Responsible Gaming Policy

Missouri Lottery Responsible Gaming Policy 

Last Updated: May 2023

EXECUTIVE SUMMARY

Mission

As a gaming entity, the Missouri Lottery recognizes that while the vast majority of Lottery players gamble responsibly, a small number of Lottery players can experience personal, financial and social difficulties due to playing Missouri Lottery games. Therefore, it is the responsibility of the Missouri Lottery to promote responsible gaming, take part in responsible gaming activities and promote the availability of problem gambling treatment. 

Purpose

The Missouri Lottery’s Responsible Gaming Policy strives to establish a system of principles designed to guide the Missouri Lottery, its employees, retailers and vendors to make responsible decisions. These principles will ensure the Lottery’s business is conducted in ways intended to minimize harm that can be caused by gambling. 

Oversight

The Missouri Lottery’s Responsible Gaming Policy will be overseen and implemented by the Missouri Lottery’s Responsible Gaming Coordinator and Responsible Gaming Committee, while considering the feedback and interests of the Missouri Lottery’s community of stakeholders, including relevant problem gambling advocacy groups. The Responsible Gaming Policy will be reviewed and updated by the Responsible Gaming Committee on an annual basis. Revisions to the policy will also be considered on a case-by-case basis during the Committee’s quarterly meetings. 

Guiding Principles

The Missouri Lottery’s Responsible Gaming Policy is designed to support and adhere to the Lottery’s core guiding principles, which include:
-    Missouri Lottery Mission: To help fund educational opportunities for Missouri students, support Missouri businesses and entertain millions.
-    Product Mission: To offer creative games that bring fun and dreams into people’s lives.
-    Economic Mission: To responsibly maximize our revenues for Missouri public education and our retail partners.
-    Social Mission: To commit to responsible gaming practices and the integrity of all our games and products, and to enhance the quality of life for the people of Missouri by supporting education and our retail partners.  
-    Missouri Lottery Vision: The Missouri Lottery strives to be an innovative leader in the Lottery industry and a trusted and valued partner for public education.
-    Missouri Lottery Core Values: Integrity, Customer-Focused, Diversity, and Entertainment
-    Missouri Lottery Aspirational Value: Innovation

Under these principles, the Missouri Lottery recognizes that gambling of any form can be done in excess, causing adverse effects in an individual’s life. Because of this reality, the Responsible Gaming Policy aims to alleviate any unintentional harm that might be caused by the Lottery’s products while ensuring that individuals are made aware of the free problem gambling treatment available to them.
 
Furthermore, as mandated by law, the minimum age to purchase Lottery products in Missouri is 18. While the Missouri Lottery acknowledges the freedom of its customers to make their own decisions regarding legal forms of entertainment, the Missouri Lottery is committed to providing necessary information and tools aimed at helping its players make informed choices when playing and enjoying the products provided by the Missouri Lottery in a responsible manner.

The Lottery’s Responsible Gaming Policy, and larger responsible gaming program, is designed to adhere to the 10 principles outlined by the World Lottery Association.

Responsible Gaming Defined

Responsible gaming is the act of an individual making informed decisions about their participation in gambling activities in ways that align with the individual’s personal limitations while also minimizing the potential harm caused by problem gambling.

Problem Gambling Defined

Problem Gambling is a behavior disorder in which an individual has an uncontrollable urge to gamble despite psychological, physical, social, vocational and financial consequences. Similar to nicotine or alcohol addiction, problem gambling is a progressive addiction characterized by increasing preoccupations with gambling, a need to bet more money more frequently, restlessness or irritability when attempting to stop, “chasing” losses, and loss of control. 

RESPONSIBLE GAMING PROGRAM

The Missouri Lottery’s Responsible Gaming Policy will focus on aspects of the Lottery’s responsible gaming program, as outlined by the Lottery and in support of industry best practices. Those aspects include:
1.    Research
2.    Employee Program
3.    Retailer Program
4.    Game Design
5.    Remote Gaming Channels
6.    Advertising and Marketing Communications
7.    Player Education
8.    Treatment Referral
9.    Stakeholder Engagement 
10.    Reporting and Measurement

1.0    Research
In recognizing its prominence as a gaming provider in the state of Missouri and that – similar to many aspects of life – gambling can be done in excess, the Missouri Lottery strives to initiate and participate in ongoing research efforts to better its knowledge and understanding of how our products and brand can affect players and Missouri citizens.

Policy Objective: The Missouri Lottery will enhance its responsible gaming program from the insights gained by an investment into responsible gaming and problem gambling research. The Lottery will pursue these endeavors through internal and independent resources.

To achieve this objective, the Missouri Lottery will:
1.1    Devote resources to engage relevant stakeholders to measure and identify prevalence, vulnerable populations and awareness. The knowledge gained from these efforts must influence change within the Lottery’s broader responsible gaming and corporate social responsibility efforts. Applicable mechanisms to collect this information include:
1.1.1    Player loyalty program surveys;
1.1.2    Employee and retailer training results; 
1.1.3    Annual stakeholder surveys; and
1.1.4    When applicable, third-party tracking and segmentation studies.

1.2    Work with its partners in responsible gaming and problem gambling fields to identify and invest in research opportunities that provide insight into how Missouri citizens perceive the Missouri Lottery, gambling and responsible gaming. These opportunities include, but are not limited to:
1.2.1    Prevalence surveys;
1.2.2    Publicity and awareness tracking; and
1.2.3    Analysis of data from the Bets Off program.

1.3    By means of various state, regional and national events and conferences, engage public health, responsible gaming professionals, problem gambling clinicians and gaming industry experts to review evidence-based best practices that can be applied within the Missouri Lottery’s responsible gaming program.

1.4    When applicable, the Lottery will communicate the results of these endeavors to relevant stakeholders. Improvements to the Responsible Gaming program will be made based on results from research endeavors and stakeholder feedback. 

2.0    Employee Program
As a gaming provider in Missouri, the Missouri Lottery requires that its workforce to be trained on problem gambling, the free treatment available through the Bets Off program, how to promote responsible gaming, and how Missouri Lottery products can potentially cause adverse effects for some players. This training subject matter is reinforced in accordance with the Missouri Lottery’s “Employee Development Policy 2.3 Section III, Lottery Core Curriculum Training No. 4: Problem Gambling and Responsible Gaming.”

Policy Objective: The Missouri Lottery will increase its workforce’s knowledge concerning problem gambling and responsible gaming practices.

To achieve this objective, the Missouri Lottery will:
2.1    Include training modules during all new employee orientation procedures.

2.2    At any given time, but with special consideration during the two recognized awareness months, engage with its employees through a variety of formal and informal procedures to: 
2.2.1    Provide updates on the responsible gaming program;
2.2.2    Enhance appreciation for the importance of promoting responsible gaming; and
2.2.3    Develop knowledge of problem gambling.

Awareness Months:
•    Problem Gambling Awareness Month (March): National campaign, hosted by the National Council on Problem Gambling, in which affiliate gaming entities participate to increase public awareness of problem gambling and the availability of prevention, treatment, and recovery services, and to encourage health care providers to screen clients for problem gambling.
•    Responsible Gaming Education Week (August): Awareness month in which the Missouri Lottery reminds players to engage in responsible play by bringing awareness to responsible gaming practices.  

2.3    Require all employees and vendors to participate in mandatory training on an annual basis.

2.4    Develop specialized training programs designed for specific positions and functions within the Lottery.

2.5    Retain materials outlining the free help available and state benefit programs in the event an employee or a loved one develops a gambling problem and provide these materials upon request. 

2.6    Administer a responsible gaming committee comprised of an array of employees and vendors from multiple departments with a goal of providing a cross-functional approach when developing and overseeing the responsible gaming policy and program at large.

2.7    When applicable, the Lottery will communicate the results of these endeavors to relevant stakeholders and make improvements based on feedback.

3.0    Retailer Program
With more than 4,600 retail partners statewide, the Missouri Lottery acknowledges that its retailer base serves as a player-facing extension of the Missouri Lottery’s community. Due to their inherent prominence with players, the importance of the Missouri Lottery’s retail community in respect to the promotion of responsible gaming and problem gambling treatment cannot be understated. By engaging with its retail community, the Missouri Lottery aims to establish an understanding about the reality of problem gambling and knowledge of the treatment available.

Policy Objective: The Missouri Lottery will develop meaningful programs designed to inform its retail partners about problem gambling and responsible gaming practices with the intent to connect anyone with a problem to help.

To achieve this objective, the Missouri Lottery will:
3.1    During new retailer orientation, provide retailers with pertinent information as it relates to responsible gaming, such as age verification, the free treatment available through the Bets Off program and self-service vending machine remote shut off procedures.

3.2    Oversee the implementation of the “Do The Right Thing” retailer integrity and responsibility program on a semiannual basis and during the new retailer orientation process. In recognizing a high employment turnover at many retail locations, the Lottery is committed to provide resources to all retail employment levels when possible. Areas of interest within the program as they relate to responsible gaming include:
3.2.1    Providing player access to treatment information for problem gambling;
3.2.2    Ensuring that electronic display monitors with responsible gaming and problem gambling information are visible within the rotation of screens to customers; and
3.2.3    Practicing age verification when selling products. 

3.3    Update its retail partners with timely responsible gaming program and problem gambling awareness information via visits with Lottery sales representatives, Lottery security audits, annual tradeshow events, regular Retailer Advisory Committee meetings, retail-specific publications and websites.

3.4    Administer retailer-focused responsible gaming surveys and training sessions when and where appropriate, including annual tradeshow events, regular Retailer Advisory Committee meetings and through the Retailer Portal.

3.5    When possible, incorporate responsible gaming material into new and existing training initiatives.

3.6    Accompany new products, promotions and equipment with materials designed to inform retail partners of associated chances of winning, applicable rules, how-to-play material and responsible gaming information.

3.7    When applicable, the Lottery will communicate these endeavors to relevant stakeholders and make improvements based on feedback.

4.0    Game Design
With each new game that is introduced, the Missouri Lottery is dedicated to ensuring that each product remains responsible in design. Each new product and supporting material will also promote playing responsibly.

Policy Objective: The Missouri Lottery will design its products and work with associated vendors to ensure that the products offered by the Lottery are fair and responsible while maximizing public education contributions, player prizes and retailer benefits.

To achieve this objective, the Missouri Lottery will:

4.1    Only offer products that adhere to the principles outlined in the internal assessment. This internal assessment will evaluate each product on the following standards:
4.1.1    Responsible Gaming:
4.1.1.1    Will this product encourage people to play beyond their means or imply that the chance of winning increases the longer one plays?
4.1.1.2    Will this product depict a pre-occupation with gambling?
4.1.1.3    Will this product imply certainty of financial reward or alleviation of personal and/or financial difficulties?
4.1.1.4    Will this product present gambling as an alternative to employment, hard work or as a financial investment?
4.1.1.5    Will this product encourage play as a means of recovering past gambling or other financial losses?
4.1.1.6    Will this product suggest that skill can influence the outcome or does the method of play involve an element of skill?
4.1.1.7    Will this product support gambling or luck myths (strategies, hot/cold streaks, due for a win)?
4.1.1.8    Will this product use words that could be associated with an impulse problem (“rush,” “obsess,” “fixate,” “passion”)?
4.1.2    Protection of Minors Under 18:
4.1.2.1    Will this product entice play by minors or negatively impact them?
4.1.2.2    Will this product appear in/on:
4.1.2.2.1    Media directed primarily to minors?
4.1.2.2.2    Venues where most of the audience is minors?
4.1.2.2.3    Media programming where the primary audience is minors?
4.1.2.3    Will this product contain cartoon figures, symbols, role models and/or others whose primary appeal could be expected to be minors?
4.1.2.4    Will this product use minors to promote gambling?
4.1.3    Advertising Standards:
4.1.3.1    Does this align with the Missouri Lottery’s advertising guidelines?
4.1.4    Social Implications:
4.1.4.1    Does this product depict any individual group insensitively?
4.1.4.2    Could the images/language/design potentially reflect poorly on the Missouri Lottery?

4.2    Include play responsibly messaging and Bets Off information on all products offered by the Missouri Lottery, including Scratchers tickets, Draw Games tickets and playslips. The same information will be featured on all game-specific how-to-play resources, as well as print and digital point-of-sale materials, when applicable.

4.3    Provide statistical information, including prize structure, chances of winning, prizes paid and remaining prizes where appropriate: on Scratchers games, Draw Games tickets, Draw Games playslips, point-of-sale materials, and on the Lottery’s website.  

4.4    When applicable, the Lottery will notify relevant stakeholders on any updates or results pertaining to product oversight in terms of responsibility. Improvements will be made based on feedback. 

5.0    Remote Gaming Channels
As trends and technologies advance in the lottery industry, so too do the types of products that the Missouri Lottery can offer its players. While the Lottery does not currently provide products outside of the traditional Scratchers, Draw Games and Pull-Tabs, the Lottery believes that the potential introduction of new types of products must be preceded by efforts focused on understanding their impact, as well engagement with the General Assembly/bill drafters to ensure responsible gaming considerations are incorporated into proposed legislation.

Policy objective:  In the event that new types of products are placed under its jurisdiction, the Missouri Lottery will pursue research and contractual initiatives designed to inform and protect the integrity of the institution. 

As such situations are presented, the Missouri Lottery will pursue the following initiatives to achieve this objective:
5.1    Conduct impact studies designed to measure public perception and feedback.

5.2    Engage with other lottery jurisdictions that offer similar products to foster a system of learning and best practices.

5.3    Collaborate with vendors to ensure that responsible gaming considerations are being incorporated into contractual agreements.

5.4    Provide relevant training to Lottery employees and retailers about new product lines and boost awareness of potential negative implications, including problem gambling. 

6.0    Advertising and Marketing Communications
The Missouri Lottery strives to be creative and responsible in the development of its advertising program. Missourians have the right to expect Lottery-related advertising and marketing to be truthful, respectful and sensitive to the potential for harm that could result from excessive spending on Lottery or other forms of gaming. These efforts will not specifically market to vulnerable sections of the population, including to anyone under the age of 18. 

Policy Objective: The Missouri Lottery will comply with Missouri Lottery policies, federal and state law to accurately and responsibly represent its brand, products and beneficiary through mass advertising. 

To achieve this objective, the Missouri Lottery will:
6.1    Follow strict advertising guidelines designed to guarantee that each advertisement remains responsible. All advertisements must meet the following standards in accordance with the Missouri Lottery’s Advertising Guidelines:
6.1.1    Honesty/Fairness: Advertising and marketing materials and campaigns must be honest, fair and open. They must:
6.1.1.1    Provide factual information that is not deceptive and contains no false statements related to the product or promotion being advertised.
6.1.1.2    Include important and relevant information about the product or promotion that may be essential for the public to make informed choices.
6.1.1.3    Describe the prizes accurately.
6.1.1.4    Provide information that is supported by facts.
6.1.1.5    When appropriate, provide information concerning Lottery proceeds supporting public education.
6.1.2    Responsible Gaming: Product advertising and marketing materials will include a responsible play message. Regarding responsible gaming, advertising and marketing campaigns must not:
6.1.2.1    Imply exaggerated chances of winning.
6.1.2.2    Encourage gaming beyond one’s means.
6.1.2.3    Explicitly imply that financial rewards are a likely outcome of playing the Lottery.
6.1.2.4    Portray playing the Lottery as an alternative to employment, hard work or as a financial investment.
6.1.2.5    Suggest that playing longer will increase the chances of winning. 
6.1.2.6    Suggest that skill can influence the outcome of purely random games of chance. 
6.1.2.7    Suggest that using playing systems or “lucky” icons can influence the outcome of a game.
6.1.2.8    Focus unduly on the possibility of benefits accrued to players based on the volume of their play. 
6.1.3    Protection of Minors: Advertising of Lottery products and promotions must never be targeted towards those under 18 and, therefore, must not:
6.1.3.1    Appear in any media where the primary target audience is under 18.
6.1.3.2    Appear at venues where the primary audience is under 18.
6.1.3.3    Be based on themes or use language intended to appeal to those under 18.
6.1.3.4    Appear anywhere where the primary audience is expected to be under 18.
6.1.3.5    Contain child-focused cartoon figures or use of celebrity endorsements whose primary appeal is to those under 18.
6.1.3.6    Where reasonable, Lottery advertising, point-of-sale and marketing materials should carry a message regarding the minimum legal age of play (18).
6.1.4    General Guidelines: Missouri Lottery advertising must be consistent with the dignity of the state and its residents.
6.1.4.1    It must not specifically target, demean, disrespect, denigrate or exploit a person, specific group or economic class. 
6.1.4.2    It will not contain themes or language that are deemed unsuitable for a mass media audience.
6.1.4.3    It will not disparage nor denigrate a person who chooses not to play.
6.1.4.4    It will not promote the Lottery as a way to enhance social standing.
6.1.4.5    It will not glamorize inappropriate or irresponsible play.
6.1.4.6    It should emphasize the fun and entertainment aspect of playing the Lottery, but it should not focus on winning as a probable outcome of play.
 
6.2    For exceptionally large Draw Games jackpot runs, if advertising funds are available, the Missouri Lottery will:
6.2.1    Begin paid advertising for jackpots starting at $300 million, which will already include the Play Responsibly logo and a play responsibly message on radio copy, per policy number 6.1.2 of this policy;
6.2.2    Include a play responsibly message on all news media communications for jackpots of more than $300 million; 
6.2.3    End all paid jackpot advertising for jackpots of more than $450 million; and
6.2.4    Limit social media content focus to player education, player protection and/or notification of a jackpot increase for jackpots of more than $500 million. Jackpot-related news releases will be limited in focus to jackpot increases and will carry a play responsibly message. 
 
6.3    Provide all responsible play communications materials for the Missouri Alliance to Curb Problem Gambling, including:
6.3.1    TV and Radio Public service announcements (PSAs) to air, at a minimum, twice yearly during the two recognized awareness months
6.3.2    Billboards
6.3.3    Brochures, posters and other print materials
6.3.4    Any digital advertisements that may apply.

6.4    When applicable, the Lottery will update relevant stakeholders with timely information pertaining to its responsible advertising and responsible play communication efforts. Improvements to the program will be made based on feedback. 

7.0    Player Education
As an integral stakeholder to the Lottery’s success, the Missouri Lottery is committed to using its own resources to provide players with relevant information that supports playing its products responsibly, as well as promoting the availability of free help. By extension, these efforts should also aim to inform the general public about these issues. 

Policy Objective: The Missouri Lottery will advance the awareness of problem gambling, responsible play, and accessibility of free help among its player base and the general public. 

To achieve this objective, the Missouri Lottery will:
7.1    Create and sustain informative awareness campaigns disseminated through a variety of player- and public-facing communication methods, to include video, audio, social, digital, and print components.

7.2    Include responsible play messaging in prominent social media activity, including paid posts. 

7.3    Feature play responsibly messaging and Bets Off information on all player-facing Missouri Lottery-issued equipment at all retail locations, products, and consumables. This is to include play centers, self-service vending machines, electronic display monitors, Scratchers tickets, Draw Games playslips and tickets.

7.4    Incorporate one-time spending limits on all self-service vending machines. The current spending limit is $250.

7.5    Host relevant information on its website supporting responsible gaming practices and featuring information concerning the Bets Off program.

7.6    Validate the age of each new My Lottery® Player’s Club loyalty program member by requiring scanning of driver’s license or the last four digits of the member’s Social Security number and enforcing a limit on how many loyalty points can be earned each month.

7.7    Age-verify all promotional winners outside of the player loyalty program, such as on-site events and social media promotion winners. 

7.8    When applicable, the Lottery will update relevant stakeholders with timely information pertaining to player education and public education efforts. Program improvements will be made based on feedback. 

8.0    Treatment Referral
The Missouri Lottery believes that partnerships with applicable experts and organizations serve as hallmarks of a well-rounded program focused on reducing harm and promoting treatment. By bringing various independent, government, industry and healthcare entities together, the Missouri Lottery and its partners can more effectively address problem gambling within the state of Missouri, the Midwest region and the United States. 

Policy Objective: The Missouri Lottery will foster and sustain relationships with relevant organizations to further advance the awareness of problem gambling, promote responsible play and maintain the availability of free treatment in Missouri.

To achieve this objective, the Missouri Lottery will:
8.1    Offer players the option to prohibit themselves from accessing the Missouri Lottery’s player loyalty program, receiving email and text alerts, and from claiming prizes of more than $600 through the Self-Exclusion Program (SEP).

8.2    Devote expertise and relevant resources towards a variety of advocacy groups focused on problem gambling and responsible gaming, including:
8.2.1    Missouri Alliance to Curb Problem Gambling (Missouri Alliance): The Missouri Lottery shall maintain all marketing, advertising, branding and publicity aspects of the Bets Off program. These efforts include all radio, television, digital, print and billboard advertisements, as well as all website, media relations, publications, trade show exhibition, video production and graphic design elements. The Missouri Lottery will also make every effort to work with the Missouri Alliance and its partners to ensure the continued availability of free treatment through the Bets Off program.
8.2.2    Midwest Consortium on Problem Gambling and Substance Abuse (MCPGSA): The Missouri Lottery shall assist in carrying out the primary mission of the Consortium in providing an annual Midwest Conference on Problem Gambling and Substance Abuse for the Consortium’s five-state region. These efforts include the Missouri Lottery’s RG Coordinator participating in the planning committee and other ad hoc support.
8.2.3    North American Association of State and Provincial Lotteries (NASPL) Responsible Gaming Committee: The Missouri Lottery shall maintain a contributing member status of the Committee, which aims to strengthen the responsible gaming programs for lottery organizations across North America. 
8.2.4    National Council on Problem Gambling (NCPG): The Missouri Lottery participates in the annual holiday campaign discouraging Lottery tickets as gifts to minors, as well as maintaining membership with the NCPG and sponsorship of the NCPG’s annual National Conference on Problem Gambling.

8.3    When applicable, the Lottery will update relevant stakeholders with timely information pertaining to treatment availability efforts. Program improvements will be made based on feedback. 

9.0    Stakeholder Engagement 
As stewards of the state of Missouri, the Lottery must consider the feedback, interests and insights of the community of individual groups that have a vested interest in the Missouri Lottery, its successes and its shortcomings. Therefore, the Missouri Lottery has integrated its relationships with these groups within the framework used to develop the strategies, goals and policies which seek to guide the organization. 

The Lottery recognizes the following groups as the primary stakeholders in its responsible gaming program:
 
-    Missouri Lottery players
-    Missouri Lottery employees
-    Missouri Lottery retailers
-    Missouri Lottery vendors
-    Missouri government
-    The general public of Missouri 
-    Lottery industry peers
-    Missouri Alliance to Curb Problem Gambling and other relevant advocacy groups 

By engaging in constant communication, engagement and learning initiatives, the Lottery integrates its stakeholders into the development of its responsible gaming program. In an effort to ensure blanket coverage of all stakeholder groups and each aspect of the Missouri Lottery’s responsible gaming program, each stakeholder group is represented in each section of the Responsible Gaming Policy.

Policy Objective:  The Missouri Lottery will engage with each of its stakeholder groups by fostering avenues of constant communication instilling opportunities for feedback to make meaningful changes to the responsible gaming program. 

To achieve this objective, the Missouri Lottery will:
9.1    Integrate stakeholder engagement efforts within each portion of the Missouri Lottery’s responsible gaming program. 

9.2    Consider stakeholder feedback when making program enhancements.

9.3    Provide timely updates to relevant stakeholder groups on the initiatives that impact them and their relationship with the Missouri Lottery

9.4    When possible, educate stakeholders about responsible gaming, problem gambling and related topics through both formal and informal mechanisms. 

10.0    Reporting and Measurement 
Using its relationships with stakeholders and the feedback sought from these groups, the Missouri Lottery aims to sustain its responsible gaming program by way of regular systematic updates. As a government entity for the state of Missouri, the Missouri Lottery is dedicated to being transparent with its stakeholders about its corporate social responsibility program. 

To ensure consistent growth, the Missouri Lottery participates in activities designed to provide continuous learning, improvement, reporting and evaluation. With this method, the Missouri Lottery’s responsible gaming program operates on a cyclical system focused on sustainability and growth. 

Policy Objectives:  Pursue continued growth of the responsible gaming program through the creation of an annual action plan. Provide all stakeholders with an annual report outlining the results of all major corporate social responsibility measures while using feedback and results to foster continued growth. 

To achieve these objectives, the Missouri Lottery will:

10.1    Compile an annual responsible gaming action plan comprised of initiatives designed to improve each area of the Lottery’s responsible gaming program. Feedback from stakeholders and industry advancements will heavily influence the plan. 

10.2    Retain results of all responsible gaming measurements within each area of the Lottery’s responsible gaming program.

10.3    Catalog these results and publish them in an annual report to all Missouri Lottery stakeholders.

10.4    Use stakeholder feedback and annual report contents to identify strengths and gaps in the overall program. These revelations should be considered for the next action plan.    
 

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