1 R. REX PARRIS (SBN 96567) [email protected] 2 KITTY K. SZETO (SBN 258136) [email protected] 3 JOHN M. BICKFORD (SBN 280929) [email protected] 4 PARRIS LAW FIRM 43364 10th Street West 5 Lancaster, California 93534 Telephone: (661) 949-2595 6 Facsimile: (661) 949-7524

7 Attorneys for Plaintiffs and the Putative Class

8 REBECCA ARAGON, Bar No. 134496 9 [email protected] HOVANNES G. NALBANDYAN, Bar No. 300364 10 [email protected] LAURA E. SCHNEIDER, Bar No. 326077 11 [email protected] LITTLER MENDELSON, P.C. 12 633 W. Fifth Street, 63rd Floor Los Angeles, CA 90071 13 Telephone: 213.443.4300 Fax No.: 213.443.4299 14 Attorneys for Defendant 15 FREEDOMROADS, LLC 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 KAMELA WOODINGS and JODI CASE NO. 2:20-cv-07072-MCS-JEM 19 DORMAIER, on behalf of themselves and all members of the putative class, Discovery Document: Referred to 20 Magistrate Judge John E. McDermott Plaintiffs, 21 v. HONORABLE MARK C. SCARSI, 22 FREEDOMROADS, LLC d/b/a COURTROOM 7C 23 CAMPING WORLD, a Minnesota Limited Liability Corporation, and STIPULATED PROTECTIVE 24 DOES 1 through 100, ORDER

25 Defendant. Action Filed: June 25, 2020 26 FAC Filed: August 27, 2020 SAC Filed: July 20, 2021 27 Trial Date: Vacated 1 Pursuant to Edwards v. County of Los Angeles,

(C.D. Cal 2 2009) and Judge McDermott’s Judicial Procedure # 11, Plaintiffs KAMELA 3 WOODINGS and JODI DORMAIER (“Plaintiffs”) and Defendant 4 FREEDOMROADS, LLC (erroneously sued as FREEDOMROADS, LLC d/b/a 5 CAMPING WORLD) (“Defendant”) (collectively, the “Parties”) in the above- 6 captioned matter entitled Woodings, et al, v. FreedomRoads, LLC d/b/a Camping 7 World, et al., through their counsel of record, hereby submit this stipulated protective 8 order and stipulate and agree as follows: 9 I. PURPOSES AND LIMITATIONS 10 A. This matter will involve the production of confidential, proprietary, or 11 private class list and information for which special protection from public disclosure 12 and from use for any purpose other than prosecuting this litigation may be warranted. 13 Accordingly, the parties hereby stipulate to and petition the Court to enter the 14 following Stipulated Protective Order. The parties acknowledge that this Order does 15 not confer blanket protections on all disclosures or responses to discovery and that 16 the protection it affords from public disclosure and use extends only to the limited 17 information or items that are entitled to confidential treatment under the applicable 18 legal principles. The parties further acknowledge, as set forth in Section XIII(C), 19 below, that this Stipulated Protective Order does not entitle them to file confidential 20 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 21 followed and the standards that will be applied when a party seeks permission from 22 the Court to file material under seal. 23 II. GOOD CAUSE STATEMENT 24 A. This action will involve the production of a class list, and other pay and 25 time data, and technical and/or proprietary information for which special protection 26 from public disclosure and from use for any purpose other than prosecution of this 27 action is warranted. Such confidential and proprietary materials and information 1 Defendant’s employees, including without limitation contact and other personally 2 identifiable information, for which the Parties or any third party have a duty to 3 maintain confidentiality, information otherwise generally unavailable to the public, 4 or which may be privileged or otherwise protected from disclosure under state or 5 federal statutes, court rules, case decisions, or common law. Accordingly, to expedite 6 the flow of information, to facilitate the prompt resolution of disputes over 7 confidentiality of discovery materials, to adequately protect information the parties 8 are entitled to keep confidential, to ensure that the parties are permitted reasonable 9 necessary uses of such material in preparation for and in the conduct of trial, to address 10 their handling at the end of the litigation, and serve the ends of justice, a protective 11 order for such information is justified in this matter. It is the intent of the parties that 12 information will not be designated as confidential for tactical reasons and that nothing 13 be so designated without a good faith belief that it has been maintained in a 14 confidential, non-public manner, and there is good cause why it should not be part of 15 the public record of this case. 16 III. DEFINITIONS 17 A. Action: This pending federal lawsuit. 18 B. Challenging Party: A Party or Non-Party that challenges the designation 19 of information or items under this Order. 20 C. “CONFIDENTIAL” Information or Items: Information (regardless of 21 how it is generated, stored or maintained) or tangible things that qualify for protection 22 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 23 Cause Statement. Further, Confidential Information is information for which 24 disclosure is likely to have the effect of causing harm to either Party, or person from 25 whom the information was obtained, or to the Parties’ or third-parties’ privacy. 26 Confidential Information also includes private information pertaining to Defendant’s 27 employees, including without limitation contact and other personally identifiable 1 confidentiality. 2 D. Counsel (without qualifier): Outside Counsel of Record and House 3 Counsel (as well as their support staff). 4 E. Designating Party: A Party or Non-Party that designates information or 5 items that it produces in disclosures or in responses to discovery as 6 “CONFIDENTIAL.” 7 F. Disclosure or Discovery Material: All items or information, regardless 8 of the medium or manner in which it is generated, stored, or maintained (including, 9 among other class lists, documents, data [including electronically stored information], 10 things, testimony, transcripts, and tangible things), that are produced or generated in 11 disclosures or responses to discovery in this matter. 12 G. Expert: A person with specialized knowledge or experience in a matter 13 pertinent to the litigation who has been retained by a Party or its counsel to serve as 14 an expert witness or as a consultant in this Action. 15 H. House Counsel: Attorneys who are employees of a party to this Action. 16 House Counsel does not include Outside Counsel of Record or any other outside 17 counsel. 18 I. Non-Party: Any natural person, partnership, corporation, association, or 19 other legal entity not named as a Party to this action. 20 J. Outside Counsel of Record: Attorneys who are not employees of a party 21 to this Action but are retained to represent or advise a party to this Action and have 22 appeared in this Action on behalf of that party or are affiliated with a law firm which 23 has appeared on behalf of that party, and includes support staff. 24 K. Party: Any party to this Action, including all of its officers, directors, 25 employees, consultants, retained experts, and Outside Counsel of Record (and their 26 support staffs). 27 L. Producing Party: A Party or Non-Party that produces Disclosure or 1 M. Professional Vendors: Persons or entities that provide litigation support 2 services (e.g., photocopying, videotaping, translating, preparing exhibits or 3 demonstrations, and organizing, storing, or retrieving data in any form or medium) 4 and their employees and subcontractors, and any Settlement Administrator designated 5 by the Court. 6 N. Protected Material: Any Disclosure or Discovery Material that is 7 designated as “CONFIDENTIAL.” 8 O. Receiving Party: A Party or Professional Vendor that receives 9 Disclosure or CONFIDENTIAL Information from a Producing Party. 10 IV. SCOPE 11 A. The protections conferred by this Stipulation and Order cover not only 12 Protected Material (as defined above), but also (1) any information copied or extracted 13 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 14 Protected Material; and (3) any testimony, conversations, or presentations by Parties 15 or their Counsel that might reveal Protected Material. 16 B. Any use of Protected Material at trial shall be governed by the orders of 17 the trial judge. This Order does not govern the use of Protected Material at trial. 18 V. DURATION 19 A. Even after final disposition of this litigation, the confidentiality 20 obligations imposed by this Order shall remain in effect until a Designating Party 21 agrees otherwise in writing or a court order otherwise directs. Final disposition shall 22 be deemed to be the later of (1) dismissal of all claims and defenses in this Action, 23 with or without prejudice; and (2) final judgment herein after the completion and 24 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 25 including the time limits for filing any motions or applications for extension of time 26 pursuant to applicable law. 27 /// 1 VI. DESIGNATING PROTECTED MATERIAL 2 A. Exercise of Restraint and Care in Designating Material for 3 Protection 4 1. Each Party or Non-Party that designates information or items for 5 protection under this Order must take care to limit any such designation to 6 specific material that qualifies under the appropriate standards. The 7 Designating Party must designate for protection only those parts of material, 8 documents, items, or oral or written communications that qualify so that other 9 portions of the material, documents, items, or communications for which 10 protection is not warranted are not swept unjustifiably within the ambit of this 11 Order. 12 2. Mass, indiscriminate, or routinized designations are prohibited. 13 Designations that are shown to be clearly unjustified or that have been made 14 for an improper purpose (e.g., to unnecessarily encumber the case development 15 process or to impose unnecessary expenses and burdens on other parties) may 16 expose the Designating Party to sanctions. 17 3. If it comes to a Designating Party’s attention that information or 18 items that it designated for protection do not qualify for protection, that 19 Designating Party must promptly notify all other Parties that it is withdrawing 20 the inapplicable designation. 21 B. Manner and Timing of Designations 22 1. Except as otherwise provided in this Order (see, e.g., Section 23 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or Discovery 24 Material that qualifies for protection under this Order must be clearly so 25 designated before the material is disclosed or produced. 26 2. Designation in conformity with this Order requires the following: 27 a. For information in documentary form (e.g., paper or 1 pretrial or trial proceedings), that the Producing Party affix at a 2 minimum, the legend “CONFIDENTIAL” (hereinafter 3 “CONFIDENTIAL legend”), to each page that contains protected 4 material. If only a portion or portions of the material on a page qualifies 5 for protection, the Producing Party also must clearly identify the 6 protected portion(s) (e.g., by making appropriate markings in the 7 margins). 8 b. A Party or Non-Party that makes original documents 9 available for inspection need not designate them for protection until after 10 the inspecting Party has indicated which documents it would like copied 11 and produced. During the inspection and before the designation, all of 12 the material made available for inspection shall be deemed 13 “CONFIDENTIAL.” After the inspecting Party has identified the 14 documents it wants copied and produced, the Producing Party must 15 determine which documents, or portions thereof, qualify for protection 16 under this Order. Then, before producing the specified documents, the 17 Producing Party must affix the “CONFIDENTIAL legend” to each page 18 that contains Protected Material. If only a portion or portions of the 19 material on a page qualifies for protection, the Producing Party also must 20 clearly identify the protected portion(s) (e.g., by making appropriate 21 markings in the margins). 22 c. For testimony given in depositions, that the Designating 23 Party identify the Disclosure or Discovery Material on the record, before 24 the close of the deposition all protected testimony. 25 d. For information produced in form other than document and 26 for any other tangible items, that the Producing Party affix in a prominent 27 place on the exterior of the container or containers in which the 1 or portions of the information warrants protection, the Producing Party, 2 to the extent practicable, shall identify the protected portion(s). Such 3 information and material shall be used only for the purpose of the class 4 settlement in this lawsuit, and shall not be used for any other purpose and 5 shall not be disseminated to any third party, other than the Professional 6 Vendor, under any circumstances. Unless and until the Court rules to 7 the contrary or the Designating Party agrees otherwise, any use, 8 disclosure, or access to confidential material related primarily to the 9 settlement or prosecution of class allegations shall cease immediately 10 upon the dismissal of class allegations or the Final Approval of class 11 settlement, whichever occurs first. 12 C. Inadvertent Failure to Designate 13 1. If timely corrected, an inadvertent failure to designate qualified 14 information or items does not, standing alone, waive the Designating Party’s 15 right to secure protection under this Order for such material. Upon timely 16 correction of a designation, the Receiving Party must make reasonable efforts 17 to assure that the material is treated in accordance with the provisions of this 18 Order. 19 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 A. Timing of Challenges 21 1. Any party or Non-Party may challenge a designation of 22 confidentiality at any time that is consistent with the Court’s Scheduling Order. 23 B. Meet and Confer 24 1. The Challenging Party shall initiate the dispute resolution process 25 under Local Rule 37.1 et seq. 26 C. Burden of Persuasion 27 1. The burden of persuasion in any such challenge proceeding shall 1 improper purpose (e.g., to harass or impose unnecessary expenses and burdens 2 on other parties) may expose the Challenging Party to sanctions. Unless the 3 Designating Party has waived or withdrawn the confidentiality designation, all 4 parties shall continue to afford the material in question the level of protection 5 to which it is entitled under the Producing Party’s designation until the Court 6 rules on the challenge. 7 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 8 A. Basic Principles 9 1. A Receiving Party may use Protected Material that is disclosed or 10 produced by another Party or by a Non-Party in connection with this 11 Action only for prosecuting, defending, or attempting to settle this 12 Action. Such Protected Material may be disclosed only to the categories 13 of persons and under the conditions described in this Order. When the 14 Action has been terminated, a Receiving Party must comply with the 15 provisions of Section XIV below. 16 2. Protected Material must be stored and maintained by a Receiving 17 Party at a location and in a secure manner that ensures that access is 18 limited to the persons authorized under this Order. 19 B. Disclosure of “CONFIDENTIAL” Information or Items 20 1. Unless otherwise ordered by the Court or permitted in writing by 21 the Designating Party, a Receiving Party may disclose any information 22 or item designated “CONFIDENTIAL” only to: 23 a. The Receiving Party’s Outside Counsel of Record in this 24 Action, as well as employees of said Outside Counsel of Record 25 to whom it is reasonably necessary to disclose the information for 26 this Action; 27 b. The officers, directors, and employees (including House 1 necessary for this Action; 2 c. Experts (as defined in this Order) of the Receiving Party to 3 whom disclosure is reasonably necessary for this Action and who 4 have signed the “Acknowledgment and Agreement to Be Bound” 5 (Exhibit A); 6 d. The Court and its personnel; 7 e. Court reporters and their staff; 8 f. Professional jury or trial consultants, mock jurors, and 9 Professional Vendors to whom disclosure is reasonably necessary 10 or this Action and who have signed the “Acknowledgment and 11 Agreement to be Bound” attached as Exhibit A hereto; 12 g. The author or recipient of a document containing the 13 information or a custodian or other person who otherwise 14 possessed or knew the information; 15 h. During their depositions, witnesses, and attorneys for 16 witnesses, in the Action to whom disclosure is reasonably 17 necessary provided: (i) the deposing party requests that the 18 witness sign the “Acknowledgment and Agreement to Be Bound;” 19 and (ii) they will not be permitted to keep any confidential 20 information unless they sign the “Acknowledgment and 21 Agreement to Be Bound,” unless otherwise agreed by the 22 Designating Party or ordered by the Court. Pages of transcribed 23 deposition testimony or exhibits to depositions that reveal 24 Protected Material may be separately bound by the court reporter 25 and may not be disclosed to anyone except as permitted under this 26 Stipulated Protective Order; and 27 i. Any mediator or settlement officer, and their supporting 1 settlement discussions. 2 IX. PROTECTED MATERIAL SUPOENAED OR ORDERED PRODUCED 3 IN OTHER LITIGATION 4 A. If a Party is served with a subpoena or a court order issued in other 5 litigation that compels disclosure of any information or items designated in this 6 Action as “CONFIDENTIAL,” that Party must: 7 1. Promptly notify in writing the Designating Party. Such 8 notification shall include a copy of the subpoena or court order; 9 2. Promptly notify in writing the party who caused the subpoena or 10 order to issue in the other litigation that some or all of the material 11 covered by the subpoena or order is subject to this Protective Order. 12 Such notification shall include a copy of this Stipulated Protective Order; 13 and 14 3. Cooperate with respect to all reasonable procedures sought to be 15 pursued by the Designating Party whose Protected Material may be 16 affected. 17 B. If the Designating Party timely seeks a protective order, the Party served 18 with the subpoena or court order shall not produce any information designated in this 19 action as “CONFIDENTIAL” before a determination by the Court from which the 20 subpoena or order issued, unless the Party has obtained the Designating Party’s 21 permission. The Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material and nothing in these provisions 23 should be construed as authorizing or encouraging a Receiving Party in this Action to 24 disobey a lawful directive from another court. 25 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 A. The terms of this Order are applicable to information produced by a Non- 1 produced by Non-Parties in connection with this litigation is protected by the 2 remedies and relief provided by this Order. Nothing in these provisions should 3 be construed as prohibiting a Non-Party from seeking additional protections. 4 B. In the event that a Party is required, by a valid discovery request, to 5 produce a Non-Party’s confidential information in its possession, and the Party 6 is subject to an agreement with the Non-Party not to produce the Non-Party’s 7 confidential information, then the Party shall: 8 1. Promptly notify in writing the Requesting Party and the Non-Party 9 that some or all of the information requested is subject to a 10 confidentiality agreement with a Non-Party; 11 2. Promptly provide the Non-Party with a copy of the Stipulated 12 Protective Order in this Action, the relevant discovery request(s), and a 13 reasonably specific description of the information requested; and 14 3. Make the information requested available for inspection by the 15 Non-Party, if requested. 16 C. If the Non-Party fails to seek a protective order from this court within 14 17 days of receiving the notice and accompanying information, the Receiving Party may 18 produce the Non-Party’s confidential information responsive to the discovery request. 19 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 20 any information in its possession or control that is subject to the confidentiality 21 agreement with the Non-Party before a determination by the court. Absent a court 22 order to the contrary, the Non-Party shall bear the burden and expense of seeking 23 protection in this court of its Protected Material. 24 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 A. If a Receiving Party learns that, by inadvertence or otherwise, it has 26 disclosed Protected Material to any person or in any circumstance not authorized 27 under this Stipulated Protective Order, the Receiving Party must immediately (1) 1 efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the 2 person or persons to whom unauthorized disclosures were made of all the terms of 3 this Order, and (4) request such person or persons to execute the “Acknowledgment 4 and Agreement to be Bound” that is attached hereto as Exhibit A. 5 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 A. When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, 9 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 11 may be established in an e-discovery order that provides for production without prior 12 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 13 parties reach an agreement on the effect of disclosure of a communication or 14 information covered by the attorney-client privilege or work product protection, the 15 parties may incorporate their agreement in the Stipulated Protective Order submitted 16 to the Court. 17 XIII. MISCELLANEOUS 18 A. Right to Further Relief 19 1. Nothing in this Order abridges the right of any person to seek its 20 modification by the Court in the future. 21 B. Right to Assert Other Objections 22 1. By stipulating to the entry of this Protective Order, no Party 23 waives any right it otherwise would have to object to disclosing or 24 producing any information or item on any ground not addressed in this 25 Stipulated Protective Order. Similarly, no Party waives any right to 26 object on any ground to use in evidence of any of the material covered 27 by this Protective Order. 1 C. Filing Protected Material 2 1. A Party that seeks to file under seal any Protected Material must 3 comply with Civil Local Rule 79-5. Protected Material may only be filed 4 under seal pursuant to a court order authorizing the sealing of the specific 5 Protected Material at issue. If a Party's request to file Protected Material 6 under seal is denied by the Court, then the Receiving Party may file the 7 information in the public record unless otherwise instructed by the Court. 8 XIV. FINAL DISPOSITION 9 A. After the final disposition of this Action, as defined in Section V, within 10 sixty (60) days of a written request by the Designating Party, each Receiving Party 11 must return all Protected Material to the Producing Party or destroy such material. As 12 used in this subdivision, “all Protected Material” includes all copies, abstracts, 13 compilations, summaries, and any other format reproducing or capturing any of the 14 Protected Material. Whether the Protected Material is returned or destroyed, the 15 Receiving Party must submit a written certification to the Producing Party (and, if not 16 the same person or entity, to the Designating Party) by the 60 day deadline that (1) 17 identifies (by category, where appropriate) all the Protected Material that was returned 18 or destroyed and (2) affirms that the Receiving Party has not retained any copies, 19 abstracts, compilations, summaries or any other format reproducing or capturing any 20 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 21 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 22 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 23 reports, attorney work product, and consultant and expert work product, even if such 24 materials contain Protected Material. Any such archival copies that contain or 25 constitute Protected Material remain subject to this Protective Order as set forth in 26 Section V. 27 B. Any violation of this Order may be punished by any and all appropriate 1 || sanctions. 2| IT ISSO STIPULATED AND AGREED. DATED: September 21, 2021 PARRIS LAW FIRM By: /s/ Kitty M. Szeto 6 R. Rex Parris, Esq. Kitty M. Szeto, Esq. 7 John M. Bickford, Esq. g Attorneys for Plaintiffs, KAMELA WOODINGS and 9 JODI DORMAIER 10 DATED: September 21, 2021 LITTLER MENDELSON, P.C. 12 3 By: /s/ Hovannes G. Nalbandyan Rebecca Aragon. esd. 14 Hovannes G. Nalbandyan, Esq. Laura Schneider, Esq. Attorneys for Defendant, 16 FREEDOMROADS, LLC 17 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20 21||Dated: 9/22/21 & W Seis 9 ORABLE JOHN E. MCDERMOTT United States Magistrate Judge 23 24 25 26 27 28 14

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND BY ORDER 3 I, [print or type full name], of 4 [print or type full address], declare under penalty of perjury that I have 5 read in its entirety and understand the Stipulated Protective Order (“Order”) that was 6 issued by the United States District Court for the Central District of California after 7 September 15, 2021 in the case of Woodings, et al. v. FreedomRoads, LLC d/b/a 8 Camping World, et al., U.S. District Court for the Central District of California, Case 9 No. 2:20-cv-07072-MCS-JEM. 10 I agree to comply with and to be bound by all the terms of this Stipulated 11 Protective Order and I understand and acknowledge that failure to so comply could 12 expose me to sanctions and punishment in the nature of contempt. A copy of the Order 13 has been provided to me. I solemnly promise that I will not disclose in any manner 14 any information or item that is subject to this Stipulated Protective Order to any 15 person or entity except in strict compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint myself as the California agent for service 20 of process in connection with this action or any proceedings related to enforcement 21 of this Stipulated Protective Order. 22 I declare under penalty of perjury that the foregoing is true and correct. 23 Date: _____ 24 City and State where sworn and signed: _ 25 Printed Name: 26 Signature: _____ 27 1 SIGNATURE ATTESTATION 2 Pursuant to L.R. 5-4.3.4, the undersigned hereby attests that all signatories listed 3 above, and on whose behalf this STIPULATED PROTECTIVE ORDER is submitted, 4 concur in and have authorized the filing of this protective order. 5 Dated: September 22, 2021 /s/ Hovannes G. Nalbandyan. 6 7 CERTIFICATE OF SERVICE 8 I hereby certify that I instructed my assistant to electronically file the foregoing 9 document with the Clerk of the Court for the United States District Court, Central 10 District of California, by using the Court’s CM/ECF system. 11 I certify that all participants in the case are registered CM/ECF users and that 12 service will be accomplished by the Court’s CM/ECF system. 13

14 Dated: September 22, 2021 /s/ Hovannes G. Nalbandyan. 15

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