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Bank of America's Motion to Seal Documents Filed in Support of Its Motion to Exclude Expert Testimony of David I. Levine
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Defendant Bank of America, N.A.'s Notice and Motion to Seal Documents Filed in Support of Its Motion to Exclude the Expert Testimony of David I. Levine, filed 10/17/25 as Document 583 in In re: Bank of America California Unemployment Benefits Litigation, Case No. 21-MD-02992-GPC-MSB in the Southern District of California. Under Local Civil Rule 79.2(c), the bank says compelling reasons support sealing because the documents could cause competitive harm or enable future fraud. It says many were designated confidential under its contract with the EDD or at its regulators' instruction because they concern ongoing remediation, and that disclosure could interfere with law enforcement investigations. It relies on the Declaration of Lindsay E. Hoyle.
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“Bank of America's Motion to Seal Documents Filed in Support of Its Motion to Exclude Expert Testimony of David I. Levine.”
Original at ecf.casd.uscourts.gov, No. 3:21-md-02992-GPC-MSB, Doc. 583. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-bofa-ca-unemployment-casd-709615/2025-10-17-gov-uscourts-casd-709615-583-0-gov-uscourts-casd-709615-583-0/
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Case 3:21-md-02992-GPC-MSB Document 583 Filed 10/17/25 PageID.35702 Page
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1 JAMES W. MCGARRY (pro hac vice)
JMcGarry@goodwinlaw.com
2 GOODWIN PROCTER LLP
100 Northern Avenue
3 Boston, MA 02210
Tel.: +1 617 570 1000
4 Fax: +1 617 523 1231
5 SABRINA M. ROSE-SMITH (pro hac vice)
SRoseSmith@goodwinlaw.com
6 MATTHEW L. RIFFEE (pro hac vice)
MRiffee@goodwinlaw.com
7 GOODWIN PROCTER LLP
1900 N Street, NW
8 Washington, DC 20036
Tel.: +1 202 346 4000
9 Fax: +1 202 346 4444
10 Attorneys for Defendant
BANK OF AMERICA, N.A.
11
12 [ADDITIONAL COUNSEL LISTED IN SIGNATURE BLOCK]
13 UNITED STATES DISTRICT COURT
14 FOR THE SOUTHERN DISTRICT OF CALIFORNIA
15 SAN DIEGO DIVISION
16 IN RE: BANK OF AMERICA Case No. 21-MD-02992-GPC-MSB
CALIFORNIA UNEMPLOYMENT
17 BENEFITS LITIGATION DEFENDANT BANK OF
18 AMERICA, N.A.’S NOTICE AND
MOTION TO SEAL DOCUMENTS
19 FILED IN SUPPORT OF ITS
MOTION TO EXCLUDE THE
20 EXPERT TESTIMONY OF DAVID
21
I. LEVINE
22
Ctrm: 12A – 12th Floor
23 Judge: Hon. Gonzalo P. Curiel
24
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27
28
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 1
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 583 Filed 10/17/25 PageID.35703 Page
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1 PLEASE TAKE NOTICE that, pursuant to Local Civil Rule 79.2(c),
2 Defendant Bank of America, N.A. (“Defendant” or “BANA”) hereby submits this
3 Notice and Motion to Seal (the “Motion to Seal”) certain documents and portions of
4 other documents submitted in connection with BANA’s Motion to Exclude the
5 Expert Testimony of David I. Levine (the “Motion to Exclude”).1
6 I. STANDARD TO SEAL DOCUMENTS
7 The public’s right to inspect and copy judicial records is not absolute, and a
8 party faced with the disclosure of confidential or proprietary information may seek
9 to file the documents under seal to avoid disclosure of business information that
10 might result in competitive harm or be used for improper purposes. See Nixon v.
11 Warner Commc’ns, Inc., 435 U.S. 589, 598 (1978) (denying disclosure); Local Civ.
12 R. 79.2(c). The documents that BANA seeks to seal each contain information that
13 qualifies as “Protected Material” pursuant to the Parties’ Stipulated Protective Order
14 (“Protective Order”), entered by the Court on September 24, 2021 (ECF 82).
15 Courts in this district have held that a party seeking to seal documents filed in
16 connection with a motion to exclude expert testimony must show “compelling
17 reasons” to seal, as such motions may be effectively “dispositive of a motion for
18 summary judgment.” Lust ex rel. Lust v. Merrell Dow Pharm., Inc., 89 F.3d 594, 597
19 (9th Cir. 1996) (noting that Daubert ruling was dispositive); see Rink v. Cheminova,
20 Inc., 400 F.3d 1286, 1288 (11th Cir. 2005) (affirming a grant of summary judgment
21 on grounds that plaintiff failed to prove causation after the plaintiff's expert was
22 excluded under Daubert).
23 In applying the “compelling reasons” standard, courts, including this Court,
24
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This Motion is based on Defendant’s Notice of Motion and Motion to Seal, the
documents filed in support of Defendant’s Motion to Exclude, including the
26 Declaration of Lindsay E. Hoyle (“Hoyle Decl.”) submitted herewith, all pleadings
and papers on file in this action, oral argument if requested by the Court, and any
27 such other matters that the Court deems appropriate. Should the Court desire more
detailed briefing to decide Defendant’s Motion to Seal, BANA respectfully requests
28 the opportunity to submit additional briefing in support of sealing.
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 2
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 583 Filed 10/17/25 PageID.35704 Page
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1 consistently seal documents where—as here—disclosure of the confidential business
2 information risks competitive harm to the litigant or improper use of the information
3 such as to commit fraud. E.g., E.W. Bank v. Shanker, 2021 WL 3112452, at *18–19
4 (N.D. Cal. July 22, 2021) (finding compelling reasons to seal confidential onboarding
5 processes, verification of customer identities, and fraud prevention measures); Soria
6 v. U.S. Bank N.A., 2019 WL 8167925, at *4 (C.D. Cal. Apr. 25, 2019) (finding
7 compelling reasons to seal internal fraud investigation procedures because there was
8 a “significant danger that someone could improperly use this information to commit
9 fraud and avoid detection.”); see also ECF 266, 293, 365, 381, 390, 391, 397, 421,
10 466, 467, 548 (the “Sealing Orders”).
11 II. COMPELLING REASONS EXIST TO SEAL THE CONFIDENTIAL
12 DOCUMENTS.
13 Compelling reasons exist to file under seal each of the confidential documents
14 (or portions thereof) filed in connection with BANA’s Motion to Exclude, and any
15 substantive discussion of those documents contained in BANA’s Motion to Exclude
16 or the declarations or testimony filed in support thereof. Each of those documents
17 and testimony were properly designated as “Confidential” or “Highly Confidential –
18 Attorneys’ Eyes Only” under the Protective Order entered by this Court because each
19 pertains to topics that are likely to cause particularized competitive harm to BANA
20 and which could potentially enable future fraud, which poses a danger to BANA’s
21 business and the public. Many of the documents were also designated Confidential
22 pursuant to the terms of BANA’s contract and confidentiality agreement with the
23 EDD (see infra at 5-6), because BANA was explicitly instructed by its regulators to
24 keep the documents confidential because they implicate regulatory protections and
25 concern ongoing remediation efforts (see infra at 7), and/or because their disclosure
26 could implicate or interfere with potential or ongoing law enforcement investigations
27 (see infra at 3).
28 All are compelling reasons which outweigh the public disclosure factors, and
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 3
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
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1 thus permit sealing of those documents. For example, in East West Bank v. Shanker,
2 a California district court granted a motion to seal portions of exhibits concerning
3 “confidential onboarding processes, digital banking platform[s], fraud management
4 techniques, and verification of customer identities, which if made public would harm
5 [the bank’s] business,” and found that public disclosure of EWB’s confidential fraud
6 prevention measures would “harm EWB’s business.” 2021 WL 3112452, at *18-19.
7 Similarly, in Soria v. U.S. Bank, N.A., another California district court found
8 compelling reasons to file under seal information related to a bank’s internal
9 procedures for investigating incidents of fraud, explaining that “[a]lthough there is a
10 public interest in [the b]ank’s procedures concerning its fraud investigations, public
11 disclosure of this information may impede [the b]ank’s ability to identify and combat
12 future instances of fraud” and that “[t]here is a significant danger that someone could
13 improperly use this information to commit fraud and avoid detection.” 2019 WL
14 8167925, at *4. Further, in Shelley v. Cnty. of San Joaquin, yet another California
15 district court protected materials where “the public release of those documents could
16 negatively impact” law enforcement investigations. 2015 WL 2082370, at *7 (E.D.
17 Cal. May 4, 2015).
18 Similar compelling reasons exist here. Indeed, this court has already found,
19 compelling reasons to seal documents just like those at issue here, which each relate
20 to confidential business practices and fraud prevention measures that could be
21 misused to commit future fraud or used by competitor banks to BANA’s
22 disadvantage. Earlier in this litigation, Judge Berg determined that there are
23 “compelling reasons” to seal a number of exhibits previously submitted with
24 Plaintiffs’ motion to compel discovery that concern the very same categories of
25 confidential information that BANA seeks to seal here. See ECF 266. In doing so,
26 Judge Berg found that compelling reasons existed to seal information concerning: the
27 Claim Fraud Filter, other fraud and claims strategies, call center operations, prepaid
28 fraud losses, state contract issues, prepaid updates and trackers, cardholder
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 4
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
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1 complaints and escalations, and certain of BANA’s interrogatory responses—which
2 are precisely the types of documents BANA seeks to seal here.
3 This Court also found compelling reasons to seal the same or similar
4 documents related to analyses of claims fraud and potential strategies to combat that
5 fraud including the Claim Fraud Filter and other fraud strategies, operational fraud
6 losses, trainings for claims investigations, fraud detection and prevention policies and
7 strategies, claims review policies and strategies and their implementation, BANA’s
8 analyses of transactional fraud, risk of competitor advantage concerning how BANA
9 structures its claims and frauds teams and the review procedures, protocols and
10 systems therein, its analyses of state prepaid unemployment program operations and
11 contractual negotiations with vendors, fraud prevention programs, organizational
12 charts, confidential regulator materials, and quotes or summary descriptions from
13 sealed exhibits. See ECF 365, 381, 390. Those prior rulings are sufficient grounds
14 alone to grant sealing here. See Lundstrom v. Young, 2022 WL 15524624, at *17
15 (S.D. Cal. Oct. 27, 2022) (J. Curiel) (considering prior sealing of exhibits when
16 granting motion to seal); Workplace Techs. Rsch., Inc. v. Project Mgmt. Inst., Inc.,
17 2021 WL 6091272, at *3 (S.D. Cal. Oct. 20, 2021) (sealing references to document
18 that court already granted sealing of).
19 Specifically, the Confidential and Highly Confidential – Attorneys’ Eyes Only
20 documents, testimony and declarations that BANA seeks to seal, include but are not
21 limited to, the following categories of documents and information, which this Court
22 has already found compelling reasons to seal:
23 • BANA’s Remediation Plan and Addenda with the OCC and CFPB, and
24 its implementation of those Plans, which both agencies themselves
25 designated as “Highly Confidential – Attorneys’ Eyes Only” (see HX
26 30, 31) (see ECF 365 at 14–16 (finding compelling reasons to seal));
27 • Testimony concerning aggregated statistics related to EDD benefit
28 recipients account balances, activity, and fraud claims that BANA is
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 5
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
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1 obligated to maintain as confidential pursuant to its agreement with
2 EDD (ECF 324-106 at 5), and otherwise would keep as confidential
3 because its disclosure could cause competitive harm to BANA or its
4 customers (see HX 30) (see ECF 365, 381 (finding compelling reasons
5 to seal));
6 • Individual EDD cardholder account, transactions, and claim
7 information, which often include personal, sensitive, or financial
8 information (see HX 36, 37, 38) (see ECF 365, 381 (finding compelling
9 reasons to seal));
10 • Expert reports and excerpts of experts’ deposition testimony, which
11 include discussions of BANA’s confidential documents, many of which
12 contain the confidential information described above, including but not
13 limited to: BANA’s handling of unauthorized transaction claims and
14 reconsiderations; BANA’s contract with EDD and the responsibilities
15 thereunder; BANA’s communications with EDD regarding fraud-
16 related measures; BANA’s fraud strategies, including the use of EMV
17 chip technology and the freezing and blocking of accounts; and BANA’s
18 call center procedures and complaint escalation intake channels (see HX
19 34, 35, 36) (see ECF 365, 381 (finding compelling reasons to seal));2
20 and
21 • Excerpt of a 30(b)(6) fact witness’s deposition testimony, which include
22 discussions of BANA’s confidential documents, many of which contain
23 the confidential information described above, including but not limited
24 to: BANA’s handling of unauthorized transaction claims and
25 reconsiderations; BANA’s contract with EDD and the responsibilities
26
2
BANA submits excerpted deposition testimony from an expert (HX 36), which
27 BANA designated as Confidential or Highly Confidential – Attorneys’ Eyes Only
because those witnesses’ testified regarding BANA’s confidential documents and to
28 the same categories of confidential information described above.
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 6
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
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1 thereunder; BANA’s communications with EDD regarding fraud-
2 related measures; (see HX 30) (see ECF 365, 381 (finding compelling
3 reasons to seal)).
4 Cardholders’ personal account, transaction and claim information.
5 Additional compelling reasons and good cause exist to seal HX 36, 37, and 38
6 because they reflect EDD cardholder account, transaction and claim information,
7 which often include personal, sensitive and financial information that the customers
8 did not intend to appear on a public docket. See Nia v. Bank of Am., N.A., 2024 WL
9 171659, at *6 (S.D. Cal. Jan. 12, 2024) (permitting sealing of exhibit reflecting
10 customer data such as internal deposit account and credit account closure data); see
11 also McAfee v. Experian Info. Sols., 2023 WL 8237364, at *2 (S.D. Ohio Nov. 28,
12 2023) (finding compelling reasons to seal documents in order to “protect Plaintiff’s
13 credit history and financial account information from public disclosure to maintain
14 Plaintiff’s privacy . . . [and] guard against the threat of identi[t]y theft…”).3
15 Moreover, BANA is obligated to keep such information confidential pursuant to the
16 terms of its contract and confidentiality agreement with EDD. See ECF 324-106 at
17 5 (prohibiting “disclosure of the EDD’s confidential information to the public”);
18 Robart Decl. ¶ 5.
19 Finally, Plaintiffs themselves designated their own interrogatory responses as
20 Confidential (HX 37, 38), and under the Protective Order, BANA is required to file
21 under seal testimony that Plaintiffs designated confidential (ECF 82 § 12.5).
22 Accordingly, cardholder claim and account details contain sensitive, personal
23 information that overcomes the presumption of public access and warrants sealing.
24 Confidential regulator materials. Compelling reasons exist to seal HX 30
25 and 31, which contain documents and testimony regarding BANA’s implementation
26
3
BANA is provisionally sealing sensitive financial information of both named
27 Plaintiffs and absent class members. If Plaintiffs request that their personal and
financial information be made public, BANA can remove sealing over Plaintiffs’
28 account, transactions and claims information, but not with respect to non-plaintiffs.
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 7
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
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1 of its Remediation Plan and Addenda with the OCC and CFPB. The regulators
2 designated the Plans “Highly Confidential – Attorneys’ Eyes Only” as a condition to
3 BANA producing them to Plaintiffs, and they contain information the OCC deemed
4 privileged and confidential under its statutes and regulations. Standing alone, the
5 regulators’ determination and designation—which Plaintiffs readily agreed to when
6 they accepted the documents last year—should be a sufficient, compelling reason to
7 seal the Plans and any documents quoting from or referencing those Plans. See, e.g.,
8 Erhart v. BofI Fed. Bank, 2019 WL 4534701, at *3 (S.D. Cal. Sept. 19, 2019) (sealing
9 information that the OCC asserted bank examination privilege over but permitted to
10 be produced subject to confidentiality protections). See also ECF 344-3 (Lennon
11 Decl.) ¶¶ 3–4, 6. This Court has previously found compelling reasons to limit public
12 access to such documents because they contain highly sensitive, and confidential
13 information that would subject any disclosure to potential fraud. ECF 381, 498.
14 BANA’s Motion to Exclude, expert reports and appendix of exhibits
15 that quote and summarize confidential exhibits. BANA has provisionally
16 redacted and sealed portions of its Motion to Exclude, expert reports appended
17 in support thereof, and the appendix of exhibits to the Motion to Exclude that
18 quote or describe the confidential documents, testimony and topics identified
19 above, including BANA’s fraud, claims and call center policies, strategies and
20 practices, as well as BANA’s implementation of the Remediation Plan and
21 Addenda (see HX 34, 35). See supra, pgs. 5–14. This is consistent with the
22 terms of the Stipulated Protective Order (ECF 82, § 3), and with rulings in this
23 circuit including by this Court. See, e.g., Darisse v. Nest Labs, Inc., 2016 WL
24 11474174, at *2 (N.D. Cal. June 2, 2016) (sealing class certification motion
25 and declarations that quote or reference confidential exhibits); ECF 365, 381.
26 For example, portions of the Motion to Exclude reference confidential
27 deposition testimony of BANA’s expert witnesses and provisionally sealed portions
28 of Plaintiffs’ expert reports pertaining to the details of the Claim Fraud Filter and
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 8
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1 other BANA claim investigation processes, as well as the Remediation Plan and
2 Addenda; reference confidential documents and testimony related to the Claim Fraud
3 Filter, the Remediation Plan and Addenda, and provisionally sealed portions of
4 Plaintiffs’ expert reports, among other confidential topics; and quote from or describe
5 the Highly Confidential – Attorneys’ Eyes Only Remediation Plan and Addenda
6 summarize BANA’s implementation of the Plans.
7 For the reasons discussed above, there are compelling reasons to seal
8 discussions of those topics, testimony and documents, as well as others discussed in
9 BANA’s Motion to Exclude and the expert reports appended in support thereof. See
10 supra, pgs. 5–15.
11 III. CONCLUSION
12 For the foregoing reasons and for the reasons set forth in the Court’s Sealing
13 Orders (ECF 365, 381, 390, 391, 397, 421, 431, 460, 466, 467, 477, 498, 507, 516,
14 531, 532, 547, 548), Plaintiffs’ Motions to Seal (ECF 322, 334, 376, 384, 394, 463),
15 BANA’s prior Motions to Seal (ECF 328, 337, 344, 347, 383, 418, 451, 457, 470,
16 481, 495, 501, 511, 539, 542) and accompanying declarations submitted in support
17 thereof (ECF 344-1, 344-2, 344-3, 347-1, 347-2), all of which are incorporated herein
18 by reference, BANA respectfully requests that the Court grant Defendant’s Motion
19 to Seal because compelling reasons support sealing of the identified documents or
20 portions thereof. Defendant has lodged a Proposed Order separately with the Court.
21 Dated: October 17, 2025 Respectfully submitted,
22
By: s/ Lindsay E. Hoyle__________________
23
LINDSAY E. HOYLE (pro hac vice)
24 LHoyle@goodwinlaw.com
VALERIE A. HAGGANS (pro hac vice)
25 VHaggans@goodwinlaw.com
GOODWIN PROCTER LLP
26 620 Eighth Avenue
New York, NY 10018
27 Tel: +1 212 813-8800
Fax: +1 212 355-3333
28
GOODWIN PROCTER LLP
ATTORNEYS AT LAW 9
BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
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1 SABRINA M. ROSE-SMITH (pro hac vice)
SRoseSmith@goodwinlaw.com
2 MATTHEW L. RIFFEE (pro hac vice)
MRiffee@goodwinlaw.com
3 GOODWIN PROCTER LLP
1900 N St. NW
4 Washington, DC 20036
Tel: +1 202 346 4000
5 Fax: +1 202 346 4444
6 JAMES W. MCGARRY (pro hac vice)
JMcGarry@goodwinlaw.com
7 GOODWIN PROCTER LLP
100 Northern Avenue
8 Boston, MA 02210
Tel.: +1 617 570 1000
9 Fax: +1 617 523 1231
10 LAURA G. BRYS (SBN 242100)
LBrys@goodwinlaw.com
11 GOODWIN PROCTER LLP
601 S Figueroa St., Suite 4100
12 Los Angeles, CA 90017
Tel.: +1 213 426 2500
13 Fax: +1 617 346 4444
14 YVONNE W. CHAN (pro hac vice)
YChan@jonesday.com
15 JONES DAY
100 High Street
16 Boston, MA 02110
Tel.: +1 617 960 3939
17 Fax: +1 617 449 6999
18 JANICE P. BROWN (SBN 114433)
jbrown@myersnave.com
19 MATTHEW B. NAZARETH (SBN 278405)
mnazareth@myersnave.com
20 MEYERS NAVE
600 B Street, Suite 1650
21 San Diego, CA 92101
22 Attorneys for Defendant
BANK OF AMERICA, N.A.
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW 10
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1 CERTIFICATE OF SERVICE
2 I hereby certify that I electronically filed the foregoing with the clerk of the
3 court for the United States District Court for the Southern District of California by
4 using the CM/ECF system on October 17, 2025. I further certify that all participants
5 in the case are registered CM/ECF users and that service will be accomplished by the
6 CM/ECF system. I certify under penalty of perjury that the foregoing is true and
7 correct.
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10 Executed: October 17, 2025 s/ Lindsay E. Hoyle
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BANA’S MOTION TO SEAL RE LEVINE CASE NO. 21-MD-02992-GPC-MSB
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