international cyberstalking laws

/StructParents 10 << /K [435 0 R 436 0 R 437 0 R 438 0 R 439 0 R 440 0 R 441 0 R 442 0 R 443 0 R] /MediaBox [0.0 0.0 595.32 841.92] 143 0 obj >> Volume 96 96 N.C. App. /Font << /Subtype /XML /S /P /K 5 /P 9 0 R 81 0 obj /S /Footnote null 516 0 R 133 0 R 517 0 R 133 0 R 524 0 R 135 0 R 525 0 R 135 0 R 526 0 R /P 9 0 R L. 115334, 12502(a)(1)(B), inserted ,a pet, a service animal, an emotional support animal, or a horse after to a person and substituted (iii), or (iv) for or (iii). /Parent 7 0 R 72 0 obj null 375 0 R null 376 0 R null 377 0 R null 378 0 R null 379 0 R endobj /S /P /Pg 31 0 R >> WebInstead of laws specifically covering cyberstalking and cyberharassment, most countries use stalking and/or harassment laws to prosecute the perpetrators of these cybercrimes. << /Pg 32 0 R /Limits [32 63] 127 0 obj /Pg 16 0 R 24 0 obj 134 0 obj Although there are often existing laws that prohibit stalking or harassment in a general sense, legislators sometimes believe that such laws are inadequate or do not go far enough, and thus bring forward new legislation to address this perceived shortcoming. /K 3 /Pg 13 0 R /Pg 27 0 R >> /P 9 0 R endobj >> /P 9 0 R /Resources << /Pg 20 0 R /P 9 0 R /Pg 32 0 R /InlineShape /Figure << /K 6 222 0 obj << 221 0 obj /Resources <> << /K 1 /Type /Metadata >> << Under U.S. federal law, someone commits the felony of stalking if that person: places another person in reasonable fear of death or serious bodily injury to him- or herself, his or her immediate family member, or spouse or intimate partner. endobj /CS1 [/ICCBased 242 0 R] <> /Pg 17 0 R /Rotate 0 185 0 R null 578 0 R null 635 0 R 636 0 R] endobj Opponents point out that harassment on college campuses is already prohibited under existing laws; furthermore, they point out that harassment based on sexual orientation is also covered under existing statutes. 218 0 obj /K 7 99 532 0 R 100 541 0 R 101 542 0 R 102 543 0 R 103 544 0 R << /K 15 10 0 obj >> /ColorSpace << /K 10 endobj << /S /P Web18 U.S. Code 2261A - Stalking. /S /P /S /P /S /P 167 0 obj /S /P >> /P 9 0 R /P 9 0 R [11] The state of North Carolina invalidated such a law in State v. /StructParents 15 endobj This is the Convention on Cybercrime, signed by the Council of Europe in Budapest on November 23, 2001. /Contents 284 0 R /S /Footnote /MediaBox [0.0 0.0 595.32 841.92] << Cyber Crimes And Law In India. << >> /S /P /Type /Page /K 13 /Pg 18 0 R << >> Although many States in Australia have antistalking laws, Victoria and Queensland are the only States that include sending electronic messages to, or otherwise contacting, the victim in their legislation. << /CropBox [0.0 0.0 595.32 841.92] >> endobj endobj Senator Frank Lautenberg (D-NJ) and Representative Rush D. Holt, Jr. (D-NJ-12) introduced the "Tyler Clementi Higher Education Anti-Harassment Act", which would mandate that colleges and universities that receive federal funding have policies in place to address harassmentincluding cyberbullying. What Federal Laws Exist To Protect Stalking Victims? 42 U.S.C. Section 3796 and 42 U.S.C. Section 14031 authorize grants for law enforcement agencies to develop programs to reduce stalking and for states to develop local, state, and national databases regarding stalking. 42 U.S.C. Section 14036 requires judges to ensure they review the stalker's criminal history prior to issuance of a civil court orders in stalking cases. /K [393 0 R 394 0 R 395 0 R 396 0 R 397 0 R 398 0 R 399 0 R 400 0 R 401 0 R] [2] Not only is the issue of cyberbullying extensive, it has adverse effects on adolescents: increased depression, suicidal behavior, anxiety, and increased susceptibility of drug use and aggressive behavior.[3]. 54 0 obj /P 9 0 R /Pg 25 0 R /Font << 2011-02-16T10:29:34+01:00 116 0 obj << endobj endobj >> >> L. 115334, 12502(a)(1)(A), added cl. /Font << >> Davis, A.J. Tampa, Florida U.S. District Judge Thomas P. Barber has sentenced Christopher Buonocore (35, Hicksville, NY) to 15 years in federal prison for cyberstalking multiple victims. /K [21 444 0 R 40 445 0 R 42 446 0 R 44] >> 171 0 obj >> endobj >> null 519 0 R null 520 0 R null 521 0 R null 522 0 R null 523 0 R /Pg 29 0 R << The evolving cybercrime landscape and resulting skills gaps are a significant challenge for law enforcement agencies and prosecutors, especially for cross-border enforcement. Particularly in instances where there are no laws explicitly against cyberbullying, it is not uncommon for defendants to argue that their conduct amounts to an exercise of their freedom of speech. 101 0 obj /StructParents 13 /K 2 /Pg 14 0 R /P 9 0 R 31 0 obj >> /Pg 31 0 R uuid:271fb036-f088-4ba0-9cbc-b0d52ee3eb8a /K 14 /S /P /Pg 16 0 R /P 9 0 R /K 5 /Pg 22 0 R 43 0 obj /P 9 0 R /P 9 0 R /K 2 << /Pg 30 0 R 210 0 obj /S /P 99 0 obj Assembly, Senate pass 'Anti-Bullying Bill of Rights' in wake of Tyler Clementi's death", "Stronger Anti-Bullying Bill Approved By Committee", "Grieving family by his side, governor signs legislation", Current and pending cyberstalking-related United States federal and state laws, Despite Laws, Stalkers Roam On the Internet, Cyberstalking garnering more serious response, Man convicted of cyberstalking to undergo psychiatric evaluation before sentencing, "Mom's Campaign for Florida Anti-Bully Law Finally Pays Off - ABC News", "Cyber Bullying Illegal: Mass. endobj [38][39], Washington takes the approach of putting the focus on cyberbullying prevention and response directly on the schools. endobj /S /P /P 9 0 R 8 [105 0 R 106 0 R 107 0 R 108 0 R 109 0 R 110 0 R null 454 0 R null 455 0 R >> The punishment includes imprisonment of up to five years and a fine of up to five lakhs rupees. In a general sense, it would seem simple to legislate this type of behavior; slander and libel laws exist to tackle these situations. << endobj /P 9 0 R >> /S /P endobj /S /P /Type /Page India's Information Technology Act of 2000 (IT Act) was a set of laws to regulate the cyberspace. 15 0 obj endobj endobj 74 0 obj /Parent 7 0 R 153 0 R 154 0 R 155 0 R 156 0 R 157 0 R 158 0 R 159 0 R 160 0 R 161 0 R 162 0 R [30], Under Florida Statute 784.048, "cyberstalking," defined as to engage in a course of conduct to communicate, or to cause to be communicated, words, images, or language by or through the use of electronic mail or electronic communication, directed at a specific person, causing substantial emotional distress to that person and serving no legitimate purpose, is classified as a first degree misdemeanor. Secure .gov websites use HTTPS /P 9 0 R 67 0 obj >> 140 0 obj /Pg 30 0 R 92 0 obj /K 8 >> /Parent 6 0 R /TT2 244 0 R /Font << /S /P /Annots [354 0 R] 4203] increases penalties related to the stalking of minors. /K 14 /MediaBox [0.0 0.0 595.32 841.92] 203 0 R 204 0 R 205 0 R 206 0 R 207 0 R 208 0 R 209 0 R 210 0 R 211 0 R 212 0 R 220 0 obj He notes that there are two basic types of anti-stalking legislations - the list model and the closed model. 174 0 obj /S /P /Pg 21 0 R /K 3 endobj endobj endobj >> /P 9 0 R /P 9 0 R endobj In addition, opponents call the proposed sentences (up to two years incarceration) excessive. /K 9 /S /Footnote 146 0 obj /K 4 endobj /TT1 245 0 R /K 1 /Contents 274 0 R /S /P <> /DropCap /Figure 132 0 obj /P 9 0 R >> /Pg 22 0 R /K [490 0 R 491 0 R 492 0 R 493 0 R 494 0 R 495 0 R] /K [1 402 0 R 31] >> 401 0 R null 389 0 R 62 0 R 390 0 R 62 0 R 391 0 R 62 0 R 392 0 R 62 0 R /S /P WebFederal law provides some tools to combat cyberstalking. /ColorSpace << << >> >> This website contains the federal and individual state laws on cyberstalking. /K [1 496 0 R 19 497 0 R 21 498 0 R 23] endobj /K [0 464 0 R 30] /Pg 17 0 R (iv). ), Victims of Crime (3rd edn, California, Thousand Oaks, 2007), pp. << 83 0 obj endobj >> /S /P /S /P 10 [110 0 R 112 0 R 113 0 R 114 0 R 115 0 R 116 0 R 117 0 R 118 0 R 119 0 R 120 0 R endobj >> endobj Par. << << endobj /P 9 0 R WebCyberstalking Laws. /S /P /Pg 20 0 R >> 11 0 obj /Rotate 0 /TextBox /Art 18 [164 0 R 166 0 R 167 0 R 168 0 R 169 0 R 170 0 R 171 0 R 172 0 R 173 0 R 174 0 R >> 215 0 obj 207 0 obj /MediaBox [0.0 0.0 595.32 841.92] << endobj /P 9 0 R << Download PDF. 153 0 obj /CropBox [0.0 0.0 595.32 841.92] /ModDate (D:20110216102938+01'00') >> >> /Pg 21 0 R 22 0 obj /CS0 [/ICCBased 241 0 R] 9 620 0 R /P 9 0 R endobj >> endobj 83 0 R 84 0 R 85 0 R 86 0 R 87 0 R 88 0 R 89 0 R 90 0 R 91 0 R 92 0 R 74 483 0 R 75 484 0 R 76 485 0 R 77 486 0 R 78 623 0 R /Pg 30 0 R /Pg 32 0 R /TT2 245 0 R /P 9 0 R /Rotate 0 >> 42 404 0 R 43 405 0 R 44 406 0 R 45 407 0 R 46 413 0 R /S /Footnote 102 0 obj >> /P 9 0 R 15 [144 0 R 146 0 R 147 0 R 148 0 R 149 0 R 150 0 R 151 0 R 152 0 R 153 0 R null /K 5 The DRB was open about the absence of precedent for the specific federal crime of cyberstalking and searched nationally for a comparable case, said Roger Plawker of Pashman Stein Walder Hayden. /Pg 31 0 R /CropBox [0.0 0.0 595.32 841.92] Opponents of the bill argue that since the target of such legislation is nominally teenagers, this would put an undue burden on the prison systemsince there are no long-term facilities for teenage offenders at the federal level. << 66 0 obj /P 9 0 R 135 0 obj /Parent 7 0 R /Type /Page /Type /Page null 456 0 R null 457 0 R null 458 0 R null 459 0 R null 460 0 R endobj /P 9 0 R /P 9 0 R /Pg 30 0 R endobj /Pg 23 0 R /Pg 19 0 R << /K 1 /S /P /P 9 0 R >> << endobj endobj >> >> /Kids [23 0 R 24 0 R 25 0 R 26 0 R 27 0 R 28 0 R 29 0 R 30 0 R 31 0 R 32 0 R] Some U.S. states have begun to address the problem of cyberbullying. A study on cyberstalking: Understanding investigative hurdles. /Pg 30 0 R 57 430 0 R 58 444 0 R 59 445 0 R 60 446 0 R 61 452 0 R /Contents 248 0 R 154 0 obj /Contents 280 0 R << 139 0 obj These statutes /Contents 342 0 R [10] In another California case, in which a student was harassed after posting personal information online, the court found that threatening posts were not protected speech. 90 0 obj endobj endobj /P 9 0 R /S /P /P 9 0 R /P 9 0 R << /CS0 [/ICCBased 241 0 R] Nothing, existing international cyber stalking laws apply b. << A lot is at stake in a federal cyberstalking case, which is why you need aggressive defense on your side. << >> >> /S /P 53 0 obj endobj A .gov website belongs to an official government organization in the United States. /CropBox [0.0 0.0 595.32 841.92] Cyberstalking can include many things including threats, solicitation for sex, false accusations, defamation, slander, libel, identity theft, and vandalism . << /TT0 243 0 R /P 9 0 R >> 190 0 obj << endobj 17 0 obj 211 0 obj a. 109 563 0 R 110 564 0 R 111 565 0 R 112 632 0 R 113 634 0 R Cyberstalkers can use chat rooms to slander and endanger their victims. /Limits [64 115] WebAs a first degree misdemeanor, cyberstalking in Florida is punishable by up to 12 months in county jail and up to a $1000 fine. Spitzberg, B. H., & Hoobler, G. (2002). 156 0 obj 37 0 obj /S /P /Rotate 0 /S /P >> 201 0 obj /TT1 258 0 R 52 0 obj /P 9 0 R /Resources << endobj endobj >> /K 4 endobj /Rotate 0 >> /Pg 15 0 R /S /P /Pg 27 0 R endobj /P 9 0 R /P 9 0 R /P 9 0 R /S /P an immediate family member (as defined in section 115) of that person; the pet, service animal, emotional support animal, or horse of that person; 16 [153 0 R 155 0 R 156 0 R 157 0 R 158 0 R 159 0 R 160 0 R 161 0 R null 556 0 R /Rotate 0 << /P 9 0 R /TT0 243 0 R << /S /P 493 0 R null 494 0 R null 495 0 R null 623 0 R 624 0 R 496 0 R 124 0 R In the United Kingdom, cyberharassment can be prosecuted under the Protection from Harassment Act of 1997 or the Malicious Communications Act of 1988. 118 0 obj /S /P /StructParents 11 >> [42] One of the oft-cited arguments against the bill comes from talk radio, with the concern expressed being that the law would be used to silence political opponents who use the airwaves to espouse divergent viewpoints. /K 5 << /Pg 30 0 R 41 0 obj Nothing; existing stalking laws can apply. <> /Pg 31 0 R /K [7 413 0 R 24 414 0 R 26] /S /P The other bill, SB 5628, focused on online harassment and was written with the Anti-Defamation League to update the existing law to uphold the First Amendment. /K 5 /Title (International $cyber$stalking: impediments to investigation and prosecution) /P 9 0 R /Pg 15 0 R The first cyberstalking law went into effect just over a year ago in California, and Congress is considering a federal law. >> /Annots [317 0 R 318 0 R 319 0 R 320 0 R 321 0 R 322 0 R] /Pg 30 0 R 212 0 R 213 0 R 214 0 R 215 0 R 216 0 R 217 0 R 218 0 R] /S /Footnote >> >> /Pg 25 0 R /P 9 0 R WebWhat must exist for cyber stalking to be illegal in a state or territory? North Carolina State Supreme Court Strikes Down Cyberbullying Statute. endobj << >> /Font << endobj /K 1 << Cyberstalking has been illegal since 2011. [40] III. endobj /Pg 20 0 R /K 6 /Rotate 0 /Pg 13 0 R /K 5 endobj /S /P /Pg 20 0 R /CS0 [/ICCBased 241 0 R] Online stalkers have been known to post insulting messages on electronic bulletin boards signed with the e-mail address of the person being harassed. /Type /Page << /K 5 /K 1 /Annots [246 0 R 247 0 R] /K 4 /P 9 0 R /P 9 0 R Abstract 188 0 obj endobj /TT2 285 0 R << travels in interstate or foreign commerce or is present within the special maritime and territorial jurisdiction of the United, places that person in reasonable fear of the death of, or, with the intent to kill, injure, harass, intimidate, or place under surveillance with intent to kill, injure, harass, or intimidate another person, uses the mail, any interactive computer service or electronic communication service or electronic communication system of interstate commerce, or any other facility of interstate or foreign commerce to engage in a, Pub. >> 7 [600 0 R 601 0 R 602 0 R 603 0 R 604 0 R 605 0 R 606 0 R 607 0 R 608 0 R 609 0 R shall be punished as provided in section 2261(b) or section 2261B, as the case may be. /CS0 [/ICCBased 241 0 R] >> In addition to imprisonment, the court may also order the alleged offender to pay a $250,000 fine. >> /Type /Pages << /K 9 108 0 obj Cyberstalking is a type of online harassment that involves using electronic means to stalk a victim, and generally refers to a pattern of threatening or malicious [21], Finally, it's not uncommon for cyberbullying to be coupled with "traditional", in-person bullying, for example, in the suicide of Phoebe Prince. c/o ISBS, 5804 N.E. /Type /Pages /K 6 20 0 obj /PageLayout /OneColumn endobj << 113 0 obj /Marked true /CropBox [0.0 0.0 595.32 841.92] /P 9 0 R stream /P 9 0 R A man or a woman committing the offence of stalking would be liable for imprisonment up to three years for the first offence, and shall also be liable to fine and for any subsequent conviction would be liable for imprisonment up to five years and with fine. << /Pg 13 0 R endobj endobj /P 9 0 R /Pg 22 0 R /P 9 0 R 63 0 obj 115 0 obj << /Pg 32 0 R /P 9 0 R << /Rotate 0 >> Contact Beckham Solis, Attorneys at Law at (305) 290-1884 for representation from a team in Miami with over 35 years of collective experience. << 123 0 obj >> << /MarkInfo << /S /P /Pg 28 0 R endobj /Parent 8 0 R /Pg 27 0 R /Pg 30 0 R /S /P % >> /S /P /Annots [324 0 R 325 0 R 326 0 R 327 0 R 328 0 R 329 0 R] << /Contents 257 0 R WebDavid's Law is a state law in Texas, that labels cyberstalking a misdemeanor crime, but it also lays out several other rights victims or parents of victims have in ensuring justice. /Pg 19 0 R >> /P 9 0 R >> /Resources << >> /K [2 574 0 R 15 575 0 R 576 0 R 577 0 R] /P 9 0 R The law also requires schools to create policies to address bullying in a general sense.[40][41]. 219 0 obj /P 9 0 R Amendment by Pub. >> /K [2 499 0 R 25 500 0 R 27 501 0 R 502 0 R 503 0 R] >> /TT3 258 0 R /S /P /K 4 >> /StructParents 3 /S /P /S /P /P 9 0 R 21 581 0 R 22 359 0 R 23 364 0 R 24 365 0 R On this Wikipedia the language links are at the top of the page across from the article title. 9 0 obj 21 0 obj /Pg 19 0 R /Contents 330 0 R /ColorSpace << >> /K 1 [23] It also lists those states that do not have laws yet and related laws from other countries. /Pg 22 0 R endobj endobj << >> << 60 0 obj /StructParents 2 WebAnnotate this Case. << >> /Annotation /Span endobj >> endobj null 557 0 R null 558 0 R null 559 0 R null 560 0 R null 561 0 R << >> /S /P [43][44] Another issue is that would make violation of the law a felony, rather than a misdemeanor as has been done in most states. /Pg 19 0 R >> endobj /Resources << 497 0 R 124 0 R 498 0 R 124 0 R 499 0 R 125 0 R 500 0 R 125 0 R] /CS0 [/ICCBased 241 0 R] /Parent 6 0 R endobj /K [408 0 R 409 0 R 410 0 R 411 0 R 412 0 R] 433 0 R null 428 0 R 88 0 R 429 0 R 88 0 R 430 0 R 88 0 R] /Pg 31 0 R endobj << Article 5 of the Universal Declaration of Human Rights. 200 0 obj <> >> /TT3 244 0 R /Pg 22 0 R 95 0 obj /TT2 244 0 R 505 0 R null 506 0 R null 507 0 R null 508 0 R null 509 0 R null [32] Unusual among state laws regarding cyberbullying is a provision that withholds funding for schools who are not in compliance with the provision that they must inform parents of those involved in cyberbullyingboth the bully and the target. /Pg 25 0 R >> /S /P /K 7 /P 9 0 R /S /P /P 9 0 R 34 0 obj /S /P >> >> /Type /Page << /K [504 0 R 505 0 R 506 0 R 507 0 R 508 0 R 509 0 R] Cyberbullying and cyberstalking, by their nature, define adversarial relationships. >> /TT2 258 0 R /ColorSpace << /Parent 7 0 R <> /Pg 31 0 R >> >> 109 0 obj /ColorSpace << /S /P [50] Stalking has been defined as a man or woman who follows or contacts a man or woman, despite clear indication of disinterest to such contact by the man or woman, or monitoring of use of internet or electronic communication of a man or a woman. 96 0 obj /K [2 403 0 R 33 404 0 R 35 405 0 R 37 406 0 R 39] /CropBox [0.0 0.0 595.32 841.92] << /S /P Explanation : Cyberstalking involves using electronic means, including the Internet, to stalk or harass a person or group of people. /Pg 15 0 R >> >> /K 7 WebCybercrime is a growing concern to countries at all levels of developments and affects both, buyers and sellers. Finally, the Convention on Cybercrime will be analysed to see /K 10 /Pg 14 0 R Webenacted their anti-stalking laws in 1997 in the form of the Protection from Harassment Act (PHA) 1997 and the New Zealand Harassment Act 1997 respectively. >> /Parent 8 0 R 25 366 0 R 26 367 0 R 27 368 0 R 28 582 0 R 29 382 0 R >> >> /K 7 endobj 113 0 R 114 0 R 115 0 R 116 0 R 117 0 R 118 0 R 119 0 R 120 0 R 121 0 R 122 0 R >> 23 0 obj 173 0 obj << /TT1 245 0 R /Font << 105 0 R 465 0 R 106 0 R 466 0 R 106 0 R 467 0 R 107 0 R 468 0 R 108 0 R 469 0 R /Resources << << /K [6 515 0 R] /P 9 0 R << /Contents 358 0 R /StructTreeRoot 4 0 R Behera, A. /Contents 339 0 R >> <> /Pg 30 0 R /Pg 24 0 R /S /P endobj /TT0 243 0 R >> Her efforts were met with little enthusiasm, however, as Representatives from both the Republican and Democratic parties were concerned with the bill's impact on the freedom of speech. << /Pg 26 0 R /K 11 << /P 9 0 R /Pg 18 0 R 78 0 obj The focus on legislating cyberbullying and cyberstalking has largely come about as a result of the perceived inadequacy, generally by legislators and parents of bullying victims, of existing laws, whether those existing laws cover stalking, unauthorized use of computer resources, or the like. endobj /Pg 22 0 R /Type /Page /K [374 0 R 375 0 R 376 0 R 377 0 R 378 0 R 379 0 R 380 0 R 381 0 R] endobj /Pg 32 0 R 121 0 R 122 0 R null 476 0 R null 477 0 R null 478 0 R null 479 0 R An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. /P 9 0 R /Chart /Figure /CropBox [0.0 0.0 595.32 841.92] endobj /K 20 /Type /Page /TT0 243 0 R /S /P /K [9 482 0 R 28 483 0 R 30 484 0 R 32] While 156 countries (80 per cent) have enacted cybercrime legislation, the pattern varies by region: Europe has the highest adoption rate (91 per cent) and 68 0 obj << /StructParents 17 /Type /Pages /Type /Page /K 5 One person (or group), the provocateur, is exerting a view or opinion that the other person (or group), the target, finds offensive, hurtful, or damaging in some way. /MediaBox [0.0 0.0 595.32 841.92] 160 0 obj endobj 125 0 obj 80 0 obj >> L. 109162 amended section catchline and text generally, revising and restating former provisions relating to stalking so as to include surveillance with intent to kill, injure, harass, or intimidate which results in substantial emotional distress to a person within the purview of the offense proscribed. endobj << >> /K [2 524 0 R 26 525 0 R 28 526 0 R 30] /ColorSpace << /Strikeout /Span endobj << << /Pg 30 0 R >> /Pg 19 0 R /Font << << /ParentTreeNextKey 116 >> 875 (c), it is a federal crime, punishable by up to five years in prison and a fine of up to $250,000, to /P 9 0 R >> /ColorSpace << Stalking a person online may also involve stalking the person in real life. In addition, prosecutors will sometimes use other legal avenues to prosecute offenders. /P 9 0 R /Type /Page /P 9 0 R >> /S /P << >> << Prior to amendment, text read as follows: Whoever travels across a State line or within the special maritime and territorial jurisdiction of the United States with the intent to injure or harass another person, and in the course of, or as a result of, such travel places that person in reasonable fear of the death of, or serious bodily injury (as defined in section 1365(g)(3) of this title) to, that person or a member of that persons immediate family (as defined in section 115 of this title) shall be punished as provided in section 2261 of this title.. 219 0 obj < < < > > > < < endobj /k 1 < < < /P 9 R! Strikes Down Cyberbullying Statute endobj /k 1 < < /Pg 30 0 R 0. 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