California False Claims Act Gov. Code § 12652 attorney fee petition mechanics: California Superior Court sealed qui tam complaint filing date as primary Welch anchor (the ONLY primary anchor in the fee-petition-mechanics series in a CALIFORNIA SUPERIOR COURT SEALED QUI TAM COMPLAINT — a Superior Court BC case number that cannot be found on the public docket, served only on the California AG under seal per § 12652(c)(2), distinct from every unsealed Superior Court case type, from federal FCA PACER cases, and from every California administrative agency complaint record), § 12652(g) mandatory relator attorney fees plus treble damages plus $5,500–$11,000 per-claim civil penalties, AG 60-day initial seal investigation period extendable indefinitely by court order outside the relator's scheduling control, concurrent federal FCA PACER dual-track in Medi-Cal fraud requiring lodestar segregation, and § 12652(g) Ketchum positive multiplier fee petition advisory on the recovery calendar

The sealed qui tam complaint preparation and first-to-file bar analysis and AG seal investigation advisory call cycle on the sealed complaint filing and AG investigation calendar: 5.39 untracked hours = $1,617–$2,695/year

The CALIFORNIA SUPERIOR COURT SEALED QUI TAM COMPLAINT FILING DATE — the date the relator's attorney files the CFCA complaint in California Superior Court under the seal procedures of Gov. Code § 12652(c)(2) — is the primary Welch temporal anchor for § 12652(g) attorney fee billing documentation. California False Claims Act qui tam practice is the ONLY practice area in the fee-petition-mechanics series where the primary Welch anchor is a CALIFORNIA SUPERIOR COURT SEALED QUI TAM COMPLAINT FILING DATE. To understand why this anchor is institutionally unique, it is necessary to examine the mechanics of the CFCA sealed complaint: when the relator's attorney files the CFCA complaint in California Superior Court, the clerk assigns a BC case number (the standard Superior Court civil unlimited jurisdiction case number format) — but immediately upon filing, the complaint and all exhibits are placed under seal pursuant to Gov. Code § 12652(c)(2). The sealed complaint is served only on the California Attorney General and the California DOJ under § 12652(c)(1); the defendant is not served, receives no notice, and the lawsuit does not appear on the court's public docket. No member of the public — including any opposing party, any potential witness, and any competing qui tam relator — can find the sealed CFCA case by searching the court's electronic case access system. This creates the fee-petition-mechanics series' unique paradox: a Superior Court case number (the institutional category that generates the greatest number of primary anchors in the entire series — civil harassment CH, domestic violence DV, workplace violence WV, unlawful detainer UD, general civil BC/CIV, probate PT, family law FL) that is simultaneously invisible on the public court record.

The CFCA sealed complaint filing date is the primary Welch anchor — not the later unsealing date when the defendant is first served — because CFCA practice generates its first and most substantial advisory work at the sealed filing date, before the defendant has any knowledge of the lawsuit. The relator interview series, the false claim category mapping, the first-to-file bar analysis, the original-source rule assessment, the statute of limitations analysis, the complaint exhibit collection, and the initial AG service advisory all occur between the sealed complaint filing date and the unsealing date. Under the Hensley lodestar standard (Hensley v. Eckerhart (1983) 461 U.S. 424), compensable work begins at the earliest billing event causally related to the § 12652(g) mandatory fee claim — which is the sealed complaint filing date and, for pre-filing investigation work, even earlier.

CFCA practice areas that generate sealed complaints in California Superior Court: (a) Medi-Cal billing fraud — California's Medi-Cal program (jointly funded by California and the federal government under the federal Medicaid Title XIX program) is the largest state government healthcare program and the most frequent target of CFCA qui tam enforcement; false claim categories include: procedure code upcoding (billing for a higher-reimbursement code than the service actually rendered), services not rendered (billing for patient encounters that did not occur), unbundling (billing individually for component services that should be billed as a single bundled code), kickback-tainted claims (claims for referrals or services generated by unlawful financial arrangements with referring providers under Cal. Welf. & Inst. Code § 14107.2); Medi-Cal fraud by licensed California healthcare providers — physicians, dentists, pharmacies, home health agencies, skilled nursing facilities, regional centers — is typically discovered by relators who are healthcare employees (billing coders, medical assistants, practice managers) with first-hand knowledge of systematic false-coding instructions. (b) California public works contractor fraud — false certifications on state-funded construction and services contracts managed by CalTrans (California Department of Transportation), DGS (Department of General Services), CalRecycle, California Energy Commission; false claim categories include: bid-rigging (coordinated contractor bids that eliminate genuine price competition on public-funded procurements), false prevailing-wage certifications (certified payroll reports showing false hourly rates for publicly-funded construction workers), subcontractor substitution fraud (listing disadvantaged business enterprise (DBE) subcontractors in the bid to meet DBE goals, then substituting non-DBE subcontractors during performance), change-order padding (falsely inflated change-order requests for altered scope with fabricated cost justifications). (c) California university research grant fraud — false certifications on California state research grants from UC system grants, Cal State grants, and California Energy Commission research awards; false claim categories include: effort misreporting (falsely certifying that a principal investigator spent the required percentage of effort on a California-funded research project while actually devoting that effort to other projects), equipment mischarging (falsely charging laboratory equipment purchased for general university use to specific California grant awards), and subrecipient monitoring failures (falsely certifying that subrecipient monitoring required under the grant terms was performed when it was not).

Initial advisory call types that generate untracked billing from the sealed complaint filing date: (a) Relator interview series and false claim category mapping advisory (40–48 min) — arrives when the qui tam relator first retains CFCA counsel (the sealed BC case number, once filed, is the Hensley lodestar start date; for pre-filing investigation work before the complaint is filed, the lodestar starts at the relator's initial retention date). The advisory covers: false claim category mapping for the specific scheme — identifying each procedure code upcoded with the billing codes, dates of service, provider NPI, and Medi-Cal claim amounts; for state contract fraud — identifying the contract number, contract period, each false certification, and the overbilling amount per invoice; first-to-file bar analysis under § 12652(d)(3) — confirming no pending CFCA qui tam action covers the same transaction or occurrence (AG's non-public pending qui tam register, PACER searches for pending federal FCA actions on the same scheme, public court record searches for any unsealed CFCA actions); government action bar analysis — confirming no pending state civil action or criminal prosecution covers the same false claim conduct; § 12654(a) statute of limitations: six years from the violation date for the earliest false claims in the scheme; ten-year absolute cap — for fraud schemes that began more than ten years ago, the earliest false claims may be time-barred and must be excluded from the complaint. (b) Complaint exhibit preparation and first-to-file filing advisory (40–48 min) — arrives during sealed complaint drafting. The advisory covers: document collection for complaint exhibits — Medi-Cal claim records (obtained from DHCS or from the relator's own employment records), state procurement records, electronic health record audit logs, contractor invoices and certified payroll records, state payment records; the CFCA complaint must plead with heightened specificity: the complaint must identify representative false claims with the precision required under the 'who, what, when, where, how' standard from Code Civ. Proc. § 430.10 (or federal Rule 9(b) if filed in conjunction with a federal FCA action); AG service: the sealed complaint is served on the California AG under § 12652(c)(1); the AG's investigation period: 60-day initial seal period under § 12652(c)(2), extendable by court order; seal extension advisory: explaining to the relator that the seal period may extend to 6 months, 2 years, or 4 years depending on the complexity of the AG's investigation and the AG's own resource prioritization — and that during the entire seal period, no billing events corroborated by public docket entries will exist, making contemporaneous call duration records from ClaimHour the only documentation mechanism for the advisory calls that constitute the § 12652(g) lodestar during the seal.

Arithmetic: 7 active California CFCA qui tam clients with sealed complaint preparation advisory, first-to-file bar analysis, relator interview series, false claim category mapping, AG investigation status advisory, and seal extension advisory needs during the year × 2 advisory calls (1 relator interview and first-to-file bar analysis and false claim category mapping advisory, 1 complaint exhibit preparation and AG service and seal extension advisory) × 42 min average × 55% untracked = 5.39 untracked hours = $1,617–$2,695/year at $300–$500/hr.

The Welch temporal anchor for sealed complaint advisory calls is the CALIFORNIA SUPERIOR COURT SEALED QUI TAM COMPLAINT FILING DATE — the date the sealed CFCA complaint is filed and the BC case number is assigned by the clerk. A § 12652(g) fee petition that begins the lodestar at the unsealing date — when the defendant is first served and the litigation enters the public docket — misses the entire sealed-complaint-to-unsealing lodestar period: the relator interview series, the first-to-file bar analysis, the original-source rule assessment, the complaint exhibit preparation, the AG investigation status advisory calls, and the seal extension advisory calls that occurred during the seal period and are compensable under § 12652(g) but will not appear in any public record until the unsealing date. In complex CFCA cases with seal periods of 2–4 years, the sealed-period lodestar can represent 200–600 compensable attorney hours — representing $60,000–$300,000 in CFCA mandatory fees at $300–$500/hr — that are recoverable only if contemporaneously documented.

The AG intervention decision advisory and concurrent federal FCA coordination advisory call cycle on the AG intervention calendar and the federal DOJ investigation calendar: 7.26 untracked hours = $2,178–$3,630/year

California CFCA qui tam practice generates two concurrent externally-controlled calendar obligations that operate entirely outside the relator's attorney's scheduling control: the California AG's intervention decision calendar (the AG decides whether to intervene, partially intervene, or decline — on the AG's own schedule at the end of the seal period) and, in Medi-Cal fraud matters involving federal financial participation funds, the federal DOJ/U.S. Attorney's concurrent FCA investigation calendar (the federal investigation proceeds on federal law enforcement's own schedule entirely independent of the CFCA AG investigation calendar). Each of these calendars generates advisory calls that are compensable in the § 12652(g) lodestar but arrive on schedules entirely outside the relator's attorney's control. Ketchum v. Moses (2001) 24 Cal.4th 1122 (positive multiplier). PLCM Group Inc. v. Drexler (2000) 22 Cal.4th 1084 (California prevailing market rate). Hensley v. Eckerhart (1983) 461 U.S. 424 (lodestar from CFCA sealed complaint filing date). Missouri v. Jenkins (1989) 491 U.S. 274 (fees-on-fees).

Three concurrent calendar advisory call types generate untracked billing: (a) AG intervention decision advisory and relator participation rights advisory (42–50 min) — arrives when the AG notifies the relator of the intervention decision at the end of the seal period. The advisory covers: Gov. Code § 12652(e)(1) — AG intervention: if the AG elects to intervene, the AG becomes the primary plaintiff; relator retains the right to continue as a party to the action; the relator's share is 15–25% of recovery under § 12652(g)(1); the relator's share range is determined by the court based on the extent to which the relator substantially contributed to the prosecution — relators whose complaint and disclosure statement were the primary driver of the AG's investigation receive shares at the higher end of the 15–25% range; after intervention, the AG controls the discovery schedule, motion practice, deposition calendar, and settlement negotiations — the AG's litigation calendar is now the externally-controlled calendar for the duration of the CFCA action; every AG litigation milestone (written discovery propounded, depositions scheduled, summary judgment motion filed, settlement conference) generates an advisory call for the relator's attorney on the AG's externally-controlled calendar. Gov. Code § 12652(f) — AG declination: if the AG declines, the relator proceeds independently; the relator's share is 25–50% under § 12652(g)(2); relator's attorney now controls the full litigation calendar but faces full litigation cost-basis risk on contingency; AG declination risk advisory: explaining to the relator the practical implications of independently prosecuting a complex Medi-Cal fraud or state contractor fraud case entirely on contingency — including the cost-basis calculation at a 25–50% relator share versus the full litigation cost. Court-approved relator share reduction advisory: if the court finds the CFCA action was based primarily on public disclosures under § 12652(d)(3)(A), the court may reduce the relator's share under § 12652(g)(3); advisory on the original-source documentation needed to defeat a § 12652(g)(3) reduction. (b) Concurrent federal FCA dual-track coordination advisory (42–50 min) — arrives when the underlying CFCA false claims also involve federal Medicaid financial participation funds and a concurrent federal FCA action has been filed in federal district court. The advisory covers: dual-track structure: California CFCA Superior Court action (CA AG investigation, § 12652(g) fee petition in Superior Court) and federal FCA federal district court action (federal DOJ/U.S. Attorney investigation, § 3730(d) fee petition in federal court) proceeding simultaneously on separate investigation and litigation calendars; federal DOJ coordination calls: the federal DOJ/U.S. Attorney investigates independently of the California AG; the federal DOJ may interview the relator on the federal investigation's own schedule; federal PACER case number created for the federal FCA action — the federal docket is the second external calendar outside the relator's attorney's scheduling control; lodestar task-level segregation advisory: advising the relator's attorney on how to attribute each advisory call to the California CFCA track, the federal FCA track, or both (proportionally) — with California-track hours documented for the § 12652(g) Superior Court fee petition and federal-track hours documented for the § 3730(d) federal court fee petition; Ketchum multiplier divergence: the California § 12652(g) petition allows the Ketchum positive multiplier; the federal § 3730(d) petition does not (City of Burlington v. Dague (1992) 505 U.S. 557); settlement coordination: if the AG and DOJ jointly settle both the CFCA and federal FCA claims in a global settlement agreement, the relator's share allocation between the California recovery (§ 12652(g)(1)/(2)) and the federal recovery (31 U.S.C. § 3730(d)(1)/(2)) must be documented for the two separate fee petitions. (c) Post-unsealing case management advisory (42–50 min) — arrives when the seal is lifted and the defendant is served. The advisory covers: defendant notification and public docket entry: the BC case number becomes publicly accessible for the first time; defendant retains defense counsel; defense discovery and motion calendar set by the court on the court's own schedule (entirely outside the relator's attorney's scheduling control); AG-controlled discovery advisory (if AG intervened): the AG controls the deposition calendar, written discovery, and expert designations; relator's participation in AG-led discovery generates advisory calls on the AG's litigation calendar; § 12651(a) civil penalty calculation advisory: California CFCA civil penalties of $5,500–$11,000 per false claim; for large Medi-Cal fraud schemes with thousands of false claims, per-claim civil penalties can substantially exceed treble damages as the primary damages measure; penalty calculation requires identifying and tallying each individual false claim (each separate billing submission to DHCS constitutes a separate false claim under § 12651(a)); joint settlement allocation advisory: when the CFCA action and any concurrent federal FCA action settle simultaneously, the relator's share under each statute must be calculated separately and the settlement agreement must allocate recovery between the CFCA track and the federal FCA track for purposes of the two separate fee petitions.

Arithmetic: 6 active CFCA qui tam clients with AG intervention decision advisory, relator participation rights advisory, federal FCA dual-track coordination advisory, and post-unsealing case management advisory needs during the year × 3 advisory calls (1 AG intervention decision and relator participation rights advisory, 1 federal FCA dual-track coordination advisory, 1 post-unsealing case management advisory) × 44 min average × 55% untracked = 7.26 untracked hours = $2,178–$3,630/year at $300–$500/hr.

The unique billing gap driven by the AG intervention calendar: unlike every other externally-controlled calendar in the fee-petition-mechanics series — the DA criminal prosecution calendar (CIPA, civil theft), the CRD administrative investigation calendar (FEHA, equal pay), the CDPH LTC survey calendar (physical elder abuse, healthcare worker whistleblower), the DCFS child welfare calendar (domestic violence, physical elder abuse) — the California AG's CFCA intervention decision calendar operates entirely in private until the moment of decision: no public docket entries are created, no court filings are made, no opposing-party contacts occur, and the entire investigation period generates only the relator's attorney's own billing records as contemporaneous documentation of advisory work. This means that the most extended externally-controlled calendar in the series — potentially 2–4 years of sealed investigation — also has the weakest external corroboration for the advisory calls that arise during it.

The § 12652(g) mandatory relator share and attorney fee petition and Ketchum positive multiplier advisory call cycle on the recovery calendar: 4.03 untracked hours = $1,210–$2,017/year

Gov. Code § 12652(g) provides mandatory attorney fees and costs to the qui tam relator who prevails in a CFCA action: "the qui tam plaintiff shall also be awarded all costs of the civil action plus reasonable attorney's fees and expenses that the court finds to have been necessarily incurred." The § 12652(g) fee petition requires a Hensley lodestar from the sealed complaint filing date through all phases — sealed investigation period (including all seal-period advisory calls documented only by contemporaneous billing records), unsealing, discovery, trial or settlement — including all advisory work on the AG's externally-controlled calendar and on the federal DOJ's concurrent investigation calendar in dual-track Medi-Cal fraud cases. The § 12652(g) fee petition presents the highest documentation challenge in the fee-petition-mechanics series precisely because the longest and most intensive phase of the lodestar — the multi-year sealed investigation period — has the least external corroboration: no public docket entries, no court filings, no opposing-party contacts, and no institutional records outside the AG's non-public investigation files. Courts reviewing § 12652(g) fee petitions apply full Hensley scrutiny to sealed-period billing entries; reconstructed entries assembled months or years after the advisory calls occurred (from memory alone, without contemporaneous call duration records) are subject to a 30–50% reduction for vagueness and unreliability.

CFCA qui tam practice presents the strongest Ketchum positive multiplier argument in the entire fee-petition-mechanics series. Ketchum v. Moses (2001) 24 Cal.4th 1122 requires an examination of the contingency risk that existed as of the earliest lodestar date — the sealed complaint filing date — and identifies risk factors that justify a positive multiplier above the lodestar amount. In CFCA qui tam practice, five independent contingency risk factors are simultaneously present as of the sealed complaint filing date: (1) no payment until judgment or settlement (the relator's attorney receives nothing until final judgment or settlement in a proceeding that may take 3–7 years from the sealed complaint filing date — the longest no-payment-until-judgment period of any practice area in the fee-petition-mechanics series); (2) AG declination risk (the AG may decline to intervene, leaving the relator to prosecute a complex false claim scheme entirely on contingency without government litigation support — a risk that is binary at the sealed complaint filing date and entirely unresolvable until the AG's decision is delivered); (3) multi-year seal period risk (the seal period may extend 2–4 years during which the attorney's entire lodestar accumulation is at risk of total loss if the action is subsequently dismissed); (4) first-to-file bar risk (the first-to-file bar under § 12652(d)(3) is a jurisdictional defect that must be resolved by the AG's investigation — if a prior pending qui tam covers the same transaction, the relator's action must be dismissed regardless of its merits, destroying the entire sealed-period lodestar); (5) original-source rule risk (if the false claim scheme was publicly disclosed in a prior administrative or legal proceeding and the relator cannot establish original-source status, the action is subject to dismissal under § 12652(d)(3)(A)). PLCM Group Inc. v. Drexler (2000) 22 Cal.4th 1084 governs the California prevailing market rate at $300–$500/hr for solo California CFCA qui tam attorneys in 2026. Missouri v. Jenkins (1989) 491 U.S. 274 fees-on-fees: time spent preparing the § 12652(g) mandatory fee petition is itself compensable in the § 12652(g) award.

Two § 12652(g) post-recovery advisory call types generate untracked billing: (a) Relator share calculation and § 12652(g) fee petition scope advisory (42–50 min) — arrives at recovery or settlement. The advisory covers: relator's share calculation under § 12652(g)(1) (AG intervention: 15–25% of recovery) or § 12652(g)(2) (AG declination: 25–50% of recovery); court-approved reduction under § 12652(g)(3) — if the action was based primarily on public disclosures, the court may reduce the relator's share; original-source documentation advisory: assembling the evidence that the relator had independent knowledge of the false claim scheme predating any public disclosure (relator's employment records, contemporaneous notes, prior disclosure evidence) to defeat a § 12652(g)(3) reduction motion; § 12651(a) treble damages and civil penalty calculation: California CFCA civil penalties of $5,500–$11,000 per individual false claim, plus treble damages on all actual damages (the difference between what was paid and what should have been paid); for large Medi-Cal fraud schemes, the per-claim penalty calculation requires itemizing each false claim — each separate billing submission — that was proven at trial or included in the settlement; § 12652(g) fee petition scope: all advisory calls from the sealed complaint filing date through judgment or settlement are compensable, including all seal-period calls (critical: these are documented only by the relator's attorney's contemporaneous billing records); Missouri v. Jenkins fees-on-fees: time spent preparing the § 12652(g) fee petition itself — assembling the sealed-complaint-date-to-judgment Hensley lodestar, documenting the five Ketchum contingency risk factors, computing the civil penalty and treble damages calculation, and segregating CFCA-specific hours from concurrent federal FCA § 3730(d) petition hours in dual-track cases — is itself compensable. (b) Sealed-period billing documentation assembly advisory and Ketchum multiplier documentation advisory (42–50 min) — arrives as counsel prepares the § 12652(g) mandatory fee petition. The advisory covers: sealed-period documentation assembly: unlike any other component of any other fee petition in the fee-petition-mechanics series, the sealed-period lodestar entries have no corroborating external records — no public docket entries, no court-generated documents, no opposing-party communications exist for the entire sealed period; the only contemporaneous records are the relator's attorney's own billing records and, for each advisory call, the call duration metadata captured by ClaimHour from the moment of sealed complaint filing through the entire seal period; courts reviewing § 12652(g) fee petitions that include large sealed-period lodestar claims apply heightened Hensley scrutiny to entries covering periods with no external corroboration; reconstructed entries (assembled from memory alone after the seal period) are reduced by 30–50% for vagueness and unreliability; Ketchum multiplier documentation: identifying and articulating each of the five compounding contingency risk factors present at the sealed complaint filing date and quantifying their impact on the attorney's decision to accept the CFCA matter on contingency; the five-factor Ketchum analysis in a CFCA fee petition is more comprehensive than the one-factor or two-factor Ketchum analyses applicable in most other mandatory-fee practice areas in the series; the social-importance Ketchum factor: California courts have recognized that CFCA qui tam enforcement protects public funds from systematic fraud by government contractors, healthcare providers, and research grant recipients — the social importance of CFCA enforcement supports the positive multiplier independent of contingency risk.

Arithmetic: 5 active § 12652(g) fee petition clients requiring relator share calculation advisory, sealed-period Hensley lodestar assembly from the sealed complaint filing date, Ketchum multiplier documentation, § 12651(a) treble damages and civil penalty calculation advisory, and federal FCA lodestar segregation advisory needs during the year × 2 advisory calls (1 relator share calculation and § 12652(g) fee petition scope advisory, 1 sealed-period billing documentation assembly and Ketchum multiplier documentation advisory) × 44 min average × 55% untracked = 4.03 untracked hours = $1,210–$2,017/year at $300–$500/hr.

How ClaimHour fits California CFCA qui tam practice

California False Claims Act (CFCA) qui tam solos billing hourly on Gov. Code § 12652(g) mandatory attorney fees and costs — with sealed complaint advisory calls arriving when relators retain CFCA counsel and the sealed Superior Court BC case number starts the Hensley lodestar (the ONLY primary Welch anchor in the fee-petition-mechanics series in a CALIFORNIA SUPERIOR COURT SEALED QUI TAM COMPLAINT FILING DATE — simultaneously a Superior Court BC case number and a sealed government investigation document inaccessible on the public docket; the sealed complaint date begins a billing period with no public docket entries, making the relator's attorney's own contemporaneous billing records the sole documentation mechanism for all seal-period advisory work), AG investigation calendar advisory calls arriving when the AG investigates on the AG's own schedule entirely outside the relator's attorney's scheduling control (60-day initial seal period extendable indefinitely by court order), concurrent federal FCA PACER coordination advisory calls arriving when Medi-Cal fraud involves federal financial participation funds and a second externally-controlled federal investigation calendar is created, AG intervention decision advisory calls arriving when the AG's intervention or declination reshapes the relator's share and litigation role, and § 12652(g) mandatory relator share fee petition advisory calls arriving at recovery — and if your § 12652(g) lodestar documentation must satisfy the Hensley contemporaneous-record standard from the sealed complaint filing date (including all seal-period advisory calls that have no corroborating public docket entries or opposing-party communications), through the AG investigation period, through unsealing, through discovery, through trial or settlement, through the § 12652(g) mandatory attorney fee petition, with the strongest Ketchum positive multiplier argument in the fee-petition-mechanics series driven by five compounding contingency risk factors simultaneously present at the sealed complaint filing date, ClaimHour was built for that gap.

The federal FCA qui tam practice area (federal FCA qui tam fee petition mechanics — 31 U.S.C. § 3730) is the federal analog to California CFCA practice: same sealed complaint structure, same relator interview series, same AG/DOJ investigation calendar — but filed in federal district court under federal law, with a federal PACER case number, federal DOJ investigation, and § 3730(d) fee petition in federal court with no Ketchum multiplier. The California CFCA practice generates a distinct California Superior Court BC sealed case number, a California AG investigation calendar, § 12651(a) per-claim penalties ($5,500–$11,000/claim), and a § 12652(g) fee petition in Superior Court with the full Ketchum v. Moses positive multiplier analysis available.

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