purpose behind rule (Pennsylvania) · Go Syfert
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purpose behind rule in Pennsylvania

43 Pennsylvania opinions name it 5 courts 1970–2025 11 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (21)

CaseFollowedCited
DiLucido v. Terminix International, Inc.yellow
pasuperct · 1996 · cited in 11 Pennsylvania opinions naming this issue, 2001–2010
2 sentences

2003The purpose behind this requirement “is to determine whether the class representatives’ overall position on the common issues is sufficiently aligned with that of the absent class members, to ensure that the pursuit of their interests will advance those of the proposed class members.” DiLucido v. Terminix International Inc., 450 Pa. Super. 393, 404 , 676 A.2d 1237, 1242 (1996).

2003The purpose behind this requirement “is to determine whether the class representatives’ overall position on the common issues is sufficiently aligned with that of the absent class members, to ensure that the pursuit of their interests will advance those of the proposed class members.” DiLucido v. Terminix International Inc., 450 Pa. Super. 393, 404 , 676 A.2d 1237, 1242 (1996).

1011
Commonwealth v. Harth, K., Aplt.green
pa · 2021 · cited in 7 Pennsylvania opinions naming this issue, 2021–2024
2 sentences

2024In establishing this exception to the general rule, the Harth majority expressed that Rule 600(C)(1) is “not a model of clarity,” hence its decision to turn to the Rule’s “commentary, the purpose behind the rule, and our prior jurisprudence interpreting Rule 600 and its predecessor.” Id. at 617.

2024In establishing this exception to the general rule, the Harth majority expressed that Rule 600(C)(1) is “not a model of clarity,” hence its decision to turn to the Rule’s “commentary, the purpose behind the rule, and our prior jurisprudence interpreting Rule 600 and its predecessor.” Id. at 617.

57
Michigan v. Harveygreen
scotus · 1990 · cited in 4 Pennsylvania opinions naming this issue, 2014–2025
2 sentences

2025The purpose behind this rule is “to prevent police from badgering a defendant into waiving his previously asserted Miranda rights.” Michigan v. Harvey, 494 U.S. 344, 350 [] (1990).

2018The purpose behind this rule is “to prevent police from badgering a defendant into waiving his previously asserted Miranda rights.” Michigan - 15 - J-S03045-18 v. Harvey, 494 U.S. 344, 350 , 110 S.Ct. 1176 , 108 L.Ed.2d 293 (1990).

24
Cribb v. United Health Clubs Inc.green
pa · 1984 · cited in 2 Pennsylvania opinions naming this issue, 2001–2003
2 sentences

2003The existence of “factual differences with regard to each member of the class does not render the named parties’ claims atypical of the class as a whole.” Cribb v. United Health Clubs Inc., 336 Pa. Super. 479, 484 , 485 A.2d 1182, 1185 (1985) (citing Ablin Inc. v. Bell Telephone of Pennsylvania, 291 Pa. Super. 40 , 435 A.2d 208 (1981)).

2003The existence of “factual differences with regard to each member of the class does not render the named parties’ claims atypical of the class as a whole.” Cribb v. United Health Clubs Inc., 336 Pa. Super. 479, 484 , 485 A.2d 1182, 1185 (1985) (citing Ablin Inc. v. Bell Telephone of Pennsylvania, 291 Pa. Super. 40 , 435 A.2d 208 (1981)).

22
Minnick v. Mississippired
scotus · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025Commonwealth v. Martin, 101 A.3d 706, 725 (Pa. 2014) (emphasis omitted). “[I]n Minnick [v. Mississippi, 498 U.S. 146, 153 (1990), the United States Supreme] Court clarified the Edwards rule by holding that ‘when counsel is requested, interrogation must cease, and officials may not reinitiate interrogation without counsel present, whether or not the accused has consulted with his attorney.’” Commonwealth v. Santiago, 599 A.2d 200, 201 (Pa. 1991).

11
Commonwealth v. Santiagogreen
pa · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025Commonwealth v. Martin, 101 A.3d 706, 725 (Pa. 2014) (emphasis omitted). “[I]n Minnick [v. Mississippi, 498 U.S. 146, 153 (1990), the United States Supreme] Court clarified the Edwards rule by holding that ‘when counsel is requested, interrogation must cease, and officials may not reinitiate interrogation without counsel present, whether or not the accused has consulted with his attorney.’” Commonwealth v. Santiago, 599 A.2d 200, 201 (Pa. 1991).

11
Commonwealth v. Wamshergreen
pa · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Further, we presume “that our Supreme Court did not intend results which were absurd, impossible of execution, or unreasonable[.]” Commonwealth v. Wamsher, 577 A.2d 595, 600 (Pa.Super. 1990).

11
Commonwealth v. Fargreen
pa · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Furthermore, bearing in mind that we must, to the extent possible, construe our Rules of Criminal Procedure in accordance with the rules of statutory construction, Commonwealth v. Far, 46 A.3d 709, 912 (Pa. 2012), we agree with Justice Wecht that requiring the Commonwealth to demonstrate that it acted with due diligence before a trial court excludes time from its Rule 600 time computation on the basis of “judicial delay” comports with the language of Rule 600(C)(1) and its commentary, the purpose behind the rule, and our prior jurisprudence interpreting Rule 600 and its predecessor.

11
In re Nomination Petition of Vodvarkared
pa · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019It is well settled that the Election Code “be liberally construed to protect a candidate’s right to run for office and the voters’ right to elect the candidate of their choice.” In re Vodvarka, 140 A.3d 639, 641 (Pa. 2016) (citation omitted).

11
Grossman v. Barkegreen
pa · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008See id.

2008See id.

11
Commonwealth v. Buckgreen
pasuperct · 1993 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

11
Commonwealth v. Formangreen
pasuperct · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

11
Commonwealth v. Byrdgreen
pa · 1980 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

11
Commonwealth v. Edwardsgreen
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

2000The purpose behind the rule is the principle that “a criminal conviction may not stand merely on the out[-]of[-]court confession of one accused, and thus a case may not go to the faet[-]finder where independent evidence does not suggest that a crime has occurred.” Commonwealth v. Edwards, 521 Pa. 134, 144 , 555 A.2d 818, 823 (1989); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Buck, 426 Pa.Super. 26, 28-29 , 626 A.2d 176, 177 (1993); Commonwealth v. Forman, 404 Pa.Super. 376, 379-81 , 590 A.2d 1282, 1284 (1991).

11
Buck v. Coldway Food Express, Inc.green
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 1991–1991
2 sentences

1991See Buck v. Coldway Food Express, Inc., 383 Pa.Super. 580 , 557 A.2d 404, 407 (1989); Roseman v. Hospital of the Univ. of Pa., 377 Pa.Super. 409 , 547 A.2d 751 (1988).

1991See Buck v. Coldway Food Express, Inc., 383 Pa.Super. 580 , 557 A.2d 404, 407 (1989); Roseman v. Hospital of the Univ. of Pa., 377 Pa.Super. 409 , 547 A.2d 751 (1988).

11
American Enka Company, in No. 82-1080 v. Wicaco MacHine Corp. American Enka Company v. Wicaco MacHine Corp., in No. 82-1109green
ca3 · 1982 · cited in 1 Pennsylvania opinions naming this issue, 1984–1984
11
Laudenberger v. Port Auth. of Alleghenygreen
pa · 1981 · cited in 1 Pennsylvania opinions naming this issue, 1984–1984
11
Commonwealth v. Garvingreen
pa · 1972 · cited in 1 Pennsylvania opinions naming this issue, 1978–1978
11
Berger v. United Statesred
scotus · 1935 · cited in 1 Pennsylvania opinions naming this issue, 1972–1972
11
Sweitzer v. Whiteheadgreen
pa · 1961 · cited in 1 Pennsylvania opinions naming this issue, 1970–1970
11
Lobalzo v. Varoligreen
pa · 1966 · cited in 1 Pennsylvania opinions naming this issue, 1970–1970
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (19)

CaseCitedYears
Davis v. United States green
scotus · 1994
2 sentences

2018The U.S. Supreme Court has held that in order “[t]o avoid difficulties of proof and to provide guidance to officers conducting interrogations,” the determination of whether the right to counsel was invoked by the accused is an “objective inquiry.” Davis v. United States, 512 U.S. 452 , 458–59, 114 S.Ct. 2350 , 129 L.Ed.2d 362 (1994).

2018The U.S. Supreme Court has held that in order “[t]o avoid difficulties of proof and to provide guidance to officers conducting interrogations,” the determination of whether the right to counsel was invoked by the accused is an “objective inquiry.” Davis v. United States, 512 U.S. 452 , 458–59, 114 S.Ct. 2350 , 129 L.Ed.2d 362 (1994).

32014–2018
Lamp v. Heyman green
pa · 1976
2 sentences

2002The purpose behind this requirement is “to avoid the situation in which a plaintiff can bring an action, but by not making a good faith effort to notify a defendant, retain exclusive control over it for a period in excess of that permitted by the statute of limitations.” Lamp, 469 Pa. at 478 , 366 A.2d at 889 .

2002The purpose behind this requirement is “to avoid the situation in which a plaintiff can bring an action, but by not making a good faith effort to notify a defendant, retain exclusive control over it for a period in excess of that permitted by the statute of limitations.” Lamp, 469 Pa. at 478 , 366 A.2d at 889 .

31993–2002
Ablin, Inc. v. Bell Tel. Co. of Pa. green
pasuperct · 1981
2 sentences

2003The existence of “factual differences with regard to each member of the class does not render the named parties’ claims atypical of the class as a whole.” Cribb v. United Health Clubs Inc., 336 Pa. Super. 479, 484 , 485 A.2d 1182, 1185 (1985) (citing Ablin Inc. v. Bell Telephone of Pennsylvania, 291 Pa. Super. 40 , 435 A.2d 208 (1981)).

2003The existence of “factual differences with regard to each member of the class does not render the named parties’ claims atypical of the class as a whole.” Cribb v. United Health Clubs Inc., 336 Pa. Super. 479, 484 , 485 A.2d 1182, 1185 (1985) (citing Ablin Inc. v. Bell Telephone of Pennsylvania, 291 Pa. Super. 40 , 435 A.2d 208 (1981)).

22001–2003
Steele v. Workers' Compensation Appeal Board (Findlay Township) green
pacommwct · 2017
1 sentence

2025We also examined the purpose behind the requirement, as stated by the bill’s sponsor, which was “a built-in incentive for volunteer fire companies to fully utilize the PennFIRS system and [] push them to provide thorough information when filling out their PennFIRS reports” and that “the utilization of the PennFIRS system would serve to document that the volunteer firefighter was present at an incident where a known carcinogen was present.” Id. (quoting Pa. Legis.

12025–2025
Commonwealth v. Martin green
pa · 2014
1 sentence

2025Commonwealth v. Martin, 101 A.3d 706, 725 (Pa. 2014) (emphasis omitted). “[I]n Minnick [v. Mississippi, 498 U.S. 146, 153 (1990), the United States Supreme] Court clarified the Edwards rule by holding that ‘when counsel is requested, interrogation must cease, and officials may not reinitiate interrogation without counsel present, whether or not the accused has consulted with his attorney.’” Commonwealth v. Santiago, 599 A.2d 200, 201 (Pa. 1991).

12025–2025
Commonwealth v. Hill green
pa · 1999
1 sentence

2024Id.; ____________________________________________ 4 The Pennsylvania Supreme Court stated in Harth that “requiring the Commonwealth” to prove its due diligence “before a trial court excludes time from its Rule 600 time computation on the basis of ‘judicial delay’ comports with the language of Rule 600(C)(1) and its commentary, the purpose behind the rule, and our prior jurisprudence[.]” Id. at 617 .

12024–2024
Com. v. Wiggins, M. green
pasuperct · 2021
2 sentences

2021See Commonwealth v. Harth, 252 A.3d 600 , 617 (Pa. 2021) (“requiring the Commonwealth to demonstrate that it acted with due diligence before a trial court excludes time from its Rule 600 time computation on the basis of “judicial delay” comports with the language of Rule 600(C)(1) and its commentary, the purpose behind the rule, and our prior jurisprudence interpreting Rule 600 and its predecessor.”) (emphasis added); Commonwealth v. Wiggins, 248 A.3d 1285 (Pa.Super. 2021) (observing general dictates of new Rule 600 remained the same as they were prior to adoption, but noting prior distinction

2021See Commonwealth v. Harth, 252 A.3d 600 , 617 (Pa. 2021) (“requiring the Commonwealth to demonstrate that it acted with due diligence before a trial court excludes time from its Rule 600 time computation on the basis of “judicial delay” comports with the language of Rule 600(C)(1) and its commentary, the purpose behind the rule, and our prior jurisprudence interpreting Rule 600 and its predecessor.”) (emphasis added); Commonwealth v. Wiggins, 248 A.3d 1285 (Pa.Super. 2021) (observing general dictates of new Rule 600 remained the same as they were prior to adoption, but noting prior distinction

12021–2021
Commonwealth v. McCoy green
pa · 2009
1 sentence

2020(Appellant’s brief at 20-27.) In Commonwealth v. McCoy, 975 A.2d 586 (Pa. 2009), our supreme court affirmed the legal principle that the Sixth Amendment right to counsel attaches at the initiation of adversarial judicial proceedings.

12020–2020
Coral Gables, Inc. v. Kerl green
pa · 1939
2 sentences

2012In support of establishing lien priority, Shipley argues that the information available in Chester County’s docketing system (CHESCOPIN) on the date the Johnsons’ deed was recorded was sufficient to apprise a searcher of Shipley’s judgment even though it had not been entered in the judgment index: Shipley argues that the information entered by [the Prothonotary’s clerk] in the COURTVIEW system on November 30, 2009 was available on the CHESCO-PIN system by December 1, 2009[,] was sufficient to satisfy both the purpose behind the requirement of indexing a judgment and the standard set forth in C

2012In support of establishing lien priority, Shipley argues that the information available in Chester County’s docketing system (CHESCOPIN) on the date the Johnsons’ deed was recorded was sufficient to apprise a searcher of Shipley’s judgment even though it had not been entered in the judgment index: Shipley argues that the information entered by [the Prothonotary’s clerk] in the COURTVIEW system on November 30, 2009 was available on the CHESCO-PIN system by December 1, 2009[,] was sufficient to satisfy both the purpose behind the requirement of indexing a judgment and the standard set forth in C

12012–2012
Kinnally v. Bell of Pennsylvania green
paed · 1990
1 sentence

2001Kinnally v. Bell of Pennsylvania, 748 F. Supp. 1136 (E.D.

12001–2001
Ohio v. Roberts red
scotus · 1980
2 sentences

1994Ohio v. Roberts, 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980).

1994Ohio v. Roberts, 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 (1980).

11994–1994
Roseman v. Hospital of University of Pennsylvania green
pa · 1988
2 sentences

1991See Buck v. Coldway Food Express, Inc., 383 Pa.Super. 580 , 557 A.2d 404, 407 (1989); Roseman v. Hospital of the Univ. of Pa., 377 Pa.Super. 409 , 547 A.2d 751 (1988).

1991See Buck v. Coldway Food Express, Inc., 383 Pa.Super. 580 , 557 A.2d 404, 407 (1989); Roseman v. Hospital of the Univ. of Pa., 377 Pa.Super. 409 , 547 A.2d 751 (1988).

11991–1991
Gerald G. v. Theresa G. green
pasuperct · 1981
2 sentences

1989Gerald G. v. Theresa G., 284 Pa.Super. 498 , 426 A.2d 157 (1981).

1989Gerald G. v. Theresa G., 284 Pa.Super. 498 , 426 A.2d 157 (1981).

11989–1989
Barton v. Thaw green
pa · 1914
2 sentences

1989Barton v. Thaw, 246 Pa. 348, 352-354 , 92 A. 312 , 313-314 *429 (1914). “[I]f an unlimited time were allowed for the creation of these future and indestructible estates the alienation of lands might be henceforward forever prevented by the innumerable future estates which the caprice or vanity of some owners would prompt them to create.” Id., 246 Pa. at 355 , 92 A. at 314 . 4 .

1989Barton v. Thaw, 246 Pa. 348, 352-354 , 92 A. 312 , 313-314 *429 (1914). “[I]f an unlimited time were allowed for the creation of these future and indestructible estates the alienation of lands might be henceforward forever prevented by the innumerable future estates which the caprice or vanity of some owners would prompt them to create.” Id., 246 Pa. at 355 , 92 A. at 314 . 4 .

11989–1989
Hunter v. Hunter green
pasuperct · 1951
2 sentences

1985Hunter v. Hunter, 169 Pa. Superior Ct. 498 , 83 A.2d 401 (1951).

1985Hunter v. Hunter, 169 Pa. Superior Ct. 498 , 83 A.2d 401 (1951).

11985–1985
Bucheit v. Laudenberger green
scotus · 1982
11984–1984
Roviaro v. United States green
scotus · 1957
11978–1978
Patterson v. Palley Manufacturing Co. green
pa · 1948
11970–1970
Staszak v. Seibel neutral
pa · 1960
11970–1970

Where else courts name it

PA 43 (1970–2025) TX 41 (1960–2022) OH 36 (1986–2026) LA 32 (1983–2024) IL 29 (1974–2025) WA 28 (1979–2026) CA 27 (1942–2022) FL 17 (1979–2024) MO 16 (1985–2017) IA 14 (1978–2022) GA 14 (1974–2016) NM 11 (1977–2023) NY 11 (1985–2015) NC 9 (1980–2020) IN 9 (1975–2015) AZ 9 (1971–2023) MI 9 (1981–2019) MD 8 (1971–2021) ID 7 (1992–2020) OK 7 (1976–1990) MA 6 (1979–2012) NJ 6 (1992–2013) SC 6 (1992–2023) VA 6 (1979–2024) SD 6 (1991–2003) KS 5 (1973–2026) WV 5 (1988–2020) MN 5 (1999–2009) UT 5 (2002–2022) NV 5 (1971–2022) CT 4 (1992–1997) WI 4 (1983–2026) WY 4 (1979–2007) DC 4 (1989–2025) TN 4 (2003–2010) AL 4 (1973–2004) ME 3 (1978–1981) AR 3 (2002–2012) VT 3 (1998–2022) KY 3 (1987–2013) MS 2 (2011–2011) CO 2 (1984–1988) OR 2 (1986–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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