The preliminary report is out from the court-appointed Receiver in the case involving “True Count Staffing Inc., d/b/a SL Account Management (“True Count”) and Prime Consulting LLC, d/b/a Financial Preparation Services (“Prime Consulting”) … Defendant Consumer Advocacy Center Inc., d/b/a Premier Student Loan Center (“CAC”), which is in bankruptcy, is not a Receivership Defendant. Albert Kim, Kaine Wen, and Tuong Nguyen are named Individual Defendants.”
Note: All the documents are at the end of this very long post.
The Receiver stated the following facts in the report:
“The overall enterprise secured more than 170,000 customers and more than $71 million in gross revenue. But, 70% of these customers cancelled their enrollments.
Historically, the sales process to secure consumers with student loan debt relief has included hard sell tactics and misrepresentations prohibited by the TRO which have misled and confused consumers.
Beginning in late August 2019, Defendants pivoted to a more compliant process, but based on recent documents and consumer complaints, this pivot was not comprehensive and, of course, it did not remedy prior unlawful practices.
Defendants collect consumer fees in advance without complying with the Telemarketing Sales Rule, which renders the entire business unlawful. The August 2019 pivot included representations that fees would be deposited to a “dedicated customer account” at third party Trusted Account Services and only paid out when work was completed. But, this appears to be a new deception designed to create the appearance of a procedure consistent with the Telemarketing Sales Rule “escrow exception” to the advance fee prohibition. Not only is Trusted Account Services not an independent third party, I have determined that it is a Receivership Defendant.”
How This Rolled Out
“As authorized by the TRO (Section XIV, page 24), we took control and exclusive custody of Defendants’2 three business premises in Irvine, California on October 23, 2019, commencing at approximately 10:30 a.m. At each location, we received support from law enforcement officers. After securing each site, we provided access to counsel and other representatives of Plaintiffs and retained locksmiths who changed all exterior locks.”
15261 Laguna Canyon Rd, Suite 200, Irvine, CA
“This 22,000 square foot space, bearing a nondescript “Prime Consulting” sign, comprises the entire second floor of a two-story building in an upscale office park. Prime Consulting is the lessee at a monthly rent of approximately $65,000.
“At our arrival, we encountered an active operation with approximately 130 personnel on site, many of whom appeared to be either brand new hires commencing training or prospects on site for job interviews. None of the Individual Defendants were present.
Given the large number of people, many with minimal history with the business, it was a challenge to assemble them as a group and secure their cooperation. While several supervisors were on site, they were not cooperative; they did not assist during our effort to explain the receivership situation and secure TRO-required questionnaires from employees.[Two of the supervisors who refused to cooperate and complete questionnaires – Compliance Manager Nicole Balestreri and HR Director Shirena Hulzar – did, however, file declarations in connection with Defendants’ opposition to a Preliminary Injunction.] We ultimately imposed order, secured questionnaires from those employees who were cooperative, and met with a small number of sales personnel.
The premises are built out to support a large telephone sales operation. The open floor space includes nearly 150 individual workstations equipped with telephones, computers, and monitors and organized in a pod-type system with each pod housing 12-15 sales workstations and one team leader. At our arrival, 97 workstations appeared to be currently active. The walls are adorned with multiple big screen TVs and the usual accoutrements of sales boiler rooms, including white boards tracking the daily “closings” of each sales agent, motivational sales posters, and instructions to “close” the sale.”
“The space also includes a large conference room, eleven interior offices, [The interior offices are allocated to Human Resources (2), Training (4), the Floor Manager and his staff (2), a Compliance Manager, Information Technology, and Marketing. The marketing office is occupied by Pub Club Leads, allegedly a third party firm to which Defendants have subcontracted advertising and lead generation.] and four exterior offices. [The exterior offices are allocated to operations/accounting (with 9 workstations), employee Le Ho (aka Calvin Ho) and one office each to Individual Defendants Tuong Nguyen (aka Tom Nelson) and Albert Kim.]”
173 Technology Drive, Suite 202, Irvine, CA
“This suite of approximately 15,000 square feet is subleased by Defendant CAC from a neighboring company at a monthly rent of approximately $18,000.
The site has capacity for nearly 120 staff with 4 individual exterior offices. At our arrival, approximately 60 employees were on site: 2 managers (the Customer Support Manager and the head of “Junior Processing”); 10-15 members of the Customer Service team; 10-15 members of the Junior Processing Team; and 30 temporary employees, just recently hired for the reverification campaign described below. Two other managers (Adon Janse and Isabel Banda) with offices at this site were both at the Hughes location, conducting hiring and training of temporary employees for the reverification campaign.
Nearly all employees at this site were cooperative, completed questionnaires, and responded to our questions.
Exhibit 3 is a schematic of the office and an inventory of the property on site.”
8 Hughes Parkway, Suite 210, Irvine, CA
“This site is an approximately 10,000 square foot suite in a two-story building in an office park leased by True Count at a monthly rate of approximately $10,000. A small sign for “SL Account Management” is posted on the front door.
About a dozen people were present – most were temporary staff from AppleOne, a staffing agency regularly used by Receivership Defendants, on their first day of training for the reverification campaign.
The suite consists of seven rooms built out along the windows (only one in active use) and a large open area with approximately 120 cubicles (almost all of which were out of use). [Both IT personnel (Keneth Hu and Mr. Vu) listed 8 Hughes as their principal office, but Mr. Hu told us that IT had offices in each location, and determined where they would spend each day based on the support requests it needed to address. Next to the IT office in the corner of 8 Hughes, we found a room containing a large rack of computer equipment apparently running bitcoin mining computations as a personal hobby of Mr. Hu. With Mr. Hu’s consent, we turned that equipment off.]
Exhibit 4 is a schematic of the space and an inventory of the property on site. [At all three locations, we observed thousands of unopened letters from various student loan servicers and the Department of Education addressed to customers but sent to Defendants’ various mail drops.”
Tried to Clean Things Up
“As important context for this receivership, we must note Defendants’ operation has attracted significant state and federal regulatory attention over the last several years. Defendants failed to comply with fundamental regulations for telemarketing sales, including the prohibition of advance fees. Only beginning in August 2019 did Defendants initiate any material changes to their operations and then only after the regulators were knocking at the door.
As alleged in Plaintiffs’ submissions to the Court and reflected in CAC’s bankruptcy filings, Defendants’ regulatory exposure was highlighted by a $31 million bankruptcy claim by the State of Minnesota and by the CFPB’s issuance on September 10, 2018 of a civil investigative demand (“CID”) to Defendant CAC.
Around the time of the CID, CAC shifted operations and assets to other Receivership Defendants – the sales operations were transferred to Prime Consulting and the customer base and revenue stream were shifted to True Count. CAC then filed bankruptcy in Florida in January 2019 with the goal, according to the testimony of Individual Defendant Albert Kim, to avoid the regulatory enforcement agencies which were circling. Because of concerns about false statements in its filings, the bankruptcy court later appointed a trustee over CAC’s bankruptcy estate.
The CFPB’s and the states’ investigation of Defendants proceeded despite the bankruptcy. In July 2019, the CFPB took the investigative testimony of at least two former employees. [Excerpts of the testimony of these former employees – Maxwell Camp and Jovani Ortoro] Individual Defendants Kaine Wen and Albert Kim were aware of this testimony and they contacted one of the witnesses just before his scheduled appearance.
Defendants appear to have reached a tipping point after the Wall Street Journal published an article highly critical of their practices on August 26, 2019, which was immediately emailed to Individual Defendants Albert Kim and Kaine Wen.”
“A day after the Wall Street Journal article ran, management [This meeting of management included Kaine Wen, Albert Kim, Isabel Banda, Sal Avila, Kenny Nguyen, and Eric Ortiz.] convened an emergency meeting which resulted in a decision to immediately suspend all sales efforts. Defendants announced to employees that “effective immediately all sales and marketing will be paused until further notice.” The stated purpose of this pause, projected to last approximately three weeks, was that “[d]uring this period the company and each department will work on re-training, compliance, and policies. In addition, each department will work together to address any and all mistakes on all client files.”
“At the outset of the sales pause, management identified prohibited practices that would be subject to a new “zero tolerance” policy. [These prohibited practices included: Accessing NSLDS (National Student Loan Data System); accessing FSA (Federal Student Aid); changing FS (family size); signing documents on behalf of clients; misrepresentation of the company (Example: we work with the DOE/servicer); submitting clients as unemployed on annual recertifications; and final pay without ROA [release of authorization]/confirmation documents uploaded.] We located a flyer reciting these new policies posted just outside the “Junior Processing” department with a character wagging his fingers, “Ah, Ah, Ah, You Didn’t Say the Magic Words.”
During this sales pause (August 29, 2019 to September 30, 2019), Defendants took some steps toward compliance, including new sales scripts and training, a reverification campaign, and new claims about not accepting advanced fees. See Section VI.E “Compliance” below. A new dba “Student Services Plus” was also launched as Defendants’ public face for new customers, replacing Financial Preparation Services which had been featured prominently in the Wall Street Journal article. The launch of a new dba was consistent with Defendants’ practice of deploying multiple generic-sounding business names.
[At the time of immediate access, we found lists identifying employee teams, each with a different, and very generic, company name including: Premier Student Loan Center; Financial Preparation Services; South Coast Financial Center; Direct Account Services; Financial Loan Advisors; Account Preparation Services; Administrative Financial; Tangible Savings Solutions; Coastal Shores Financial Group; First Choice Financial Centre; Administrative Account Services; Primary Account Solutions; Prime Document Services; Financial Accounting Center; Doc Management Solutions; Sequoia Account Management; Pacific Palm Financial Group; Pacific Shores Advisory; First Document Services; Keystone Document Center; Administrative Accounting Center; Global Direct Accounting Services; Signature Loan Solutions; Best Choice Financial Center; Yellowstone Account Services; Regional Accounting Center; and Financial Direct Services.]
The business changes implemented after the Wall Street Journal article could fairly be interpreted as a mad scramble to correct illegal practices to stave off potential regulatory, civil, and possibly criminal liability. Or, the changes might be a sincere effort to embrace compliance. But as Receiver, I need not reach a definitive conclusion on such internal motivations, which do not impact my determination, as detailed below, that the Receivership Defendants operated unlawfully even after the August pivot and the businesses cannot operate profitably and lawfully using the assets of the Receivership Estate going forward.
With this history as context, we present below a summary of the operations as we found them.
“Defendants’ current position, which is that their collection of advance fees is now lawful because the fees go to dedicated client accounts provided by third-party Trusted Account Services, is an ill-conceived effort to invoke the escrow exception to the TSR’s advance fee prohibition.”
Consumer payments for Defendants’ services have been and continue to be collected long before any work has been completed or the customer has made a first payment on a new renegotiated plan. During the initial sales call, Defendants acquire the customer’s payment information and schedule the first payment, which is generally processed almost immediately after the customer executes the Services Agreement.
The recurring monthly “recertification fee” is by definition collected in advance for 12 months before the annual recertification process even commences.”
Escrow Company is a Problem
“In four years of operation, Defendants have not had escrow or trust procedures which could lawfully invoke the TSR’s Escrow Exception. [There are two very minor exceptions. Defendants contracted with third party dedicated account holders Reliant Account Management and Account Management Plus for a very short time. As best we can discern this was done so Defendants could steal these companies’ trade practices, methods, and documents.]
Consumer payments have been collected and deposited directly to Defendants’ bank accounts. Nearly $71 million have flowed directly to Defendants in this manner.
Despite these immediate deposit procedures, Defendants have for years falsely trumpeted the absence of advance fees. A standard “No Advance Fees” provision of the form contract recites: A “third-party dedicated account provider (“DAP”) [will be used] to collect and deposit payments that Client has agreed to make with company . . . and to deposit and hold Client’s funds in a trust account established and serviced by the DAP. The DAP will not disburse any Client fees until Client has received a consolidation, adjustment, or otherwise satisfactory result, and Client completes one payment towards such.”
“Now, Defendants have introduced Trusted Account Services into this “No Advance Fees” misrepresentation. The October 21, 2019 Sales Script in use at the time of the TRO proclaims:
• “Our fees will be placed into your own Dedicated Client Account and these funds belong to you at all times. Your dedicated account provider is Trusted Account Services, and they will only release our fees after the Department of Education approves your Income Driven Repayment Program every year.” See Exhibit 11.
• “As noted earlier on the call, all payments to us will be placed into your Dedicated Client Account. Any time before completion of the work, you can cancel and get your funds back. Your funds will only be released to us after we prove to you and Trusted Account Services that we have completed the work . . . .”
“The “Compliance Call Script” within the Sales Script further recites:
“Do you understand that our company does not take any upfront fees, and that your payments to us will be placed into your own Dedicated Client Account for your benefit until we successfully complete our work for you?” If the consumer responds No, then the script continues: “It is very important to us your money is protected. You are making payments for our fees to your own Dedicated Client Account held by a non-related company (like a trust company). Your payments will be released to our company only after the Department of Education accepts your program/plan. That money belongs to you at all times and you can ask for it back prior to completion of our work.”
“Even if Defendants followed procedures as described in the scripts, they do not comply with the specific requirements of the TSR.”
“Defendants’ fundamental misrepresentation is that a Dedicated Client Account has been set up with a third party: Trusted Account Services. Our investigation has revealed that Trusted Account Services is not a third party, but an appendage of Defendants’ operation which is maintained in-house by a very narrow group of insiders. Hence, Trusted Account Services does not provide Defendants cover that they are in compliance with the TSR.
Given the complex history of Defendants’ deep deception as to Trusted Account Services, we present below as Section V a summary of Trusted Account Services’ formation and implementation based on the materials available to us from the immediate access.”
Trusted Account Services
Trusted Account Services (sometimes referred to as TAS) is not an independent third-party provider of dedicated client accounts. Rather, it was created and is beneficially owned and controlled by the Defendants who have closely guarded their ownership secret. The truth was shared with only a handful of Defendants’ high-level and trusted employees, who, in turn, relied on internal IT personnel and IT contractors located in Vietnam to build the Trusted Account Services facade. [Outside the C-suite executives and IT functionaries, employees within Defendants’ companies were fed the party line about Trusted Account Services. Despite that, however, some employees we interviewed – who were mid-level managers and line employees – noted they were suspicious about the independence of Trusted Account Services.]
Because Trusted Account Services is owned and controlled by the Individual Defendants and affiliated with the Receivership Defendants – and indeed is part of the Defendants’ student loan debt relief common enterprise – I have determined it is a Receivership Defendant.
Once Trusted Account Services was operational, it was touted as the independent provider of dedicated client accounts for Receivership Defendants, all in an effort to create the appearance of an escrow procedure compliant with the TSR advance fee rule.”
Defendants Deceive DebtPayPro to Get Trusted Account Services on the Platform
“For Trusted Account Services to function, it had to be integrated with Defendants’ customer relation management (CRM) software, provided by DebtPayPro. Kaine Wen along with Calvin Ho orchestrated a ruse to get Trusted Account Services accepted and integrated in the DebtPayPro CRM database. They went to great lengths to posture Trusted Account Services as a real and independent company, including creating fictional characters to interact with DPP via email and over the telephone.
On May 1, 2019, Kaine Wen emailed DebtPayPro’s support team, writing:
“Please provide detailed answers and explanations to the following questions from Trusted Account Services. We are testing out their dedicated account provider services (same services as Reliant Account Management or Account Management Plus). Thank you in advance.
1. How can we integrate with DPP?
2. Do you have any document that details what information we need to receive from DPP’s end or pass to DPP from our end?
3. Do you have any API to use for integration?
4. How can we manage the transactions and clients between our systems and DPP?”
“The questions posed by Kaine Wen did not, however, originate from Trusted Account Services, but were crafted by Defendants’ IT employee [We believe the Vietnam company, Processing Service Co., Ltd., is owned by Calvin Ho’s mother. It received nearly $600,000 from Horizon Consultants.] who had been tasked to integrate Trusted Account Services into the DebtPayPro platform.
Kaine Wen created these questions and the lead-in to them to paint the mirage of Trusted Account Services as a separate company. When DebtPayPro support staff followed up with a request for the company’s website and the name of a direct contact there, Calvin Ho responded with a link to the website (https://trustedaccountservices.com) and an email address ([email protected]). See Exhibit 19. DebtPayPro support then asked, “[i]s there a person there you’ve been working with that I can ask reach [sic] out to specifically?” Id. Calvin Ho responded with a name: Michael Tabin ([email protected]) whose signature listed him as Trusted Account Services’ Chief Technology Officer. Id. We believe, however, that “Michael Tabin” is a fictional name invented by Kaine Wen and Calvin Ho to deal with DebtPayPro.
On May 23, Ho emailed the group – addressing both DebtPayPro and “Michael” – to ask how the integration was proceeding and when Defendants could begin using Trusted Account Services. Id. DebtPayPro responded that they were still reviewing the API documentation and drafting a scope of work proposal and quote. Id. Throughout the email chain with DebtPayPro, Wen and Ho maintained the deception that they were Trusted Account Services. Trusted Account Services was ultimately accepted by DebtPayPro – which gave Defendants the ability to process consumer payments through Trusted Account Services on the DebtPayPro platform.”
Reliant Account Management and Account Management Plus Get Taken
Our review also revealed that in establishing Trusted Account Services, Defendants just copied the methods, operations and documents of other such providers like Reliant Account Management (“RAM”) and Account Management Plus (“AMP”). Defendants had their IT contractor in Vietnam copy wholesale the practices and documents (generally word-for-word) of RAM and AMP which were then only slightly modified and rebranded as Trusted Account Services materials. We located in Defendants’ team management software, Monday.com (which is used to monitor IT and operations projects), a project associated with the creation of Trusted Account Services. The Defendants’ Monday.com platform includes tasks such as “Figure AMP’s services charges to find a processing comp for TAS” and “Create a new agreement based on RAM Authorization Form,” as well as “Build database for TAS” and “Revise TAS Contents.”
[Notably, Defendants contracted with both RAM and AMP for a short period of time. For example, Defendants entered into a contract in November 2018 with RAM, but the relationship terminated in roughly March of 2019 – Defendants having used RAM for only a couple of dozen customers (out of the Defendants’ roughly 50,000 active customers). But in doing so, Defendants learned the methods of these third party dedicated account provider companies and accessed their agreements and contracts which the Defendants promptly plagiarized.] This “creative” history demonstrates that Trusted Account Services was hatched by Defendants, complete with intellectual property thievery.”
New Payment Processor Secured
Once Defendants integrated Trusted Account Services into the DebtPayPro platform, they still needed a payment processing vendor. Defendants had been on alert for payment processing options for several months. See Exhibit 23. When the arrangement with Donald Cook fell apart, the Defendants went back to Jimmy Lai, who, like Cook, acts as a middle man between high-risk merchants and payment processors. [In this instance it is unclear whether Lai was acting as a broker or as an employee of National Merchant Center, as we see that he uses a National Merchant email address in connection with Trusted Account Services.] He has worked with Defendants on numerous occasions to secure payment processing for their various entities.
Defendants did not have to present an elaborate charade of Trusted Account Services’ independence with Jimmy Lai. Lai was in on the lie. He understood that Defendants owned and controlled TAS 2019 and that Kenny Huang was a front. He had worked with Defendants for years and, in fact, had previously executed nearly this exact “front” scam with Defendants.
In late 2018, Lai worked with Individual Defendants Wen and Nguyen to use a front – this time Keneth Hu, an IT employee of Defendants – to apply for a merchant processing account in the name of Horizon Consultants LLC d/b/a Premier Student Loan Center. Hu claimed to be the 100% owner of Horizon Consultants for purposes of the application – but all involved understood that Defendants own and control the company. When the application was finalized – in Keneth Hu’s name and containing all of his personal information – Lai sent it to Individual Defendants Wen and Nguyen, not Hu, with a note: “Please review for accuracy, sign and return.” Kaine Wen then forwarded the application on to Hu with instructions, “Please sign on page 6 (twice) and page 7.” See Exhibit 24. Horizon Consultants’ merchant application was approved and it proceeded to run consumer charges through the account.”
“Eight months later, Defendants approached Lai about filing another application package using a “front” – this time for Trusted Account Services. Lai was happy to oblige. On June 19, Lai submitted an application for TAS 2019 with National Merchant Center with Kenny Huang as the “front” – listed as the 100% owner. See Exhibit 26. Six days later, the associate director of underwriting wrote to Lai and identified a number of holes in the application. Lai simply forwarded the email with a one sentence introduction: “Kaine/Kenny, There are a lot of things missing that we need to obtain before we can send to First Data for review and approval.” Id. The application was revised and submitted on July 1. See Exhibit 27. Again, Kenny Huang was the “front,” listed as the owner of TAS 2019. On July 9, Lai forwarded the final application for signature, listing Kenny Huang as the 100% owner. But Lai did not send the application to Kenny Huang; he sent it only to Kaine Wen with the instruction to “[p]lease execute with Wet Signature.” See Exhibit 28.
National Merchant Center accepted the application – an application that Kaine Wen, Kenny Huang and Jimmy Lai knew was false. Processing for Trusted Account Services began on September 12 and by the end of the month more than $800,000 in consumer funds had been processed. Another $2,000,000 in consumer charges were processed before the TRO was issued.”
Student Loan Assistance Business is Challenging
“Defendants’ student loan debt relief business is built on a challenging premise: identify and target consumers with student loan debt to sell them a utilitarian service they can do themselves (by filling out Department of Education forms or with the assistance of resources available from the DOE, DOE-approved loan servicers, and other consumer-friendly resources. And do this in an environment that is heavily regulated to protect consumers and prohibits advance fees until the work is completed and accepted by consumers. By any definition, this is not a promising business model for a lawful operator, and this reality is borne out by Defendants’ 70% cancellation rate.”
Pub Club Leads Was Major Suppier
“New customers are secured by the telemarketing sales team by calls to and from consumer “leads.” Lead generation has been managed by Pub Club Leads (“Pub Club”), the marketing business which operated from an interior office at the Laguna Canyon site. Pub Club was tasked to generate “Billable Leads” based on parameters set forth in time-specific orders from Prime Consulting. Pub Club did this by retaining and managing multiple sub-vendors who deployed various data mining techniques. Pub Club was compensated by a percentage of the total “advertising buy” for each of the Orders. Our review indicates that for the period October 2018 to October 2019, Pub Club received approximately $9 million from Prime Consulting. Pub Club also received approximately $5 million from Horizon Consultants between March 2019 and September 2019.”
Family Size Increased With Dogs
“Defendants’ new “zero tolerance compliance” protocols, announced in August 2019, are themselves confirmation of bad practices that historically permeated the sales process. See Exhibit 7. One such practice related to family size where sales agents, with or without the customer’s assistance, inflated family size to secure lower payments. In one recorded telephone call from July 25, 2019, that we reviewed, the sales advisor added the customer’s two dogs to increase family size. In June 2019, a customer service manager identified an issue internally that customers felt “scammed” because they were paying $1,300 when Defendants do “very little.” See Exhibit 34. In April, 2019, Individual Defendant Nguyen internally reported that he had done a small audit on family size and found that 6 out of 10 failed with “All fake FS.” See Exhibit 35.”
“Our review of the Laguna Canyon site confirmed the obvious reality that Defendants were in the sales business with sales personnel incentivized to sell:
• The Sales Department was physically structured to maximize results with sales agents organized in pods headed by a Team Leader, each with a separate white board to track results and weekly goals.
• Sales advisors (who were retitled Student Loan Specialists on September 30, 2019) were paid weekly with an hourly minimum ($12-$15 per hour) and a commission based on a percentage (18%-22%) of the dollar value of closed deals after the enrollment payment cleared. The applicable percentage was determined by the advisor’s rank, which was based on total revenue from sales over the previous four weeks. See Exhibit 36.
• Sales advisors were also paid bonuses through various “performance sprints”, including special bonuses for same day closings/payments and 5 deals in a day. The big producers even got to participate in raffles for laptops, gaming consoles, headphones and movie tickets. See Exhibit 37.
• The overriding mission was to “Close.” A big screen TV in the main room ranked the highest closers. Inspirational signs promoted “Always Be Closing” and “Assume the Close.”
• Sales advisors were exhorted to complete the “Hard Close,” sometimes called “Same Days,” by manufacturing a need to close now. Rebuttals to customers wanting to “call back” included “the government is very strict” and the “system does not allow me to keep your application open.” See Exhibit 38.
Absent aggressive real time supervision, these incentives created an atmosphere where sales agents are tempted to do whatever necessary to “close” and get their commissions and bonuses.
We reviewed scripts, training materials, and sales directives found at each workstation in the Sales Department. After August 2019, the Sales Scripts were revised several times, but even the most recent Sales Script – October 21, 2019 (Exhibit 11) – may confuse consumers about the services and the related fees, and creates the impression that fees paid to Defendants would be credited to their loan. This confusion is reflected in consumer complaints.”
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