The UK Jurisdiction Taskforce (UKJT), one of the six taskforces of the LawTech Delivery Panel, an industry-led group that is tasked with supporting the digital transformation of the UK legal services sector, has published a legal statement on the status of cryptoassets and smart contracts under English and Welsh law, providing legal certainty for the first time.
1 What is the legal statement?
The legal statement is an opinion of four lawyers (Lawrence Akka QC, David Quest QC, Matthew Lavy and Sam Goodman), commissioned by the UKJT and published following a market-wide public consultation, addressing several legal questions relating to cryptoassets and smart contracts. It was commissioned by the UKJT with the intention of providing clarity on several areas of perceived legal uncertainty, and thereby improving market confidence.
Although the legal statement does not, strictly speaking, have the force of law (as it is neither legislation nor a court ruling) or constitute formal legal advice, it can be compared to formal legal opinions commissioned by trade associations to resolve matters of legal uncertainty and which are generally adopted by market participants as outlining the market consensus as to the legal basis on which the relevant market transacts.
The consultation process The UKJT conducted a consultation process prior to the publication of the legal statement to address issues of perceived legal uncertainties with respect to these new technologies. Linklaters led on the drafting of the associated consultation paper, published in May 2019, and assisted in running a public event in June 2019 seeking input from market participants.
The legal statement Linklaters also provided input on the legal statement itself. Providing legal certainty on the status of cryptoassets and smart contracts under English and Welsh law for the first time, the landmark statement recognises cryptoassets as property and smart contracts as enforceable. The influential statement is a critical step in the future application of private law to transactions involving cryptoassets.
FAQs on the legal statement Below, we consider the key takeaways from the legal statement. The below FAQs expand on an abridged version which is accessible here.
We expect the courts to give very significant weight to it, particularly given the status of its authors and the wide range and standing of market participants consulted in connection with its publication.
3 What type of cryptoassets did the legal statement focus on?
Although parts of the legal statement did consider permissioned, private DLT applications and different types of cryptoasset such as â€œsecurity tokensâ€, the primary focus of the legal statement was on â€œnativeâ€ cryptoassets â€“ i.e. those cryptoassets that have no manifestation or feature other than as a digital record on a distributed ledger. We consider different types of non-native cryptoassets and permissioned distributed ledgers, together with their legal implications, later.
4 If a cryptoasset can be owned, what exactly is the asset?
The asset is the set of arrangements that give rise to the ability to update or spend (i.e. render inert or retire) certain data, to the exclusion of another party. Accordingly, once a cryptoasset has been spent, the corresponding spent transaction record becomes inert data and ceases to be property.
Specifically, the legal statement states that a cryptoasset is represented by data (a public key, one or more private keys and certain other data (for example, a transaction record) on a distributed ledger), none of which would, alone or together, constitute property under English law, as they are merely information, which cannot be property under English law. The legal statement (at paragraph 65) states, and we agree, that the asset comprises a combination of such data and the relevant system protocol or rules (including the embedded cryptography) that ensures that certain transaction data can be updated or spent once and once only.
Technically, the legal statement acknowledges that a cryptoasset is not a thing that can be possessed (chose in possession) and does not, without some specific additional legal act (see the discussion on native versus other types of cryptoassets below), confer enforceable legal rights against any person (typically associated with a chose in action) (paragraphs 67 and 68).
5 Does control of a private key confer ownership of a cryptoasset?
Sometimes, but not always.
The legal statement describes the owner of a cryptoasset as â€œa person who has acquired control of a private key by some lawful meansâ€ (paragraph 43). It also confirms, however, that it is possible (although perhaps unwise) for the original owner of a cryptoasset to transfer ownership of that cryptoasset â€œoff-chainâ€ (for example, through a symbolic sharing of the private key to a third party).
As noted above, a private key itself is data/information that cannot be owned: it is vulnerable to double spend. We interpret the reference to â€œacquiring control of the private key by some lawful meansâ€ as a reference to some act involving passing knowledge of the private key from a transferor to a transferee with the intention and agreement of the parties that this should have the effect of transferring ownership of the underlying cryptoasset.
We expect the courts to give very significant weight to it, particularly given the status of its authors and the wide range and standing of market participants consulted in connection with its publication. We expect that the adoption by market participants of the legal statement as described above will further reinforce this status. As such, the legal statement carries greater legal weight than other publications by individual legal academics or practitioners. It is also open to other common law jurisdictions to adopt the legal statement.
2 What were the main conclusions of the legal statement?
The legal statement provides confirmation that cryptoassets can be owned and smart contracts can be, or be part of, binding legal contracts. Specifically, the legal statement explained that, without the need for lengthy legislation:
> English law can recognise cryptoassets as property under English law; and
> parties wishing to enter into smart contracts that are legally binding can use English law to achieve this, in much the same way as with more conventional contracts. The legal statement rightly recognised that such smart contracts are simply a subset of recognised forms of contract even if they raise some issues specific to that context.1
More broadly, the legal statement demonstrates the flexibility and adaptability of English law to meet the expectations of modern commerce, in particular in relation to new developments, technologies and structures and structures, both in the wholesale and retail markets. We think it is appropriate to focus on the common law characterisation of cryptoassets and smart contracts before pursuing a legislative approach. A challenge with such a legislative approach is that it can lead to a need to codify large interrelated areas of law and how they apply to the evolving market prematurely, with the risk that the codified framework may not meet the demands of the market, reflect market practice or evolve with the market. The common law approach provides more flexibility and permits the development of appropriate remedies to reflect market expectations.
1 There was less need to focus on other issues in relation to smart contracts as the conclusion of the legal statement is that existing legal principles of contract law are broadly adequate to cover issues relating to smart contracts. This also explains why the focus of these FAQs is on the sections of the legal statement devoted to cryptoassets and not smart contracts.
We think it is appropriate to focus on the common law characterisation of cryptoassets and smart contracts before pursuing a legislative approach.
A real-world analogue is the transfer of title to a car through the symbolic delivery of a key to the car, which may operate as a transfer of possession and thereby title to the car under English law, where the holder of the key is the owner of the car or authorised by the owner of the car to transfer possession or constructive possession of the car, even where the owner may have retained a duplicate key.
In our view, therefore, the ownership of a cryptoasset linked to a private key must start with the person who created that private key. Subsequent owners of the same cryptoasset must be identified through a chain of ownership. If that involves an â€œoff-chainâ€ transfer, proving title to the relevant cryptoasset will ultimately come down to the best evidence available.
As noted in the legal statement, accepting such a transfer of a cryptoasset may be unwise from the perspective of a transferee because the transferor may have retained a copy of the private key and may therefore still be able to spend the cryptoasset before the transferee does so, thereby depriving the transferee of the economic value of its ownership of the cryptoasset.
An interesting question that the legal statement does not address is whether the current holder of a cryptoasset always has absolute title to it, no matter how they obtained it. A classic example is that of a hacker or person who abuses a position of confidence to access another personâ€™s private key and who causes a cryptoasset to be unlawfully spent in that personâ€™s favour. The legal statement refers to a person â€œwho has acquired control of the private key by some lawful meansâ€ (paragraph 43). Such a person may have created or acquired control of the relevant private key quite lawfully whilst unlawfully causing the cryptoasset to be spent in that personâ€™s favour. In our view, as the analysis of the legal statement confirms (see paragraph 45) that such an â€œon-chainâ€ transfer creates a new asset, such a person would be regarded in law as the owner of the new asset, but this would not release such owner from any claims that the lawful owner of the spent cryptoasset may have against such owner of the new cryptoasset. Such claims may include equitable claims or remedies, such as a proprietary tracing claim against such ownerâ€™s new cryptoasset. In short, such a holder of a cryptoasset will be the owner in law but may not be the owner in equity.
In reality, and subject to other remedies that may be available, this legal flaw in title is likely to prove more theoretical than practical for so long as the owner of the new cryptoasset has exclusive control of the cryptoasset through exclusive knowledge of the private key, for such a cryptoasset (and any subsequent ones) may be spent countless times before any legal redress may be available, leading to likely insurmountable obstacles to the recovery of property.
6 How can a cryptoasset be transferred?
By way of an â€œon-chainâ€ or an â€œoff-chainâ€ transfer. The legal statement makes clear that:
> an â€œon-chainâ€ transfer is what is typically understood by a â€œtransferâ€ of a cryptoasset, resulting in the relevant records on the ledger being updated. Such a transfer operates by consuming the property of the transferor and creating an entirely new cryptoasset that is owned by the person who lawfully has control over the private key relating to such new cryptoasset (see paragraph 45). In that sense, an â€œon-chainâ€ transfer is only a â€œtransferâ€ in a loose sense: the asset held by the transferor is a different asset to that held by the transferee. Furthermore, the transfereeâ€™s ownership interest will defeat all ownership claims to the previous cryptoasset, which will have ceased to be property by reason of it being rendered inert (although the transfereeâ€™s ownership interest would still be subject to the remedies available to the owner of the prior cryptoasset, as discussed in FAQ 5 above); and
> an â€œoff-chainâ€ transfer relates to any other transfer, including by the symbolic sharing of a private key. The legal statement notes the vulnerabilities of off-chain transfers to supervening on-chain transfers (as described above) (paragraph 48). It is clear, however, that the vulnerability of an off-chain transfer to a supervening on-chain transfer does not change the legal effectiveness of that off-chain transfer unless and until the cryptoasset is spent. Off-chain transfers of title are therefore subordinate to on-chain transfers of title.
7 What is the legal mechanism by which on-chain and off-chain transfers are made?
The legal statement refers to off-chain transfers being made by assignment or assumption (paragraphs 44-48).
Assignment is a legal mechanism associated with transfers of choses in action as opposed to transfers of choses in possession. The legal statement considers whether cryptoassets are choses in action or some other kind of property and does not form a definitive view (on the basis that little turns on the question) (paragraphs 66 to 84).
In our view, as it is accepted in principle in the legal statement that off-chain transfers may be effected in law, the precise legal mechanism by which off-chain transfers are made is likewise open to further interpretation by the courts. A key issue that is likely to be litigated is whether a sharing of a private key was intended to act as an outright transfer of ownership of the cryptoasset or to create some other form of relationship, such as a duty of confidentiality, an agency or a trust, or something equivalent to a form of shared â€œpossessionâ€.
An â€˜on-chainâ€™ transfer is only a â€˜transferâ€™ in a loose sense: the asset held by the transferor is a different asset to that held by the transferee.
The answer to this question (which will be highly dependent upon the particular facts and circumstances under consideration) is likely to determine the kind of remedy that the court would award if one party breaches the arrangement between the two so as to cause a loss to the other (e.g. by spending the cryptoasset).
The legal statement concludes that an on-chain â€œtransferâ€ is not strictly a transfer: the asset â€œspentâ€ by the transferor is a different asset to that received by the transferee. This is because the property of the transferor is consumed or destroyed (i.e. the spent cryptoasset cannot be spent again) and an entirely new cryptoasset is created that can in turn be spent by the transferee (paragraph 45). A parallel is drawn with the transfer of a bank balance from one accountholder to another (paragraph 45), however, such a transfer relates to an acknowledged chose in action and either its assignment or its substitution by another chose in action.
8 Can a cryptoasset have no owner?
In our view, yes. There are acknowledged examples of cryptoassets being locked into a smart contract in respect of which no person knows or controls the associated private key (which has been created and stored within the smart contract algorithm). Whilst the cryptoasset is locked up, it can be compared to abandoned property.
9 What are the implications for permissioned DLT applications?
That depends on the specific features of the permissioned system: subject to those features, the conclusions in the legal statement may or may not apply (as is recognised in the legal statement in paragraph 33). Those features may bring the cryptoasset within a specific legal regime and may even change the fundamental legal nature of the cryptoasset. For example:
> if the system is subject to a set of rules that include a governing law, the cryptoasset may be more clearly categorised as a chose in action; and
> if one or multiple master nodes may be able to amend the records in the ledger or to direct the re-registration of a cryptoasset from one public key to another (for example, if transfers are effected other than by way of a consensus mechanism, or there exists an ability to override any consensus transfer mechanism), this may undermine the property status of the cryptoasset and may have the effect of preventing such cryptoassets from having the hallmarks of negotiability (see our discussion on negotiability in FAQ 12 below).
That said, the legal statement is helpful in that it provides guidance for those permissioned DLT systems that do intend to establish a native digital asset capable of being owned as to the features that system must have in order to achieve that end.2
10 What are the implications for native cryptoassets compared to other kinds of cryptoassets or structures involving DLT, including tokenisation?
Again, this depends on the precise structure of those other types of arrangement. The legal statement notes that cryptoassets may represent or be linked to rights, assets, services or other things (paragraph 68) (non-native cryptoassets). Such linkages will need to be examined to determine if they create separate legal rights. We expect any such rights to attach to (and be distinct from) ownership of the cryptoasset itself.
As noted in FAQ 3 above, the legal statement is only concerned with native cryptoassets (i.e. those that do not benefit from any such linkages). A legal right or interest may, however, attach to ownership of a cryptoasset (referred to in the legal statement as tethered, exogenous or off-chain â€“ we often use the term stapled) or there may be no legal right attaching to it, but merely an expectation of the owner or holder of that cryptoasset that it will benefit from some arrangement (e.g. the existence of a soft, non-legally binding market making arrangement that will stabilise the price of the cryptoasset) or an ability to exchange the token for a good or service, such as a digital service (often referred to as a utility cryptoasset). Generally, to be legally effective, it is likely that there will be a distinct legal mechanism that has been used to staple a legal right to the native cryptoasset. Such a legal mechanism (or its absence) ought to be more easily identifiable and capable of assessment. In all likelihood, there will continue to be two distinct regimes applicable to non-native cryptoassets (subject to our discussion in relation to permissioned DLT applications in FAQ 9 above), namely the native cryptoasset as something that is capable of being owned and the legal mechanism by which legally enforceable rights or property interests are stapled to the native cryptoasset. It is possible that the nature of the right attached to the cryptoasset becomes determinative of its identity and value (in the same sense that a negotiable instrument made out to the bearer is written on a piece of paper, which is capable of being seen as a separate item of property, but the value of which is derived entirely from the instrument).
11 Does the legal statement accurately capture specific life-cycle events relating to blockchain or DLT systems (such as forks)?
Yes: the legal statement generally clarifies that events such as forks do not impact the overall analysis (paragraphs 53 to 56).
The legal statement notes that there may be computational delays in registering changes to a ledger and that the system protocol rules (including the consensus algorithm) may change (for example, as a result of a â€œhard forkâ€). These sorts of issues may lead to possible revisions to previously recorded data (therefore impacting unspent cryptoassets), the loss of the ability to spend cryptoassets and even the deletion of all data on all ledgers. This is consistent with the fact that many types of property may, by their inherent nature, deteriorate or be subject to unanticipated changes, generally without giving rise to any legal redress.
2 As noted, the legal statement focuses on permissionless cryptoassets. Many enterprise deployments of DLT or blockchain introduce some form of permissioning within the network. This could encompass one or all of the following: permission to access the system (permissioned access) â€“ this could be self-executing or rules-based and might typically be used to enforce some kind of know your customer (KYC) requirement to ensure compliance with anti money- laundering and terrorist financing (AML) regimes; some form of overriding rulebook/legal framework that sets out the terms on which the system operates (permissioned governance); or the inclusion of master nodes that have editorial rights over some entries on the distributed ledger (permissioned nodes) â€“ these may or may not have a jurisdictional nexus.
12 The legal statement concludes that cryptoassets are not negotiable. Isnâ€™t this a significant drawback?
No: although the legal statement concludes cryptoassets are not negotiable in the strict legal sense, the legal nature of on- chain transfers is such as to render cryptoassets equivalent to negotiable instruments (paragraph 124).
As noted in the legal statement, negotiability is an example of an exception to the rule that a purchaser cannot obtain a better title to property than the person who sells that property, so if the seller does not own the property, no â€œbuyerâ€ from that seller will own the property. If property is negotiable, then any person who buys that property from another in good faith (e.g. without any knowledge or suspicion of a defect in title) will acquire ownership of that property, whether or not the seller owns it. Negotiability is a key feature of many tradeable instruments that permits the trading of them in the international markets. Examples of negotiable instruments are bills of lading and bearer bonds.
If cryptoasssets are not negotiable, then how can the law recognise an ownership interest in a cryptoasset when, due to the anonymous nature of on-chain transfers, it is not possible to trace title from one cryptoasset owner to another? This would create the risk that the law would recognise someone as entitled to the cryptoasset who is different from the on- chain owner. The legal statement, however, recognises that an on-chain transfer involves the destruction of the spent cryptoasset and the creation of a new cryptoasset. As a result, the concept of negotiability, which concerns the circumstances in which a person (acquirer) may acquire a superior title to an asset than the person that transfers it to the acquirer, is not strictly relevant. The question, therefore, must be whether a person may become the owner of a new cryptoasset where the person who spent the prior cryptoasset was not entitled to spend it. The legal statement confirms that this is the case (although such ownership interest would still be subject to the remedies available to the owner of the prior cryptoasset, as discussed in FAQ 5 above).
We therefore conclude that, although cryptoassets are not negotiable in the strict legal sense, the legal nature of on-chain transfers of cryptoassets is such as to render cryptoassets as equivalent to negotiable instruments (see, however, our discussion in relation to permissioned cryptoassets in FAQ 9 above and paragraphs 131 to 133).
13 What remedies are available to protect ownership of a cryptoasset?
The legal statement does not discuss remedies in depth. The next step following the confirmation in the legal statement that cryptoassets are capable of constituting property is to determine which remedies are available in relation to that property. This is something which the legal statement does not set out to address in detail, although we agree with the statement in the legal statement that the remedies which the law will provide flow from the analysis of the specific legal rights in question, and that new remedies can be developed over time as necessary (paragraph 10) to fill any vacuum (for example, it is clear from the legal statement that cryptoassets, not being choses in possession, cannot benefit from possessory based claims such as the tort of conversion, being a right to claim against a person who realises value from another personâ€™s property).
14 What is the point of the legal statement if cryptoassets that have been misappropriated canâ€™t be recovered?
For a cryptoasset to be recovered in practice, it is necessary first to determine that the person trying to recover it has a right in or to that cryptoasset. The legal statement seeks to lay the foundations enabling that question to be answered. Whether or not it is then possible in practice to recover a particular cryptoasset will come down to the facts of a specific case.
The legal statement acknowledges that some remedies may be difficult to pursue in practice, but that is an entirely different proposition from there being an absence of legal remedy when circumstances would otherwise permit the exercise of those remedies. For example, when the identity of a person who has misappropriated cryptoassets can be identified, a personal claim based on misappropriation of ownership may be made even if the cryptoassets resulting from an inappropriate spend cannot be traced. In the case of an insolvency, security arrangement, purchase and sale agreement, trust, custody relationship, estate of a deceased owner and many other real- world scenarios where we are not concerned with cryptoassets that have been misappropriated, many uncertainties are resolved by the legal statement, which will enable people to plan their arrangements with greater certainty of outcome.
15 Can a trust or bailment be created over a cryptoasset?
The legal statement concludes that it is possible to declare a trust over an ownership interest in a cryptoasset (paragraph 133).
However, as the legal statement concludes that as a cryptoasset is not a physical thing, it cannot be subject to a possessory relationship, such as a bailment, a lien or a pledge.
Although cryptoassets are not negotiable in the strict legal sense, the legal nature of on-chain transfers of cryptoassets is such as to render cryptoassets as equivalent to negotiable instruments.
16 How can security be taken over a cryptoasset?
By way of charge or mortgage, but not pledge or lien.
The legal statement concludes that cryptoassets are not choses in possession. This means that security interests based on possession, i.e. liens and pledges, cannot be used to create security interests in cryptoassets.
The legal statement sees no issue with the creation of security and states that cryptoassets may be subject to a mortgage or an equitable charge. A mortgage involves the legal transfer of the asset subject to the mortgage, whereas a charge involves the appropriation of an ownership interest in an asset that continues to be owned by the chargor. The legal statement suggests that an off-chain transfer may be used to create some forms of security, although it acknowledges that such security is inherently vulnerable to a security giver that has retained knowledge of the private key spending the cryptoasset and defeating the security. Likewise, any form of security that involves the security giver having knowledge of the private key faces similar risk. In our view, one way to overcome this would be for the security giver to spend the cryptoasset in favour of the security taker so as to create a new cryptoasset owned by the security taker subject to the security, which would likely be a legal mortgage. If such an arrangement is recognised as creating a mortgage, the cryptoasset would not form part of an English security takerâ€™s insolvency estate and the security giver would retain an equity of redemption (being the right to have the asset retransferred to it (or, more accurately, spent in its favour) upon discharge of the secured liability) in the cryptoasset. The security giver is, however, vulnerable to its equity of redemption being defeated by an unauthorised transfer of the cryptoasset from the security taker to a third person. A possible compromise where there is a lack of trust between a security giver and security taker is for the cryptoasset to be transferred to a trusted third party and subject to security, which could be a charge or a mortgage, depending upon who the trusted third party acts for.
17 Which are the applicable laws for disputes about cryptoassets and which courts have jurisdiction to resolve those disputes?
The legal statement does not address this question. Indeed, the legal statement itself expressly acknowledges that this is a highly significant limitation on its scope (paragraphs 89 to 99).
The limitation relates to the determination as to which legal systemâ€™s laws should apply to determine the answer to a dispute in relation to property interests in a cryptoasset and which jurisdictionâ€™s courts will have jurisdiction over such a dispute.
Property interests are most relevant in scenarios where personal claims have limited value. These mostly relate to occasions when there are more than two people involved in a dispute over ownership of the property, when one person may be or become insolvent, when a person dies or when someone wishes to assert a claim or remedy based on a proprietary interest. Taxation, regulation, criminal law and other property related laws â€“ for example, trust law â€“ may also depend upon the applicable law governing rights to the property.
The law that applies to determine the applicable law is a matter for each jurisdiction. Although the details may vary from one jurisdiction to another, there are general principles that are common across most jurisdictions. Questions relating to property are generally subject to the law of the â€œsitusâ€ (location) of the property. For a tangible chose in possession, this will be where it is physically located. For an intangible chose in action, this will depend upon the nature of the chose in action â€“ typically the governing law of a chose in action determines its location, but a registered security is often located at the place where the register is kept. For a cryptoasset, which is not a chose in possession, determining its situs is no easy task. The very nature of a distributed ledger means that there is unlikely to be a governing law of the asset or a single location, in either case, that can be used to determine the law governing a dispute relating to property interests in a cryptoasset.
Despite the above, there are many circumstances in which English law may be the most appropriate law to determine disputes relating to ownership interests in cryptoassets. Examples are: when an English owner of cryptoassets becomes insolvent or dies, when English law security is created over a cryptoasset or a cryptoasset is held under the terms of an English law trust and when a cryptoasset is owned by an English resident person, including when it is entrusted to a custodian resident in England. Additionally, in the case of a permissioned cryptoasset, the nature of the permissioning (for example if there is a law that governs the permissioning or if there is a master permissioned node located in a single jurisdiction) may also point towards an applicable governing law. Whilst the above does not detract from the challenges of determining which law should apply to a dispute between several people located in different countries over ownership to a cryptoasset, these principles will help where there is a clear connection with English law.
In addition to considerations as to which law should determine the allocation of property interests in a cryptoasset, there will also be challenges in determining which are the appropriate courts to resolve any dispute. Again, the issues are complex, but the English courts can be expected to accept jurisdiction when English law determines the allocation of property interests in a cryptoasset.
18 Doesnâ€™t this open the floodgates to categorising as property many things that have not traditionally been recognised as property under English law?
We think that is unlikely. It is true, however, that the basis for concluding that cryptoassets should in principle be capable of being owned is not specific to cryptoassets. It is conceivable, therefore, that the same analysis may apply equally to other arrangements (whether innovative or already established).
The legal statement presents a case for cryptoassets being property by reference to the broad characteristics of property (see paragraphs 49-58). It describes certain key features commonly associated with cryptoassets and applies these general descriptions to the identified characteristics of property.
19 Which issues did the legal statement not cover?
There were many issues that the legal statement was not commissioned to address (see paragraphs 10 to 12). These include:
> conflicts of laws questions, such as when English law would be the correct law to consider matters of ownership of cryptoassets. We have provided some detail on this in FAQ 17 above;
> remedies, such as what recourse would there be against someone who interferes with the ownership rights of someone who owns cryptoassets. We have provided some detail on this in FAQs 13 and 14 above;
> regulation, such as whether a licence or other regulatory approval is required to effect certain dealings in cryptoassets and questions of specific regulatory characterisation, for example under settlement finality legislation; and
> other legal matters more appropriately dealt with by legislation, such as taxation, criminal law, partnership law, data protection, intellectual property, consumer protection, regulatory capital, anti-money laundering and counter- terrorist financing.
This publication is intended merely to highlight issues and not to be comprehensive, nor to provide legal advice. Should you have any questions on issues reported here or on other areas of law, please contact one of your regular contacts, or contact the editors.
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