Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

Introducing the new legal challenges of E-Sports. By N. Emre Bilginoglu

Editor’s Note: Emre Bilginoglu[1] is an attorney in Istanbul and the co-founder of the Turkish E-Sports Players Association, a non-profit based in Istanbul that aims to provide assistance to professional gamers and to work on the relevant laws affecting them. 


The world is witnessing the rise of a new sport that is growing at an incredible speed: E-Sports. We are only starting to understand its legal implications and challenges.

In recent years, E-Sports has managed to attract thousands of fans to arenas to see a group of people play a video game. These people are literally professional gamers (cyber athletes)[2] who make money by competing in tournaments. Not all video games have tournaments in which professional players compete against each other.

The most played games in E-Sports competitions are League of Legends (LoL), Defense of the Ancients 2 (DotA 2) and Counter-Strike: Global Offensive (CS:GO). LoL and DotA are both Multiplayer online battle arena (MOBA) games, a genre of strategy video games in which the player controls a single character in one of two teams. The goal of the game is to destroy the opponent’s main structure. CS:GO is a first-person shooter (FPS) game, a genre of video games where the player engages combat through a first-person perspective. The main objective in CS:GO is to eliminate the opposing team or to terrorize or counter-terrorize, planting bombs or rescuing hostages. Other games that have (popular) E-Sports competitions include Starcraft II (real time strategy), Hearthstone (collectible card video game), Call of Duty (FPS) and FIFA (football).

The gaming requires cooperation between team players, a high level of concentration, rapid reactions and some seriously fast clicking. E-Sports is a groovy term to describe organized competitive computer gaming. The E-Sports industry is exponentially growing, amounting to values expressed in billions of dollars. According to Newzoo, a website dedicated to the collection of E-Sports data, there are some 250 million occasional viewers of E-Sports with Asia-Pacific accounting for half of the total amount. The growth of the industry is indubitably supported by online streaming media platforms. This article aims to explain what E-Sports is and to give the readers an insight on the key legal questions raised by it. More...


Time for Transparency at the Court of Arbitration for Sport. By Saverio Spera

Editor’s Note: Saverio Spera is an Italian lawyer and LL.M. graduate in International Business Law from King’s College London. He is currently an intern at the ASSER International Sports Law Centre.


The time is ripe to take a closer look at the CAS and its transparency, as this is one of the ways to ensure its public accountability and its legitimacy. From 1986 to 2013, the number of arbitrations submitted to the CAS has grown from 2 to more than 400 a year. More specifically, the number of appeals submitted almost doubled in less than ten years (from 175 in 2006, to 349 in 2013[1]). Therefore, the Court can be considered the judicial apex of an emerging transnational sports law (or lex sportiva).[2] In turn, the increased authority and power of this institution calls for increased transparency, in order to ensure its legitimacy.[3]

More...


UEFA’s betting fraud detection system: How does the CAS regard this monitoring tool? By Emilio García.

Editor’s note: Emilio García (emilio.garcia@uefa.ch)  is a doctor in law and head of disciplinary and integrity at UEFA. Before joining UEFA, he was the Spanish Football Federation’s legal director (2004–12) and an arbitrator at the CAS (2012–13).In this blog, Emilio García provides a brief review of a recent case before the Court of Arbitration for Sport (CAS): Klubi Sportiv Skënderbeu v UEFA (CAS 2016/A/4650)[1], in which he acted as main counsel for UEFA. 


Sport and match-fixing – A quick overview

Match-fixing is now legally defined as “an intentional arrangement, act or omission aimed at an improper alteration of the result or the course of a sports competition in order to remove all or part of the unpredictable nature of the aforementioned sports competition with a view to obtaining an undue advantage for oneself or for others”.[2] It has been said that there has always been match-fixing in sport.[3] From the ancient Olympic Games to the most important global sports competitions of today, manipulation of results has always been an all-too-frequent occurrence.

We have seen a number of very prominent instances of this kind of issue over the years. One of the most remarkable examples, which was even the subject of a film,[4] was the match-fixing episode during the 1919 World Series, where several players from the Chicago White Sox were found guilty of accepting bribes and deliberately losing matches against the Cincinnati Reds.[5]

The situation has changed considerably since then. In particular, the globalisation of the sports betting industry has had a massive impact, with recent studies estimating that between €200bn and €500bn is betted on sport every year.[6] Match-fixing does not just affect football either;[7] it is also affecting other sports, most notably tennis.[8] More...


The Diarra Ruling of the Tribunal of Charleroi: The New Pechstein, Bosman or Mutu?

Yesterday the sports law world was buzzing due to the Diarra decision of the Tribunal de Commerce du Hainaut (the Tribunal) based in Charleroi, Belgium. Newspapers were lining up (here, here and here) to spread the carefully crafted announcement of the new triumph of Jean-Louis Dupont over his favourite nemesis: the transfer system. Furthermore, I was lucky enough to receive on this same night a copy of the French text of the judgment. My first reaction while reading quickly through the ruling, was ‘OMG he did it again’! “He” meaning Belgian lawyer Jean-Louis Dupont, who after a string of defeats in his long shot challenge against FIFA’s TPO ban or UEFA’s FFP (see here and here), had [at least I believed after rushing carelessly through the judgment] manufactured a new “it”: a Bosman. Yet, after carefully re-reading the judgment, it became quickly clear to me that this was rather a new Mutu (in the sense of the latest CAS award in the ‘Mutu saga’, which I have extensively analysed on this blog and in a recent commentary for the new Yearbook of International Sports Arbitration) coupled with some reflections reminding a bit (but not really as will be explicated below) the Pechstein case.

In this blog, I will retrace briefly the story behind the case and then analyse the decision of the Belgium court. In doing so, I will focus on its reasoning regarding its jurisdiction and the compatibility of article 17(2) RSTP with EU law.More...

The Russian Doping Scandal at the Court of Arbitration for Sport: The IPC’s Rio Ineligibility of Russian Paralympic Athletes

Editor's note: This blog is part of a special blog series on the Russian doping scandal at the CAS. Last year I analysed the numerous decisions rendered by the CAS ad hoc Division in Rio and earlier this year I reviewed the CAS award in the IAAF case.

Unlike the International Association of Athletics Federations (IAAF), the International Paralympic Committee (IPC) was very much unaffected by the Russian doping scandal until the publication of the first McLaren report in July 2016. The report highlighted that Russia’s doping scheme was way more comprehensive than what was previously thought. It extended beyond athletics to other disciplines, including Paralympic sports. Furthermore, unlike the International Olympic Committee (IOC) the IPC had a bit more time to deal with the matter, as the Rio Paralympic Games were due to start “only” in September.

After the release of the McLaren Report, the IPC president Sir Philip Craven was “truly shocked, appalled and deeply saddened at the extent of the state sponsored doping programme implemented in Russia”. He immediately announced the IPC’s intention to review the report’s findings and to act strongly upon them. Shortly thereafter, on 22 July, the IPC decided to open suspension proceedings against the National Paralympic Committee of Russia (NPC Russia) in light of its apparent inability to fulfil its IPC membership responsibilities and obligations. In particular, due to “the prevailing doping culture endemic within Russian sport, at the very highest levels, NPC Russia appears unable or unwilling to ensure compliance with and the enforcement of the IPC’s Anti-Doping Code within its own national jurisdiction”. A few weeks later, on 7 August, the IPC Governing Board decided to suspend the Russian Paralympic Committee with immediate effect “due to its inability to fulfil its IPC membership responsibilities and obligations, in particular its obligation to comply with the IPC Anti-Doping Code and the World Anti-Doping Code (to which it is also a signatory)”. Indeed, these “obligations are a fundamental constitutional requirement for all National Paralympic Committees (NPCs), and are vital to the IPC’s ability to ensure fair competition and to provide a level playing field for all Para athletes around the world”. Consequently, the Russian Paralympic Committee lost all rights and privileges of IPC membership. Specifically, it was not entitled to enter athletes in competitions sanctioned by the IPC, and/or to participate in IPC activities. Thus, “the Russian Paralympic Committee will not be able to enter its athletes in the Rio 2016 Paralympic Games”. More...


The Russian Doping Scandal at the Court of Arbitration for Sport: The IAAF’s Rio Ineligibility of Russian Athletes

Since the release of the earth-shattering ARD documentary two years ago, the athletics world has been in a permanent turmoil. The International Athletics Association Federation (IAAF) is faced with both a never-ending corruption scandal (playing out in front of the French police authorities) and the related systematic doping of Russian athletes. The situation escalated in different phases led by the revelations of Russian insiders. First, in December 2014 with the ARD documentary, which demonstrated how widespread (and organized) the recourse to doping was in Russian athletics. It triggered the Pound investigation financed by the World Anti-Doping Agency (WADA), which led to two damaging reports (available here and here) for the Russian anti-doping system and the IAAF itself. Thereafter, in November 2015, the IAAF had no other choice but to provisionally suspend the Russian athletics federation (ARAF then RusAF) and its members from IAAF competitions. Yet, this was only the beginning as shortly after the former head of Moscow’s anti-doping laboratory provided a detailed sketch to the New York Times of the operation of a general state-led doping scheme in Russia. The system was designed to avert any positive doping tests for top-level Russian sportspeople and was going way beyond athletics. These allegations were later largely confirmed and reinforced by the McLaren investigation initiated by WADA in May 2016, and which published its first report in July 2016 shortly before the Rio Olympics. In June 2016, the IAAF anticipated the conclusions of the report (it had received most of McLaren’s evidence beforehand) and decided to maintain the ineligibility of Russian athletes for IAAF competitions, and for the Rio Olympics. It did, however, foresee a narrow exception for Russian athletes able to show that they were properly tested outside of Russia. Nonetheless, the athletes using this exception were to compete under a neutral flag at the Olympics. Unsurprisingly, Russian athletes led by pole superstar (and now IOC member), Yelena Isinbayeva, and the Russian Olympic Committee decided to challenge this decision in front of the Court of Arbitration for Sport (CAS). Interestingly, while the decision was rendered on 21 July 2016, the full text of the award was publically released only on 10 October 2016. In September, I analysed the Rio CAS Ad Hoc Decisions involving Russian athletes aiming to participate to the Olympics. I will now turn to the IAAF decision, which is of great importance to the future of the anti-doping system. Indeed, it lays out the fundamental legal boundaries of the capacity of international federations to impose sanctions on their members (and their members) in order to support the world anti-doping fight. More...

International and European Sports Law – Monthly Report – November and December 2016. By Saverio Spera.

Editor’s note: This report compiles all relevant news, events and materials on International and European Sports Law based on the daily coverage provided on our twitter feed @Sportslaw_asser. You are invited to complete this survey via the comments section below, feel free to add links to important cases, documents and articles we might have overlooked. 


The Headlines

The Russian State Doping Scandal and the crisis of the World Anti-Doping System

Russian doping and the state of the Anti-Doping System has been the dominant international sports law story in November and December. This is mainly due to the release of the second report of the McLaren’s investigation on 9 December 2016. The outcome of McLaren’s work showed a “well-oiled systemic cheating scheme” that reached to the highest level of Russian sports and government, involving the striking figure of 30 sports and more than 1000 athletes in doping practices over four years and two Olympic Games. The report detailed tampering with samples to swap out athletes’ dirty urine with clean urine.More...


FIFA’s provision on the protection of minors - Part 3: The compatibility of Article 19 with EU law. By Kester Mekenkamp.

Editor’s note: Kester Mekenkamp is an LL.M. student in European Law at Leiden University and an intern at the ASSER International Sports Law Centre. This blog is, to a great extent, an excerpt of his forthcoming thesis, which he shall submit in order to complete his master’s degree.

This final blog aims to provide some broader perspective, by sketching first the grander scheme in which Article 19 RSTP – FIFA's provision on the protection of minors – operates. Thereafter, the focus will shift towards testing Article 19 RSTP, thereby keeping in mind the previous blogs (Part 1: The Early Years and Part 2: The 2009 reform and its aftermath), against EU free movement law.  


Putting Article 19 RSTP into perspective: The bigger picture

After having investigated the nuts and bolts of FIFA’s provision on the protection of minors in the first two parts of this blog, it might be useful to address its bigger picture.

Article 19 RSTP and its accompanying provisions regulate only a small share of the targeted activity. There is, unfortunately, also an illegal world. Circumvention of the prohibition is allegedly commonplace.[1] Visas and passports can be falsified.[2] Work permits can be obtained on the basis of jobs arranged by clubs.[3] More...


FIFA’s provision on the protection of minors - Part 2: The 2009 reform and its aftermath. By Kester Mekenkamp.

Editor’s note: Kester Mekenkamp is an LL.M. student in European Law at Leiden University and an intern at the ASSER International Sports Law Centre. This blog is, to a great extent, an excerpt of his forthcoming thesis, which he shall submit in order to complete his master’s degree.


This is the second part of a three-piece blog on FIFA’s provision on the protection of minors, Article 19 of the Regulations on the Status and Transfer of Players. The contribution in its entirety aims to provide an encompassing overview of the rule’s lifespan since its inception in 2001. The previous (first) part has shed light on the “birth” and “first years” of the provision, and as such illustrated the relevant developments from 2001 till 2009. This second part covers the rule’s “adolescent years”, which span from 2009 to the present. The major changes put forward in the 2009, 2015 and 2016 versions of the RSTP will be addressed. Thereafter the important CAS decisions concerning Article 19, Muhic, Vada I and II, FC Barcelona, RFEF, and the FIFA decisions relating to Real Madrid and Atlético Madrid, will be scrutinized. The third, and final, part will constitute a substantive assessment of the provision under EU Internal Market law.

Given that the version adopted in 2008 left Article 19 untouched, the 2009 RSTP represented the next significant step in the regulation of the protection of minors. It had become clear that the system as used up to that point was inadequate to achieve its goal,[1] most notably because several national associations still neglected to strictly apply the rules.[2] More...


FIFA’s provision on the protection of minors - Part 1: The Early Years. By Kester Mekenkamp.

Editor’s note: Kester Mekenkamp is an LL.M. student in European Law at Leiden University and an intern at the ASSER International Sports Law Centre. This blog is, to a great extent, an excerpt of his forthcoming master thesis. 


On 24 November 2016, a claim was lodged before a Zurich commercial court against FIFA’s transfer regulations by a 17-year-old African football player.[1] The culprit, according to the allegation: The provision on the protection of minors, Article 19 of the Regulations for the Status and Transfer of Players.[2] The claimant and his parents dispute the validity of this measure, based on the view that it discriminates between football players from the European Union and those from third countries. Besides to Swiss cartel law, the claim is substantiated on EU citizenship rights, free movement and competition law. Evidently, it is difficult to assess the claim’s chance of success based on the sparse information provided in the press.[3] Be that as it may, it does provide for an ideal (and unexpected) opportunity to delve into the fascinating subject of my master thesis on FIFA’s regulatory system aimed at enhancing the protection of young football players and its compatibility with EU law. This three-part blog shall therefore try to provide an encompassing overview of the rule’s lifespan since its inception in 2001. More...


Asser International Sports Law Blog | Human Rights as Selection Criteria in Bidding Regulations for Mega-Sporting Events – Part II: FIFA and Comparative Overview – By Tomáš Grell

Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

Human Rights as Selection Criteria in Bidding Regulations for Mega-Sporting Events – Part II: FIFA and Comparative Overview – By Tomáš Grell

The first part of this two-part blog examined the new bidding regulations adopted by the IOC and UEFA, and concluded that it is the latter who gives more weight to human rights in its host selection process. This second part completes the picture by looking at FIFA's bidding regulations for the 2026 World Cup. It goes on to discuss whether human rights now constitute a material factor in evaluating bids to host the mega-sporting events organised by these three sports governing bodies.

 

FIFA: 2026 World Cup

About the host selection process

The United States, Mexico, and Canada together on the one side and Morocco on the other are bidding to host the 2026 World Cup. The bidders must now prepare and submit their Bid Books to FIFA by no later than 16 March 2018, providing the world's governing body of football with information regarding their hosting vision and strategy, the country's political system and economic situation, technical matters, other event-related matters, or human rights and environmental protection.[1] FIFA will then commission a Bid Evaluation Task Force,[2] composed of the chairman of the Audit and Compliance Committee, the chairman of the Governance Committee, one member of the Organising Committee for FIFA Competitions, and certain members of the General Secretariat with relevant expertise, to prepare a written report evaluating each bid. This report will be split into three sections, namely (i) compliance assessment; (ii) an assessment of the risks and benefits of each bid, including the risks of adverse impacts on human rights; and (iii) an assessment of key infrastructural and commercial aspects of each bid, including stadiums, transport infrastructure, organising costs, or estimated media and marketing revenues.[3] The Bid Evaluation Task Force will apply a scoring system that might eventually lead to the exclusion of a bid from the host selection process in the event of its failure to reach a required minimum score.[4] It is critical to note, however, that this scoring system will only be used to evaluate infrastructural and commercial aspects of each bid.[5] In other words, human rights or environmental protection are not subject to this scoring system.

The Bid Evaluation Task Force will forward its report to the members of the FIFA Council who will determine whether or not each bid qualifies to be voted on by the FIFA Congress.[6] While until now the decision on the venue for the FIFA's flagship event has been taken by the Council (formerly the Executive Committee), the host of the 2026 World Cup will be elected for the first time by the members of the Congress.[7] The Congress will meet for this purpose in June 2018 and it may either award the right to host the tournament to one of the candidates or reject all bids designated by the Council.[8] In the latter case, FIFA will launch a new procedure that will culminate with a final decision in May 2020.[9] It is also worthwhile noting that the entire host selection process will be overseen by an independent audit company.[10]

Human rights as selection criteria

A number of human rights requirements could be found across different bidding documents relating to the host selection process for the 2026 World Cup. This section takes a closer look at the content of these requirements. 

First, each member association bidding to host the tournament must undertake to respect all internationally recognised human rights in line with the United Nations Guiding Principles on Business and Human Rights (UN Guiding Principles).[11] Importantly, this commitment covers not only the member association's own activities, but also the activities of other entities that are in a business relationship with the member association, be it for the production of goods or provision of services. In this respect, FIFA acknowledges that ''a significant part of human rights risk may be associated with the activities of third parties''.[12]

Second, FIFA requires that each bidder provide a human rights strategy outlining how it is going to honour its commitment mentioned above.[13] While a similar requirement also appears in the UEFA's bidding documentation for the Euro 2024, FIFA is much more specific in defining the essential elements of this strategy. Accordingly, the strategy shall include a comprehensive report ''identifying and assessing any risks of adverse human rights impacts […] with which the member association may be involved either through its own activities or as a result of its business relationships''.[14] Perhaps the most remarkable aspect of the entire host selection process is the follow-up requirement that this report be complemented by an independent study carried out by an organisation with recognised expertise in the field of human rights.[15] This independent expert organisation will examine to what extent does the national context, including the national legislation, influence the member association's capacity to respect all internationally recognised human rights.[16] As part of their strategy, the bidders should further explain what measures they intend to take in order to mitigate any human rights risks identified in the comprehensive report.[17] Moreover, the strategy should contain information about the implementation of an ongoing due diligence process, the plans for meaningful community and/or stakeholder dialogue and engagement,[18] the protection of human rights defenders' and journalists' rights, or grievance mechanisms.[19]

Third, each bidder must provide a report summarising its ''stakeholder engagement process implemented as part of the development of the […] human rights strategy''.[20] Fourth and last, the government of each country bidding to host the 2026 World Cup shall express its commitment to: (i) respecting, protecting, and fulfilling human rights in connection with the hosting and staging of the tournament; and (ii) ensuring that victims of human rights abuses will have access to effective remedies.[21] To this effect, each of the involved governments is required to sign a separate declaration.


A comparative overview

It remains to be seen whether the new bidding regulations will help reduce the number and severity of adverse human rights impacts linked to mega-sporting events. For the time being, it is essential to identify the strong and weak points of these regulations.

When discussing strengths, FIFA and UEFA come to mind. Both organisations should be applauded for demanding that the bidders pledge to respect and protect internationally recognised human rights independently of the locally recognised human rights.[22] FIFA moreover extends this obligation to the activities of third parties that are in a business relationship with the bidding member association. Both FIFA and UEFA also ask for a human rights strategy that should include some crucial information such as evidence of meaningful consultation with potentially affected communities. Again, FIFA goes one step further by requiring that this strategy be accompanied by an independent expert study.

All three sports governing bodies reserve the right to assign a role to independent human rights experts in evaluating or preparing bids.[23] And while this is in itself commendable, it should be noted that such a role is limited because it does not entail decision-making competences. For instance, the expert institution responsible for developing an independent study in the host selection process for the 2026 World Cup will not have the power to exclude a bid if it ascertains that the national context significantly undermines the member association's capacity to respect internationally recognised human rights. This expert institution will certainly put more pressure on FIFA in the sense that any action contrary to the institution's recommendations will have to be publicly justified by compelling reasons, but FIFA may nevertheless decide to consider a bid even if it entails serious human rights risks. Moreover, it is difficult to understand why only infrastructural and commercial aspects of a bid are subject to the scoring system applied by the Bid Evaluation Task Force. If the main reason for this is the fact that the members of the Bid Evaluation Task Force lack expertise in the field of human rights, then the assessment of human rights aspects should perhaps be left to independent experts only. It would be crucial to give these human rights experts some power to decide whether or not a bid qualifies for the next stages of the host selection process. A greater role for independent human rights experts in evaluating bids to host mega-sporting events could come with the establishment of an independent Centre for Sport and Human Rights in 2018. However, this will probably not affect the host selection processes that are currently underway.


Conclusion 

Including human rights within the criteria for evaluating bids to host mega-sporting events may deter many countries, especially those with a negative human rights record, from launching a bid. However, as Professor John Ruggie makes clear, human rights requirements in bidding regulations for mega-sporting events are not aimed at ''peremptorily excluding countries based on their general human rights context''.[24] Indeed, a country where human rights abuses occur can nevertheless deliver an abuse-free event. To do so, it will need to develop an effective strategy and, if selected, guarantee the implementation of this strategy from day one.


[1]    FIFA, Structure, Content, Presentation, Format and Delivery of Bid Book for the 2026 FIFA World Cup.

[2]    FIFA, Bidding Registration regarding the submission of Bids for the hosting and staging of the 2026 FIFA World Cup, pp. 23-28.

[3]    Ibid. pp. 24-25. See also FIFA, Guide to the Bidding Process for the 2026 FIFA World Cup, p. 7.

[4]    FIFA, Bidding Registration, pp. 25-27.

[5]    Ibid.

[6]    Ibid. p. 31. See also FIFA Statutes, Article 69(2)(d).

[7]    FIFA, Bidding Registration, pp. 31-32. See also FIFA Statutes, Article 69(1).

[8]    FIFA, Bidding Registration, p. 31.

[9]    FIFA, Guide to the Bidding Process, p. 13.

[10]   FIFA, Bidding Registration, pp. 22-23.

[11]   FIFA, Structure, Content, Presentation, Format and Delivery of Bid Book, Section 23 – Human Rights and Labour Standards. In addition to international treaties and instruments mentioned in Principle 12 of the UN Guiding Principles, FIFA concedes that ''the scope […] of internationally recognised human rights may be enlarged to include, for instance, the United Nations instruments on the rights of indigenous peoples; women; national or ethnic, religious and linguistic minorities; children; persons with disabilities; and migrant workers and their families''. See FIFA, Bidding Registration, p. 74.

[12]   FIFA, Structure, Content, Presentation, Format and Delivery of Bid Book, Section 23 – Human Rights and Labour Standards.

[13]   Ibid.

[14]   Ibid.

[15]   Ibid.

[16]   Ibid.

[17]   Ibid.

[18]   The community and/or stakeholder dialogue and engagement should be in line with relevant authoritative standards such as the AA1000 Stakeholder Engagement Process.

[19]   FIFA, Structure, Content, Presentation, Format and Delivery of Bid Book, Section 23 – Human Rights and Labour Standards.

[20]   Ibid.

[21]   FIFA, Overview of Government Guarantees and the Government Declaration, pp. 11-12.

[22]   In this regard, FIFA also notes that ''where the national context risks undermining FIFA's ability to ensure respect for internationally recognised human rights, FIFA will constructively engage with the relevant authorities and other stakeholders and make every effort to uphold its international human rights responsibilities''. See FIFA's Human Rights Policy, para. 7.

[23]   IOC, Report of the IOC 2024 Evaluation Commission, p. 7. UEFA, Bid Regulations for the UEFA Euro 2024, Article 14. As mentioned earlier in this blog, FIFA demands that the bidders put forward a human rights strategy complemented by an independent expert study.  

[24]   John G. Ruggie, For the Game. For the World. FIFA and Human Rights, p. 32.

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