Military Law Blog: The use of Private Military and Security Companies (PMSCs)

by Legal Author on May 1, 2012

We are pleased to welcome Mark McAuley, law graduate and director at Legal Media Solutions, as he publishes a comprehensive piece on the use of private military and security companies (PMSCs) by international organisations and individual states.

“the ambiguous legal status and amorphous character of PMCs under existing international law offers leeway for countries to not only bend but breach their international legal obligations, thus tearing at the very fabric of the international legal order.”

Laura A. Dickinson, Government For Hire: Privatizing Foreign Affairs And The Problem Of Accountability Under International Law, 47 WM. & MARY L. REV. 135, 152–53 (2005).

  “…contractors now operate in a legal no man’s land, beyond established boundaries of military or international law. The reality of the fact is that since contractors do not fall within the formal military hierarchy, they are generally self-policing entities.”

Peter W. Singer, Outsourcing the War, Brookings Institution, Apr. 16, 2004, http://www.brookings.edu/articles/2004/0416defenseindustry_singer.aspx#.

The use of Private Military and Security Companies (PMSCs) by international organisations and individual states, although not a new phenomenon, has become a pressing issue for the international community as a result of some recent high-profile human rights abuses in which PMSC personnel have been implicated[1](A relatively recent example of such abuses can be found in the scandal surrounding the torture of individuals at Abu Ghraib prison in which employees of CACI and Titan Corp. (both major contributors to PMSC personnel in Iraq) were found to be involved.   See Major General G. Fay, Investigation of the Abu Ghraib Detention Facility and 205th Military Intelligence Brigade (2004), available at http://files.findlaw.com/news.findlaw.com/hdocs/docs/dod/fay82504-pt.pdf).

The presence of PMSC personnel in the military operations of organisations like the United Nations, or in the activities of coalition forces around the world (particularly in Iraq and Afghanistan) has presented some interesting problems for international law.  One of the primary concerns occupying international lawyers and publicists is the question of who exactly is responsible for the conduct of PMSCs?  In addressing this question this essay will consider the principles relating to attribution and state responsibility, as well as also considering whether PMSCs are capable of being held responsible in and of themselves for any wrongdoing under international law.

It is useful however to first of all examine the nature of the problem posed by the use of PMSCs in relation to the provisions of international law governing armed conflict.

Mercenaries and PMSCs – one and the same?

There is a general uneasiness surrounding the use of PMSCs that stems from a historical desire to conduct, or at least appear to conduct, just and lawful warfare.  The concept of paying non-national private individuals to perform functions, particularly coercive functions that are traditionally carried out by organs of the state i.e. the military, is widely accepted to be the antithesis of any perceived code of morality in armed conflict.  Christopher Greenwood, in his excellent chapter in the collected works The Handbook of Humanitarian Law in Armed Conflicts, states that the “morals of war regressed towards the end of the Middle Ages” in particular due to the “creation of armies consisting of mercenaries”[2].  In a substantive legal sense this attitude favouring the ‘just war’[3] is evinced in the various international law instruments pertaining to warfare.

In the current context Article 47, para. 1, of the Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts (Protocol I), 8 June 1977[4] is particularly relevant.  This Article declares that mercenaries are to be considered “unlawful combatants” and, as such, cannot be capable of being authorised by a recognised subject of international law to carry out armed combat activities.

Article 47, para. 2 AP I, goes on to detail six criteria that, collectively, define what constitutes a mercenary[5].  This definition has been criticised however as being too narrow in that “even members of armed forces who are not nationals of the party to the conflict are not considered to be ‘mercenaries’ if they serve in special units consisting only of foreigners (e.g. the French Foreign Legion)”[6].  The provisions of the Geneva Conventions relating to mercenaries have also been criticised in that they do not effectively cover the more nuanced modern-day relationship between international law subjects and PMSCs[7] (Such prohibition of mercenarism has been termed “anachronistic” – Afsah E., From Mercenaries to Market.  The Rise and Regulation of Private Military Companies, European Journal of International Law, 2010, Publication Review, edited by Chester S. & Lehnardt C, reviews by Afsah E., E.J.I.L., 2010, 21(1), 251-256.).  It is therefore unsatisfactory to draw the corollary between the historical concept of the mercenary and the more recent, post-Cold War, reality of the PMSC.

Article 43 AP I [8], which defines what constitutes a state’s ‘armed forces’, is similarly unhelpful when attempting to categorise PMSCs in that it emphasises a chain of command and a relationship of subordination before a particular group can be classed as an organ of the state.  Article 43 does not reflect the reality of the day-to-day activities of PMSCs as quite often there is a wide degree of autonomy afforded, as well as an often-unclear chain of command[9] (See, for example the views of one former Special Forces veteran – “the military really can’t tell you [the PMCs] how to do your job—they can advise you, but they really have no control over you” – Singer P.W., Outsourcing the War, Brookings ).  The crux of the matter therefore lies in whether PMSCs are to be classified as state or non-state actors as this will have important consequences for the applicability of various international law principles.

The lack of clarity surrounding the legal status of PMSCs also has the effect that it is more difficult to attribute international legal obligations and norms to the entity itself.  This is obviously a problem due to the occasionally violent nature of the work undertaken by PMSCs and the potential for human rights and International Humanitarian Law (IHL) violations.

The problem then for international law is that “international avenues fail to pursue lines of accountability that embrace the activities of private agents and particularly the modern PMC, a creature that was never in their contemplation at the time of drafting”[10] (P 102, Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.).

Issues relating to accountability

Corporations “have not been regarded traditionally as possessing international legal personality”[11] and, as a result of this, do not carry the international legal obligations relating to, inter alia, human rights law and IHL.   This notion has been challenged somewhat through an analysis of the Island of Palmas case[12], where the Dutch East India Trading Company was capable of exercising elements of sovereignty over the island on behalf of the state of Netherlands.  This, according to Nigel White and Sorcha Macleod in their journal article EU operations and private military contractors: issues of corporate and institutional responsibility[13], demonstrates “a historical acceptance of corporations as actors on the international plane”[14].  It is therefore argued that there is no real reason for the reluctance to afford international legal personality to corporations other than, as the authors go on to state, that of a lack of political will; a problem elsewhere described as “that bugaboo of all law”[15] (P 103, Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.).

As a result of the difficulties in holding PMSCs accountable directly for their actions, it is desirable to attribute their conduct to either the state or the international organisation that has contracted with them.

A further point must be made at this stage in that international organisations like the U.N. do, in contrast with corporations, possess separate international legal personality.  This concept was established in the Reparations case[16] (Reparation for Injuries Suffered in the Service of the United Nations, Advisory Opinion [1949] ICJ Rep 174, at 179.) and means that it is possible to attribute responsibility for, inter alia, the conduct of PMSCs to such organisations.  It has been remarked that this type of responsibility is “more complex, and therefore will lead to some differences in the Articles on Institutional Responsibility when compared with those on State Responsibility”[17].  Such complexities are beyond the scope of this article, however for present purposes any discussion relating to the attribution of responsibility is taken to apply to both states and international organisations equally.

The doctrine of state responsibility holds states liable for the unlawful actions of the organs of that state however, where non-state actors are concerned, the situation is a bit more complex.  Nyamuya Maogoto and Sheehy, in their journal article Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility[18], identify two approaches to state responsibility where non-state agents are concerned.  Namely these are; whether non-state actors should be treated as de facto organs of state, or whether there should instead be a focus on the tasks delegated to these non-state agents[19].

Article 8 of The Draft Articles on the Responsibility of States for Internationally Wrongful Acts[20] declares that:

“The conduct of a person or group of persons shall be considered an act of a State under international law if the person or group of persons is in fact acting on the instructions of, or under the direction or control of, that State in carrying out the conduct.”

The level of control necessary for state responsibility to attach is further discussed in the Nicaragua case[21].  Here the ICJ considered, inter alia, whether it was possible to attribute the conduct of a non-state actor to a state.  It was satisfied that this was indeed possible, and the Court then went on to declare that it had to:

“determine … whether or not the relationship of the contras to the United States Government was so much one of dependence on the one side and control on the other that it would be right to equate the contras, for legal purposes, with an organ of the United States Government, or as acting on behalf of that Government”

The Court here, again, emphasizes the need for some sort of control by the state over the non-state actor in order for state responsibility to attach.  The ICJ goes on to say that it would “have to be proved that that State had effective control of the military or paramilitary operations in the course of which the alleged violations were committed”[22].

As well as this concept of ‘effective control’[23], the Nicaragua case also shows the attitude of the ICJ in that it will attempt to “grasp the reality”[24] of the relationship between the state and the entity in question as “any other solution would allow States to escape their international responsibility”[25].

This ‘effective control’ test stands in contrast to a later control principle developed in the Tadic case[26], where a less stringent test of ‘overall control’ was preferred.  White and Macleod state that this “better reflects the realities of the growth of non-state actors in international law, whether insurgents, terrorists,or PMCs who may not necessarily be the agents of the state, but may well be under sufficient influence…and control”.  Depending on the application of the relevant control test, non-state actors may be classified as de facto agents of the state and, under the state responsibility doctrine, would render the state liable for any unlawful conduct they undertake.

The second approach to state responsibility posited by the authors focuses on the nature of the task delegated by the state to the non-state actor.  In other words state responsibility will attach when a state delegates “elements of government authority” to non-state agents[27].  The operation of this approach can be seen in the Island of Palmas case mentioned above.  Delegation of government authority can also be illustrated in the context of modern warfare by examining the instructions given to PMSCs by states or coalition forces.  It can be seen that PMSCs are frequently used for intelligence gathering and interrogation purposes, as well as for their more straightforward combat capabilities.  Nyamuya Maogoto and Sheehan therefore state that “it seems incontrovertible that private…entities engaged in government sponsored military activities or services are anything other than de facto government agents”[28] (P 110, Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.).

These principles relating to the attribution of state responsibility are just one aspect of a concerted effort to bring corporations, and more pertinently PMSCs, firmly within the ambit of international law.  There has been much academic discussion surrounding the utilization of other aspects of international law to enforce some minimum standard of conduct and accountability.  Hannah Tonkin, in her journal article Common article 1: a minimum yardstick for regulating private military and security companies[29], seeks to impose on all international law subjects a positive obligation on the basis of a reading of Common Article I of the 1949 Geneva Conventions.  This Article states that:

“‘the High Contracting Parties undertake to respect and to ensure respect for this [Convention or Protocol] in all circumstances.”

While this provision may seem to be nothing more than an aspirational statement, Tomkin advocates the view that it creates a positive obligation on states to ensure compliance with IHL[30].  She does however concede that the “the precise requirements of Common Article 1 have hitherto gone untested in any court”[31].

There are numerous other debates taking place in relation to how the conduct of PMSCs may be effectively brought within the international legal framework.  This is recognition of the fact that national legal provisions are limited in reach, and international legal provisions lack clarity or substance when it comes to the accountability of PMSCs.  There is a gap between PMSCs and international law, and it is this gap that “offers leeway for countries to not only bend but breach their international legal obligations”[32] (Dickinson L.A., Government For Hire: Privatizing Foreign Affairs And The Problem Of Accountability Under International Law, 47 WM. & MARY L. REV. 135, 152–53 (2005).) .

The aforementioned ideas relating to the attribution of state responsibility present, in my opinion, the basis for effectively holding PMSCs accountable for breaches of international law.

Conclusion

The use of mercenary forces in armed conflict has, historically, been met with much vilification.  The traditional concept of the ‘soldier of fortune’ is however somewhat anachronistic, and modern PMSCs are not met with the same level of consternation.

This change in attitude, particularly in the western world on the part of both states and international organisations in relation to the ethical issues surrounding the privatisation of war, is the result of a combination of both macroeconomic and geopolitical factors.  The explosion in the use of PMSCs, particularly from the 1990’s to the present day, has been attributed elsewhere[33] (Dickinson L.A., Government For Hire: Privatizing Foreign Affairs And The Problem Of Accountability Under International Law, 47 WM. & MARY L. REV. 135, 152–53 (2005)) to the fundamental re-evaluation of the role of the state under Thatcher and Reagan, along with the rise of a more market-oriented ideology.  Whatever the reason it is obvious that, with the contraction of state military forces around the world as a result of the global financial crisis[34] (See for example the UK-France defence treaties signed as recently 2nd November 2010 – http://www.bbc.co.uk/news/uk-politics-11670247), the need for the services provided by PMSCs will only grow.

These factors therefore point to a pressing need for the development of systems of accountability in relation to the conduct of PMSCs.  The development in the courts of the aforementioned principles relating to state responsibility represent, in this writer’s opinion, the most effective way of bridging the gap between international law and non-state actors like the PMSC.


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FOOTNOTES

[1] A relatively recent example of such abuses can be found in the scandal surrounding the torture of individuals at Abu Ghraib prison in which employees of CACI and Titan Corp. (both major contributors to PMSC personnel in Iraq) were found to be involved.   See Major General G. Fay, Investigation of the Abu Ghraib Detention Facility and 205th Military Intelligence Brigade (2004), available at http://files.findlaw.com/news.findlaw.com/hdocs/docs/dod/fay82504-pt.pdf

[2] P 15, para. 111, Various, The Handbook of Humanitarian Law in Armed Conflicts, Edited by Fleck D., 1995, Oxford University Press.

[3] Bellum iustum.

[4] Art. 47 AP I.

[5] See Appendix.

[6] P 69, para. 303, Various, The Handbook of Humanitarian Law in Armed Conflicts, Edited by Fleck D., 1995, Oxford University Press.

[7] Such prohibition of mercenarism has been termed “anachronistic” – Afsah E., From Mercenaries to Market.  The Rise and Regulation of Private Military Companies, European Journal of International Law, 2010, Publication Review, edited by Chester S. & Lehnardt C, reviews by Afsah E., E.J.I.L., 2010, 21(1), 251-256.

[8] See Appendix.

[9] See, for example the views of one former Special Forces veteran – “the military really can’t tell you [the PMCs] how to do your job—they can advise you, but they really have no control over you”.  Singer P.W., Outsourcing the War, Brookings Institution, Apr. 16, 2004: http://www.brookings.edu/articles/2004/0416defenseindustry_singer.aspx#.

[10] P 102, Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.

[11] P 968, White N.D. & MacLeod S., EU operations and private military contractors: issues of corporate and institutional responsibility, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 965-988.

[12] The Islands of Palmas Case (The Netherlands v. United States), 2 RIAA (1928) 829.

[13] P 968, White N.D. & MacLeod S., EU operations and private military contractors: issues of corporate and institutional responsibility, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 965-988.

[14] Ibid, p 969.

[15] P 103, Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.

[16] Reparation for Injuries Suffered in the Service of the United Nations, Advisory Opinion [1949] ICJ Rep 174, at 179.

[17] P 973, White N.D. & MacLeod S., EU operations and private military contractors: issues of corporate and institutional responsibility, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 965-988.

[18] P 109, Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.

[19] Ibid.

[20]  Article 8 of the International Law Commission (ILC), Articles on the Responsibility of States for Internationally Wrongful Acts, Report of the International Law Commission on the Work of its Fifty-Third Session, Official Records of the General Assembly, Fifty-Sixth Session, UN Doc. A/56/10 Supplement No. 10 (2001), chp.IV.E.2 (hereinafter the ASR Commentary).

[21] PP 62-64, Para 109, Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States of America) (Merits, Judgment, I.C.J. Reports 1986.

[22] Ibid, pp. 62 and 64–65, paras. 109 and 115.

[23] Later affirmed in the paras. 392-393 of the Case Concerning the Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and Herzegovina v Serbia and Montenegro) Unreported February 26, 2007 (ICJ).

[24] PP 62-64, Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States of America) (Merits, Judgment, I.C.J. Reports 1986).

[25] ibid

[26] Prosecutor v. Tadic, Case No. IT-94-1-A, Judgment, ¶¶ 117–18 (July 15, 1999).

[27] Article 5 from ASR Commentary.

[28] P 110, Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.

[29] Tonkin H., Common article 1: a minimum yardstick for regulating private military and security companies, Leiden Journal of International Law, 2009, L.J.I.L. 2009, 22(4), 779-799.

[30] A similar idea can be found in the requirement to prevent and punish Genocide.

[31] P 799, Tonkin H., Common article 1: a minimum yardstick for regulating private military and security companies, Leiden Journal of International Law, 2009, L.J.I.L. 2009, 22(4), 779-799.

[32] Dickinson L.A., Government For Hire: Privatizing Foreign Affairs And The Problem Of Accountability Under International Law, 47 WM. & MARY L. REV. 135, 152–53 (2005).

[33] ibid.

[34] See for example the UK-France defence treaties signed as recently 2nd November 2010 – http://www.bbc.co.uk/news/uk-politics-11670247

Bibliography

Textbooks

Brownlie I., Principles of Public International Law, 7th edition, 2008, Oxford University Press.

Harris D., Cases and Materials on International Law, 7th edition, 2010, Sweet & Maxwell.

Various, The Handbook of Humanitarian Law in Armed Conflicts, Edited by Fleck D., 1995, Oxford University Press.

Journal Articles

Afsah E., From Mercenaries to Market.  The Rise and Regulation of Private Military Companies, European Journal of International Law, 2010, Publication Review, edited by Chester S. & Lehnardt C, reviews by Afsah E., E.J.I.L., 2010, 21(1), 251-256.

Akande D., Clearing the fog of war? The ICRC’s interpretive guidance on direct participation in hostilities, International and Comparative Law Quarterly, 2010, I.C.L.Q. 2010, 59(1), 180-192.

Tonkin H., Common article 1: a minimum yardstick for regulating private military and security companies, Leiden Journal of International Law, 2009, L.J.I.L. 2009, 22(4), 779-799.

Milanovic M., State responsibility for acts of non-state actors: a comment on Griebel and Plucken, Leiden Journal of International Law, 2009, L.J.I.L. 2009, 22(2), 307-324.

Nyamuya Maogoto J. & Sheehy B., Private Military Companies & International Law: Building New Ladders Of Legal Accountability & Responsibility, Cardozo Journal of Conflict Resolution, 2009, Vol.11: 99.

White N.D. & MacLeod S., EU operations and private military contractors: issues of corporate and institutional responsibility, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 965-988.

Hoppe C., Passing the buck: state responsibility for private military companies, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 989-1014.

Lehnardt C., Individual liability of private military personnel under international criminal law, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 1015-1034.

Ryngaert C., Litigating abuses committed by private military companies, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 1035-1053.

Cockayne J., Regulating private military and security companies: the content, negotiation, weaknesses and promise of the Montreux Document, Journal of Conflict & Security Law, 2008, J.C. & S.L. 2008, 13(3), 401-428.

Francioni F., Private military contractors and international law: an introduction, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 961-964.

Chesterman S., “We can’t spy…if we can’t buy!”: the privatization of intelligence and the limits of outsourcing “inherently governmental functions“, European Journal of International Law, 2008, E.J.I.L. 2008, 19(5), 1055-1074.

Dickinson L.A., Government For Hire: Privatizing Foreign Affairs And The Problem Of Accountability Under International Law, 47 WM. & MARY L. REV. 135, 152–53 (2005).

Cases

The Islands of Palmas Case (The Netherlands v. United States), 2 RIAA (1928) 829.

Reparation for Injuries Suffered in the Service of the United Nations, Advisory Opinion [1949] ICJ Rep 174.

Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States of America) (Merits, Judgment, I.C.J. Reports 1986, pp. 62-64)

Case Concerning the Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and Herzegovina v Serbia and Montenegro) Unreported February 26, 2007 (ICJ).

Prosecutor v. Tadic, Case No. IT-94-1-A, Judgment, ¶¶ 117–18 (July 15, 1999).

International Treaties / Conventions

Article 43 of Additional Protocol I (AP I) (1977) of the Geneva Conventions of 1949.

Article 47 of Additional Protocol I (AP I) (1977) of the Geneva Conventions of 1949.

International Law Commission (ILC), Articles on the Responsibility of States for Internationally Wrongful Acts, Report of the International Law Commission on the Work of its Fifty-Third Session, Official Records of the General Assembly, Fifty-Sixth Session, UN Doc. A/56/10 Supplement No. 10 (2001).

Other Sources

‘Cameron and Sarkozy hail UK-France defence treaties’:

BBC News – http://www.bbc.co.uk/news/uk-politics-11670247

Singer P.W., Outsourcing the War, Brookings Institution, Apr. 16, 2004:

http://www.brookings.edu/articles/2004/0416defenseindustry_singer.aspx#.

Major General G. Fay, Investigation of the Abu Ghraib Detention Facility and 205th Military Intelligence Brigade, (2004):

http://files.findlaw.com/news.findlaw.com/hdocs/docs/dod/fay82504-pt.pdf.

Appendix

Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts (Protocol I), 8 June 1977.

Art 43.

Armed forces
:

1. The armed forces of a Party to a conflict consist of all organized armed forces, groups and units which are under a command responsible to that Party for the conduct of its subordinates, even if that Party is represented by a government or an authority not recognized by an adverse Party. Such armed forces shall be subject to an internal disciplinary system which, inter alia, shall enforce compliance with the rules of international law applicable in armed conflict.

2. Members of the armed forces of a Party to a conflict (other than medical personnel and chaplains covered by Article 33 of the Third Convention) are combatants, that is to say, they have the right to participate directly in hostilities.

3. Whenever a Party to a conflict incorporates a paramilitary or armed law enforcement agency into its armed forces it shall so notify the other Parties to the conflict.

Article 47

Mercenaries:

1. A mercenary shall not have the right to be a combatant or a prisoner of war.

2. A mercenary is any person who:

(a) is specially recruited locally or abroad in order to fight in an armed conflict;

(b) does, in fact, take a direct part in the hostilities;

(c) is motivated to take part in the hostilities essentially by the desire for private gain and, in fact, is promised, by or on behalf of a Party to the conflict, material compensation substantially in excess of that promised or paid to combatants of similar ranks and functions in the armed forces of that Party;

(d) is neither a national of a Party to the conflict nor a resident of territory controlled by a Party to the conflict;

(e) is not a member of the armed forces of a Party to the conflict; and

(f) has not been sent by a State which is not a Party to the conflict on official duty as a member of its armed forces

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