YouTube channel owners: Is your content directed to children?

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Under COPPA, how do I know if my channel is “directed to children”? Since the FTC and New York Attorney General announced their September 2019 settlement with YouTube for violations of the Children’s Online Privacy Protection Act Rule, we’ve heard that question from channel owners – sometimes called content creators. If you’re a channel owner who shares content on user-generated platforms like YouTube, read on for FTC staff guidance about the applicability of the COPPA Rule and how those covered by the Rule can comply with its requirements.

The FTC action against YouTube and Google

The lawsuit against YouTube and Google alleged that the companies illegally collected personal information from children, in violation of COPPA. According to the complaint, the companies collected that information from viewers of child-directed YouTube channels in the form of persistent identifiers that track users across the Internet, but didn’t notify parents and get their consent. To settle the case, YouTube and Google agreed to create a mechanism so that channel owners can designate when the videos they upload to YouTube are – to use the words of COPPA – “directed to children.” The purpose of this requirement is to make sure that both YouTube and channel owners are complying with the law.

A COPPA recap

That provision of the settlement has raised questions among content creators about how to determine if what they upload to YouTube or other platforms is “directed to children.” The answer requires a brief summary of some key COPPA provisions. Passed by Congress in 1998, the Children’s Online Privacy Protection Act is a federal law that protects the privacy of children under 13. COPPA’s foundational principle is one that most people can agree on: Parents – not kids, companies, platforms, or content creators – should be in control when it comes to information collected from children online.

The FTC enforces the law through the COPPA Rule. In general, COPPA requires operators of commercial websites and online services that are directed to children (more about that in a minute) to provide notice and obtain verifiable parental consent before they collect personal information from kids under 13.

The COPPA Rule defines “personal information” to include obvious things like a child’s first and last name or home address, but that’s not all. Under COPPA, personal information also covers what are called persistent identifiers – behind-the-scenes code that recognizes a user over time and across different sites or online services. That could be an IP address or a cookie when it’s used to serve targeted ads. Keep in mind that an operator also might be collecting personal information through an open comment field on its site or service that allows a user under 13 to make personal information publicly available. For example, think of a comment like this on a child-directed site: My name is Mary Jones from Springfield. I love this video!

How COPPA applies to channel owners

So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. If a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is directed to children and if the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads), the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements. For information on how to comply with COPPA, please visit the FTC’s COPPA page for our Six-Step Compliance Plan for Your Business.

How channel owners can determine if their content is directed to children

Under COPPA, there is no one-size-fits-all answer about what makes a site directed to children, but we can offer some guidance. To be clear, your content isn’t considered “directed to children” just because some children may see it. However, if your intended audience is kids under 13, you’re covered by COPPA and have to honor the Rule’s requirements.

The Rule sets out additional factors the FTC will consider in determining whether your content is child-directed:

  • the subject matter,
  • visual content,
  • the use of animated characters or child-oriented activities and incentives,
  • the kind of music or other audio content,
  • the age of models,
  • the presence of child celebrities or celebrities who appeal to children,
  • language or other characteristics of the site,
  • whether advertising that promotes or appears on the site is directed to children, and
  • competent and reliable empirical evidence about the age of the audience.

The determination of whether content is child-directed will be clearer in some contexts than in others, but we can share some general rules of thumb. First, unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. For example, if your videos are about traditionally adult activities like employment, finances, politics, home ownership, home improvement, or travel, you’re probably not covered unless your content is geared toward kids. The same would be true for videos aimed at high school or college students. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone.

Third, the complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Want to see the FTC’s analysis in context? Read pages 10-14 of the YouTube complaint.

Finally, if you’ve applied the factors listed in the COPPA Rule and still wonder if your content is “directed to children,” it might help to consider how others view your content and content similar to yours. Has your channel been reviewed on sites that evaluate content for kids? Is your channel – or channels like yours – mentioned in blogs for parents of young children or in media articles about child-directed content? Have you surveyed your users or is there other empirical evidence about the age of your audience?

What are the possible penalties for violating COPPA?

The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business. While Google and YouTube paid $170 million, in another COPPA case settled this year, the operator paid a total civil penalty of $35,000.

Isn’t the FTC taking another look at the COPPA Rule?

Yes, the FTC is currently evaluating the Rule in light of rapid changes in technology. If you would like to comment on the effectiveness of the COPPA Rule and whether changes are needed, the FTC has extended the comment deadline to December 9, 2019.

Where can channel owners go for more information?

A look at the factors in the COPPA Rule will help most channel owners determine if their content is directed to children. If you’re still unsure about how COPPA applies to you, consider contacting an attorney or consulting with one of the COPPA Safe Harbor programs – self-regulatory groups that offer guidance on how operators can comply with the law. Visit the FTC’s website for a list of currently approved Safe Harbor organizations. For more resources, visit the FTC’s Children’s Privacy page for our Six-Step Compliance Plan for Your Business.

 
 
 

Comments

This has gone way too far. My apologies, but this idea is probably one of the worst ideas I have heard of so far. A lot of people who gain money from making youtube videos are going to be affected. A lot of lives are going to be ruined. Eventually YouTube is going to start losing a lot of users. Most of the kids on YouTube don't watch kid-friendly things. Instead, they actually watch whatever they want. It's not YouTube's fault for this. Parents are at fault. Parents are the one who allow their kids to do whatever they want on YouTube. I hope you make some changes and don't go too crazy on this. This is just going to repeat itself on other video-sharing websites. Have a wonderful day (if you're reading this)

Thank you SO much for this. Though it still seems a little broad, it still put me at ease.

So many people were freaking out about this because MANY YouTuber I watch direct their content to everyone. However, would this include those who play videogames that could be made for kids? I know plenty of people who play games like Minecraft that cuss A L O T in their videos.

But thanks again! YouTube gave us all little explanations to what was made for kids and what was not. But please make this better understandable for those who don't understand!!

This is an unenforceable litigious nightmare that really only benefits Disney. The FTC can't seem to put a dent in the billions of monthly robocalls we collectively receive, but they apparently have no problem swiftly destroying the livelihood of thousands of content creators. Bravo.

Since the definition of child attractive it's so broad, I think that before people are fined, they should get a warning and maybe about 30 to 60 days to come into compliance of the COPPA law.
There are several content creators that have characters that children can like and action figures/toys in their videos but they are not targeting children under 13. But the videos are still for a general audience because YouTube wants us to make our videos family friendly and not have a bunch of violence and cursing. Or because these people have family who watch them and they don't want to be disrespectful.
A lot of people aren't intentionally breaking the law so a warning would be awesome. Some of my friends who are grown adults who has been sharing their geek (Nerd, pop culture) life with the world and have over 3,000 videos. When I found those videos I never for once thought that only kids under 13 year old would be watching them.

How about just stop the data mining all together so that we can stop being marketing targets. That would resolve this whole thing. I don't think this covers the crafting community where things are made for kids by adults, so making toys and dolls, where does that fall?? Teaching a craft, where does that fall?? Specifics please.

Because if they stop the data mining altogether neither creators nor YouTube will make enough money to stay in business. So either you pay for the service or get it for free in exchange for your data being collected.

I think that my content is made for kids cause I’m funny and I don’t cuss and if the song I’m using cusses I blurt it out or I just don’t make my avatar say it

I want to know if you are clear that Japanese anime is not childish content at all, and don't confuse it

Unfortunately the wording is too ambiguous. For example my 10 year old nephew watches painting videos not aimed at children but interesting to children ... he enjoys them and has improved his painting skills dramatically! There are many crafting and hobby channels on YouTube that are interesting to children but not aimed at them eg. Crafting (patchwork, scrapbooking, painting etc.) some children may like to watch but which do involve needles, varnish etc. Also game playing or collectibles. There should be an option like 'Mixed audience/parental advisory'. Surely parents have to take some responsibility for their under 13 year old children. If this goes ahead in it's present form You Tube will have no family friendly content and will become a cesspool of extreme 'adult' content!

Please don't let this go through, it has so many flaws. It will only hurt everyone.

Coppa is way too strict and vague it needs to be repealed or updated immediately

youtube is the best of life for enjoy

The description of what is considered child content is too vague. For example I crate videos which feature model trains and not toy trains. Manufacturers of model trains such as Lionel have recommended ages of 14 & up printed on the boxes. If I go by this then my videos are not targets at kids which is 13 and under. However does the FTC define a difference between a toy and a model or even a difference between a chillds toy and adult collectible. I ran the lifetime statics on my YouTube channel and no one under 18 has viewed it. Also why disable comments on YouTube. I have mine set to approve so I screen every comment to make sure it is appropriate to show up. Why can't YouTube put a age barrier program in place so ads and data won't be retrieved by any viewers who are 13 and under? Basically the way YouTube has changed the rules the channels marked made for kids content won't be promoted, will have comments disabled and notifications removed. This has ended pretty much any channel that depends on YouTube for money or promoting a hobby.

There are tons of bright animation that include swearing and blood. Plenty of youtubers who play bright and happy games who swear and target people over 15+ so what happens to them?

Why is it that everyone seems to be ignoring the giant pink elephant in the room? There is a VERY simple solution to this issue that the FTC could enact that would protect not only those defined as "kids" under the law, but would also protect the content creators and the platforms they use as well.

It falls to basic coding in the form of the "IF/THEN" and "AND/OR" lines of code. These platforms can require that to view content one must be signed in via an email address that has been verified. Most email groups, such as Google and Yahoo already require date of birth to be given when creating a new e-address. It is then a simple task for a competent coder who knows current internet protocol language to create a line or 2 of code to go something like: "IF" the email address of the viewer is less than 13 years "THEN" any cookies (or other forms of data collection) is blocked from reaching them. "AND" when said address reaches 13 years, "OR" a parental/guardian of the user of said e-address consents to them data collection it may then be allowed.

Seriously people. This has been the obvious solution from the start. Why has nobody implemented it thus far?

Thank you for allowing the public to voice their thoughts on this issue because right now this law looked like it was going to eradicate a lot of YouTubers which isn't fair. But there are still unanswered questions. For example, gaming as you said is not a one size fits all group. So will it come down to the game itself or the context in which the game is being played and spoken about? As a gamer myself, I'm very worried about this and I'm sure you are just as worried as I am.

I'm also glad you cleared up about animated shows not being just for kids as there are some animated shows like South Park, Family Guy, The Simpsons, etc. that are primarily for teens and adults. But what about shows that are somewhat in the middle? These shows appeal to kids yet they can have stuff in it that may not be for kids at all. Two examples of this are Teen Titans (not Teen Titans Go!) and Ninjago: Masters of Spinjitzu. These two shows do appeal to kids but may appeal to older audiences also. I hope you can clarify a bit more about this and hopefully come to a reasonable conclusion that doesn't destroy YouTube as a whole.

Thank you and have a great day.

I am still worried about channels that review, theorize, or parody about children shows or movies, like Pokemon for example. They shouldn't be punished just for using topic popular with children. Context is very important here and that's something robots on Youtube wont be able to analyze.

I feel that the onus for advertising and management of access should not be on content creators on a shared platform. Especially one such as YouTube that has In the past inserted advertising into videos that were never intended to have any due to their mistaken belief the content had a claim by a third party.
With such automated systems already mucking up creators abilities to control advertising and access to their own videos it should be the host site's responsibility to restrict access to above 13, as the original law intended instead of punishing creators who create videos that may unintentionally draw draw In 12 year olds who share interests with 15 year olds.

Proof of age could and should be more strict if this is a serious issue.

i am comply here all riles & regulation under India governments

The rules are to vauge. Anything you do could be classified as family friendly even if you are doing not family friendly things. This will absolutely ruin YouTube and spme of the stock market. Please ether make your own type of youtube and make clear and direct rules or fix coppa

My videos are made for everyone it's so confusing I don't know.

I really don’t know either, I posted a really short video about my birds, I was confused so I labeled it as ‘for kids’ as I don’t wanna get sued.

To whom it may concern,

It is my opinion that the burden of COPPA should fall on the shoulders of the advertisers. It should not be on the content creators nor Youtube. For a start, content creators have no input in what advertisers have access to their content. That is between advertisers and Youtube itself.

The second problem with the existing law and its outdated language. It passed before anyone had an inkling of what the internet could or would would become. The Federal Radio Commission, over time, became the FTC. Likewise, the laws governing radios and phones adapted over the course of a century. Now we must look to the current landscape and have COPPA adapt.

Furthermore, children very are curious by nature. If left unsupervised, they will access all manners of subjects on the internet. The duty of protecting children from questionable content is 100% the parent's responsibility. But its not FTC's place to control parents. So regulation should fall to the companies that advertise to children instead.

That said, should companies be trying to gather information on children? No. But should companies be trying to advertise to children in the first place? Of course not. A commercial advertisement serves to sell a good or service. The last time I looked, grade school children generally have zero income. Children cannot enter a legal contract or be responsible for their actions. So why advertise to them?

Companies should not be advertising - targeted or otherwise, to children under the age of 13. These children are not an economic demographic. A company should not attempt to engage in commerce with a 5th grader. As long companies can market their wares at children, there will be motive to do so. And they will on any platform that will have them.

In 1990, The Children’s Television Act passed. It meant to provide more educational programming while limiting advertising. Now, children's programming shouldn't 100% education, children deserve entertainment as well. But the law shouldn't have limited children's advertising. It should have eliminated it.

A Youtube video can have bright colors, fun characters and catchy songs. An advertisement for a product; toys, clothes, games, food, even vitamins, should not.

In closing, I ask you to consider who is behind the tracking and identifying child viewership. It's the advertisers.

P. Sandoval

Pierre, The Federal Trade Commission (FTC) was created in 1914, when President Woodrow Wilson signed the signed the Federal Trade Commission Act into law.

The Federal Radio Commission regulated radio communiction from 1927 - 1934. The Federal Communications Commission (FCC) was formed in 1934.

Can You Please Save My Youtube Channel? I Really Don’t Wanna Get Sued!

I do not like this new law in YouTube. Please reconsider that law!

So i don't think people should get fined,

This is insane you are giving very broad definitions that are insane for instance pewdiepie is Not for keep kids but kids watch or any gaming content

 youtube seems stupid to erase the option to comment my 9-year-old brother comments and does not comment I sell my address is such that he does not comment good video seems good to me the coppa law but that they remove community and commentary stories is a fool of them

This new rule doesn’t make much sense. It is also gonna ruin a lot of people’s careers too

Where do I click if my channel if it is for see for kids.

How are you going to enforce this on creators in countries outside the USA? Your legal writ only extends to the US.

Foreign-based websites and online services must comply with COPPA if they are directed to children in the United States, or if they knowingly collect personal information from children in the U.S. The law’s definition of “operator” includes foreign-based websites and online services that are involved in commerce in the United States or its territories.

U.S.-based sites and services that collect information from foreign children also are subject to COPPA. See COPPA FAQS B.7. https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions

The FTC clearly hasnt taken into account that a lot of teen-to-adult focused channels use many forms of modern media as part of their videos. I follow a channel directed towards players of a particular video game that only recently became widely known, yet they use imagery and music on occasion from "children's shows" such as Pokemon, Spongebob Squarepants, and others.

This COPPA act, while on paper, sounds like a method of protecting children, is badly designed, when you consider that 12 year olds can hear the name "PewDiePie" and know exactly who someone is talking about, even though that particular content creator is focused more towards adults. There is no well defined line between what properly counts as "child oriented" when it comes to some media such as video games like Minecraft, or television shows like Spongebob. For games like Minecraft, are more geared towards adults, due to its content being largely cartoonish animated violence (when applicable) and generally child-friendly; many older adults who still hold the mindset that videogames are "for children" will not be of sound enough or educated enough mind to acknowledge that while under 13s can play and enjoy a game such as that without being exposed to "harmful subjects", the game was not meant, for them.

And television shows like Spongebob, while childishly animated and very kid-friendly, have a large variety of adult oriented topics and subtle references and jokes - the same as many "children's" cartoons since the animated image became an American pastime - and get used by adult content creators to connect with their similarly adult, or older teen, audiences.

This COPPA act requires an extensive review by some of the larger, and a few of the lesser known, content creators on sites like Twitch.tv, YouTube.com and others, as there are glaring holes in its wording and alleged stipulations, that can be all to easily abused by someone who simply decides they do not like the idea of a 30 year old woman playing video games and earning money from it.

As this act was created as an attempt to "protect the children" something that must be noted is that the Entertainment Software Ratings Board (Hereby called the ESRB) was created to determine the suitability of video games for younger generations. All games released in America, have an ESRB rating from E (for Everyone) and M (For Mature). However, many modern parents do not pay attention to the ESRB rating, thus allowing the very children this act is allegedly designed to protect, to experience the same sorts of content that would be experienced on non-child-focused websites.

Not to mention, current video websites like YouTube, use what is called a "bot" to track and monitor users clicks to various videos, and change both recommendations for videos, as well as advertisements, based on these actions. This system, can very well lead a child to see an ad for a violent, otherwise M-Rated game, or lead them to a channel designed and intended for adults, filled with "foul language" and "harmful imagery", even though neither the content creator themselves, nor the child, intended for said child to witness it. Under this COPPA act, the FTC would then be holding the content creator responsible for this incident, even if they followed all the required directives to "flag" (or designate) their channel as "not intended for children".

Therefore, due to this glaring oversight in the creation of this act, that one potential incident holds a high chance of becoming a needless and fierce legal battle, because of how vague and improperly defined the boundaries of this act are.

Therefore, as both a consumer and a content creator myself, I call upon everyone involved, to review this COPPA act, and actually enlist the experience of multiple content creators, to better revise the parameters of what can count as "child oriented". Because the world is not so blatantly black and white, and many things that older people, including lawmakers, would consider "for children", are actually designed for adults, that happen to like very similar imagery. Which is, needless to say, a far larger group of people than these "lawmakers".

Please don't do this.

Please stop it. Your making a lot of people on YouTube Upset at you.

DON'T YOU DARE RUIN YT FOR US AND CHANNEL CREATORS

I'm still not sure if COPPA will cover my YouTube channel. I know that I make drawings and animations with characters but sometimes I draw them in different ways that feature more skin than clothes or hurt in a certain way.

Is my YouTube channel going to be covered?

ftc my favorite series my little pony is not for younger children either and for all ages i am 18 years old and watching and also the creator herself said that for all ages ok and yes i am a brony

please we cant have this because if we do then its going to probably have a big affect on youtube :(

These rules are clearly written by people who do not understand the internet and Youtube. They are short sighted and poorly defined. Please engage actual experts rather than guessing and hoping. No matter your intention, you are in essentially killing the career of a significant number of Youtube content creators.
Again, please, please, please engage actual experts rather than trying to guess and hope for the best.

I think you should put the blame on youtube and not on the youtubers

Dear FTC, I watch a multitude of different channels that cover a broad audience. Just because a Chanel has something that appeals to kids doesn’t mean it’s just a kids things. I’m 15 and I like to watch therioes on Minecraft or Five Nights at Freddie’s and you should fine content creators that cover those subjects because they are a broad topic that anyone can like. Like doll repaint videos, squishes being repainted, slime videos, therioes on beloved games like I said before Minecraft. Or anime because anyone can like anime. It doesn’t matter wether or not you’re a kid or an adult those are both things that anyone can enjoy. So it’s unfair to everyone covering those topics because it is such a broad subject. Or people making family vlogs. You shouldn’t do that it’s just unfair to both the audience and the creators. So please, to all those at your work who don’t have a phone or if you do have a phone reconsidered what you are doing because YouTube is a broad platform that anyone can find what they like. Sure a bunch of kids are on it, but what wide range platform doesn’t? To give penalties to people who are doing what they love and are some/most times depend on YouTube for giving them their paycheck since it’s the only thing they have for a job or can make to support themselves. It’s likes saying, “Hey you aren’t doing you’re job as I want you because it cover a wide range of topics. I’m giving you an 80-90% deduction on you’re paycheck ever time you don’t do as I say.” Because that just isn’t fair. I know you are trying to do the right thing. But this isn’t the way for doing it because A) We don’t have a smart enough AI to sort out what is and isn’t for kids or is a broad subject that anyone can enjoy and B) Don’t have both the time or people to check over Every. Single. Video. That. A. Person. Makes.
So please for the love of everything holy and unholy. DONT FINE CREATORS FOR NOT BEINGING ABLE TO DECIDE WETHER OR NOT THEY ARE MAKING VIDEOS TARGETED FOR KIDS BECAUSE THEY MAKE SUCH BROAD CONTENT!!! Also isn’t it excessive to fine them $42,000!?! Seriously an average person isn’t able to make that kind of money in under a month!! It could literally put people into poverty. You are basically dictating whether or not a person has a job to support either them or their family. You are basically fining nearly (for what I understand) nearly 70-90% of YouTube creators. I could be wrong but a majority of YouTubers do appeal to a wide audience. So for the love of everything holy and unholy, please. Give people more time and rethink what can both benefit/help you, YouTube, Content Creators/YouTuber, and the audience that is on YouTube. Thank you and for the love of God/Gods watch GameTherioes video on this to grasp the ACTUALLY SCALE OF WHAT YOU ARE DOING!!!!!!!

I think the new rule is unfair. The children going on youtube have there parents permission or maybe the parents should just pay more attention to there kids. The new rule will ruin many channels,lives, and the whole website. games like minecraft that might appeal to children will be taken down which is unfair. Story time animators will be gone to because they might mention a toy. Just because your guidelines are so tight it does not mean we should suffer and have are favorite channels taken away. Now the only stuff we could watch are math problems being solved because of these silly rules. Now stuff cant be two edgy and no way in heck can it be family friendly. These rules ruin youtube for everyone who is over thirteen and likes gaming or animation channels. I think this rule should be changed.

FTC: "Hello FTC, I'm a big youtuber's fan and some rulles about new Youtube politics can be prejudice some creators about pop culture... Like when they need to talk about
famous characters or cartoons... Not every content is destined for kids... Could you change this us?"

My son is 16 and autistic. He is in bits over this change. Utube is his gateway to socialisation ......his only way of comfortably communicating. He is devastated that many of his favourite utubers are no longer going to make videos and feel that his life is over. Before you go making changes think of the way this will affect people like my son who rely heavily on the internet. He literally cannot concentrate on anything but the potential negative outcome this change will impose on utube and the millions of utubers who use it. This is not a simple rule change to him and there is nothing i can say or do to help him. This change is affecting his school work and his entire life and although this may sound silly and stupid to most, until you have walked in his shoes and understand how the mind of someone affected with autism this really is life changing for him and not in a positive way.

When the FTC does something like COPPA, they don't realize that it will pretty much DESTROY millions of lives. Please FTC, add an option for "Mixed Audience/All Ages Content/Parental Advisory for videos that use the things that qualify as "For Kids" but also do other things.

Special care needs to be taken that video game-related content is not unfairly targeted. Just because someone is streaming a game intended for children does NOT mean the channel is made for or intended for children. Many adult YouTubers enjoy playing games from their childhood, but use adult humor and language. This does not make the channel content made for children.

I would like to say that, could you please make the rules more understandable and not so vague? Like for example, you have been saying that gaming content is directed towards kids, but it is not kids who watch it. Gaming content should not be labeled as kids content. It should be mature content.

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