[2011] FWA 8903 |
|
DECISION |
Fair Work Act 2009
s.394—Unfair dismissal
Bruce Turton
v
FMC Australasia Pty Ltd
(U2011/10931)
COMMISSIONER HAMPTON |
ADELAIDE, 22 DECEMBER 2011 |
Unfair dismissal application - preliminary point - whether dismissal within the meaning of the Act - whether dismissal at the employer’s initiative - whether applicant resigned and if so, whether forced by employer’s conduct - whether application has no reasonable prospects of success - dismissal found - considerations going to whether dismissal unfair to be taken into account in the substantive hearing - matter to be listed for conciliation.
INTRODUCTION AND CASE OUTLINE
[1] This matter arises in the context of an application by Mr Bruce Turton (the applicant or Mr Turton) pursuant to s.394 of the Fair Work Act 2009 (the Act). The respondent employer is FMC Australasia Pty Ltd (FMC or the respondent).
[2] FMC has sought that the unfair dismissal application itself be dismissed on the basis of a preliminary point; namely, that it did not dismiss the applicant within the meaning of the Act. On that basis, it contends that the unfair dismissal application should be considered to be beyond the jurisdiction of Fair Work Australia and dismissed pursuant to s.587 of the Act given that it would be frivolous or vexatious, or in the alternative, having no reasonable prospects of success. The respondent employer relied upon the decision of the Federal Court in Australian Postal Corporation v Gorman [2011] FCA 975 (Gorman) to support the notion that these circumstances could be considered and dealt with pursuant to s.587.
[3] Section 587 of the Act provides as follows:
“587 Dismissing applications
(1) Without limiting when FWA may dismiss an application, FWA may dismiss an application if:
(a) the application is not made in accordance with this Act; or
(b) the application is frivolous or vexatious; or
(c) the application has no reasonable prospects of success.
(2) Despite paragraphs (1)(b) and (c), FWA must not dismiss an application under section 365 or 773 on the ground that the application:
(a) is frivolous or vexatious; or
(b) has no reasonable prospects of success.
(3) FWA may dismiss an application:
(a) on its own initiative; or
(b) on application.”
[4] It is common ground that during the course of a meeting conducted on 6 July 2011, the respondent informed the applicant that their employment relationship could not continue and that the relationship had effectively concluded by the end of the meeting.
[5] Mr Miller, who appeared for the respondent, contended that although the employer intended the employment relationship to conclude, what in fact occurred was that the parties agreed to a mutual termination where the applicant resigned as part of an agreed arrangement. This, it was contended, meant there was no dismissal and the resignation was an act of free choice. In that light, the applicant should not be given the opportunity to change his mind and have the alleged unfair dismissal matter determined. The respondent referred to Ozaras v Toll Pty Ltd [2008] AIRC 333 1 (Ozaras) as support for the proposition that a relevant dismissal should not be found in equivalent circumstances.
[6] The applicant, who was represented with permission by Mr Telfer (of counsel), contended that he was dismissed by the respondent employer and the alleged resignation was in fact the direct consequence of the employer’s decision to conclude the relationship. That is, the applicant had the choice to resign or be sacked. This, it was said, was a constructive dismissal within the meaning of the authorities and a dismissal within the meaning of the Act.
THE EVIDENCE
[7] I heard the evidence of Mr Pegg, 2 the respondent employer’s Managing Director, and Mr Turton3. I found both to be witnesses of truth and the tensions between their evidence were generally the result of marginally different, but genuine, recollections.
[8] In fact, there are only marginal differences between the versions given by each party and I have resolved those conflicts based upon my assessment of each witness and the consistency of that evidence.
[9] I note that a witness statement from Mr Walsh, the respondent’s Finance Manager, was also provided however he was unable to attend the hearing and FMC did not press for the admission of that evidence.
WHAT HAPPENED LEADING INTO AND ON 6 JULY 2011?
[10] Mr Turton was at the time of these events the Business Development Manager (SA, WA and NT) for the respondent employer. There had been certain performance and customer relationship issues discussed between the parties and a performance management process was being undertaken during most of 2011.
[11] On 6 July 2011, the applicant was in Brisbane to attend a national sales meeting that was due to be conducted over three days. Immediately prior to the scheduled time for the meeting to commence, Mr Turton was approached in the meeting room where the sales staff were assembled and requested by his immediate supervisor to have a private discussion with Mr Pegg.
[12] When Mr Turton attended Mr Pegg’s office, he found Mr Walsh was also there.
[13] Mr Pegg provided the applicant with a copy of a letter from a major customer of FMC which made a number of negative comments about Mr Turton and amongst other matters, indicated that he would not be welcome to attend at the customer’s premises. Without detailing the alleged basis of those concerns in this decision, it is appropriate to note that there was no suggestion of impropriety by Mr Turton.
[14] Mr Turton then made a number of comments about the basis of the customer’s alleged complaints and observed that the writer of the letter was a difficult person who had had strained relationships with others at FMC. This and related issues were then also discussed between the applicant and Mr Pegg.
[15] Mr Turton then said “Where are you going with this” and Mr Pegg said words to the effect of “We can no longer have you as part of FMC”.
[16] Mr Turton, not surprisingly, become concerned that he was being dismissed and sought details of what FMC was offering. Mr Pegg advised that he would be paid one months pay in lieu of notice and support from an outplacement service provider. Mr Turton was then handed a copy of that service provider’s brochure.
[17] Mr Turton indicated that they should be talking about a redundancy package of six weeks per year of service and an additional six weeks pay. Mr Pegg replied in effect that this was not a redundancy but rather a dismissal or alternatively, a resignation; that they could both save face; and the applicant should resign. Mr Pegg offered to give Mr Turton an extra months pay and the alternative of $2,000 in lieu of the outplacement services.
[18] The applicant indicated that this was “OK” and subsequently clarified that he wanted the outplacement services.
[19] It is also likely that the men discussed the applicant’s motor vehicle and other non-cash benefits, which were part of the salary package, as part of these exchanges and that their continuing provision was agreed.
[20] Mr Pegg indicated that he would have Mr Walsh write up a letter and they then discussed and agreed that Mr Turton would not (continue to) attend the sales meeting and would make arrangements to travel home to Adelaide that day. Mr Pegg directed the applicant to arrange his travel with another employee and that he was to leave his laptop computer with the national office (after removing any personal material).
[21] When attending upon the other employee, Mr Turton became aware that potential flights for him to travel back to Adelaide had already been sourced and that his laptop computer had already been removed from the meeting room where he had left it.
[22] After checking out of his Brisbane hotel, the applicant attended back at head office and was in due course given a letter by Mr Walsh to countersign, which he did. That letter read as follows:
“6th July 2011
Bruce Turton
...
Dear Bruce
I refer to your formal discussions with us this morning and confirm our agreement that you will resign your position with FMC Australasia Pty Ltd and that your last day of employment will be Friday 5 August 2011.
In addition to the salary and other benefits which you will continue to enjoy until 5 August, and the payment of your statutory entitlements at the time, FMC have agreed to provide you with the following additional benefits:
a) An ex-gratia payment in the sum of $5,720.08 representing one month’s salary. This amount will be taxed as an Employment Termination Payment;
b) One month’s coaching / counselling programme provided by Talent2 to the value of $2,000.00. You will be provided with a letter addressed to Talent2 which will enable you to access these services. All of the costs incurred in relation to the provision of those services will be met by FMC.
c) In addition to your cash salary and the ex-gratia payment referred to above, you will continue to enjoy the use of the company car and/or an allowance to the equivalent value for a period of two months, until Tuesday 6 September 2011. In relation to the use of the motor vehicle, the company will continue to be responsible for and pay all costs associated with your reasonable use of the motor vehicle, including fuel. In this respect, reasonable use means ordinary day-to-day personal travel but excludes extended journey unless FMC permission has been obtained.
Although you will remain in employment with FMC until 5 August, FMC does not expect you to undertake any new business or initiatives but expect you to complete any outstanding matters prior to handover. In that regard, Ian Pegg will contact you prior to 5 August.
In relation to any discussions you may now undertake with prospective employers, FMC understand that you may wish to attend discussions and interviews during the course of the next few weeks. Any enquiries from a prospective employer should be made to Ian Pegg.
The company will issue a short statement to its staff, customers and suppliers noting that you have resigned your employment, with the company with effect from 5 August. It will also be appropriate for you to notify you personal contacts in the industry, should you wish to do so. Beyond that, it is agreed that there will be no statement or discussion on either side in relation to this matter or in relation to this agreement and that nobody on the part of FMC will make any disparaging statement about you and you will not make any disparaging statement to anyone about FMC or any of its officers, employees or agents.
You acknowledge that you understand the terms of this letter and that you have had the opportunity to seek appropriate independent advice prior to agreeing to these terms.
Apart from any reasonable communication to any professional adviser, it is a term of this agreement that the parties will keep these terms absolutely confidential.
You should signify your agreement to these terms by signing this letter in the place provided below and returning it to us.
Yours sincerely
(signed)
FMC
I, BRUCE TURTON , agree to the terms of this letter.
DATED this day of July 2011
(signed)
...............................................
Signature of Bruce Turton”
WAS MR TURTON DISMISSED BY FMC?
[23] Fair Work Australia will only have jurisdiction to deal with the unfair dismissal application if Mr Turton was dismissed within the meaning of the Act. This is evident from s.385 of the Act which provides:
“385 What is an unfair dismissal
A person has been unfairly dismissed if FWA is satisfied that:
(a) the person has been dismissed; and
(b) the dismissal was harsh, unjust or unreasonable; and
(c) the dismissal was not consistent with the Small Business Fair Dismissal Code; and
(d) the dismissal was not a case of genuine redundancy.
Note: For the definition of consistent with the Small Business Fair Dismissal Code: see section 388.”
[24] Section 386 of the Act provides as follows:
“386 Meaning of dismissed
(1) A person has been dismissed if:
(a) the person’s employment with his or her employer has been terminated on the employer’s initiative; or
(b) the person has resigned from his or her employment, but was forced to do so because of conduct, or a course of conduct, engaged in by his or her employer.
(2) However, a person has not been dismissed if:
(a) the person was employed under a contract of employment for a specified period of time, for a specified task, or for the duration of a specified season, and the employment has terminated at the end of the period, on completion of the task, or at the end of the season; or
(b) the person was an employee:
(i) to whom a training arrangement applied; and
(ii) whose employment was for a specified period of time or was, for any reason, limited to the duration of the training arrangement;
and the employment has terminated at the end of the training arrangement; or
(c) the person was demoted in employment but:
(i) the demotion does not involve a significant reduction in his or her remuneration or duties; and
(ii) he or she remains employed with the employer that effected the demotion.
(3) Subsection (2) does not apply to a person employed under a contract of a kind referred to in paragraph (2)(a) if a substantial purpose of the employment of the person under a contract of that kind is, or was at the time of the person’s employment, to avoid the employer’s obligations under this Part.”
[25] Only ss.386(1) is relevant to this application.
[26] Although applied under the previous Act, the following approach of the Full Bench of the Australian Industrial Relations Commission in O’Meara v Stanley Works Pty Ltd 4 in my view remains generally apposite:
“Termination at the initiative of the employer
[19] The circumstances in which a resignation, while apparently a termination of employment by the employee, nevertheless constitutes a termination at the initiative of the employer, have been considered in a number of cases. A prominent authority is the decision of a Full Court of the Federal Court of Australia in Mohazab v Dick Smith Electronics Pty Ltd (Mohazab). In that case, the employer made a threat that unless the employee resigned the employer would ask the police to charge the employee with an offence. The analysis of the concept of termination at the initiative of the employer by the Court in that case has not always been quoted in full. It is desirable that we do so in this case. After referring to dictionary definitions of the term “initiative” and the convention giving rise to the statutory provisions, the Full Court said:
“These definitions reflect the ordinary meaning of the word ‘initiative’. Viewed as a whole, the Convention is plainly intended to protect workers from termination by the employer unless there is a valid reason for termination. It addresses the termination of the employment relationship by the employer. It accords with the purpose of the Convention to treat the expression ‘termination at the initiative of the employer’ as a reference to a termination that is brought about by an employer and which is not agreed to by the employee. Consistent with the ordinary meaning of the expression in the Convention, a termination of employment at the initiative of the employer may be treated as a termination in which the action of the employer is the principal contributing factor which leads to the termination of the employment relationship. We proceed on the basis that the termination of the employment relationship is what is comprehended by the expression ‘termination of employment’: Siagian v Sanel (1994) 1 IRCR 1 at 19; 54 IR 185 at 201. In many, if not most, situations the act of the employer that terminates the employment relationship is not only the act that puts in train the process leading to its termination but is, in substance, the entire process. An example would be a situation where the employer decided to dismiss an employee and did so orally or in writing with immediate effect. Other situations may be more complex as exemplified by the circumstances considered by Moore J in Grout v Gunnedah Shire Council (1994) 1 IRCR 143; 57 IR 243 where an employee had given written notice purporting to terminate the employment relationship. The notice was not reasonable but was accepted by the employer which later refused to allow the employee to withdraw the notice. A question arose as to whether that was a termination of the employment at the initiative of the employer and his Honour held it was. His Honour said at 160-161; 259:
‘I have already said that Div 3 concerns termination at the initiative of the employer. The respondent submits that “initiate” means “to begin, commence, enter upon; to introduce, set going, or initiate”: see Shorter Oxford English Dictionary. In this matter, it is submitted, it was the applicant and not the respondent that initiated the termination by writing the letter of 18 May. This, in my opinion, gives the expression “termination” in the Act, read in conjunction with Art 3 of the Convention which speaks of “termination … at the initiative of the employer”, a narrow meaning that was not intended. A principal purpose, if not the sole purpose, of Div 3 is to provide an employee with a right to seek a remedy in circumstances where the employee did not voluntarily leave the employment. An employee may do some act which is the first in a chain of events that leads to termination. An example would be an employee who engaged in misconduct at work which ultimately led to the employer dismissing the employee. However, that situation and the present are not situations where the termination was at the initiative of the employee. In both instances the step or steps that effectively terminated the employment or purported to do so were taken by the employer.’
In these proceedings it is unnecessary and undesirable to endeavour to formulate an exhaustive description of what is termination at the initiative of the employer but plainly an important feature is that the act of the employer results directly or consequentially in the termination of the employment and the employment relationship is not voluntarily left by the employee. That is, had the employer not taken the action it did, the employee would have remained in the employment relationship. This issue was addressed by Wilcox CJ in APESMA v David Graphics Pty Ltd (unreported, Industrial Relations Court of Australia, 12 July 1995, Wilcox CJ). His Honour, at p 3, referred to the situation of an employee who resigned because ‘he felt he had no other option’. His Honour described those circumstances as:
‘… a termination of employment at the instance [of] the employer rather than of the employee.’
And at p 5:
‘I agree with the proposition that termination may involve more than one action. But I think it is necessary to ask oneself what was the critical action, or what were the critical actions, that constituted a termination of the employment.’”
[20] Moore J, one of the members of the Full Court in Mohazab, addressed the question further in Rheinberger v Huxley Marketing Pty Limited (Rheinberger). His Honour said, after referring to extracts from Mohazab:
“However it is plain from these passages that it is not sufficient to demonstrate that the employee did not voluntarily leave his or her employment to establish that there had been a termination of the employment at the initiative of the employer. Such a termination must result from some action on the part of the employer intended to bring the employment to an end and perhaps action which would, on any reasonable view, probably have that effect. I leave open the question of whether a termination of employment at the initiative of the employer requires the employer to intend by its action that the employment will conclude. I am prepared to assume, for present purposes, that there can be a termination at the initiative of the employer if the cessation of the employment relationship is the probable result of the employer's conduct.”
“[21] In this Commission the concepts have been addressed on numerous occasions and by a number of Full Benches. In Pawel v Advanced Precast Pty Ltd (Pawel) a Full Bench said:
“[13] It is plain that the Full Court in Mohazab considered that an important feature in the question of whether termination is at the initiative of the employer is whether the act of an employer results directly or consequentially in the termination of the employment and that the employment relationship is not voluntarily left by the employee. However, it is to be noted that the Full Court described it as an important feature. It plainly cannot be the only feature. An example will serve to illustrate this point. Suppose an employee wants a pay rise and makes such a request of his or her employer. If the employer declines and the employee, feeling dissatisfied resigns, can the resignation be said to be a termination at the initiative of the employer? We do not think it can and yet it can be said that the act of the employer i.e. refusing the pay rise, has at least consequentially resulted in the termination of the employment. This situation may be contrasted with the position where an employee is told to resign or he or she will be terminated. We think that all of the circumstances and not only the act of the employer must be examined. These in our view, will include the circumstances giving rise to the termination, the seriousness of the issues involved and the respective conduct of the employer and the employee. In the instant case the uncontested factual findings are that the applicant had for almost the whole of his employment performed welding duties; that there was no objective threat to his health and safety involved in the requirement that he undertake welding duties so long as it was not on a continuous basis and that the welding he was required to do was not continuous.”
[22] In the Full Bench decision of ABB Engineering Construction Pty Ltd v Doumit (ABB Engineering) it was said:
“Often it will only be a narrow line that distinguishes conduct that leaves an employee no real choice but to resign employment, from conduct that cannot be held to cause a resultant resignation to be a termination at the initiative of the employer. But narrow though it be, it is important that that line be closely drawn and rigorously observed. Otherwise, the remedy against unfair termination of employment at the initiative of the employer may be too readily invoked in circumstances where it is the discretion of a resigning employee, rather than that of the employer, that gives rise to the termination. The remedies provided in the Act are directed to the provision of remedies against unlawful termination of employment. Where it is the immediate action of the employee that causes the employment relationship to cease, it is necessary to ensure that the employer’s conduct, said to have been the principal contributing factor in the resultant termination of employment, is weighed objectively. The employer’s conduct may be shown to be a sufficiently operative factor in the resignation for it to be tantamount to a reason for dismissal. In such circumstances, a resignation may fairly readily be conceived to be a termination at the initiative of the employer. The validity of any associated reason for the termination by resignation is tested. Where the conduct of the employer is ambiguous, and the bearing it has on the decision to resign is based largely on the perceptions and subjective response of the employee made unilaterally, considerable caution should be exercised in treating the resignation as other than voluntary.”
[23] In our view the full statement of reasons in Mohazab which we have set out together with the further explanation by Moore J in Rheinberger and the decisions of Full Benches of this Commission in Pawel and ABB Engineering require that there to be some action on the part of the employer which is either intended to bring the employment to an end or has the probable result of bringing the employment relationship to an end. It is not simply a question of whether “the act of the employer [resulted] directly or consequentially in the termination of the employment.” Decisions which adopt the shorter formulation of the reasons for decision should be treated with some caution as they may not give full weight to the decision in Mohazab. In determining whether a termination was at the initiative of the employer an objective analysis of the employer’s conduct is required to determine whether it was of such a nature that resignation was the probable result or that the appellant had no effective or real choice but to resign.” 5
[27] An objective consideration of the respondent’s conduct is required. If the applicant had resigned, the question would be whether the employer’s course of conduct was such that resignation was forced as the probable result or that the applicant had no effective or real choice but to resign.
[28] In relation to any form of alleged dismissal in a case such as this, it is also important to look beyond the stated intentions of the parties and to objectively consider the effect of the parties’ action in the context in which they occurred. 6
[29] There is little doubt that Mr Turton ultimately negotiated and agreed the terms upon which he was to leave the business. However, his only choice was in reality to resign (as part of a hopefully agreed package) or be dismissed. This choice was effectively acknowledged by Mr Pegg in his evidence. 7 The conclusion of the relationship was announced by Mr Pegg when he advised words to the effect of “We can no longer have you as part of FMC”. Thereafter, the parties discussed and agreed how that would be handled.
[30] This case is squarely on foot with that discussed in ABB Engineering and clearly distinguishable from that faced by the Commission in Ozaras. In Ozaras, the applicant had a choice to allow the disciplinary process to run its course, however he offered and provided his resignation on certain conditions. In this case, Mr Turton’s choice was, as put by Mr Telfer, resign or be sacked, having already been informed by the employer that the employment relationship was ending.
[31] The cessation of the employment relationship was objectively the inevitable result of the employer's decision to end the applicant’s employment and to advise him of that fact.
[32] The fact that it was agreed to handle the dismissal in the form of a resignation and to provide additional benefits in that regard are all relevant to the assessment as to whether the dismissal was unfair. 8 However, in this case these factors do not turn what was a dismissal at the employer’s initiative into a different legal character.
[33] Given that this matter has been argued pursuant to s.587, I have considered whether the subsequent agreed resignation should in its own right be taken to mean the substantive application has no reasonable prospects of success. This was raised indirectly by the respondent as part of its reliance upon the Gorman decision. In Gorman, Besanko J said:
“30 The applicant’s case is that there was an accord and satisfaction between it and the first respondent. It is not suggested that the agreement constituted an accord executory (McDermott v Black (1940) 63 CLR 161 at 184 per Dixon J (as his Honour then was)). It would not matter if the accord and satisfaction was conditional as the applicant is prepared to carry out its obligations under the agreement (Seddon N and Ellinghaus M, Cheshire and Fifoot’s Law of Contract (8th Australian ed, LexisNexis Butterworths, 2002) [4.24]).
31 An accord and satisfaction extinguishes the existing cause of action and replaces it with a new cause of action based on the agreement. A valid accord and satisfaction is not a discretionary factor relevant to the subsequent litigation of the original claim; it is an answer to the claim.
32 It seems to me that the fact of an accord and satisfaction can either be raised under the Act at an ‘interlocutory’ stage and at the final hearing or it cannot be raised at all. As it is a complete answer to a claim there would be no reason why it could be raised at a final hearing but not at a preliminary stage under a section such as s 587.
33 There is nothing in the Act which suggests that an accord and satisfaction should not be recognised. At a general level the object of Chapter 3 Part 3-2 and the general statements of the manner in which FWA is to perform its functions and the matters to which it is to have regard are consistent with the recognition of an accord and satisfaction. Furthermore, the words of subsection 587(1) are wide enough to include the recognition of an accord and satisfaction. As I have said, a valid and effective accord and satisfaction extinguishes the pre-existing cause of action and continued pursuit of an application based on such cause of action is clearly capable of being considered to be frivolous or vexatious or without reasonable prospects of success.
34 Although the Australian Industrial Relations Commission was dealing with s 111(1)(t) of the Workplace Relations Act 1996 (Cth) in Zoiti-Licastro v Australian Taxation Office the considerations which led it to conclude that the Senior Deputy President had the power to dismiss an application on a summary basis on the ground that there was a binding settlement agreement apply with equal force under the Act.”
[34] However, in this case there is no suggestion that the agreement between the parties represented any form of release from proceedings or legal rights and I have already found that it did not change the legal character of the dismissal for present purposes. There may also be other considerations raised by s.387 of the Act that could mean the dismissal was unfair, despite the apparent circumstances and the manner in which it was ultimately handled.
CONCLUSION
[35] I have found that Mr Turton was dismissed within the meaning of the Act. There is jurisdiction to hear and determine the unfair dismissal application. There is also at present, no basis to dismiss that application pursuant to s.587 of the Act.
[36] I note that conciliation of this matter has not yet taken place. Without making any more detailed assessment of the respective merits, as outlined earlier, the facts discussed in this application would be relevant to the consideration of whether this dismissal was unfair. There was also apparently a relevant recent history of performance management and this suggests that the respondent’s defence of the unfair dismissal application may have substance.
[37] Of course, I have not heard from the applicant as to the substantive merit of the application. In any event, it would be prudent for both parties to consider whether this application can be resolved without the need for further litigation and expense.
[38] The matter will be assigned for conciliation at the earliest opportunity.
COMMISSIONER
Appearances:
J Telfer of counsel (with permission) for Mr Turton.
D Miller of the Australian Industry Group for FMC Australasia Pty Ltd.
Hearing details:
2011
Adelaide
December 16
1 Ozaras v Toll Pty Ltd [2008] AIRC 333, 23 April 2008 per Redmond C.
2 Exhibits R1 and R2.
3 Exhibit A1.
4 PR973462, 11 August 2006 per Giudice J, Watson VP and Cribb C. This appeal was determined under the provisions of the Workplace Relations Act 1996 pursuant to the provisions of the Act as in force prior to the coming into operation of the Workplace Relations Amendment (Work Choices) Act 2005. As a result, the primary jurisdictional question was whether the applicant had been dismissed by the employer which was considered having regard to the formulation in the Termination of Employment Convention which in turn referred to the concept of termination at the initiative of the employer.
5 PR973462 (footnotes omitted).
6 See the discussion of related concepts in Dover-Ray v Real Insurance Pty Ltd [2010] FWAFB 2670, 9 April 2010 per Lawler VP, Richards SDP and Larkin C.
7 Transcript PN66, PN70 to PN75 as examples.
8 The considerations established by s.387 of the Act would include the nature of these matters.
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