Professional Documents
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Ladinsky V Ivey Complaint
Ladinsky V Ivey Complaint
v.
Defendants.
COMPLAINT
Roe, individually and on behalf of his minor child, Mary Roe; and Jane Doe,
individually and on behalf of her minor child, John Doe (collectively “Plaintiffs”),
bring this Action for Declaratory and Injunctive Relief against Defendants Kay Ivey,
in her official capacity as Governor of the State of Alabama; Steve Marshall, in his
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official capacity as Attorney General of the State of Alabama; Jill H. Lee, in her
official capacity as District Attorney for Shelby County, Alabama; and Danny Carr,
PRELIMINARY STATEMENT
Alabama’s Vulnerable Child Compassion and Protection Act (the “Act”), passed by
the Alabama Legislature on April 7, 2022, and signed into law by Governor Kay
criminal penalties on parents and health care providers who obtain or provide such
care.
medical treatments recognized as the standard of care for the treatment of gender
dysphoria in minors and that are safe, effective, and medically necessary. If this
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enforced, parents will not only be unable to obtain that treatment for their children
transgender minors, and the transgender minors themselves all will suffer irreparable
harm as a result.
necessary care for transgender minors lack a rational foundation and serve no
legitimate purpose.
6. As detailed below, the Act violates Section 1557 of the Affordable Care
impermissibly intruding into parents’ fundamental right to obtain safe, effective, and
enforcement of the Act. Without the injunctive relief sought, the Act will bar the
healthcare provider Plaintiffs from being able to administer essential care to their
patients, who include transgender minors living in Alabama; will prevent the parent
Plaintiffs from obtaining such care for the minor Plaintiffs; and will cause the minor
psychological harm.
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PARTIES
8. Plaintiff Robert Roe is and has at all relevant times been a resident of
transgender girl, for whom he also appears in this case as her next friend. Because
of concerns about his and his child’s privacy and safety, Robert Roe and Mary Roe
9. Plaintiff Jane Doe is and has at all relevant times been a resident of
Shelby County, Alabama. She is the mother of Plaintiff, John Doe, a 17-year-old
transgender boy for whom she also appears in this case as his next friend. Because
of concerns about her and her child’s privacy and safety, Jane Doe and John Doe
10. Plaintiffs Jane Doe and Robert Roe (collectively, the “Parent
Plaintiffs”) are the parents and legal guardians of Plaintiffs John Doe and Mary Roe
(collectively, the “Transgender Plaintiffs”), respectively. They bring this action for
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Alabama and is an active member of the medical staff at the University of Alabama
Hospital of Alabama and is an active member of the medical staff at UAB Hospital,
include transgender minors living in Alabama. Dr. Abdul-Latif resides and works in
III. Defendants
13. Defendant Kay Ivey is the Governor of the State of Alabama. Governor
Alabama. He is the chief law enforcement officer of the State with the power to
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initiate criminal action to enforce the Act. In his capacity as Attorney General,
Mr. Marshall has the ability to enforce the Act. Mr. Marshall is sued in his official
Alabama. She is the chief law enforcement officer of Shelby County, who prosecutes
all felony and some misdemeanor criminal cases which occur within Shelby County.
In her capacity as District Attorney, Ms. Lee has the ability to enforce the Act. Ms.
Lee is sued in her official capacity as District Attorney of Shelby County, Alabama.
prosecutes all felony criminal cases that occur within the Birmingham Division of
Attorney, Mr. Carr has the ability to enforce the Act. Mr. Carr is sued in his official
17. Defendants each have separate and independent authority to enforce the
18. Plaintiffs seek redress for the deprivation of their rights secured by
Section 1557 of the Affordable Care Act, the United States Constitution, and the
equitable powers of this Court to enjoin unlawful official conduct. This action is
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from enforcing the Act and for a declaration that the Act violates federal law.
Therefore, this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331
and 1343.
Defendants are domiciled in Alabama and the denial of Plaintiffs’ rights guaranteed
20. All defendants reside in Alabama, and, upon information and belief,
Defendants Lee and Carr reside in this judicial district. Therefore, venue is proper
21. If enforced, the Act would violate the federal statutory and
22. This Court has the authority to enter a declaratory judgment and to
and 65, 28 U.S.C. §§ 2201 and 2202, and this Court’s inherent equitable powers.
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FACTUAL ALLEGATIONS
people’s gender identity is consistent with their birth sex. Transgender people,
however, have a gender identity that differs from their birth sex.
24. Gender dysphoria is the clinical diagnosis for the distress that arises
when a person’s gender identity does not match their birth sex. To receive a
diagnosis of gender dysphoria, a young person must meet the criteria set forth in the
Am. Psychiatric Ass’n, Diagnostic and Statistical Manual of Mental Disorders (5th
ed. 2013) (“DSM-5”).1 If left untreated, gender dysphoria can cause anxiety,
considered killing themselves and 40% have attempted suicide. 56% of youth
reported a previous suicide attempt and 86% reported suicidality. See Austin,
1
Earlier editions of the DSM included a diagnosis referred to as “Gender Identity
Disorder.” The DSM-5 noted that Gender Dysphoria “is more descriptive than the
previous DSM-IV term gender identity disorder and focuses on dysphoria as the
clinical problem, not identity per se. Being diagnosed with gender dysphoria
“implies no impairment in judgment, stability, reliability, or general social or
vocational capabilities.” Am. Psychiatric Ass’n, Position Statement on
Discrimination Against Transgender & Gender Variant Individuals (2012).
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based and cannot be changed. In the past, mental health professionals sought to treat
gender dysphoria by attempting to change the person’s gender identity to match their
birth sex; these efforts were unsuccessful and caused serious harms. Today, the
medical profession recognizes that such efforts are unethical and put minors at risk
care that has been adopted by the major medical and mental health associations in
the United States including, but not limited to, the American Medical Association,
and others, with a mission of promoting evidence-based care and research for
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the most recent edition of the Standards of Care for the treatment of gender dysphoria
in minors and adults in 2011 and is in the process of finalizing a revised edition of
the Standards of Care, which will likely be published later this year.
29. The Endocrine Society has also promulgated a standard of care for the
as transition. There are several components to the transition process: social, legal,
medical, and surgical. Each of these components is part of the approved, medically
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hairstyle, and clothing that match that person’s gender identity, and treating that
person consistent with their gender identity in all aspects of their life, including
home, school, and everyday life. Following those steps, transgender people often
obtain a court order officially changing their name and, where possible, correcting
the sex listed on their birth certificate and other identity documents.
33. For transgender people who have already begun puberty, it may be
appropriate for them to start taking puberty-blocking medication and later hormone-
replacement therapy to ensure their body develops in a manner consistent with their
gender identity.
34. Finally, surgical treatment may be part of essential medical care for a
and create a male chest contour for transgender males. Like all treatments for gender
dysphoria, male chest reconstruction surgery is safe and effective in treating gender
basis that considers the age of the patient, medical need, and appropriateness of the
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35. Longitudinal studies have shown that children with gender dysphoria
who receive essential medical care show levels of mental health and stability
Child & Adolescent Psychiatry 116 (2017); Kristina Olson, et al., Mental Health of
(2016). In contrast, children with gender dysphoria who do not receive appropriate
medical care are at risk of serious harm, including dramatically increased rates of
36. On April 8, 2022, Defendant Kay Ivey signed the Act into law, and the
some cases, surgeries, the Act makes it criminal for any person, including healthcare
providers, to provide these treatments. The Act likewise makes it criminal for a
38. The Act abandons science and seeks to stop safe, effective, and
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39. The Act ignores established medical science finding that transgender
minors who do not receive this essential medical care suffer serious injuries to their
40. In short, the Act prevents healthcare professionals from providing, and
transgender children.
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including the Parent Plaintiffs, are forced to choose between withholding medically
necessary treatment from their minor transgender patients or children, on the one
44. The Act also prohibits the Healthcare Provider Plaintiffs from
at the same time placing no restrictions on the prescription or provision of the same
treatments when necessary for other medical conditions. For example, the law
early puberty while preventing the endocrinologist from prescribing the same
45. By so doing, the Act singles out and prohibits treatment when it is
necessary for a transgender person’s medical care while allowing the same treatment
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this medical condition—while permitting the very same treatments for minors to
including puberty blockers and hormone therapy, for gender dysphoria. If allowed
to take effect, the Act will interrupt these medically necessary treatments, prevent
them from obtaining future medically necessary treatments for gender dysphoria,
47. Mary Roe is a 13-year-old transgender girl who resides with her parents
48. The Roe family has deep roots in Alabama. Robert Roe is an Alabama
native and a state employee. Both Robert and his wife are graduates of public
County.
49. When Robert and his wife found out their first child was a boy, they
were excited to have a son. They named Mary after a revered patriarch in Robert’s
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family who was also an important figure in the history of the Civil Rights Movement
in Alabama.
50. But, from an early age, Mary started showing behaviors that indicated
her female gender identity. Robert and his wife treated Mary as a boy and dressed
her in boys’ clothing, but Mary would come home from preschool every day and
51. When she was around six years old, Mary became reclusive and was
very often unhappy, including frequent emotional outbursts where Mary would slam
her head into the wall. Concerned for her well-being, Mary’s parents brought her to
a therapist to get insight into her behavior and guidance on how to support her.
52. Around the same time, Mary began to regularly say that she is a girl.
Her statements and actions made clear that this was not simply imaginative play.
53. Based on the advice of Mary’s therapist, Robert and his wife began to
permit Mary to wear clothing reflecting her female gender identity outside the home.
She wore dresses throughout summer and to church on Sundays. The pastor of the
local Baptist church and the entire church community were very supportive of Mary.
54. Mary’s mental health and behavior greatly improved when her parents
allowed her to dress as a girl outside the house. She became a happy child who loved
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55. By the end of that summer and the beginning of the school year, Robert
and his wife advised Mary’s school that Mary is transgender and would be returning
to school as female. Although the school administration assured them that Mary
would be allowed to express her gender identity freely in school and be referred to
by her new name, Mary was met with hostility—some accidental, but some
intentional. For example, some teachers continued to refer to Mary by her birth
name. And her peers—picking up on cues from the teachers—would also use her
birth name, and some would refuse to play with her if she tried to correct them.
classes, hid in the bathroom, went to the nurse’s office during class hours to avoid
her teachers and other classmates, and hid any documents that bore her birth name.
Initial efforts to transfer Mary to another school were unsuccessful. In the summer
between first and second grade, Robert and his wife found a new school for Mary.
57. At the new school, Mary is no longer referred to by her birth name and
is accepted as a girl. She dresses as a girl, interacts with others as a girl, and is private
58. Since Mary’s transfer to the new school, she has returned to being the
happy, active child she was during the summer prior to first grade.
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59. All through these times, Robert and his wife continually checked in
60. When Mary visited her pediatrician in early 2021, the pediatrician
confirmed that she had started puberty, and needed to be evaluated to determine
whether she is a good candidate for puberty-blocking medication. Mary has been
61. It is essential for Mary’s mental health that she continues to receive
puberty-blocking medications every three months and is able to obtain any future
medical treatments that her healthcare providers determine are medically necessary
to treat her gender dysphoria. For Mary to be forced to go through male puberty
depression, anxiety, and distress. Mary’s parents are also concerned that without
access to the puberty-blocking medication she needs, Mary would resort to self-harm
62. Like all parents, Robert and his wife want the best for Mary and have
been careful to follow the advice of professionals, making decisions based on the
standards of care.
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63. If the Act goes into effect, Mary’s medical care will be disrupted.
testosterone, and she will begin to develop secondary sex characteristics associated
transgender girl and would cause her to experience again the distress she experiences
from having a body seen by others as inconsistent with her female identity.
64. John Doe is a 17-year-old high school student living in Shelby County,
Alabama. He has lived in Alabama all his life. John is a transgender boy.
65. As a young child, John fashioned his behavior and conduct after other
boys. He often asked his parents questions about “boys’ activities” and told his father
that he thinks he should have been a boy. John also had rules about birthday gifts
66. John’s parents thought it was a phase, or that perhaps John was a
lesbian. It didn’t matter either way to his parents; they were very accepting of who
he was.
67. Despite his parents’ support, John experienced significant isolation and
depression that affected his performance in school and made it difficult for him to
sleep. John’s parents started taking him to a therapist when he was around eight or
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nine years old. Although therapy helped temporarily, John’s mental health declined
further when he started puberty. He quickly developed large breasts, which was very
distressing for John. He would often cry in the shower because of the shape of his
chest, wear multiple sports bras at a time, and slouch his shoulders to make the
appearance of his chest less prominent. Getting his period was equally distressing
for John. John’s dysphoria was so severe that he stayed home from school for at least
changing his appearance to be more masculine. He cut his hair shorter so that it
would look like a more typical boys’ hairstyle and wore more masculine clothing—
anything baggy enough to hide the female-appearing parts of his body. John even
grew out his leg hair, which he hid from everyone, including his parents; he loved
having hair on his legs. When Jane found out, she made him shave, but John just
understanding of the source of his dysphoria and the vocabulary to explain what he
was experiencing. Soon after that, John told his parents that he is transgender. As in
70. Unfortunately, John’s peers and school were not as accepting as his
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and harassment. He was also not permitted to use the boys’ restroom facilities, which
led him to not use the restroom all day until he returned home. Not only did that
mistreatment make him feel unwelcome at the school, but not having access to a
restroom made it impossible for John to focus while in class. His grades soon began
to suffer to the point that he was at risk of failing several classes in both his freshman
71. Besides choosing a new name as part of his transition, John began also
contour. John wore his binder all the time and often for hours longer than he was
supposed to. Having the binder became crucial to John’s ability to function because
it gave him a newfound confidence, which helped buoy him against the mistreatment
he experienced in school.
72. Not long after John came out as transgender, Jane started reaching out
to healthcare providers to get John appropriate mental health and medical treatment.
She knew of the clinic at UAB due to her work as an interpreter and contacted Dr.
Ladinsky. Through the clinic, John was able to connect with both mental health and
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medication to stop his period, it took about a year before he started testosterone.
diagnosing him with gender dysphoria, and both he and his parents researched and
talked extensively to John’s healthcare providers about the risks, benefits, and
alternatives to that treatment. Confident that this course of treatment was in their
child’s best interests, his parents eventually consented to testosterone treatments for
John.
74. Starting testosterone has been amazing for John. He finally is feeling
more like himself, building greater confidence, and is happier overall. Over the past
year and a half, John’s voice has dropped and he has developed facial hair. Those
features have allowed him to feel more comfortable in his body and eased his
significant distress for him. Due to severe chaffing caused by his binder, John is only
able to wear his binder every other day, as recommended by his treating healthcare
providers. And, because of the size of his chest, wearing the binder for extended
periods of time causes John significant physical discomfort. With the support of his
treating mental health and medical providers, John consulted with a surgeon who
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John, the surgeon indicated that he was a good candidate and was willing to schedule
76. If the Act is allowed to go into effect, John’s medical care will be
disrupted because he will not be able to access medications his physicians have
prescribed to treat his gender dysphoria. John will also be unable to obtain male
chest reconstruction surgery in Alabama until he reaches the age of majority, which
in Alabama is age 19. Thus, if the Act is allowed to go into effect, it will lead to
77. Dr. Ladinsky and Dr. Abdul-Latif are physicians at the Children’s
Dr. Ladinsky has treated and is currently treating dozens of transgender young
people for gender dysphoria, including John Doe and Mary Roe.
prescribing puberty blocking medication and hormone therapy to treat their gender
dysphoria.
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79. Drs. Ladinsky and Abdul-Latif know, based on data, their observations
and years medical practice, as well as their familiarity with medical research on the
treatment of gender dysphoria in minors, that transgender young people who receive
interactions, and better academic performance, as compared with their peers who do
their transgender minor patients, one or more mental health providers evaluate the
patient, confirm the gender dysphoria diagnosis, and thoroughly assess the patient’s
mental health, maturity, and readiness to undergo medical treatment for gender
dysphoria. Each patient’s mental health provider then provides a letter detailing the
81. Both Dr. Ladinsky and Dr. Abdul-Latif then conduct their own
assessment of the patient to determine whether they agree with the mental health
provider’s assessment. Additionally, Drs. Ladinsky and Abdul-Latif meet with the
patient and their parents to explain the risks, benefits, alternatives to the treatment
and consequences of forgoing it. The patient and their family are also given written
materials that review the information covered during the appointment. To ensure that
patients and their families take the time to read those materials and discuss them
among themselves, the clinic requires the patient to return for an additional
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or hormone-replacement therapy.
82. In the time between appointments, the patient and family are
encouraged to discuss their options further with the patient’s mental health provider,
or to engage with the other services offered by the clinic, such as pastoral care.
83. At the second appointment, Drs. Ladinsky and Abdul-Latif review the
consent forms with the patient and their parents again, giving them another
opportunity to ask questions and address any concerns. If, after that discussion, the
patient and their parents provide written consent for treatment, and if Drs. Ladinsky
and Abdul-Latif believe that such treatment is safe, effective, and medically
appropriate for the patient, Drs. Ladinsky and Abdul-Latif will write the necessary
prescriptions.
84. Both Dr. Ladinsky and Dr. Abdul-Latif then see their patients for
follow-up care at regular intervals to evaluate the patients’ physical and mental
health and address any questions the patients or their parents may have.
hormone-replacement therapy are safe and effective at treating their patients’ gender
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being and preventing the decompensation seen in transgender minors who are unable
86. If the Act goes into effect, thereby denying transgender minors access
to this essential treatment, Drs. Ladinsky and Abdul-Latif’s patients will experience
severe psychological distress and irreversible physical changes to their bodies that
patients, Drs. Ladinsky and Abdul-Latif cannot comply with the Act. As a result of
the Act, both Drs. Ladinsky and Abdul-Latif will face the ever-present threat of
necessary and appropriate treatments for gender dysphoria to their minor transgender
COUNT I
Preemption
Healthcare Provider Plaintiffs and Transgender Plaintiffs Against Defendants in
Their Official Capacities
42 U.S.C. § 18116
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90. Under Section 1557 of the Affordable Care Act, “an individual shall
not . . . be excluded from participation in, be denied the benefits of, or be subjected
Agency or any entity established under this title (or amendments)” on the basis of
92. The Transgender Plaintiffs obtain their medical care from providers
who are recipients of federal financial assistance and therefore subject to the non-
against them because they are transgender. As such, the Act conflicts with the non-
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their obligations under Section 1557 and also comply with the restrictions imposed
by the Act. On the one hand, refusing to comply with the Act would bring them into
compliance with Section 1557, but subject them to criminal penalties under the Act.
On the other hand, complying with the Act would subject the Healthcare Plaintiffs
the full purposes and objectives of Congress, including the objective of preventing
97. The Healthcare Plaintiffs have no adequate remedy at law to redress the
wrongs alleged herein, which are of a continuing nature and will cause them
irreparable harm.
injunctive relief.
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COUNT II
Deprivation of Equal Protection
Transgender Plaintiffs Against Defendants in Their Official Capacities
Healthcare Provider Plaintiffs Against Defendants in Their Official Capacities
U.S. Const. Amend. XIV
Healthcare Provider Plaintiffs bring this Count against Defendants Kay Ivey, Steve
enforceable pursuant to 42 U.S.C. § 1983, provides that no state shall “deny to any
person within its jurisdiction the equal protection of the laws.” U.S. Const. Amend.
XIV, § 1.
102. The Act singles out transgender minors and prohibits them from
obtaining medically necessary treatment based on their sex and transgender status.
103. The Act also treats transgender minors differently and less favorably
than non-transgender minors by allowing minors who are not transgender to obtain
the same medical treatments that are prohibited when medically necessary for
transgender minors.
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than their birth sex, they comprise a discrete group. This defining characteristic bears
transgender people have faced historical discrimination and have been unable to
108. The Act does nothing to protect the health or well-being of minors, or
anyone else. To the contrary, the Act undermines the health and well-being of
interest and is not substantially related to any important governmental interest. Nor
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COUNT III
Deprivation of Substantive Due Process
Parent Plaintiffs Against Defendants in Their Official Capacities
Violation of Parent Plaintiffs’ Right to Direct Their Children’s Medically
Necessary Care
U.S. Const. Amend. XIV
111. The Parent Plaintiffs bring this Count against all Defendants.
the rights of parents to make decisions “concerning the care, custody, and control of
their children.” Troxel v. Granville, 530 U.S. 57, 66, 120 S. Ct. 2054, 147 L.Ed.2d
49 (2000). That fundamental right includes the liberty to make medical decisions for
their minor children, including the right to obtain medical treatments that are
113. The Act violates this fundamental right by preventing the Parent
Plaintiffs from obtaining medically necessary care for their minor children.
from ensuring their children can receive essential medical care. The Act does not
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COUNT IV
Deprivation of Procedural Due Process
All Plaintiffs Against Defendants in Their Official Capacities
Void for Vagueness
U.S. Const. Amend. V and XIV
118. Under the Due Process Clause, a criminal statue is void for vagueness
if it either (1) fails “to provide the kind of notice that will enable ordinary people to
119. Subsection 4(a) of the Act states, in relevant part, that “no person shall
120. As written, the Act does not provide sufficient definiteness to ordinary
discriminatory enforcement against anyone who is aware of, refers, discusses, talks
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RELIEF REQUESTED
Act violates federal law for the reasons and on the Counts set forth above;
(3) declare that the Act violates the Fifth and Fourteenth Amendments to the
(4) award Plaintiffs their costs and attorneys’ fees pursuant to 42 U.S.C. §
(5) grant such other relief as the Court finds just and proper.
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202.628.4160
[email protected]
[email protected]
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