Variety of fast electronic ways for police officers

16 / Journal of the MISSOURI BAR
H. Morley Swingle
Beam Me Up: UpgradWith Technology
Technology now offers a
variety of fast electronic
ways for police officers and
prosecutors to seek search
warrants from judges, but
care must be taken to ensure
that Fourth Amendment
requirements are met.
“Beam me up, Scotty!”
The judge heard the detective’s voice in
her living room just before two clouds of
whirling bright particles appeared in front
of her sofa. She made sure her bathrobe
was secure as the shapes began materializing into the recognizable forms of the detective and the assistant prosecutor coming
to her home to apply for a search warrant.
This wasn’t the first time she had issued a
search warrant in the middle of the night,
but the latest technology still amazed her.
“Good morning, Judge,” said the detective, when his face finally quit flickering.
The teleportation device used in Star
Trek is not yet available in most Missouri counties, but many high-tech
ways of applying for a search warrant
are currently in use that are far beyond
the dreams of even the most imaginative member of the Constitutional
Convention. When James Madison
and other Founding Fathers drafted the
oath requirement of the Fourth Amendment, they most likely envisioned law
enforcement officers personally appearing in front of magistrate judges with
raised hands while applying for search
warrants. The idea of swearing to an
oath by telephone, fax machine, e-mail,
iPad, Skype or other modern technological development could hardly have
been foreseen. Both federal rules2
Missouri statutes3
now allow search
warrants to be obtained by “electronic
means.” The U.S. Supreme Court
recently observed that it is unwise to
“elaborat[e] too fully on the Fourth
Amendment implications of emerging
technology before its role in society has
become clear.”4
What can be said is that,
as a matter of constitutional law, the
oath requirement must always be met
when applying for a search warrant, but
that modern technology provides a variety of ways to satisfy that prerequisite.
Oath Requirement
The warrant clause of the Fourth
Amendment provides that “no warrants
shall issue but upon probable cause,
supported by oath or affirmation.”5
Missouri Constitution has an identical
Missouri’s search warrant
statutes require an application and its
supporting affidavit to “[b]e verified
by oath or affirmation.”7 Black’s Law
Dictionary defines an oath as “[a]
solemn declaration, accompanied by
a swearing to God or a revered person
or thing, that one’s statement is true or
that one will be bound to a promise,”8
while an affirmation is defined as “[a]
solemn pledge equivalent to an oath but
without reference to a supreme being or
to swearing,”9
and the legal effect of either an oath or affirmation is to subject
Lane P. Thomasson
January-February 2013 / 17
ding Search Warrants
the person to “the penalties for perjury”
if the testimony is false.10 The oath requirement exists to ensure accountability and to prevent governmental abuse.
Its purpose is to “ensure that the truth
will be told by insuring that the witness
or affiant will be impressed with the solemnity and importance of his words.”11
Invading someone’s person, home,
papers or effects is a serious matter. By
requiring the affiant to be under penalty
of perjury when providing the probable
cause for the search, the Constitution is
forcing the government to take care not
to stretch facts, exaggerate or fabricate
the truth. The oath requirement is one
of the great protections provided by the
Fourth Amendment.
Since search warrants are often
needed after regular business hours,
generations of judges have opened their
homes to police and prosecutors in the
middle of the night and sat bleary-eyed
in bathrobes as they administered oaths
and read hastily-typed probable cause
affidavits. The modern, technicallysavvy judge, however, may never again
be caught in a bathrobe. More and more
cases are making it clear that taking an
oath when applying for a search warrant does not necessarily involve being
in the physical presence of the judge.12
The constitutional test is whether the
procedures being used sufficiently impress upon the affiant the importance of
telling the truth.
Warrants by Telephone
The Federal Rules of Criminal Procedure specifically authorize the issuance
of search warrants “based on information communicated by telephone or
other reliable electronic means.”13 At
least part of the motivation of Congress
in allowing telephonic search warrants
was to make it easier to get warrants
quickly and thereby decrease the need
for warrantless searches.14 The Federal
Rules initially authorized telephonic
search warrants in 1977, added approval
of fax machines in 1993,15 and included
the reference to “other reliable electronic
means” in 2006. Likewise, some states
have enacted specific statutes setting
forth procedures to follow when getting
18 / Journal of the MISSOURI BAR
search warrants by telephone.16 Under
the federal rules, an officer may verbally describe the probable cause for
the judge over the phone. The conversation is “recorded by a court reporter
or by a suitable recording device, and
the judge must file the transcript or
recording with the clerk”17 so that
a reviewing court can later rule on
the issue of whether the warrant was
supported by probable cause. The
2nd Circuit eloquently explained why
swearing an oath over the telephone
comports with the Fourth Amendment:
In a ritualistic sense, it may
be that an oath taken over the
telephone appears less formal
or less solemn than one taken
in the physical presence of
the oath taker. The constitutionality of oaths does not
depend, however, on such
purely ritualistic considerations. In every meaningful
sense, [the officers on the
telephone] were under oath.
We hold that search warrant
application procedures can
constitutionally be brought
into line with twentieth century technology.18
Missouri has no statutory authority
allowing telephonic search warrants
based upon oral testimony. Missouri
law requires the application and affidavit for a search warrant to be in
writing.19 “Oral testimony [is] not
[to] be considered” when a judge is
making a determination as to whether
to issue a search warrant.20 Any
Missouri search warrant must meet
those requirements. The Minnesota
Supreme Court, however, upheld the
validity of a search warrant issued by
telephone under procedures similar to
those in the federal rules, even though
Minnesota’s statutory scheme did
not specifically authorize them and
the procedure technically violated a
Minnesota statute requiring the issuing judge to sign the warrant.21 The
Illinois Court of Appeals, on the other
hand, held that an Illinois statute
saying that search warrants could “be
issued electronically . . . by the use of
a facsimile transmission machine”22
did not authorize the oral issuance of
a warrant without the judge’s signature.23 It seems unlikely Missouri
courts would uphold a telephonic
search warrant unsupported by a written application and affidavit, even if
the entire conversation were recorded.
A 2012 survey of the 115 Missouri
prosecutor’s offices showed that not
even one has ever obtained a search
warrant by oral testimony over the
Combining Fax and Telephone
Missouri amended its search warrant statutes in 2004 to specify that an
application for a search warrant “may
be submitted by facsimile or other
electronic means”25 and made another
amendment in 2010 specifying that
“[t]he application or execution of a
search warrant shall not be deemed
invalid for the sole reason that the application or execution of the warrant
relies upon electronic signatures of
the peace officer or prosecutor seeking the warrant or judge issuing the
warrant.”26 Many states specifically
allow search warrants to be obtained
by use of fax machines.27 Courts
have ruled that it does not violate
the Fourth Amendment for a police
officer to fax a search warrant affidavit
to a judge and then swear to it over
the telephone.28 The Michigan Court
of Appeals held that “[t]he telephonic
link by which the judge and the officer communicated creates enough of
a presence to satisfy” the statutory and
Fourth Amendment purposes.29 In
the 2012 survey, 27 Missouri prosecutor’s offices (23.4 percent) reported
obtaining search warrants after having
the judge verify a written affidavit by
swearing the officer over the telephone.30
Combining Fax and Notary
Courts have unanimously approved
having the officer sign an affidavit
in front of a notary public before
faxing it to the judge.31 In 2004,
the Idaho Court of Appeals noted
that the Fourth Amendment’s oath
requirement does not mean the judge
must be the person administering the
oath to the affiant, and that the oath
requirement is satisfied by having the
officer swear to the truthfulness of his
affidavit before a notary.32 The 8th
Circuit reached the same result when
dealing with a Missouri state court
search warrant where the underlying affidavit had been sworn in front
of a notary instead of a judge.33 The
bottom line is that an oath in front
of a notary public, court clerk34 or
other person authorized to administer
oaths35places the affiant under penalty
of criminal prosecution for swearing
to false facts. Thus, the purpose of an
oath requirement is being fulfilled.
Fifty-one Missouri prosecutor’s offices
(44.3 percent) report satisfying the
oath requirement by having the officer
swear to the search warrant affidavit
in front of a notary instead of the
Oaths on Forms Bearing Perjury
Courts have held that the Fourth
Amendment’s oath requirement is
met when the document the officer
is signing specifically states that the
officer is signing it under penalty of
criminal prosecution for making a
false affidavit. In People v. Sullivan,
the New York Court of Appeals noted
that facing the threat of criminal prosecution ensures that an officer will be
careful to state facts accurately. In that
case, the form specifically said: “False
statements made herein are punishable
as a Class A Misdemeanor pursuant
to section 210.45 of the Penal Law.”38
The Sullivan court held that voluntarily acknowledging and accepting
the consequences of potential criminal
prosecution “should suffice for pur-
January-February 2013 / 19
poses of the constitutional mandate
that a warrant be issued upon proof
‘supported by oath or affirmation.’”39
This procedure seems to be specifically authorized in Missouri, where
Rule 22.03(e) specifies that the oath
requirement for an arrest warrant is
satisfied by having the officer make
the statement “on a form bearing
notice that false statements therein are
punishable by law.” Fourth Amendment scholar Wayne R. LeFave has
noted that the “true test” for meeting
the oath requirement is whether the
affiant could be charged with perjury
if a material allegation in the affidavit
were false.40 Nineteen Missouri prosecutor’s offices (16.5 percent) have satisfied the oath requirement by having
the officer sign the affidavit on a form
bearing notice that false statements
therein are punishable as a crime.41
Search Warrants by E-Mail
The 2004 and 2010 amendments
to Missouri’s search warrant statute
authorizing search warrant applications to be made by electronic means
and with electronic signatures permit
e-mail search warrants and indicate
the state’s intent to make it easier to
obtain search warrants in ways other
than a face-to-face appearance in front
of a judge. When the federal rule was
amended in 2006 using identical language, the Advisory Committee Notes
instructed that “[t]he term ‘electronic’
is used to provide some flexibility to
the rule and make allowance for further technological advances in transmitting data.”42
By June of 2012, 15 Missouri
prosecutor’s offices (13.0 percent) had
used e-mail to obtain search warrants,
and five others (4.3 percent) indicated
that although they had not yet done
so, they had a process in place to accomplish it.43
Speed is probably the biggest advantage of getting search warrants by
e-mail. With e-mail, officers can get
search warrants quickly without leaving the crime scene.44 An officer who
has e-mail capability can electronically
send his affidavit to the prosecutor,
who can forward it with the application for the search warrant to the
judge, who can return the warrant
by e-mail. The entire process can be
accomplished within minutes when
officers, prosecutors and judges have
the right technology. In San Diego, 95
percent of the telephonic search warrants issued in 1973 were processed in
less than 45 minutes.45 It seems likely
that “warrants obtained by e-mail
would take even less time.”46
One advantage of search warrants
by e-mail or fax is that a contemporaneous written record is made of the
probable cause affidavit at the time
the search warrant is issued. This is
preferable to the telephonic method,
where a recording of the verbal probable cause statement must later be
The Fourth Amendment’s oath
requirement can be met in the e-mail
situation by having the officer’s affidavit indicate that a false statement
in the document is punishable as a
crime. Cases from other jurisdictions
and Rule 22.03 provide support for
this procedure.48
Various options are available for
putting the officer’s signature on the
affidavit, the prosecutor’s signature on
the application, and the judge’s signature on the warrant. Different local
jurisdictions may choose to satisfy the
requirement in different ways.
One method is for the officer, prosecutor and judge to use an “electronic
signature.” Many computer programs
for use with e-mail have the capability of putting a person’s signature
onto a document. For example, iPad
and iPhone applications exist, such as
DocuSign Ink,49 SignMyPad,50 and
Sign-N-Send,51 that allow the user to
create a signature that can be securely
applied to any number of documents, including e-mails and PDF
documents. In Christian County, the
local prosecutor and judge have used
a 99-cent signature application to
produce signatures on search warrants
obtained by e-mail using iPads.52 Per
the 2010 Missouri statute, a search
warrant is not to be deemed invalid
merely because an electronic signature
procedure was used.53
Another option would be for the
officer and judge to place their signatures on the documents using the
format: /s/ John or Jane Person. This
format has been approved in Missouri
in the context of Rule 103.04(d),
effective September 1, 2011, which
provides: “An electronic document
requiring a signature shall be signed
by an original signature, stamped
signature or an electronic graphic
representation of a signature, or in
the following manner: /s/ John or
Jane Person.” Although Rule 103 and
Court Operating Rule 27 dealing with
electronic filing do not yet provide a
statewide procedure for an electronic
search warrant application process, it
is possible they may in the future. For
now, the instructive language regarding electronic signatures is helpful.
A third option is for the judge
to authorize the officer to sign the
judge’s signature. This method was
approved by the Supreme Court of
Idaho, which noted that as a ministerial function a judge could direct a
third person (in that case a prosecutor
participating in a three-way phone call
with the judge and the police officer)
to sign the warrant on the judge’s behalf.54 Likewise, federal rules allow the
judge to sign the original and direct
the officer to sign the judge’s name to
a “duplicate original.”55
Yet another alternative would be the
use of a program that allows the officer and judge to photograph signed
20 / Journal of the MISSOURI BAR
documents with a smartphone and
send the documents to each other.
Several iPhone applications such as
JotNot Scanner Pro and TurboScan
already exist for such a procedure, as
well as an Android application called
Another possibility is to e-mail the
affidavit to the judge but swear to it
over the telephone.57 In Henry County, a streamlined process has been
established whereby the officer e-mails
the affidavit and application to the
prosecutor, who adds his electronic
signature using his Droid phone and
DocuSign Ink technology; the prosecutor then e-mails the documents
back to the officer, who forwards
them to the judge and swears to the
affidavit over the telephone; the judge
signs the warrant using DocuSign Ink
and e-mails it to the patrol car of the
state trooper, which is equipped with
a printer.58 Platte County has a plan in
place to use Skype59 with its electronic
search warrant process, so the judge,
prosecutor and law enforcement
officer can see each other by video
conferencing while the warrants are
being obtained.60
Technology will undoubtedly come
up with easier, faster and cheaper
ways to satisfy the oath and signature
requirements. For now, no statewide
standard exists. Local jurisdictions
will find methods that work best for
them while still satisfying the Fourth
Amendment protections.
Retention of Records
Whatever method is being used,
the judge should make sure to retain a
copy of the application, affidavit and
search warrant for the court records.
In that way, the court can guard
against the officer’s electronic records
being tampered with and can preserve
for the record the exact probable cause
on which the search warrant was
issued, so that the defense can later
challenge it, should it be defective.
Impact on Warrantless Searches
The availability of electronic search
warrant procedures can be a benefit
to the defense, as well as the prosecution. In jurisdictions where electronic
search warrants are authorized by law,
the fact that law enforcement agencies and prosecutors could be utilizing
these time-efficient methods to obtain
search warrants is working against
them when they later try to justify a
warrantless search on the grounds of
exigent circumstances. For example, a
recent Utah case61 (cited with approval
by the Supreme Court of Missouri62)
held that the availability of telephonic
and electronic search warrants was a
factor to consider when determining
whether a warrantless search of blood
was reasonable under the totality of
the circumstances. The court upheld
the search, but only after noting: “We
are confident that were law enforcement officials to take advantage of
available technology to apply for
warrants, the significance of delay in
the exigency analysis would markedly
diminish.”63 Federal courts have been
considering the availability of telephonic warrants in the exigency analysis since at least 1981.64 Many commentators are encouraging defense
attorneys to challenge warrantless
searches as being unreasonable on the
grounds that it would have been easy
for the officer to obtain a telephonic
or electronic search warrant.65 Sometimes a court will conclude, however,
that even a telephonic or electronic
search warrant would have taken too
long under the circumstances, so a
warrantless search was still justified.66
Communications technology is advancing at warp speed. Since time is of
the essence when seeking some search
warrants, especially those for alcohol
in the blood of drunk drivers,67 new
developments in electronic communication will continue to be used when
applying for and issuing search warrants. As long as the procedures meet
the oath requirement and provide a
written record of the probable cause
supporting the warrant, a face-toface meeting with the issuing judge
will not be necessary. Things like fax
machines and e-mail will suffice until
that future time when Star Trek-type
technology will allow the police officer
and prosecutor to be “beamed” into
the judge’s living room to present the
affidavit. Until then, officers will not
be seeing many judges in bathrobes.
1 Mr. Swingle, who served as prosecuting
attorney for Cape Girardeau County, Missouri,
for 25 years, is an Assistant U.S. Attorney
for the Eastern District of Missouri. The
viewpoints expressed in this article do not
necessarily reflect those of the Department
of Justice. Ms. Thomasson is a law student at
Southern Illinois University School of Law.
2 Fed. R. Crim. P. 41(d)(3).
3 Sections 542.276.3 and 542.276.11,
RSMo Supp. 2011.
4 City of Ontario, Cal. v. Quon, 130 S.Ct.
2619, 2629 (2010).
5 U.S. Const., amend. IV.
6 Mo. Const., art. I, §. 15.
7 Sections 576.276.2(6) and 576.276.3,
RSMo Supp. 2011.
8 Black’s Law Dictionary 1167 (9th ed.
9 Black’s Law Dictionary 68 (9th ed.
10 Id.
11 United States v. Brooks, 285 F.3d 1102,
1105 (8th Cir. 2002).
12 Brooks, 285 F.3d at 1104-06 (8th Cir.
2002) (affidavit sworn in front of notary public before giving to judge); State v. Scholes, 753
N.W.2d 377 (N.D. 2008) (affidavit sworn in
front of clerk before presenting to judge); State
v. Bicknell, 91 P.3d 1105, 1107 (Idaho 2004)
(affidavit sworn in front of notary); People v.
Fournier, 793 P.2d 1176, 1179 (Colo. 1990)
(affidavit sworn before clerk); People v. Peck,
113 Cal. Rptr. 806 (1974) (sworn to judge
over telephone); People v. Chavez, 104 Cal.
Rptr. 247 (1972) (sworn in front of clerk).
See also 2 Wayne R. LaFave, Search and
Seizure: A Treatise on the Fourth Amendment § 4.3(e), at n. 58 (4th ed. 2004).
13 Fed. R. Crim. P. 41 (d)(3).
14 Justin H. Smith, Press One for Warrant:
Reinventing the Fourth Amendment’s Search
Warrant Requirement Through Electronic
Procedures, 55 Vand. L. Rev. 1591, 1606-07
15 Michael John James Kuzmich, Arrest and Search Warrants by E-mail,
30 McGeorge L. Rev. 590, 591 (1999).
16 See Alaska Stat. § 12.35.015 (2012);
Neb. Rev. Stat. § 29-814.03 (2011); S.D.
Codified Laws § 23A-35-5 (2012).
17 Fed. R. Crim. P. 41 (d)(2)(C).
18 United States v. Turner, 558 F.2d 46, 50
(2nd Cir. 1977).
19 Sections 542.276.2(1) and 542.276.3,
RSMo Supp. 2011.
20 Section 542.276.3, RSMo Supp. 2011.
January-February 2013 / 21
54 State v. Zueger, 152 P.3d 8 (Idaho 2006).
See also State v. Andries, 297 N.W.2d 124, 126
(Minn. 1980).
55 Fed. R. Crim. P. 41(e)(3)(D).
56 Bob Tedeschi, Scanner Apps Turn the
Phone Into a Fax Machine, New York Times,
Feb. 1, 2012, at B8.
57 People v. Snyder, 449 N.W.2d 703, 706
(Mich. Ct. App. 1989) (oath over telephone
satisfies Fourth Amendment).
58 Interview with Richard Shields, prosecuting attorney of Henry County, Missouri (June
27, 2012).
59 Skype is a software application that allows users to communicate over the Internet
by both voice and video at the same time. As
of September 2011, it had 663 million registered users. See
Skype (last visited Dec. 10, 2012).
60 Interview with Amy Ashelford, assistant
prosecuting attorney for Platte County (June
29, 2012).
61 State v. Rodriguez, 156 P.3d 771 (Utah
62 State v. McNeely, 358 S.W.3d 65, 70-71
(Mo. banc 2012).
63 156 P.3d at 778.
64 United States v. McEachin, 670 F.2d
1139, 1146 (D.C. Cir. 1981). See also United
States v. Ford, 56 F.3d 265, 272 (D.C. Cir.
1995); United States v. Patino, 830 F.2d 1413,
1416-17 (7th Cir. 1987); United States v.
Baker, 520 F.Supp. 1080, 1083-85 (S.D. Iowa
65 Hingson, note 45, at 40; Geoffrey P.
Alpert, Special Topic: Telecommunication in the
Courtroom:Telephonic Search Warrants, 38 U.
Miami L. Rev. 625, 632 (1984); Beci, note 44,
at 319-22.
66 United States v. Reid, 929 F.2d 990, 993-
94 (4th Cir. 1991). See also United States v.
Tarazon, 989 F.2d 1045, 1050 (9th Cir. 1993).
67 See State v. McNeely, 358 S.W.3d 65
(Mo. banc 2012); State v. Smith, 134 S.W.3d
35 (Mo. App. E.D. 2003).
21 State v. Andries, 297 N.W.2d 124, 125
(Minn. 1980). See also State v. Lindsey, 473
N.W.2d 857, 863 (Minn. 1991).
22 725 Ill. Comp. Stat. 5/108-4(a) (2007).
23 People v. Taylor, 555 N.E.2d 1218, 1220
(Ill. App. Ct. 1990).
24 The authors contacted all 115 Missouri
prosecutor’s offices in June of 2012. As of that
time, none had tried to get a telephonic search
warrant based on oral testimony. Sixty-two
(53.9 percent) had obtained search warrants
using fax machines. Fifty-one (44.3 percent)
had used a procedure where the officer would
sign the affidavit in front of a notary before sending it to the judge. Nineteen (16.5
percent) had satisfied the oath requirement by
having the officer sign the affidavit on a form
bearing notice that false statements therein
were punishable as a crime. Twenty-seven
(23.4 percent) had verified a written search
warrant affidavit by having the judge swear
the officer over the telephone. Fifteen (13.0
percent) said they had used e-mail to obtain a
search warrant. Five (4.3 percent) said they had
not yet used e-mail to get a search warrant, but
had a process in place to do so.
25 Section 542.276.3, RSMo Supp. 2011.
26 Section 542.276.11, RSMo Supp. 2011.
27 See Alaska Stat. § 12.35.015 (g)
(2012); Cal. Penal Code § 1526(a)(2) (West
28 People v. Snyder, 449 N.W.2d 703 (Mich.
Ct. App. 1989).
29 Id. at 706.
30 See note 23.
31 United States v. Brooks, 285 F.3d 1102,
1104-06 (8th Cir. 2002); State v. Bicknell, 91
P.3d 1105 (Idaho 2004).
32 Bicknell, 91 P.3d at 1107-08.
33 United States v. Brooks, 285 F.3d 1102,
1104-06 (8th Cir. 2002).
34 State v. Scholes, 753 N.W.2d 377 (N.D.
2008); People v. Fournier, 793 P.2d 1176, 1179
(Colo. 1990); People v. Chavez, 104 Cal. Rptr.
247 (Cal. Ct. App. 1972).
35 United States v. Copeland, 538 F.2d 639
(5th Cir. 1976) (affidavit sworn before a special agent for the Bureau of Alcohol, Tobacco
and Firearms authorized by law to administer
36 See note 23.
37 People v. Sullivan, 437 N.E.2d 1130
(N.Y. 1982).
38 437 N.E.2d at 1132.
39 Id. at 1133.
40 2 Wayne R. LaFave, Search and
Seizure: A Treatise on the Fourth Amendment § 4.3(e) (4th ed. 2004).
41 See note 23.
42 Fed. R. Crim. P. 41, Committee Notes
to 2006 Amendments, subdivision (e).
43 See note 23.
44 Donald L. Beci, Fidelity to the Warrant Clause: Using Magistrates, Incentives, and
Telecommunications Technology to Reinvigorate
Fourth Amendment Jurisprudence, 73 Denv. U.
L. Rev. 293, 325 (1996).
45 See Kuzmich at n. 12; John Henry
Hingson, III, Telephonic and Electronic Search
Warrants: A Fine Tonic for an Ailing Fourth
Amendment, The Champion, Sept.-Oct. 2005,
at 38.
46 Kuzmich, note 15, at n. 12.
47 See Beci at n. 175; 2 John Wesley Hall,
Jr., Search and Seizure, § 42.14 (3rd ed.
48 See People v. Sullivan, 437 N.E.2d 1130
(N.Y. 1982).
49 See (last
visited Dec. 10, 2012).
50 See (last visited Dec.
10, 2012).
51 See (last visited
Dec. 10, 2012).
52 Interview with Benjamin J. Miller,
Technology/Automation Resource Prosecutor
at the Missouri Office of Prosecution Services
and former Assistant Prosecuting Attorney for
Christian County (June 25, 2012).
53 Section 542.276.11, RSMo Supp. 2011.
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