[Governance] 170 orgs send an open letter to UN SG to stop plans for a new High Level Multistakeholder Body
Mueller, Milton L
milton at gatech.edu
Tue Mar 23 13:39:21 EDT 2021
As I stated earlier, I think this dialogue is worth having, even if most of Parminder's arguments are weak and the neoMarxist ideology underlying them have been proven time and again to lead to stunted economic development and authoritarian systems of governance. It is worth having because it deals with the fundamentals of internet governance and many may share some of his ideas and mistakes.
In Parminder's response, he said that I "have defined Internet/ digital governance to be the technical governance of the Internet." False. I pointed out that technical governance of the internet - to quote me accurately, I said "key elements of the internet infrastructure" - is taking place via private sector and civil society-based multi-stakeholder institutions. I note that these are actually working quite well, and you have been unable to offer serious critiques of those institutions. And far from being in an ivory tower, we have been directly involved in all of them.
But I went on to point out that "many new problems and new forms of governance are evolving at the transnational layer that go well beyond critical internet resources. They affect issues areas such as cybersecurity, content moderation, and privacy." I recognize those (and others, such as platform governance) as IG issues - indeed, IGP focuses more and more on those issues now. That is the space we are debating about. Your inability to accurately represent this distinction between CIR governance and IG policy does not bode well for the kind of contribution you think you can make to the broader IG debate.
Now let's take a look at your JustNet letter. https://justnetcoalition.org/big-tech-governing-big-tech.pdf Note that I chose to take it seriously enough to respond, unlike many others.
Keep in mind that, as I stated the first time, IGP is not a supporter of any specific proposal in the 'Roadmap for Digital Cooperation.' But we do find your attack on it to push in a direction that is much worse than anything they proposed.
You say it is "unacceptable that such an apex policy body will have corporation and government nominees sitting as equals." So, let's be clear: you are rejecting the multistakeholder principle and advocating for a traditional intergovernmental arrangement of the sort favored by authoritarian states. Their preference has always been to exclude the private sector and civil society from direct participation and make IG a governments-only game. Your attempt to revive the long-dead "enhanced cooperation" process pushes in that direction as well.
You also object to the use of private sector funding, allegedly because this will corrupt the process. While it is true that, say, an entity funded entirely by Microsoft or Facebook would be biased and problematic, I am curious as to why you have no similar concerns about governmental funding. Are you saying that the U.S., China, Russia, the UK or European Union are entirely selfless, virtuous entities with no special interests they would push? Are you saying that nation-states never support or withhold support for UN agencies based on their politics? Maybe you have forgotten about the recent US withdrawal from WHO? Or the infiltration of the UN Human Rights Council by states that want to suppress discussion of HR violations?
Note that it is overwhelmingly private sector funding and operation that built the internet and keeps it going. Are you proposing a return to the state-owned PTTs of the 19th and early 20th century? They have a pretty poor record, both in terms of development and rights.
Fact of the matter is, if IGF - even in its current form - is going to survive, it is going to need money, and whoever provides that money is going to see it as in their interests in some way. Ergo, drawing on diverse private sector resources in addition to UN's governmental budget or governmental sources can actually improve its independence and quality.
More broadly, the corporations who would most likely be tapped do not have common interests, which I am sure you know if you have been paying any attention to the Apple-Google-Microsoft-Facebook-Tiktok disputes).
You assert that "a High level Multistakeholder Body for 'Digital Cooperation'...would become the de facto body for 'global digital governance'." This is either a tremendously ignorant or absurdly demogogic statement. Just to take the three most significant power centers, the US, the EU and China, all have active and powerful antitrust authorities, who are engaged in a rather systematic assault on the platforms. All three, plus India, have legal and regulatory powers over data, privacy and so on, and are actively using them. With the exception of the US, all have extensive censorship powers, and are actively using them. All are partitioning the internet based on claims of "national security." All are asserting, or exercising, extra territorial jurisdiction I various ways.
If you are claiming that somehow a loose, weakly funded UN-based multistakeholder alliance is going to negate or supersede these uses of state power, you are really out of touch with the political and economic realities of internet governance and have no business accusing anyone of being in an ivory tower.
Now let's consider your (quite vague) ideas about what should be done instead. All you say is that you want a "a genuinely democratic system for global digital governance, keeping vested corporate interests at bay." It is evident that you, like the People Republic of China, mean by "democratic" a multilateral system, one government one vote, in which individuals have no role and the actual private sector owners and operators of networks and applications are "kept at bay" and regulated in a top-down manner by a collection of states. You have no idea how states with fundamental disagreements about rights, law, political economy and economic policy will come to agreement on how to do this, of course.
So I am sorry, I fail to see anything in your letter other than posturing, raising the spectre of a huge and powerful corporate-dominated entity in order to mobilize a bunch of fringe groups into another anti-capitalist diatribe.
Dr. Milton L Mueller
Georgia Institute of Technology
School of Public Policy
From: parminder <parminder at itforchange.net>
Sent: Monday, March 22, 2021 7:51 AM
To: Mueller, Milton L <milton at gatech.edu>; governance at lists.igcaucus.org
Subject: Re: [Governance] 170 orgs send an open letter to UN SG to stop plans for a new High Level Multistakeholder Body
On 22/03/21 2:15 am, Mueller, Milton L wrote:
I've looked over the letter and am not impressed;
Milton, thanks for responding, even though you find the Digital Cooperation initiative irrelevant. This is certainly much better than what many here who are actively engaged with shaping and pushing this initiative have bothered to do. I hope they also express their response and views.
not with the argument it presents nor with the astroturfed list of 170 organizations.
So you find the active involvement and support of global organisations that are, for instance, the primary global networks of grassroots organisations in areas like health, education, food security, and conservation; top global trade unions; top global organisations working on gender justice, and global trade; some of the most prominent global development NGOs; as astroturfing? The most prominent among these, if not members of Just Net Coalition, are actually in active partnerships with the JNC on Internet/ digital governance issues. And mind you, this is the support we got over just 3 days which unfortunately included a weekend -- owing to a deadline for submitting comments to the UN process.
You dismiss them as some irrelevant anti-globalisation organisations and activists from two decades ago; losers, perhaps, who lap up any global campaign letter thrown at them for getting their names printed on it!
I reckon then that real people's perspectives and representation in Internet/digital governance matters should come from from a certain professorial chair at Syracuse University in the US, or it is that you have now shifted to somewhere in Georgia.
A group of around 20 prominent global organisations and networks, having prepared this letter, are currently collaborating over an e-list for follow-ups, including establishing contacts with people inside the UN, government delegates etc, apart from spreading the message wider among CS groups and engaging them.. And this is outside the Just Net Coalition, JNC being just a participant in this collaboration.
This should puncture the pompous arrogance with which you typically come to such matters, and we can move now to more substantive matters. See in-line.
We at IGP have largely, and deliberately, ignored the UN's initiatives around so-called High Level
Digital Cooperation. Not because we think it is leading in a bad direction or is part of an evil capitalist plot, nor do we think the people promoting it are badly motivated. We just think it is mostly irrelevant. It is founded on model of governance that is unrealistic and unlikely to have any impact on the internet (or platforms, which is not the same as the internet).
The Internet consists of 70,000 autonomous systems using a common layer 3 and 4 protocol to communicate. Key elements of the internet infrastructure are governed by what we call the Organically Developed Internet institutions, such as IETF (standards), ICANN (domain names) the Regional Internet Registries (IP addressing) and cooperative action among network operators (routing, interconnection).
Because the internet has created a globalized space for communication, many new problems and new forms of governance are evolving at the transnational layer that go well beyond critical internet resources. They affect issues areas such as cybersecurity, content moderation, and privacy.
So, you have defined Internet/ digital governance to be the technical governance of the Internet plus largely these three areas involving a digital version of libertarian minimal state. You do not consider, for instance, data, AI or platform regulation, especially the distributive issues involved therein, as Internet/digital governance, right. You have the right to your definitions of Internet/ digital governance, but it is evident that the world overwhelming disagrees with you, including the IGF (see its program).
Some of these transnational initiatives are, in our opinion, praiseworthy; others are not. But it is both unlikely and undesirable for them to be consolidated or centralized in the hands of a single global body, whether it is called "multistakeholder" or "intergovernmental." No such body is going to be able to have the power or the expertise or the widespread legitimacy and participation to address all these areas. Only a dialogue forum is possible at the IGF level.
Two responses to this: One, lets consider the WHO; It really cannot be considered as global health governance being 'consolidated or centralized in the hands of a single global body' . But it still does very useful norms and standards setting work, develops global legal instruments, as required and possible, develops and coordinates frameworks of responses and other programmatic action, does neutral public interest global research and capacity development, and so on. WHO's existence has been extremely useful, and has not impeded other transnational initiatives This is true of UN global governance bodies in all areas. Digital is more inherently global than any other sector. So, why would a similar body for Internet/ digital governance not also be useful.
Second: But if in any case you still remain absolutely opposed to a cross-sectoral, apex, digital policy and governance body, and I have been raising this same issue for at least 12-13 years now, why you never oppose the OECD's Committee on Digital Economy Policy (CDEP)? In the name of the body, 'Economy' is there only for forms sake. This committee shapes digital policy in all areas, from principles for tech architecture, to platforms and content, to data and AI. Why do OECD needs a transnational, single digital governance body, when you so strongly oppose such a body at the global level. I have raised this issue often, and at one time when you could not avoid responding, you dismissed this body as a capacity building body, which is of course an untruth. OECD committees do go as far as developing legal instruments<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Flegalinstruments.oecd.org%2Fen%2Finstruments%2FOECD-LEGAL-0347&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107742995041%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=5A%2F4HOwxmh%2F26SLcBCw7igI4RLu6o3EJ8ybTozsEdDs%3D&reserved=0>.
The latest initiative of the CDEP is on government access to data held by the private sector<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.oecd.org%2Fsti%2Fieconomy%2Ftrusted-government-access-personal-data-private-sector.htm&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743005033%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=%2BsnBqk3C3gn8Ra9l8QcZJNzw7oS0OjELQu8WZ39qW6E%3D&reserved=0>. The likely outcomes could be a document of policy principles but it could even be a legal instrument. Since digital policy making is a cross-sectoral work, CDEP often works in collaboration with other OECD Committees towards different ends. For instance, it worked with the Committee on Health to develop Health Data Principles<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fone.oecd.org%2Fdocument%2FCOM%2FDELSA%2FDSTI(2016)1%2Fen%2Fpdf&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743005033%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=fPxsGyoM%2BliqBAFlwep5erlwRZ2Sy4TRYzgBsA2CW24%3D&reserved=0>. A very appropriate kind of output, and done in the right way too. Similarly a UN body on digital governance -- while all countries and not just the richest ones are represented -- should work with the WHO to develop global Health Data Principles. In default of an UN Internet/ digital governance body, OECD's norms, principles and policies become the default global one.
But here you develop cold feet... OECD committees should keep functioning and rolling out global governance norms, principles and policies, but not any UN body. That is not needed, any such thing is completely relevant. This is plainly a colonial attitude. It is a pity that in the global Internet/ digital governance space one can openly do such a thing. It normally does not happen elsewhere, in global civil society spaces.
You are from the US, why dont you advocate to the OECD, where your gov sits, to cede its one-point cross-sectoral digital norms/ policy work, and abolish the body specifically made for this purpose? What right do you have to tell the rest of the world to not do it? I repeat, it is plain and simple colonialism.
Worse, increasingly, national governments are trying to interfere with or control usage of the internet at the application layer. This is leading to an increasingly fragmented, costly, and repressive environment. One could call this tech nationalism, jurisdictional alignment, fragmentation or a digital neo-mercantilism. IGP has published numerous critiques of these pathologies.
In this context, for JustNet and its partners to portray "regulation of big tech" as the salvation of the internet, and the UN's attempt to create a High Level MS Body as an entity with "overweening power" that "would help Big Tech resist effective regulation" is just laughable.
First, the term 'overweening power' is used for Big Tech, and not the proposed High Level MS body. And if you do not think that Big Tech today has overweening power, which needs to be urgently regulated, it is you who is entirely out of touch with global intellectual, political, as well as public opinion. You are sitting lonesomely in some untenable libertarian ivory tower. But one thing I must commend you for is consistency. You responded to one of my emails years back in this very same space saying that you think 'social justice' is a meaningless term. So while consistent you might be, you are completely out of touch with contemporary digital reality. Internet, and those who were associated with it, were seen 20 years ago as representing counter power; today the Internet is controlled by those who represent the most pernicious incumbent power. Counters have now to be developed to this entrenched and fast expanding power. If 'your' internet governance is not taking note of this -- what is happening just outside your window -- it is you who is stuck in some 20 year old realities, not the organisations that developed and supported this campaign letter.
I do not see how anyone with any deep knowledge of IG can take it seriously. It has very little relevance to contemporary problems of IG.
Your IG knowledge has perhaps gone too deep - so deep that you may be alone wallowing there in the deep, in a manner very irrelevant to contemporary problems of IG. Although, your no doubt incisive and well written analyses -- however besides the point mostly -- do often provide very good cover to contemporary 'bad' digital forces. And therefore they get lapped up. Like this current email of yours is doing great favours to the shapers and supporters of the Digital Cooperation High Level MS Body, who themselves have little to be able to present their case in a democratic-discursive way, in spaces like this public elist.
Insofar as it has any substance, it seems to call for more nation-state based regulation of internet operations and content. But this is something that, from Trump's Great Firewall of America, to Russia's "sovereign" Internet, to Europe's NIS2, to India's app blocking and censorship, to China's insulated internet, we already have plenty of. And we are getting more and it seems to be making things worse.
There has to be a limit to the Libertarians' clever technique to continue quoting the undoubted statist excesses vis a vis the digital to keep at bay appropriate regulation of Big Tech, and also the needed national policies to escape the coming bi-polar US-China's complete digital and AI domination of the word. State's undue power has to be resisted at the same time as a rule of law has to be established and applied for governing non-state bad actors.
By the way, has anyone at JustNet noticed that Facebook is joining them in their call for more internet regulation at the national level? Think about the implications of that for a moment: https://about.fb.com/regulations/<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fabout.fb.com%2Fregulations%2F&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743015025%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=9JSoftenN07OggfE7WOl8hKhaP54A4QNK2oiyJH8k9Q%3D&reserved=0>
If you read the letter, you can see that they obtained the support of all these organization - very few of whom actually focus on Internet or ICT governance
For you Internet governance is about core technical systems of the Internet/ digital. For everyone else, its scope and meaning is fast expanding outwards, getting closer to the points and manners of the real-life impacts of the digital. There are of course organisations in this list of 170 plus organisations that deal centrally with digital governance, but then many others that are looking at platform/data/AI governance in relation to food and agriculture, health, education, trade, gender relations, labour, and so on. There is one that is a chief port-of-call for developing country governments on e-commerce issues in trade deals (btw, much of IG today is done in and through trade deals), another is represented in a new data working group of the World Committee on Food security of FAO, a third is developing health data principles, another working on feminist digital justice, another on how platforms use data to control dependent businesses, .... I can keep going, but you get the point.
Should they all come to Prof Milton Mueller to get what Internet/ digital governance is!? It is perhaps time you go to them, if you have to keep 'your' IG relevant.
- by equating the UN HLDC with the World Economic Forum. This is factually wrong, but it does succeed at throwing red meat in front of the anti-globalization activists from two decades ago.
No one equated UN HLDC with the WEF. It is was another WEF we wont have such a problem. What we have shown is that UN HLDC represent the exact unfolding of a plan for global governance that WEF laid out 10 years back through its Global Redesign Imitative. And we provide exact quotations. Dont you see the difference?
I have already described what these organisations are. You make fun of them at your own cost.
Internet governance needs to be accomplished from the bottom up, and rely heavily on networked, non-hierarchical forms of governance.
But not when OECD does it ... They are rich people and nations, mostly of the western civilisation, they know what they are doing, they have superior rights over the world! Please stop this colonial narrative.
We need to protect and strengthen, not destroy or undermine, the organically developed internet institutions. When state-based, hierarchical interventions are necessary, they need to be carefully circumscribed and focused to address real problems that cannot be handled in any other way, such as crime, fraud, and coercion.
Your libertarian definition of the scope of Internet/ digital governance! Sorry, developing countries at least cannot agree. For us economic issues, regulating Big Tech, developing domestic digital industry, etc are all very important.
The UN should stop trying to become a centerpoint of global internet governance and continue to serve as a place for dialogue and network building.
Go first tell this to your country and the OECD...
Meanwhile, further discussion is very welcome.
Dr. Milton L Mueller
Georgia Institute of Technology
School of Public Policy
From: Governance <governance-bounces at lists.igcaucus.org><mailto:governance-bounces at lists.igcaucus.org> On Behalf Of parminder via Governance
Sent: Saturday, March 13, 2021 12:30 AM
To: governance at lists.igcaucus.org<mailto:governance at lists.igcaucus.org>
Subject: [Governance] 170 orgs send an open letter to UN SG to stop plans for a new High Level Multistakeholder Body
The open letter was sent to the official consultation process, signed by more than 170 organisations.
It was titled ""More than 170 Civil Society Groups Worldwide Oppose Plans for a Big Tech Dominated Body for Global Digital Governance" .
Please see the final statement and endorsements at
It was also translated into Spanish, French, German and Dutch. All versions are linked from the enclosed document
We had just 3 days to get sign ons, out of which 2 were weekend days. In the circumstances, the number is quite good. It shows the groundswell to opposition to this move. Thanks to everyone who supported this.
We will now get this letter also sent directly to the UN SG and his new Tech Envoy.
We will like to keep this campaign open for some time to get additional support and build awareness ...
This ongoing campaign is just a start, much more needs to be done and will be done to stop this assault on democracy and on possibilities of effective regulation of Big Tech. We will be doing all it takes, including engaging with governments.
We will follow a twin track: develop a powerful movement within civil society groups, and engage with governments and the UN.
Will keep you posted.
On 05/03/21 2:15 pm, parminder via Governance wrote:
This is an open letter to the UN Secretary General<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fjustnetcoalition.org%2Fbig-tech-governing-big-tech.pdf&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743025019%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=3TT8bEZQ3%2B%2BctKS6oTJgzZFiND6Jwl5gv4vXvmdr9Zc%3D&reserved=0> initiated by 16 global and national level civil society networks and organisations urging him to shelve plans for a High Level Multistakeholder Body which, if set up, can be expected to become the default apex global digital governance and policy body. This body is proposed to have a private funding model, with strong hints also at a 'pay to play' model. It is but obvious that Big Tech will come to dominate any such body.
Quoting from the letter:
Not only in developing countries but also in the US and EU, calls for stronger regulation of Big Tech are rising. At the precise point when we should be shaping global norms to regulate Big Tech, plans have emerged for an 'empowered' global digital governance body that will evidently be dominated by Big Tech. Adding vastly to its already overweening power, this new Body would help Big Tech resist effective regulation, globally and at national levels. Indeed, we face the unbelievable prospect of 'a Big Tech led body for Global Governance of Big Tech'.
Two technical annexes to the open letter explain the background of the matter in considerable detail.
This letter is open for endorsements, which can be done by writing an email to secretariat at justnetcoalition.org<mailto:secretariat at justnetcoalition.org> or filling this form<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fjustnetcoalition.org%2Fbig-tech-governing-big-tech-form&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743025019%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=OHqaUWlDEw2GrBwrCfqJ%2F7DxnMYCbUPvoMLTkjuWGng%3D&reserved=0> before midnight PST (GMT-8) of the 7th of March.
Please also do circulate to other groups and networks where it may attract interest.
The open letter may also be accessed at https://justnetcoalition.org/big-tech-governing-big-tech.pdf<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fjustnetcoalition.org%2Fbig-tech-governing-big-tech.pdf&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743035014%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=1%2FkmdHKbyNos00%2FjJKXEYAiDMmo9YqYxycHhBbk8ODM%3D&reserved=0>
French text is at : https://justnetcoalition.org/big-tech-governing-big-tech-french.pdf<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fjustnetcoalition.org%2Fbig-tech-governing-big-tech-french.pdf&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743045008%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=9SmzlOs7upKDdi%2FtZOK9phgb00rUbsol2vJeWMQ1G7I%3D&reserved=0> and Spanish version at - https://justnetcoalition.org/big-tech-governing-big-tech-spanish.pdf<https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fjustnetcoalition.org%2Fbig-tech-governing-big-tech-spanish.pdf&data=04%7C01%7Cmilton%40gatech.edu%7C2dcfd5131f4f441c626c08d8ed28bb9a%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637520107743045008%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=Kmx1IA2dhXbY8saboeEMC%2Frkis8Ul0%2FxCVLITBygdLk%3D&reserved=0>
Please let us know if you have any questions or comments regarding the above.
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