is less than complete, it has demonstrated the political will and ability to use technology to create a climate friendly to business while limiting free expression. Many other nations, including China and Saudi Arabia (discussed below) have looked to Singapore's model in developing their own Internet policies. Even politicians in Australia have eyed the model, although only a few of the Australian proposals have actually become law so far (EFA, 1999).

China's Plan for Information Control

Unlike Singapore, the Chinese government has made little effort to trumpet loosening of speech restrictions on the Internet. China, with its largely successful efforts to maintain tight controls over access to sites abroad that are critical of the government and of "subversive" online discussions at home, remains the most notable example of government restrictions to free speech in Asia. Robert Marquand (2001) noted that China claimed over 22.5 million people had Web access by the August 2001 (other sources put the figure somewhat lower). Many pundits, especially in the U.S., pointed toward the growing number of users as foretelling cracks in the Chinese government's control over information and communication technologies. Kalathil and Boas (2001) repudiate this stance by documenting the Chinese government's long history of tight control over the technologies. The Chinese government began a process of "informatization" in 1993, utilizing information technology to modernize the economy and decentralize decision-making, while making it more easily controlled from Beijing. It recognized the increased challenge of social control and has so far met it through an ambitious program of restrictions in the form of filtering, monitoring, selective arrests, crackdowns, and promoting self-censorship, as well as proactive propaganda efforts.

In 1995, the Central Propaganda Department's (CDP) Minister Ding Guan?gen traveled to Singapore to study how it managed communications flow. By 1996, China began a technological program similar to Singapore's to limit its citizens from accessing external websites with news, pornography, human rights groups, and other dangerous material (Lynch, 1999). In China, as in other East Asian states, including Singapore, information has been seen as not only something to be controlled, but something valuable (Foster and Goodman, 2000). Various Chinese agencies have engaged in turf wars to stake their claim to the Internet, resulting in a multitude of regulations. The first major regulations, promulgated in 1997, went far beyond Singapore's, with banned material ranging from "making falsehoods" to "promoting feudal superstitions." (Computer Information, 1997) - a list that Lynch believed to be so nebulous as to potentially cover nearly any imaginable use of the Internet.

Marquand (2001) observes that the recent crackdowns shows that even in the face of exploding Internet use, the Chinese government has not hesitated to limit unfettered access to the Web.  Beginning in April 1999, the government began an active campaign to regulate public Internet cafés. Unlicensed cafes were closed and computers seized in major cities in the name of protecting young people from the "online heroin" of pornography and computer games (China Internet Café, 2001). Licensed cafes were required to install filtering software to ostensibly block pornographic sites. Human Rights Watch (HRW) (2001) reported that a moratorium was placed on new cafés in April 2001 and numerous existing cafés were closed down permanently.  These regulations have encouraged café owners to keep a close watch on their users, and for café users to police themselves. Staff of the Feiyu Internet Café (Beijing) roam through the café, observing over the shoulders of patrons and reporting any illegal use to the police.

As of January 2001, sending "secret" or "reactionary" materials over the Internet became a capital crime, although no known cases have been prosecuted on this charge yet; all convictions have so far been prosecuted under China's Criminal Code and have resulted in lesser sentences. Charges have ranged from "subversion" to "libeling police," as well as promoting the Falun Gong movement. One detainee arrested in June 2000, Huang Qi, a computer engineer, and his wife, Zeng Li, founded a missing persons website, [2] to help find relatives and friends of those who died or disappeared in the crushing of the 1989 pro-democracy demonstrations. Human rights groups urged business interests and even the World Bank to intervene, but with no success (Jendrzejcyk, 2000). Huang was brought to trial in February 2001, but the trial was delayed due to his illness until August 2001, when he was secretly tried on charges of "instigation to subvert state power." His website remains up on a U.S. server and is accessible outside of China (China Tries, 2001); a letter (translated into English) from Zeng Li, pleads for financial support to continue the missing persons work and for someone to adopt their son, about whom a government official reportedly told Zeng, "After your husband is sentenced, don't expect your son to go to school or to have any future" (Tianwang, 2001). The government has so far refused to reveal the verdict on Huang and he is still in detention (Vincent, 2001).

The government has proactively directed discussions of certain national issues and has made effective use of the Internet for propaganda. Following the 1999 bombing of the Chinese embassy in Belgrade, the government set up the People's Daily Strong Country web forum, which saw a resurgence of interest following the crash of the U.S. spy plane on Hainan Island. Nationalistic postings were encouraged until a number appeared that were critical of the Chinese government. Kalathil and Boas (2001) note that the government has set up web sites on specific issues to promote the official perspective on current events such as the Falun Gong. These sites fit with the government's plan to create a large and well-coordinated on-line propaganda system, which Ding Guangen, China's publicity chief, directed the major state run media to develop as quickly as possible. He urged the state media to spread government and Party messages via Internet throughout China, as well as promote a good image abroad. The government would delete "harmful" material from Internet news reporting and further enforce new rules against independent news reporting (Ma, 2001).

In addition to internally and externally directed propaganda efforts, China is also moving ahead with creation of a second-generation national Intranet to substitute for the global Internet. The Xinhua News Agency announced the project in January 2001 to provide online services for the Chinese people and business. "The current one by itself has too many faults and is incapable of satisfying the needs of the Chinese government and companies as they enter the digital age." Analysts suspect that the new network will be paired with much more sophisticated means of blocking unwanted information, and may offer very little access to the global Internet (China to Build, 2001).

Like Singapore, China is counting on economic development to co-opt political dissent. Despite the pro-democracy, reformist, separatist and religious groups that the government strives to suppress, the actual numbers of people involved are small. A recent survey by Guo Liang and Bu Wei of the Chinese Academy of Social Sciences indicated a vast majority of Chinese trust traditional - and heavily censored - sources of information such as state-run TV, even though Chinese Internet users spent 25-40% of their time on sites outside of China and viewed the web as a source of political information (Hachigian, 2001). Marquand (2001) quotes Eric Harwit, a University of Hawaii China expert and co-author of "Shaping the Internet in China," a study published in the May-June 2001 issue of Asian Survey, who argues that the Chinese are overwhelmingly self-censoring and that most new Internet users are young males who have benefited economically and socially from China and the Party. "Why should they oppose a system that allowed them a good position?"

China's entry in the World Trade Organization may test this idea as the WTO's transparency requirements take hold and many sectors of the Chinese economy face foreign competition (Elliot, 2001). Although, as Singapore's example shows, a liberalized business climate need not be matched with political liberalism, the likelihood of social upheaval in China is significant. In the interior, the wheat, corn and cotton growing areas will be hit particularly hard and this may foster rebellion among farmers. Gilley (2001) notes that each major change in Chinese society over the past 100 years caused farmers to rebel and argues that the coming market changes will be no different - and that the scale will likely be much greater. Other sectors may also face unrest as workers are thrown out of work when inefficient business shut down. China must be able to manage the upheavals that will accompany the economic changes and its efforts to control the Internet and media may be a serious challenge, depending on the rate of change. For the present, however, the highly publicized moves to control the Internet and arrests of activists like Huang Qi's, demonstrate the Chinese government's continued strong determination to limit free speech and unauthorized discourse.

Saudi Arabia Makes the Internet Safe for Saudis

Free flow of information has not been a traditional freedom in the Middle East, particularly when it has collided with Islam and authoritarian regimes. Nearly every government in the region strives to control information in some fashion, ranging from strict censorship of print material to detailed regulations on Internet use. Some nations, like Morocco, heavily limit what can be published in print and broadcast media, but impose little if any restrictions on the Internet. Others, like Tunisia, match restrictions on traditional media with equally strict regulations on the Internet (HRW, 1999). Saudi Arabia and Iran, discussed below, take very different approaches, as the former attempts to control access through proxy servers, while the latter has encouraged Internet use and has yet to place meaningful restrictions on users.

Many Middle Eastern nations have embraced the Internet to varying degrees, with even the last holdouts, Libya (Africa Connectivity, 2000), Iraq, and Syria (Committee to Protect Journalists, 2000), recently opening Internet cafés and limited public access ISPs. As the world becomes increasingly wired, the potential economic benefits for even the more isolationist nations become clearer. Although Saudi Arabia has had an Internet connection since 1994, use was limited to selected academic, medical and research institutions (private citizens could, however, connect to foreign ISPs through international phone service at high rates). King Fahd didn't approve public access until 1997 and the first ordinary citizens had to wait until early 1999 while the government worked out an ambitious plan to block undesirable information flow across its borders.

Saudi Arabia has striven to withstand outside influences since the Saud family came to power in the early 1920, and has remained under rule of one of the most autocratic and repressive regimes in the world. The Saud family adheres to Wahhabism - a flavor of Islam characterized by a strict interpretation of the Quar'an and deep suspicion of outsiders [3] (Bachman, 2001). Newspapers and magazines have long been censored, so the government's caution in granting ordinary Saudis Internet access is not surprising.

Saleh Abdulrahman Al-'Adhel, president of the King Abdul-Aziz City for Science and Technology (KACST) - the state institution charged with coordinating Saudi Arabia's Internet policy - announced in 1998 that a standing committee had been formed to protect Saudi society from material on the Internet that violated Islam or encroached on traditions and culture. The state would actively block corrupting material from Saudi citizens. It would also create a firewall to prevent outsiders from breaching Saudi cyberspace. The government hinted that it would allow Saudis to access only sites on an approved list and all others would be blocked by default (HRW, 1999).

In order to control access, the government created a hub outside Riyadh, through which all Internet traffic would be routed. NY Times reporter Douglas Jehl reported in 1999, soon after the opening, that when users tried to access blocked sites through these proxy servers, they were met with messages warning them that the sites were forbidden and their attempts to view them were being logged. The government put a positive spin on the restrictions, opting to trumpet what was possible, such as online banking, over what was blocked. In practice, chat rooms and video conferencing (both could allow contact between unmarried men and women), nudity and sexual material, and anything hinting at political criticism was blocked. Jehl noted that the government utilized blocking software, such as Secure Computing's SmartFilter, and that the blacklists were updated daily.

The Council of Ministers released a resolution containing a set of Internet rules in February 2001 that were broad enough to cover any material the government should deem harmful. Prohibitions against users publishing or accessing information included "anything contravening a fundamental principle or legislation, infringing the sanctity of Islam and its benevolent Shari'ah, or breaching public decency," and " anything contrary to the state or its system." Additional rules detail what might be contrary to the state. Additional sections discuss various trade practices relating to licensed activities and advertising, requirements for official approval for media sites, and rules for service providers (Saudi Internet, 2001). Not long after the publication of the new rules, the government claimed it would ban 200,000 Internet sites with new technology - double the previous number (200,000 Sites, 2001).

Saudis continue to be able to use modems and rapidly proliferating sites (as well as shifting IP addresses) have meant that forbidden sites are available to savvy users, at least until the new addresses are added to the blacklists. Foreign-based encrypted sites present another option. Until the government blocked the company in late 2000, many Saudis were able to use the SafeWeb [4] secure surfing site to access anything they wanted to (Matthews, 2000). The company has since developed a peer-to-peer application, "Triangle Boy" that lets users evade government firewalls. Other companies and organizations, including the hacker group Hactivismo, have created various methods for users in countries such as Saudi Arabia to get past Internet restrictions (Hackers, 2001).

The Saudi government's control of dissent within its borders has been rigorous, but they have much less control abroad. Bunt (2000, p. 92-93) notes that several prominent opposition sites had been set up in Britain and elsewhere, including the MIRA (Movement for Islamic Reform in Arabia), CDLR (Campaign for Democracy and Civil Rights), and the Committee Against Corruption in Saudi Arabia's Al-Saud House (CACSA) websites [5].

The Saudi government and Saudi-connected organizations have proactively set up portals on Middle East information and religious matter, following Singapore's model in ensuring appropriate access (see below) (Bunt, 2000, p. 91). From the extensive use of English in many of these sites, they are clearly aimed beyond the country's borders.

Saudi officials admit that even as they add sites to their blacklist, nearly half of users are able to access banned sites through proxy servers or via modem (200,000, 2001). Advances in blocking technology will be matched by advances in ways to circumvent restrictions. Like China, Saudi Arabia faces pressures of global integration, and with that integration, a social and political opening. So far, Saudi Arabia has been able to maintain cultural separation even while supplying a major portion of the oil that has driven globalization. Whether it can successfully continue to do both remains to be seen.

Internet Popularity Catches Iran by Surprise

Of the four countries surveyed in this paper, Iran, although an Islamic republic with a strong, conservative clergy, has, at present, the fewest restrictions on Internet use of the four nations surveyed. Print and broadcast media continues to be censored - the conservative-controlled judiciary shut down nearly 40 reformist newspapers and magazines in 2000, but the Iranian government has taken a cautious approach to clamping down on inappropriate use (Moore, 2001). Iranians weren't allowed graphic Web access until the end of 1997, when the election of President Mohammad Khatami brought in a new openness (Jehl, 1999). Service became widely available only in 1998, but since then, Internet cafés, or "coffee-nets," have opened at a rapid pace - nearly one a day opened in Tehran by the summer of 2001. Estimates put the number of users between 350,000 to 1 million, up from only a couple of thousand a few years ago.

Despite suspicions that fears of backlash from hard-line clerics were behind the government's reluctance to legalize Internet access, many prominent clerics have embraced the Net as way to spread the Islamic thought - most notably, the Qom Theological Center (founded by Ayatollah Khomeini after the revolution and closely associated with his spiritual successor, Ayatollah Kahmenei), has established its own website, which suggests endorsement by Khameini, himself (Bunt, 2000, p. 53).

Unlike Saudi Arabia, the government hasn't prohibited chat rooms full of uncensored socializing and expressions of political views, nor have they banned websites offering links for gay men and lesbians in a country where homosexuality remains a forbidden topic (Moore, 2001). In part, this freedom is due to the Internet's uncontrolled growth of popularity that has overwhelmed government efforts to regulate it. Years of economic stagnation left the nation with an antiquated and overloaded telecommunications infrastructure that, coupled with government bureaucracy, created an opening for private enterprise. Private ISPs easily out-competed government agencies to attract customers for their business.

In May of 2001, police shut down many of the Internet cafés, claiming they lacked operating licenses. To many observers, this closure signaled the government was moving to restrict access, but some analysts suspected economic, rather than social or political motives; the state-owned telephone monopoly was fighting back against competition. Although the actual motive is unclear, the telephone company reported losing revenue to Internet cafés where customers where able use Internet telephony to bypass the phone company for long-distance calls. Joseph Braud, of Pyramid Research, notes that only cafés with high-speed access were closed, and nearly all have since reopened (Gruenwald, 2001).

The Minister of Communications and Modern Technology (formerly Post, Telegraph and Telephone), Dr. Ahmad Motamedi, has proposed restrictions to President Khatami, including obscenity and "extremism" (Moore, 2001), but so far, nothing official has been made public. Hambastegi, a pro-reform newspaper, reported in June that the Iran Telecommunications Company had ordered ISPs to bar access to those under 18 and filter all material presumed immoral or against state security (Iran Takes, 2001). Iran Telecommunications immediately denied the report in a message faxed to the Islamic Republic News Agency (IRNA), the official media outlet, saying that new regulations merely prohibited under-18s from opening cybercafes. The IRNA said the telecom lacked the authority to interpret new regulations (Iran Denies, 2001).

So far, the greatest use of the Internet in Iran has been as a way for young people to gain a window on entertainment and ideas from the outside world. Iran's isolation following the revolution has created a population of young people eager to peer beyond its borders. The government may yet bring some measure of control to free expression via the Internet, but its ability to do so may never catch up its peoples' use of the Web.


The Internet is still an evolving technology; the Web and other developing technologies, notably wireless communications, will have many unforeseen consequences. The role of these technologies as a route to democratization and widening of free speech worldwide is still a matter of speculation. The degree of freedom sought by the people appears to heavily depend on the size of a technologically sophisticated elite and on a tradition of opposition as much, if not more than, the mere presence of technology alone. Singapore's tradition of self-censorship supports the government's efforts to limit information, and a similar situation exists in China, and to some extent, in Saudi Arabia. At least some authoritarian governments, such as China and Saudi Arabia, have proved to be capable of adapting their controls to new technologies. Iran's current Internet freedom appears to be more an accident of Iran's interrupted technological development following its revolution than substantial government support for free expression. Singapore has demonstrated the possibilities of combining market economies and strict socio-political controls - a model that has been watched closely in Asia and elsewhere. While activists and ordinary people within these nations and beyond their borders chip away at restrictions, they may yet spur democratic revolutions, but not without a fight.


  1. Satellite broadcasting is effectively banned on Singapore, with access available only to a few international business people and diplomats (Rodan, 2000).
  2. The name refers to the events at Tiannamen Square on June 4, 1989, a choice which created a red flag for the authorities.
  3. The Taliban also follows Wahhabi beliefs.
  4. SafeWeb: The New York Times reported in August that SafeWeb would also be used to help the Chinese people evade their country's censors.
  5. MIRA: CDLR is no longer online after running afoul of British authorities, nor is CACSA is currently online.


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