LIBOR

Research entry · not admitted

LIBOR methods, enforcement records and transition dates, with submissions, published rates and legal outcomes kept distinct.

LIBOR connected financial contracts to published interest-rate benchmarks, but its settings did not share one unchanged method throughout their history. To understand a setting, a reader needs its currency, tenor, date and calculation rules. The retained record distinguishes banks’ submissions from the published panel average, the later transaction-prioritizing waterfall from earlier assessments, and temporary synthetic settings from the markets the bank panels had sought to measure.

Enforcement and legal outcomes also require their own boundaries. The Barclays regulatory and Justice Department records describe particular findings, admissions and penalties; later records concern different institutions and proceedings. In July 2025 the UK Supreme Court quashed Hayes’ and Palombo’s convictions after finding errors in jury directions. That result must be stated alongside, without being enlarged into a reversal of every institutional resolution. This dossier compares those records, separates the June 2023 panel ending from final synthetic publication in September 2024, and leaves daily-rate effects, contract-specific losses and worldwide penalty totals unresolved.

Scope

LIBOR was a family of interest-rate settings, not one continuously comparable number. A useful description identifies the currency, tenor, observation date, contributor population and method. This dossier follows three related but distinct records: benchmark construction and reform; selected institutional enforcement actions and individual appeals; and the wind-down of panel and synthetic publication.

The methodological comparison starts with the 2012 Wheatley Review and the historical definitions discussed in the retained Barclays orders and 2025 Supreme Court judgment. It then moves to ICE's April 2019 transition announcement and its expressly bounded USD methodology for 4 January 2022 through 30 June 2023. The transition account distinguishes the last bank panel's cessation from the final synthetic publication. The enforcement comparison uses Barclays' June 2012 US/UK components, dated UBS and RBS announcements and the August 2016 multistate Barclays settlement. It ends with the two appeals decided in R v Hayes; R v Palombo [2025] UKSC 29, without claiming a later docket search.

EURIBOR appears because some proceedings concern both benchmarks and Palombo's appeal concerns EURIBOR. It is not another name for euro LIBOR. The historical definitions, panel populations and trimming rules differ. Neither this comparison nor LIBOR's cessation establishes that EURIBOR ceased.

Key distinctions

Submission versus setting: A bank contributes an input; the administrator calculates a benchmark from a panel. A changed input does not mechanically imply an equal change in the published setting.
Setting versus transaction: A published benchmark can enter a contract's interest formula. It is not itself a record of every bank loan, trade or borrower payment.
Could borrow versus did borrow: The historical submission question required an assessment. An actual borrowing transaction may inform that assessment without exhausting it.
Methodological period: Historical judgment-based submissions, transaction-prioritizing waterfall submissions and synthetic settings cannot be flattened into a timeless estimate-only description.
Weighting at two stages: A volume-weighted input within a contributing bank is different from the equal weighting of retained bank submissions in the panel's trimmed mean.
Eligibility versus representativeness: A methodology's eligible trades are a specified input set. They are not a census or random sample of all borrowing, nor proof that every contract using the resulting rate faces the same risk.
LIBOR versus EURIBOR: Similar names and overlapping enforcement records do not make their definitions, currencies or legal obligations interchangeable.
Attempt, false report and effect: The particular violation or finding must be named. Attempted manipulation, false reporting, an altered submission and measured benchmark impact are different propositions.
Institution versus individual: A corporate settlement, a subsidiary's agreement to plead and an individual's conviction or appeal concern different persons and procedures.
Currency and remedy: US-dollar penalties, a sterling financial penalty, restitution and disgorgement cannot be added without an explicit scope, conversion and duplicate-counting rule.
Date roles: Misconduct periods, announcement dates, judgment dates, methodology applicability and the 2026 retrieval date are separate.
Panel end versus final publication: 30 June 2023 and 30 September 2024 describe different LIBOR milestones.
Alternative versus universal fallback: SOFR is a USD alternative. A currency map is not a determination of every contract's replacement rate, spread or legal effectiveness.
Legal error versus universal vindication: The 2025 judgment quashes the two appellants' convictions; it is not an order vacating all institutional resolutions or a finding that every historical submission was sound.

Questions and evidence limits

C1 — Methodology changed through time(provisional claim analysis)
C2 — A published setting is a selected and aggregated measure(provisional claim analysis)
C3 — Barclays' 2012 institutional record has three distinct components(provisional claim analysis)
C4 — Two cessation milestones describe different objects(provisional claim analysis)
C5 — The 2025 judgment must be read at its actual scope(provisional claim analysis)

Analysis

LIBOR connects measurement design to incentives and institutional judgment. A reader can agree that misconduct occurred in a particular proceeding while still asking what effect a particular submission had on a particular setting. The calculation matters to that question: trimming may exclude an input, but it does not provide a general immunity from coordinated or strategically placed inputs. The necessary evidence for a daily effect is narrower and more demanding than a broad headline about a scandal.

The later record complicates an equally simple rehabilitation story. Reform changed the submission methodology, but the continued dependence on a fragile underlying market helped motivate transition. A synthetic rate could continue to serve a limited legacy function while being declared permanently unrepresentative of the market previously measured. The same familiar name therefore does not promise the same object through time. These distinctions let the reader inspect what each source actually establishes without turning a source's authority in one domain into authority over every related question.

Questions in the research record

C-1 — An assessment is not necessarily an invented number
C-2 — The waterfall has two calculation stages
C-3 — Reform, representativeness and continuity answer different questions
C-4 — Regulatory findings and individual criminal appeals cannot be collapsed
C-5 — Motive, direction of input and effect on a setting
C-6 — Penalty components retain their units and legal roles

Why not?

BEST "WHY NOT?" SPECIMEN

Why not say that every inaccurate bank submission changed the rate paid by every borrower?

Tempting claim: A bank altered its input, so the published LIBOR and all LIBOR-linked payments changed by the same amount.

What the recorded basis actually supplies: Historical and later methodologies aggregate selected panel submissions after trimming. The CFTC and DOJ Barclays accounts distinguish trader-oriented attempts, reputation-related lowering, inclusion in the published calculation and some occasions of effect. None of the fourteen sources is a complete daily counterfactual dataset tied to all contracts.

Reason for withholding that conclusion: The path has several steps: submission, ranking and trimming, published setting, chosen currency/tenor, reset date, contract formula and payment. Evidence for the first step does not fill the remainder. Nor does potential trimming prove that all misconduct was harmless; other inputs and coordinated conduct may change which observations remain. The relevant amount and direction depend on the actual setting and contract.

Qualification: Describe the recorded violation or admission precisely, and separately identify any demonstrated published-rate effect. This is an editorial explanation of evidential scope, not a Check result, damages calculation or exoneration.

Reopening condition: Obtain the date-specific submission panel, applicable methodology and an explicitly justified no-misconduct counterfactual; then apply the relevant contract terms and dates. Keep uncertainty in those stages visible.

Original dossier basis: LIB-S03 pp. 2–6; LIB-S07 pp. 2–6 and p. 4 footnote 2; LIB-S10's reputation-related submission discussion; LIB-S14 paragraphs 19–22.

Origin of this passage

Research dossier · E. BEST "WHY NOT?" SPECIMEN · lines 450–462

Artifact SHA-256: bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e

Attributed research text; this locator does not establish source support or standing.

SECOND "WHY NOT?" — A SINGLE METHOD AND END DATE

Why not say that LIBOR was always a guess, ended in June 2023 and was replaced everywhere by SOFR?

Tempting claim: One sentence describes the whole benchmark family, its construction and its replacement.

What the recorded basis actually supplies: Wheatley proposed transaction corroboration; ICE later announced the completed waterfall transition. The retained USD methodology prioritizes transactions while allowing bounded fallback levels. The FCA distinguishes the end of the bank panel from temporary synthetic publication, and its transition page lists different alternatives for different currencies.

Reason for withholding that conclusion: The sentence collapses dates, currencies and methods. A panel-based wholesale funding measure differs from a synthetic Term SOFR-plus-spread calculation. A third-level judgment process differs from a claim that no transaction evidence existed. The final synthetic publication date was 30 September 2024. SONIA, SARON, TONAR and €STR appear alongside SOFR in the retained currency map; none of those labels determines a particular contract's legal fallback by itself.

Qualification: Use a currency/tenor/date/method description and name the milestone meant. The dated FCA description of synthetic use and representativeness is preserved as its own regulatory account; this draft does not supply individual contract advice.

Reopening condition: For a narrower rate or contract claim, identify the applicable historical methodology and actual contract/fallback record. Reopen a general timeline only with evidence addressing the same setting and event, not an undated page carrying the same name.

Original dossier basis: LIB-S01 printed pp. 7–8 and 28; LIB-S02 dated announcement; LIB-S03 pp. 1–6; LIB-S04–LIB-S06 dated transition passages.

Origin of this passage

Research dossier · F. SECOND "WHY NOT?" — A SINGLE METHOD AND END DATE · lines 468–480

Artifact SHA-256: bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e

Attributed research text; this locator does not establish source support or standing.

THIRD "WHY NOT?" — UNIVERSAL LEGAL REVERSAL

Why not say that the Supreme Court proved there was no LIBOR misconduct and cancelled the banks' penalties?

Tempting claim: The quashing of Hayes' and Palombo's convictions reverses every LIBOR/EURIBOR finding and proves every institution and submission innocent of wrongdoing.

What the recorded basis actually supplies: The 2025 judgment answers the certified question and explains why the two convictions cannot stand. The historical institutional records concern different legal persons, authorities and procedural forms. Palombo's case concerns EURIBOR, while the dossier's Barclays, UBS and RBS records also have their own currency and temporal bounds.

Reason for withholding that conclusion: The judgment's actual disposition cannot be enlarged to proceedings it does not decide. It identifies serious legal error; that is a substantive result and must be stated plainly. It does not create a universal factual finding that every submission was accurate or rescind the separate orders and agreements catalogued here. Conversely, repeating an earlier allegation or corporate admission does not undo the appellate disposition or justify presenting the quashed convictions as still standing.

Qualification: State the two convictions were quashed, explain the jury-direction issue and attribute each institutional finding or admission to its own record. Do not relabel the judgment as a mere technicality, or the whole prior institutional record as automatically null. The annex's reproduced directions are material under review, not the court's adopted rule.

Reopening condition: A claimed effect on another conviction, settlement or order needs the exact subsequent judicial or administrative instrument addressing that matter. This retained record contains no fresh later-docket search and no blanket rescission instrument.

Original dossier basis: LIB-S14 paragraphs 1–7 and 231–235; procedural terms in LIB-S07, LIB-S09–LIB-S12. LIB-S13 is a separate 2016 multistate settlement announcement.

Origin of this passage

Research dossier · G. THIRD "WHY NOT?" — UNIVERSAL LEGAL REVERSAL · lines 486–498

Artifact SHA-256: bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e

Attributed research text; this locator does not establish source support or standing.

Temporal bounds

The selected enforcement record begins with conduct and controls periods described as starting in 2005, with narrower dates for particular findings. Barclays' CFTC order, FSA notice and DOJ announcement are dated 27 June 2012. The Wheatley final review is from September 2012; the retained manifest records publication on 28 September. The UBS and RBS announcements are dated 19 December 2012 and 6 February 2013, while the multistate Barclays settlement announcement is dated 8 August 2016. These announcement dates are not the dates of every underlying act or of later completion of an agreement.

ICE announced completion of the waterfall transition on 1 April 2019. The retained USD panel methodology expressly applies from 4 January 2022 through 30 June 2023. The last bank panel ended on 30 June 2023, as reported by the FCA on 3 July; remaining synthetic settings continued until their final publication on 30 September 2024, reported in the joint release on 1 October. The Supreme Court delivered its Hayes/Palombo judgment on 23 July 2025. All fourteen research representations were downloaded on 6 November 2026; that retrieval date neither backdates a living webpage nor supplies later legal or contractual outcomes.

Sources

LIB-S01 — Wheatley reform review — HM Treasury (The Wheatley Review of LIBOR)
source · research candidate
LIB-S02 — ICE waterfall transition announcement — Intercontinental Exchange / ICE Benchmark Administration
source · research candidate
LIB-S03 — USD panel methodology, 2022–2023 — ICE Benchmark Administration Limited (IBA)
source · research candidate
LIB-S04 — End of the USD bank panel — Financial Conduct Authority (FCA)
source · research candidate
LIB-S05 — Final synthetic publication — Financial Conduct Authority; Bank of England; Working Group on Sterling Risk-Free Reference Rates
source · research candidate
LIB-S06 — Living transition summary and currency alternatives — Financial Conduct Authority (FCA)
source · research candidate
LIB-S07 — CFTC Barclays settlement order — US Commodity Futures Trading Commission (CFTC)
source · research candidate
LIB-S08 — CFTC announcement of the same Barclays order — US Commodity Futures Trading Commission (CFTC)
source · research candidate
LIB-S09 — FSA Final Notice to Barclays — Financial Services Authority (FSA)
source · research candidate
LIB-S10 — DOJ Barclays agreement announcement — US Department of Justice, Office of Public Affairs
source · research candidate
LIB-S11 — DOJ UBS Japan and UBS AG announcement — US Department of Justice, Office of Public Affairs
source · research candidate
LIB-S12 — DOJ RBS Japan and parent announcement — US Department of Justice, Office of Public Affairs
source · research candidate
LIB-S13 — Connecticut multistate Barclays settlement announcement — Office of the Attorney General, State of Connecticut
source · research candidate
LIB-S14 — Supreme Court judgment in Hayes and Palombo — UK Supreme Court
source · research candidate

Inspect

Research-basis references identify material in the underlying research dossier. They are not admitted Counterpedia claims, citations, or source bindings.

Research pack: demo-corpus-wave2
Artifact: libor-methodology-enforcement-transition-demo-corpus-dossier-v0-1
Artifact kind: dossier
SHA-256: bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e
Standard: counterpedia.lead/v0.1
Research artifact: demo-corpus-wave2 / libor-methodology-enforcement-transition-demo-corpus-dossier-v0-1
Artifact SHA-256: bdefe3c42d80…
Sidecar state: current
Research basis: LIB-S01, LIB-S03, LIB-S04, LIB-S05, LIB-S07, LIB-S09, LIB-S10, LIB-S14

Sources

14 research source candidates are carried by this entry, as authored in its research dossier. Each is a research candidate, not an admitted Counterpedia Source.

The dossier records an issuer for 14 of 14 and a date for 14; where it labels no issuer, the card says so. Addresses are shown as recorded. A recorded address is not a Counterpedia capture and does not establish retrieval, authenticity or support for any claim. A card links to a Counterpedia source page only where an accepted record relates a capture of an address recorded for that document to that public source; listing a candidate implies no other association.

Sources by recorded issuer

HM Treasury (The Wheatley Review of LIBOR): Wheatley reform review
Intercontinental Exchange / ICE Benchmark Administration: ICE waterfall transition announcement
ICE Benchmark Administration Limited (IBA): USD panel methodology, 2022–2023
Financial Conduct Authority (FCA): End of the USD bank panel; Living transition summary and currency alternatives
Financial Conduct Authority; Bank of England; Working Group on Sterling Risk-Free Reference Rates: Final synthetic publication
US Commodity Futures Trading Commission (CFTC): CFTC Barclays settlement order; CFTC announcement of the same Barclays order
Financial Services Authority (FSA): FSA Final Notice to Barclays
US Department of Justice, Office of Public Affairs: DOJ Barclays agreement announcement; DOJ UBS Japan and UBS AG announcement; DOJ RBS Japan and parent announcement
Office of the Attorney General, State of Connecticut: Connecticut multistate Barclays settlement announcement
UK Supreme Court: Supreme Court judgment in Hayes and Palombo

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Detail	Wheatley reform review	ICE waterfall transition announcement	USD panel methodology, 2022–2023	End of the USD bank panel	Final synthetic publication	Living transition summary and currency alternatives	CFTC Barclays settlement order	CFTC announcement of the same Barclays order	FSA Final Notice to Barclays	DOJ Barclays agreement announcement	DOJ UBS Japan and UBS AG announcement	DOJ RBS Japan and parent announcement	Connecticut multistate Barclays settlement announcement	Supreme Court judgment in Hayes and Palombo
Recorded title	Exact titleThe Wheatley Review of LIBOR: final report	Exact titleICE Benchmark Administration Successfully Completes the Transition of LIBOR Panel Banks to the Waterfall Methodology	Exact titleUSD LIBOR Methodology	Exact titleThe US dollar LIBOR panel has now ceased	Exact titleThe end of LIBOR	Exact titleAbout LIBOR transition	Exact titleIn the Matter of Barclays PLC, Barclays Bank PLC and Barclays Capital Inc. — Order Instituting Proceedings, Making Findings and Imposing Remedial Sanctions	Exact titleCFTC Orders Barclays to pay $200 Million Penalty for Attempted Manipulation of and False Reporting concerning LIBOR and Euribor Benchmark Interest Rates	Exact titleFinancial Services Authority — Final Notice to Barclays Bank Plc	Exact titleBarclays Bank PLC Admits Misconduct Related to Submissions for the London Interbank Offered Rate and the Euro Interbank Offered Rate and Agrees to Pay $160 Million Penalty	Exact titleUBS Securities Japan Co. Ltd. to Plead Guilty to Felony Wire Fraud for Long-running Manipulation of LIBOR Benchmark Interest Rates	Exact titleRBS Securities Japan Limited Agrees to Plead Guilty in Connection with Long-Running Manipulation of LIBOR Benchmark Interest Rates	Exact titleAG Jepsen: States Reach $100M Settlement with Barclays for LIBOR Manipulation	Exact titleR v Hayes; R v Palombo — [2025] UKSC 29
Issuer / publisher	IssuerHM Treasury (The Wheatley Review of LIBOR)	IssuerIntercontinental Exchange / ICE Benchmark Administration	IssuerICE Benchmark Administration Limited (IBA)	IssuerFinancial Conduct Authority (FCA)	IssuerFinancial Conduct Authority; Bank of England; Working Group on Sterling Risk-Free Reference Rates	IssuerFinancial Conduct Authority (FCA)	IssuerUS Commodity Futures Trading Commission (CFTC)	IssuerUS Commodity Futures Trading Commission (CFTC)	IssuerFinancial Services Authority (FSA)	IssuerUS Department of Justice, Office of Public Affairs	IssuerUS Department of Justice, Office of Public Affairs	IssuerUS Department of Justice, Office of Public Affairs	IssuerOffice of the Attorney General, State of Connecticut	IssuerUK Supreme Court
Documentary role	Authority / postureGovernment-commissioned final review and recommendations, not a particular enforcement adjudication or proof of implementation.	Authority / postureAdministrator/company announcement, not an independent audit of every submission.	Authority / postureAdministrator methodology with express currency, tenor and applicability bounds.	Authority / postureDated FCA institutional account of cessation and synthetic-use measures; linked legal notices not separately inspected.	Authority / postureJoint FCA, Bank of England and Sterling Risk-Free Reference Rates Working Group release.	Authority / postureFCA living institutional summary captured as a 2026 representation.	Authority / postureAdministrative order, Docket 12-25, making findings and imposing remedial sanctions on an accepted settlement offer.	Authority / postureCFTC release 6289-12, summarizing its own enforcement action.	Authority / postureFinal Notice under section 206, Financial Services and Markets Act 2000; Principles 2, 3 and 5 findings.	Authority / postureArchived DOJ announcement of conditional non-prosecution and admissions; separate agreement attachment not inspected.	Authority / postureArchived announcement of subsidiary signed plea agreement, parent NPA and separately charged individuals.	Authority / postureArchived announcement of subsidiary signed plea agreement and parent deferred prosecution agreement.	Authority / postureAttorney General announcement of 44-state settlement, not an adjudication of every borrower loss.	Authority / postureOfficial retained HTML judgment, [2025] UKSC 29, delivered 23 July 2025; case URL UKSC/2024/0087.
Recorded dates	Selected edition / datePublished 2012-09-28; cover September 2012; ISBN 978-1-909096-01-1	Selected edition / date2019-04-01	Selected edition / dateMethodology expressly applicable to panel-bank USD LIBOR from 2022-01-04 through 2023-06-30	Selected edition / date2023-07-03; describes panel cessation on 2023-06-30	Selected edition / date2024-10-01; reports final publication on 2024-09-30	Selected edition / dateFirst published 2019-09-02; last update observed 2026-03-09; snapshot at acquisition	Selected edition / dateCFTC Docket 12-25, 2012-06-27	Selected edition / dateCFTC release 6289-12, 2012-06-27	Selected edition / dateNotice dated 2012-06-27; FSA reference 122702; URL path includes 2013 but document date is 2012	Selected edition / date2012-06-27	Selected edition / date2012-12-19	Selected edition / date2013-02-06	Selected edition / date2016-08-08	Selected edition / dateJudgment delivered 2025-07-23; UKSC/2024/0087
Recorded identifiers	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.	Not supplied in this view.
Recorded locators	Recorded locatorhttps://assets.publishing.service.gov.uk/media/5a7b3fe2e5274a319e77e076/wheatley_review_libor_finalreport_280912.pdf	Recorded locatorhttps://ir.theice.com/press/news-details/2019/ICE-Benchmark-Administration-Successfully-Completes-the-Transition-of-LIBOR-Panel-Banks-to-the-Waterfall-Methodology/default.aspx	Recorded locatorhttps://www.ice.com/publicdocs/USD_LIBOR_Methodology.pdf	Recorded locatorhttps://www.fca.org.uk/news/news-stories/us-dollar-libor-panel-has-now-ceased	Recorded locatorhttps://www.fca.org.uk/news/press-releases/end-libor	Recorded locatorhttps://www.fca.org.uk/markets/libor-transition	Recorded locatorhttps://www.cftc.gov/idc/groups/public/@lrenforcementactions/documents/legalpleading/enfbarclaysorder062712.pdf	Recorded locatorhttps://www.cftc.gov/PressRoom/PressReleases/6289-12	Recorded locatorhttps://www.fca.org.uk/your-fca/documents/final-notices/2013/fsa-final-notice-2012-barclays-bank-plc	Recorded locatorhttps://www.justice.gov/archives/opa/pr/barclays-bank-plc-admits-misconduct-related-submissions-london-interbank-offered-rate-and	Recorded locatorhttps://www.justice.gov/archives/opa/pr/ubs-securities-japan-co-ltd-plead-guilty-felony-wire-fraud-long-running-manipulation-libor	Recorded locatorhttps://www.justice.gov/archives/opa/pr/rbs-securities-japan-limited-agrees-plead-guilty-connection-long-running-manipulation-libor	Recorded locatorhttps://portal.ct.gov/ag/press-releases-archived/2016-press-releases/ag-jepsen-states-reach-%24100m-settlement-with-barclays-for-libor-manipulation	Recorded locatorhttps://www.supremecourt.uk/cases/judgments/uksc-2024-0087
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Research profile	Demo Corpus
Artifact kind	dossier
Source candidates	14
Source candidates	See source list
Research source	View source artifact

Scope

Key distinctions

Questions and evidence limits

Analysis

Questions in the research record

Why not?

BEST "WHY NOT?" SPECIMEN

Why not say that every inaccurate bank submission changed the rate paid by every borrower?

SECOND "WHY NOT?" — A SINGLE METHOD AND END DATE

Why not say that LIBOR was always a guess, ended in June 2023 and was replaced everywhere by SOFR?

THIRD "WHY NOT?" — UNIVERSAL LEGAL REVERSAL

Why not say that the Supreme Court proved there was no LIBOR misconduct and cancelled the banks' penalties?

Temporal bounds

Sources

Sources

Wheatley reform review

ICE waterfall transition announcement

USD panel methodology, 2022–2023

End of the USD bank panel

Final synthetic publication

Living transition summary and currency alternatives

CFTC Barclays settlement order

CFTC announcement of the same Barclays order

FSA Final Notice to Barclays

DOJ Barclays agreement announcement

DOJ UBS Japan and UBS AG announcement

DOJ RBS Japan and parent announcement

Connecticut multistate Barclays settlement announcement

Supreme Court judgment in Hayes and Palombo

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