Consumer Research Inputs to Public Policy and Legal Decisions


William L. Wilkie and Stephen A. Greyser (1974) ,"Consumer Research Inputs to Public Policy and Legal Decisions", in NA - Advances in Consumer Research Volume 01, eds. Scott Ward and Peter Wright, Ann Abor, MI : Association for Consumer Research, Pages: 511-522.

Advances in Consumer Research Volume 1, 1974    Pages 511-522


William L. Wilkie

Stephen A. Greyser

[William L. Wilkie is Assistant Professor, Purdue University, on leave as 1973-4 Visiting Research Associate, Marketing Science Institute, and Visiting Lecturer, Harvard Business School. Stephen A. Greyser is Professor of Business Administration, Harvard Business School, and Executive Director. Marketing Science Institute.]

The purpose of this workshop session was to review and examine consumer research inputs to public policy in terms of both legal decisions and the management of public policy. The workshop was divided into two sessions. The first was devoted to consumer research in the legal process,principally FTC cases involving allegedly deceptive advertising. The second was addressed to consumer research in the managerial context, principally its uses in FTC planning. Since consumer research is and can be applied in both decision areas -albeit in different ways -- the two zones were explicitly distinguished as the focus of each of two sessions.


The first half of the workshop concentrated on the introduction and application of consumer research in the legal process. This is within the rather well-defined setting of the advocacy system. Here, the role of consumer research is typically to provide "facts" that are prospectively useful in resolving particular cases or issues. Within the advocacy setting, however, the use of consumer research will vary based on the way in which issues are defined, the way in which research information is interpreted, and the weight given to the consumer research evidence. Consumer research evidence has not always had much weight -- and has certainly had differential weight -in cases before the Federal Trade Commission.

At the session, issues growing from the successful conduct, introduction, and defense of consumer research within the legal environment were treated. The format included formal presentations as well as an open discussion period. The presentations were made by Thomas J. Donegan, a trial attorney with the FTC's Division of National Advertising; by Gilbert Weil of Weil, Lee and Bergin, an attorney experienced in defending major advertisers before the FTC; and by Raymond A. Bauer, a Harvard Business School professor active as both expert witness and as commentator on the use of consumer research in the legal process.

(Note to readers: The following sections are our summaries of the particiPants' presentations and the discussion periods.)


(Mr. Donegan is a graduate of University of Wisconsin and the University of Michigan Law School. He served in the U.S. Navy JAG. He has been with the FTC for almost three years, during six months of which he was assistant to Robert Pitofsky in the Bureau of Consumer Protection. His remarks here reflect his own opinions, not necessarily shared by his FTC colleagues.)

This kind of dialogue between lawyers working with specific FTC cases and consumer researchers is an important step in understanding the mutual problems involved in using consumer research in litigation.

Consumer research at the FTC has several uses. The first is at the investigation stage. This is where the staff itself is reviewing advertisements and advertising programs in order to determine whether to make a recommendation to the Commission that a false or unfair advertising case be instituted. The use that can be made of empirical data at this stage is to have a sense of the real consumer world rather than merely a staff member's opinion of what an advertisement may say or what a consumer may discern from it. Because of the limitation on FTC resources for doing its own consumer research, the primary source of information at this stage is research that has been conducted by the company and/or its advertising agency in pretesting the ads or in doing general consumer research to determine how people perceive their product.

To carry out such research is, of course, a sensible business practice for business decisions. Such research also can provide insights into whether implied, deceptive, or unfair representations in fact are being derived from the advertising claims. By the same token, if consumer research has been done, it can be used at the investigative stage to show that FTC allegations are not borne out.

Beyond the investigation stage, consumer research again becomes pertinent at the actual trial stage. There are many problems regarding the use of consumer research in this process. Historically, the "hearsay rule" has been an impediment: This says, in essence, that the out-of-court statement of a person not available for cross-examination cannot be introduced as evidence. The concern over survey evidence is that respondents in a consumer study may total several hundred people scattered across a wide geographical area, who obviously are not available for cross-examination. Courts have been relatively slow to come around to recognize such consumer research as a science and profession with built-in checks and balances for reliability of response and tabulations. Thus, even though substantial progress has been made in accepting survey evidence in legal proceedings, there is a residual set of problems that should be kept in mind in preparing consumer research for use in litigation process.

One of the problems is a feeling on the part of the legal community that somehow a survey has to be a "perfect survey" to be given considerable weight. Lawyers on both sides will certainly be trying to point out the weak elements of the opponent's research. As a result, the kind of consumer research for business decision-making purposes -- research that might not include some of the checks and balances which might otherwise be incorporated into a more carefully conducted survey -- may well run into problems in the litigation process. It might not be questioned as a tool on which a company might commit its advertising spending, but it will be questioned in the litigation process.

Hence, it is important to understand the limitations of a piece of research that is being introduced into testimony. One of the more common errors made in introducing consumer research in litigation is to try to put a consumer study forward for something more than it actually is ... to represent it as extending to the universe when it has a far more limited applicability to a particular sample of people and their thoughts about a particular question. The suggestion here is not to shy away from using research that is less than perfect but is to be careful to explain its limitations.

The two main issues for which consumer research has been used in FTC litigation are: (a) for implied representations in advertisements, particularly as they relate to deception; and (b) for remedy in the context of showing the need for corrective advertising. In the first area, it is useful to understand that the Commission itself views consumer research as Just one of the places to which it can look for the answers to questions of implied representations in advertisements.

The recent Wonder Bread case reaffirms on the Commission's part its view of its own accumulated knowledge and expertise for the determination of whether or not an advertisement is deceptive or misleading without resorting to extrinsic evidence of deception. In essence then, consumer research is only one of three sources of insight. The Commission's own expertise is another, and expert testimony, in the form of subjective analyses and interpretations of ads, is a third.

Two recommendations are offered to further the understanding between those engaged in conducting consumer research and those who are lawyers at the FTC. First, the program of having experts from the academic community spend short periods of time as consultants to the staff and the Commission in this area should be continued. These have been very valuable inputs to the staff and the Commission thus far.

Second, those with consumer research skills who are called upon either by respondents in FTC cases, or by the staff itself, should try to become involved by lending their expertise in the litigation process, in order for us all to try to answer these questions through empirical data, rather than through merely expert opinion.


(As attorney for the Association of National Advertisers, the Advertising Research Foundation, 2nd a number of major advertisers, Mr. Weil is perhaps the most experienced lawyer in this field. He has been involved with a number of recent cases where consumer research was introduced into testimony before the FTC.)

The "hearsay rule" has been cited as a major problem in the use of consumer research. The problem with respect to alleged misleading advertising is really broader than that of the hearsay rule. It is more a question of reliability. The courts and the FTC want to have assurances that whatever evidence is presented to them is indeed reliable; this has given rise to many of the exclusionary rules regarding evidence. The witness should have direct knowledge of the events to which he testifies, in order to meet the criterion of being subject to cross-examination on the facts. Much consumer research does not permit meaningful cross-examination of the available witnesses -- because managerial people from research firms would only be recounting what has been reported to them by others. However, records kept in the course of business that themselves have considerable assurance of reliability can serve this purpose.

Behavioral studies of consumers fall into two categories, with different rules of procedure. First are surveys to determine one specific act or conduct, such as the meaning of a given advertisement to the people interviewed in a survey. The other research type is that seeking the general characteristics of human beings without necessarily being related to one particular event (such as an ad).

The first kind of research has been recognized as either an exception to the hearsay rule or as not constituting hearsay evidence in the first place. The courts have recognized the impossibility of producing survey respondents to testify that the answers given to the interviewer were indeed true. However, some assurances of reliability are still required. These would include producing interviewers and supervisors so that the court can get some indication of the strength of the survey administration and its reliability.

One of the major problems in dealing with much of this research is that most surveys used for business decision-making are not all that well done. They may even be fairly shoddy pieces of research -- perhaps nothing more than a set of convenience interviews with a small number of housewives.

There is a big difference between research done for business purposes, and the kind of research required for legal evidence. A businessman is free to run his business any way he wants. If he wants to make a decision based on sloppy research he is playing with Xs own money; if he wants to spend that money unwisely that is his own affair. Further, if it begins to appear that he made the wrong decision, he can change it and start out again in a different direction.

In contrast, legal decisions are relatively immutable. When the law makes a decision, it is extremely difficult to come back with later evidence and get that decision changed -- even though the original decision may have been based on shoddy research. Thus the consequences of a legal decision -where the court or the FTC tells the businessman what he must do -- are quite different from the conditions for the use of research in making one's own business decisions. The cliche that "if the businessman himself relies upon this research, it is a good enough guarantee of its reliability for the courtroom or FTC"is simply wrong.

The incorrectness of this view applies both at the investigation stage as well as at the trial stage. What companies may be forced to do in light of the use of shoddy and superficial research in such proceedings is to take either of two difficult actions. The first is always to spend the additional funds on more thoroughly reliable research. The second is to forego the "quick and dirty" kind of research which may aid business decision-making but does not stand up as reliable in a legal proceeding.


(Raymond A. Bauer is Professor of Business Administration at the Harvard Business School. As a social psychologist and author of many books and articles in the consumer behavior field, he has been active in the application of consumer research to the legal process. He has served as expert witness in several FTC cases most notably the Wonder Bread case.)

Several years ago when the concept of corrective advertising was advanced, it seemed possible to have this important decision area made empirical. Many of us committed to the empirical approach -- i.e., using consumer research to assess what was on the minds of consumers -- thought that real progress was being made. In the Wonder Bread case the same sense of elation was present. The issues explored and the cross-examination conducted were both informed and addressed to the right empirical questions. When the report of the hearing judge was issued, again the cause of empiricism had prevailed.

But the Commission's report on this case has tried to stop the development of this empirical process and has dealt a major blow to the role that consumer research should play in such proceedings. In order to support this view, several observations are offered from the record -- and from my knowledge of the case.

First, and most important, the FTC report fails to describe in a full and meaningful way the important matter of the consumer context for Wonder Bread's nutritional claim. The facts are that for 16 years, the company had been promoting bread on a nutritional basis. At that point, they did some consumer research in six cities investigating why people say they buy their favorite brand of bread. In the six surveys conducted, -- with answers coded down to one-half of one percent -- no category resembles "nutrition". No one says they buy bread for nutrition. The Commission did not report this -- a very major oversight in that the rest of the arguments in the case regarding nutrition relate to an attribute which is apparently totally irrelevant to the consumer.

(Professor Bauer went on to cite several other specific areas wherein he believed that his testimony had been misinterpreted by the Co_mission.)

As Mr. Donegan noted, the Commission has reserved its right to exercise its own expertise in these cases. This truly represents a very low standard of progress with regard to the relative weight given to consumers' own beliefs regarding the advertising and the characteristics of the brand. In essence, the Commission is arguing that the existence of evidence on how consumers actually react to advertisements shouldn't deter the FTC from stating what it thinks about how they have reacted.

My dismay grows from the fact that the trial itself was conducted on a very empirical basis. My concern is not that the empirical evidence fails to have impact on the Commission's final report. Rather it is the relative status of such evidence -- or more properly the lack of status of such evidence -- that is so distressing.


A considerable portion of the discussion focused on the status of empirical research particularly in the light of the rather discouraging tone of Professor Bauer's remarks. Commissioner Jones urged that the consumer researchers present not be discouraged. Rather they should try to understand what the decision-makers are really worried about and help in the education of those decision-makers.

The role of the consumer research specialist was also debated. Professor Alan Andreason (SUNY-Buffalo) noted that, often, rather than commenting on and interpreting empirical data, expert witnesses are asked to look directly at advertisements and hypothesize knowledgeably as to what the consumer actions would be. A number of researchers present argued that this latter role is in fact undesirable, and could constitute improper professional behavior.

Professor Dorothy Cohen (Hofstra) raised the question of determining the "materiality" of a particular claim. It was agreed that the legal standard is whether the advertisement at issue in fact would exercise any substantial influence on the consumers' purchase decision. This would appear to be an empirical matter.

Mr. Weil added a comment regarding the expertise of the Commission in making decisions about what an advertisement means or does not mean. He suggested that the Commissioners' expertise became imbedded in the law at a time when there seemed to be no better way to make these decisions. Since better ways to assess the impact of ads on consumers have been developed, the principle of the Commission's expertise is somewhat outmoded, to say the least. Mr. Donegan noted that the fact that several experts may have different interpretations of the same phenomena means that the Commission may still have to exercise its own ultimate ability. The general feeling expressed in discussion was that expert opinion could indeed be abused. The distinction between expert opinion unsupported by data versus empirical data interpreted by expert opinion was considered an important one.

Several participants raised the matter of reliability as it relates to the adversary system. Kay Ryan (Cost of Living Council) questioned whether the adversary system would not always be raising doubts about the reliability of research, since the adversary system is designed to attack research. In this light should new standards of presumption in the law with regard to reliability be developed along this line? Mr. Donegan noted that one should not categorize research into only "perfect" and "sloppy", and reiterated his earlier point that considerable usefulness of "less than perfect" consumer research can be made -- as long as its limitations are made clear. Commissioner Jones indicated that the question of "shoddiness" would relate less to whether a piece of research should be admissible than to the weight it would be given in the eventual Judgments.

Another question was addressed to whether consumer research might be of value at the early case selection stage referred to by Mr. Donegan. This would permit empirical data to play a role in resource allocation as among cases. Mr. Donegan noted that guidance along these lines was one of the contributions made by the in-house FTC academic consultants referred to earlier.

The final question area related to the proportion of consumers misinterpreting an advertisement that would be considered "too high" or "too low" for Commission action. There was considerable debate over threshold percentages and particularly their implications for research on low-involved consumer populations. In addition, the distinction between misunderstanding and being deceived on the part of the consumer was also raised.

George Brosseau (National Science Foundation) made a concluding remark distinguishing short-term from long-term research. He viewed the longer-term context as one where academic consumer researchers can be expected to play a far more important role.

(On this suggested transition between the first and second sessions of the workshop, the first period came to an end.)


The second half of the workshop-shifted its attention from the short-range circumscribed role of research within the advocacy process to the broader concerns of using consumer research in managing a public agency. The basic issues covered in this session thus involved the interface of research with organizational decisions and the difficulties in communication between consumer researchers and public policy-makers.

The format for this session again included formal presentations and an open discussion period. Commissioner Mary Gardiner Jones (Federal Trade Commission) provided an extensive analysis of the reactions of key personnel of FTC to their recent exposure to consumer research and suggested that researchers must recognize and adapt to the world of the policy-maker. Summary perspectives on such adaptation were then provided by three marketing academics who have recently concluded six-month in-house consulting assignments with FTC. Professor David Gardner (University of Illinois) spoke to the questions of organizational change and the need for consumer researchers to better analyze the value of our research. Professor Neil Beckwith (Columbia University) summarized the planning, allocation, and evaluation activities of FTC and suggested specific research topics in these zones. Professor Harold KassarJian(UCLA) then discussed the significant issue of the differences between adversary and scientific approaches to problem resolution, suggesting that the answer is not so straightforward as most ACR members would think. A heated discussion period followed before time ran out for the workshop.


(Commissioner Jones, a graduate of Wellesley College and Yale Law School, was appointed as an FTC commissioner in 1964. She served in this capacity until late 1973, and now holds a joint appointment as Professor of Law and Business Administration at the University of Illinois. She is generally recognized as the person most singularly responsible for bringing consumer researchers and research evidence into FTC. Her paper to the workshop provided an interpretation of this "diffusion" process and its implications for ACR members.)

The relationship between consumer research and public policy-makers today bears a striking resemblance to that between marketing researchers and advertising management in the 1950's. In both cases this relationship is characterized by (1) the manager's belief that his decisions are necessarily subjective and thus not amenable to scientific analysis, (2) parochialism in outlook and training on the part of the research users (now the legal profession), and (3) a general lack of confidence, aggressiveness, and problem-orientation by researchers.

Progress is being made, however, and researchers should understand what roadblocks remain. Three significant problems are encountered by the policy-maker desirous of increased research inputs. These are, first, a basic unfamiliarity with research on the part of other commissioners and staff members, which calls for further education and persuasion by researchers. The second is resistance by budgeters and legislators to the allocation of funds for consumer research (e.g., FTC's first request for a research line item was stricken by OMB). Third is the widespread unfamiliarity of The legal profession in general, including the courts.

Several recent FTC cases illustrate both the types of research input and problems encountered in utilizing such input. (The use, lack of use, and misuse of consumer surveys by opposing counsels, hearing examiners, the Commission, and Court of Appeals were described in important detail. Examples were drawn from three recent FTC cases against Firestone, Hi-C, and Wonder Bread. Arguments concerning the probative value of consumer surveys were also presented, the basic issue involving whether or not attitudinal measures can or should reflect causal linkages between specific advertising claims and consumer misperceptions of the brand.)

One point highlighted in this analysis is that difficult problems are faced by a policymaker when confronted with lengthy technical research evidence and conflicting testimony on the research There are realistic problems to be overcome, but consumer research is being increasingly recognized by public policymakers. Researchers should keep in mind the need for more education, should keep pressing to play a role in policy decisions, and should not be discouraged by occasional lapses. Full utilization of consumer research will take a while, but major advances have been made.


(Professor Gardner drew upon his recent experience as a consultant in FTC's Office of Policy Planning and Evaluation in his discussion of the current and future implementation of consumer research at FTC.)

Organizational theory -- in particular the concept of "dynamic homeostasis" -- can explain the course of developments to date and, given adaptation by researchers, can predict the nature of future changes. A broad view of events needs to be taken rather than narrow focus on one or two cases. It is also necessary to understand that it is natural for any person or organization to resist change in areas outside of its expertise. However, when it must accept change from external forces, we can expect adaptation via internal attempts to control the rate and manner of change to reduce the abruptness of its impact.

There are four factors currently supporting the status quo with respect to consumer research:

(1) Legal applications of the "hearsay rule".

(2) Staff personnel who are not familiar with inferential research.

(3) Characteristics of the adversary system which act to suppress evidence susceptible to strong counterattack.

(4) A natural desire to retain flexibility in action zones, which works against the use of research in planning and priority determination.

Simultaneously,there are two major forces supporting change. First,success in removing major perceived violations calls for a choice between undertaking increasingly trivial cases in existing areas, or moving onto other questions, questions where consumer research may hold insights. Secondly, change has already begun through FTC's program of bringing academics into the agency for six-month to one year "in-house consulting" assignments. The seven persons in the program to date have been successful in spreading initial familiarity with research.

Researchers, however, must consider the likelihood that our research may not be of much direct value at present. Consumer research has tended to borrow concepts from other behavioral sciences, often without considering special constraints inherent in a consumer focus. Furthermore, a lack of comprehensive research programming results in few definitive generalizations. Thus, researchers should carefully consider both the organizational "buyer" and the extent to which research will meet its public policy decision needs.


(Professor Beckwith has also recently consulted for FTC's Office of Policy Planning and Evaluation, and in his presentation summarized the zones of research needed by various activities of the Commission)

Fundamentally, the implementation of consumer research in public agencies encounters a general "focusing down" from complex problems to researchable questions. Researchers arrive seeking naively simple questions and find policy- makers seeking naively simple answers. Both parties will need to compromise, and a useful start involves the researcher's understanding of problems.These can be summarized into five categories, partitioned by intended usage of results.

Priority Planning research is aimed at selection among program alternatives. This is particularly difficult when, as in the case of FTC, legislative mandates are vaguely worded to encompass a broad range of possible activities. The choice of particular programs depends upon several considerations, including consumer needs, benefits expected, costs and diffused positive and negative impacts on other economic sectors. Both omnibus and single issue surveYs have been suggested for this activity.

Impact studies are aimed at providing one subset of planning decisions, i.e., predicting the effects of a program if implemented. Several alternative implementation plans for a program can be considered, which would be likely to improve the ultimate outcome of the program. Precise estimates are not required; what is needed is information to help distinguish good programs from bad ones.

Evaluation of existing programs may offer the best opportunity for researchers working outside of the Commission. It should be remembered, however, that decisions on the continuation, alteration, or elimination of programs are the primary interests of decision-makers. There are many topic possibilities, including current programs in deceptive advertising, consumer education, and case quotas for regional offices. A related approach on these topics is to assess the underlying program rationale in terms of consumer theory development. Finally, increasing utilization of research as legal evidence provides an opportunity for narrow but rigorous research. It is necessary that such research be credible, and therefore it is likely to require careful controls on sampling,interviewing, and questionnaire biases. In summary, many opportunities exist for the consumer researcher to assist in informed public policy decisions.


(Professor Kassarjian recently served as in-house consultant to FTC's Bureau of Consumer Protection. His presentation was constrained by a five-minute time limit and was therefore pointed in his well known style.This summary cannot reflect the tenor of his presentation.)

The scientific method and the adversary method are alternative means of arriving at truth. In the adversary method each side presents its view, emphasizing the strong points and suppressing the weak points. Then the Judge or a jury miraculously arrives at the truth. The scientific method, conversely , involves hypotheses, control groups, and unbiased statistical testing to arrive at the truth. It is so far superior to any other approach that we are appalled that any irrational person would fail to use it.

How the scientific method really works in consumer research was then described in detail: How publishable topics are selected, how and why data are collected from college students, then cleaned and sequentially analyzed to yield interpretable results. This is then followed by polite reactions of the conference audiences exposed to presentations of the research. The final stages relate to the timing and route of a given humble study's movement into a consumer behavior law. At this point, some lawyers interested in a related study arrive and use the consumer research study as legal evidence. The adversary process, however, does not respect our rules of the game, and this piece of research finds its rightful place. Which, then, is the better approach?


Prior to open discussion, Raymond Bauer and Gilbert Weil responded to several issues raised in Commissioner Jones' presentation. Professor Bauer pointed out that, although there is no established code of professional conduct with regard to expert testimony, he personally recommends that whenever possible, behavioral scientists advocate that empirical research be used in place of subjective judgments by an expert witness. He also noted that the broad perspectives in the second session's presentations do help in understanding that progress is being made. Mr. Weil amplified his contention that consumer research must meet higher standards of reliability and validity in terms of causal relationships between, for example, advertising claims and consumer perceptions. He expressed strong disagreement with the Commission's acceptance of research on the basis that brand management uses it for decision-making.

Discussion moved to organizational forces which will promote further utilization of research at the Commission. Commissioner Jones suggested that an awareness of the need is now present and that researchers should try to move into different areas of the organization, including staffs of individual commissioners, the Bureau of Competition, and the eleven field offices. Mr. Donegan reported that staff attorneys now ask whether empirical data are available when investigating possible cases, obviously a recent advance.

In response to concern with misrepresentation of research results by attorneys in oral argument, it was reported that no specific procedures may be available to handle the problem. The adversary system does require that the opposing counsel register a strong objection and will, over time, raise serious credibilitY Problems for the offender.

The issue of "unfairness" as an FTC rationale was raised. How does FTC plan to define and use unfairness? Commissioner Jones pointed out that this is a relatively recent problem springing from a Supreme Court decision, and that the heavy turnover at FTC has impeded progress to date. The Wonder Bread case, for example, contained an allegation of unfairness to children which was simply dispensed with in the Commission decision. She suggested that the legal staff is currently developing test cases of the rationale,which will not appear in the near future, however.

A strong denunciation of FTC's failure to finance research on children's advertising was expressed by Robert Choate, who then asked when one might expect some movement in this direction. Professor Greyser noted that government should not be viewed as the only source of funding for good research, and pointed out that the Marketing Science Institute has been active in this particular sphere for the past three Years.

Mrs. Kay Ryan, of the Cost of Living Council, concluded the open discussion period with comments from her perspective as a lawyer and consumer activist. First, she suggested that some subset of ACR members should adopt an activist role in terms of implementing research and policy decisions. Attempt not only to join the staff, but also to become a Commissioner. Go to Congress and point out that since the government is a major user of our research, it should support this research. Work with law professors on joint articles; publish in the law journals also. In sum, avoid simply talking to one another.


The chairmen of this workshop sought to improve upon some aspects of past meetings on public policy issues. One of the major problems with sessions on this topic has been a tendency to foster optimism about the role of consumer research. Our purpose was to provide an opportunity for realistic assessment of that role -- both positive and pessimistic. Thus we structured the program in part to stimulate the annoyance mechanisms of panelists and participants. We asked the speakers to be candid and straightforward in their remarks, and they were. Members of the audience responded in kind, and some troublesome issues were raised.

Few, if any issues were resolved, but it does appear that progress is at hand. A body of experience, literature, and court decisions is becoming available for analysis and discussion. There are major new areas which weren't addressed in the workshop, but will provide still further problems to attack. The field of consumer behavior should be ahead of public policy issues rather than lagging behind, and fora such as this workshop are providing an important impetus.

(A full report on the entire workshop including all presentations and a summary of the discussion, is being prepared for publication by the Marketing Science Institute.)



William L. Wilkie
Stephen A. Greyser


NA - Advances in Consumer Research Volume 01 | 1974

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