The Enduring Campaign for Life: A Socio-Legal History of the Global and American Pro-Life Movement

The Enduring Campaign for Life: A Socio-Legal History of the Global and American Pro-Life Movement I. Introduction and Foundational Ideology The anti-abortion movement, widely known as the pro-life movement, represents one of the most sustained and politically consequential social movements in modern American and global history. Spanning over a century and a half of legislative conflict and deep philosophical debate, its trajectory has culminated in a fundamental reshaping of constitutional law and the political landscape of the United States. To understand the movement's success and its future direction requires an analysis of its strategic use of terminology, its unwavering philosophical basis in fetal personhood, and its deep institutional ties to religious organizations. I.A. Defining the Movement and Terminological Conflicts The nomenclature surrounding the abortion debate is inherently strategic and reveals the political priorities of the factions involved. The labels "pro-choice" and "pro-life" are recognized as political framing terms designed to validate one’s stance by implying endorsement of broadly held values such as liberty or the sanctity of life, while simultaneously suggesting that the opposition must be "anti-life" or "anti-choice". This rhetorical maneuver allows the movement to occupy a presumed higher moral ground, framing the debate as one between protecting life and supporting abortion. However, the movement’s legislative outputs often generate critical counter-framing. For instance, scholars of communication often suggest that extreme legislative efforts, such as those prohibiting abortion in almost all cases, are more accurately described as "pro-birth" or "forced-birth" policies rather than genuinely "pro-life" measures. This critique arises from the observation that such restrictive laws frequently lack corresponding provisions guaranteeing comprehensive support, such as food, healthcare, and education, necessary for sustaining both the woman and the child after birth. Furthermore, this legislative pattern is sometimes coupled with simultaneous efforts to cut or reduce funding for supportive programs like Medicaid or family planning services. This systemic prioritization of legal prohibition over social welfare provision indicates a significant tension between the movement’s declared moral rhetoric of protecting "life" and its specific political prioritization of criminalization. I.B. Philosophical Pillars: The Potentiality Argument and Fetal Personhood The ideological foundation of the pro-life movement rests upon the conviction that human life, and consequently a right to life, begins at conception. This conviction addresses the central moral question of the debate: whether there is a morally relevant point during the biological development of the fetus—such as the onset of movement, consciousness, the ability to feel pain, or viability—that justifies abortion restriction. The movement rejects these markers, arguing instead for protection beginning at the unicellular zygote stage. This philosophical stance is formally articulated through the potentiality argument, which seeks to extend the moral and legal right to life to the unborn based on their trajectory toward personhood. The standard argument against abortion, according to this framework, operates on three premises: All innocent persons have a moral right to life. Since all innocent persons have a moral right to life, all potential innocent persons also have a moral right to life. The human fetus is a potential innocent person. The conclusion is therefore that the human fetus has a moral right to life. A critical component of this argument is the justification for the second premise. Proponents argue that a moral right to life constitutes a benefit for a potential person, and the denial of that right constitutes a harm to a potential person. This approach allows proponents to dismiss counterarguments based on a strict definition of legal personhood. The strategy involves simply rejecting the thesis that one must be an actual person to possess a right to life, arguing instead that the fetus’s potential is sufficient to extend this right. Legally, this philosophy translates into the demand that the fetus should possess a basic legal right to live, or at least a claim to life, forming the basis for the comprehensive legal objective known as "fetal personhood". I.C. The Religious Foundations and Mobilization Blueprint The organizational and moral force of the pro-life movement owes its genesis significantly to the Roman Catholic Church. The consensus among some historians is that the Church essentially "created the right-to-life movement," suggesting that without its institutional backing and ideological consistency, the movement would not exist in its modern form. The Catholic doctrinal position has remained remarkably consistent across centuries. Since the first century, the Church has affirmed the moral evil of every procured abortion, maintaining an unchangeable teaching that direct abortion is gravely contrary to the moral law. Early Christian texts, such as the Didache and the Letter of Barnabas (1st and 2nd centuries), condemned both abortion and infanticide, sharply distinguishing early Christians from surrounding pagan cultures. This deep historical anchor provides the movement with a powerful moral defense against arguments based on shifting biological markers, such as viability or consciousness. While some early Christian thinkers, including St. Augustine in the 5th century, accepted the limited biological theories of their time (such as those based on Aristotle’s delayed ensoulment), the central moral conviction that abortion is gravely wrong at every stage remained unchanged. This commitment to the inherent human destiny of the unborn, independent of scientific knowledge concerning the exact moment of ensoulment or biological development, has allowed the movement to consistently pursue constitutional fetal personhood based on inherent status, regardless of developmental stage. This profound moral conviction was translated into a highly structured political strategy in the mid-1970s. In anticipation of the 1976 election and in an effort to transform abortion into a decisive electoral issue, the National Conference of Catholic Bishops released the "Pastoral Plan for Pro-Life Activities". This unprecedented document explicitly called for local and grassroots mobilization, recognizing that to reach the goal of a Human Life Amendment, the Church would need to transition from hierarchical decree to localized action. Today, this core religious opposition is shared by Evangelicalism and Eastern Orthodoxy, contrasting sharply with the support for legalization found among most mainline Protestant denominations. II. The Origins and Rise of the American Movement (1857-1972) The modern pro-life movement did not emerge from a vacuum. Its organizational framework was built upon earlier, separate efforts to control reproductive life, originating long before the judicial conflicts of the mid-20th century. II.A. Pre-Modern Anti-Abortion Efforts (19th Century) In the early 19th century and prior, abortion was generally legal in the United States until the stage of "quickening" (when the woman first felt fetal movement). However, a fundamental shift occurred mid-century, driven largely by medical professionalization. The organized movement to restrict abortion access began significantly with the American Medical Association (AMA) campaign, which commenced in 1857. This effort, led by physicians seeking to distinguish themselves from lay practitioners and to claim authority over reproduction, resulted in rapid legal change. Between 1860 and 1880, state legislatures across the nation enacted at least 40 anti-abortion statutes. Further federal restriction came with the Comstock Act of 1873, which made it illegal to sell or mail materials related to contraception or abortifacients, reinforcing the moral and legal constraints on reproductive knowledge and resources. It is important to recognize that while the laws restricting abortion were primarily 19th-century phenomena, the modern, organized political movement emerged nearly a century later. II.B. The Pre-Roe Coalescence (1950s-1972) The modern pro-life political movement began its phase of "coming together" during the 1950s and 1960s. This organizational period occurred precisely when the Supreme Court began establishing a constitutional right to privacy regarding reproductive decisions. The 1965 case, Griswold v. Connecticut, protected marital contraception, followed by Eisenstadt v. Baird in 1972, which extended the right to contraception to unmarried individuals. The emergence of sustained, organized activism was specifically a counter-movement designed to oppose this judicial expansion of reproductive autonomy. The groups forming during this time anticipated the broader trend toward liberalization. A crucial milestone in this organizational phase was the formation of the National Right to Life Committee (NRLC) in 1968. NRLC quickly grew into the largest and oldest pro-life organization in the United States, positioning itself as the umbrella structure for the subsequent political and legal battles. The mission established by the NRLC was, and remains, "to protect and defend the most fundamental right of humankind, the right to life of every innocent human being from the beginning of life to natural death". This foundational structure was critical for preparing the movement for the shockwave that would follow the 1973 Supreme Court decisions. III. The Mobilization Era: From Roe v. Wade to Political Power (1973-1992) The judicial actions of 1973 did not suppress the anti-abortion movement; they became the ultimate mobilizing catalyst, transforming a nascent organizational structure into a powerhouse of national activism and political integration. III.A. The Catalyst of Roe v. Wade (1973) and Mass Response On January 22, 1973, the Supreme Court issued Roe v. Wade and the companion case Doe v. Bolton. These decisions invalidated restrictive state abortion bans, legalizing abortion nationwide and striking down laws that had been in place in most states in the 1960s. This judicial decree triggered an "explosion of activism" , providing the movement with a clear and existential threat to rally against. Within months, leaders gathered in the Washington, D.C., home of activist Nellie Gray in October 1973 to discuss how to commemorate the one-year anniversary of Roe. This meeting led to the founding of the March for Life Education and Defense Fund, which organized the first March for Life in January 1974. The annual March for Life quickly established itself as the movement's most important public gathering, drawing participants to Washington D.C. every year to lobby Congressional leadership for a legislative solution to the Supreme Court’s decision. Nellie Gray, the founder, remained a prominent figure, sustaining this tradition and leveraging the massive annual attendance for targeted grassroots lobbying efforts on Capitol Hill. III.B. Key Figures, Organizations, and Legislative Milestones The mobilization era saw critical legislative victories and the professionalization of advocacy efforts. The Hyde Amendment One of the most profound early successes was the passage of the Hyde Amendment in 1977. Championed by Congressman Henry Hyde, this legislative provision restricts the use of any federal funds for abortion. It is attached annually to the Labor, Health and Human Services, and Education (L-HHS-Ed) appropriations act, covering major federal health care programs such as Medicaid. The restriction includes limited exceptions, allowing payment for terminating pregnancies only when the life of the pregnant person is endangered, or when the pregnancy results from rape or incest. The effect of the Hyde Amendment was transformative. By restricting funding, it created a de facto two-tiered system of access based on poverty, significantly limiting reproductive choice for low-income women, even though abortion remained legal under Roe. Only 17 states and the District of Columbia currently use state funds to cover abortions for Medicaid recipients beyond the Hyde limitations, leaving the majority of low-income women subject to the federal restriction. This victory demonstrated the movement’s ability to achieve substantial restriction through budgetary means, an effective tactic when direct legislative prohibition was blocked by the courts. Political Integration and Organizational Growth The movement moved beyond public protest to successful political integration throughout the 1980s and 1990s, becoming a core component of the Republican Party’s platform. This ascendency was visually confirmed in 1981 when an anti-abortion delegation was received in the Oval Office by President Ronald Reagan, symbolizing the movement's shift from external opposition to internal political influence. Further professionalization occurred with the founding of organizations focused specifically on electoral politics. Susan B. Anthony Pro-Life America (SBA Pro-Life America, originally the Susan B. Anthony List) was founded in 1992 and reorganized in 1997, with Marjorie Dannenfelser serving as its president. This group specialized in electing "national leaders and advocating for laws that save lives," indicating a sophisticated strategy focused on leveraging targeted electoral campaigns, especially those promoting pro-life women leaders. The following table summarizes the foundational figures and organizational achievements of this era: Table III.1: Major US Pro-Life Figures and Organizational Structure Entity/Figure Role/Contribution Founding/Impact Period Relevant Strategy Source Reference National Right to Life Committee (NRLC) Largest and oldest U.S. pro-life organization; strong grassroots focus (3,000+ chapters) Founded 1968 Legislative lobbying, state-level activism, public education Nellie Gray Founder of the March for Life Education and Defense Fund 1974 - Death Sustained national visibility, annual public protest, political witness Henry Hyde (Congressman) Key proponent and namesake of the Hyde Amendment 1976 (Amendment passed 1977) Restricting federal funding via appropriations bills Susan B. Anthony Pro-Life America (SBA Pro-Life America) Political action and advocacy group (501c4) focused on electoral outcomes Founded 1992 Electing pro-life women and leaders; targeted electoral campaigns IV. Strategies of Constraint and Legal Incrementalism (1992-2022) Following the 1992 decision in Planned Parenthood of Southeastern Pennsylvania v. Casey, which affirmed the core right to abortion but allowed states to impose regulations that did not constitute an "undue burden," the pro-life movement adopted a strategy of legal incrementalism. The objective was to test the boundaries of Casey through state laws, setting the stage for an eventual judicial reversal of Roe. IV.A. Strategic Judicial Testing and Viability Rules The movement focused its legal challenges on regulating procedures, limiting access through funding, and pushing the definition of viability. Key judicial victories demonstrated the efficacy of this strategy: Webster v. Reproductive Health Services (1989): This ruling, preceding Casey, upheld state rules requiring doctors to test for fetal viability after 20 weeks and blocking state funding and state employee participation in abortion services. Rust v. Sullivan (1991): Upheld a ban on certain federal funds being used for abortion referrals or counseling, a significant win for restricting information and access. Gonzales v. Carhart (2007): This decision marked a critical achievement by upholding a federal ban on the dilation and extraction (D&X) abortion procedure. The victory confirmed Congressional power to regulate the type of procedures performed, thereby weakening the judiciary's role in micromanaging abortion regulations. IV.B. Legislative Weapons: Trigger Laws and Fetal Personhood Creep While fighting incremental battles in the Supreme Court, the movement simultaneously prepared the legislative ground for a post-Roe America. The Trigger Law Infrastructure This was a profound example of long-term planning. As early as 2005-2007, states began passing "trigger laws". These statutes were designed to make performing, procuring, or prescribing an abortion a felony, automatically going into effect if Roe v. Wade were ever overturned. The legislative ambition spanned a wide spectrum, ranging from incremental heartbeat bills (making abortions illegal once a heartbeat is detected, e.g., HB 1500 in Texas) to total bans and proposals to actively disregard federal court rulings (e.g., HB 896 in Texas). This infrastructure ensured that a judicial victory would translate into immediate, widespread legislative restriction. The Fetal Personhood Movement The ultimate legal objective is to end legalized abortion entirely, achieving the status where abortion and infanticide are viewed as wrongful killing in both law and popular opinion. The strategy to achieve this hinges on the concept of "fetal personhood"—laws granting full legal protection to the unborn, with potential downstream consequences for reproductive technologies like IVF and specific forms of contraception. The movement advanced this concept incrementally through "fetal personhood creep" : Protecting Pregnant People: Laws increasing penalties for crimes committed against a pregnant person that result in pregnancy loss. Holding Pregnant People Responsible: Laws holding pregnant people legally responsible for fetal ailments, pregnancy loss, or even behaviors that could harm the pregnancy. Acknowledging Loss as Child Loss: Practices such as making death certificates available whenever a pregnancy ends. This legal approach is aimed at establishing a world where the pregnant individual is not ultimately in charge of any aspect of their pregnancy. IV.C. Cultural and Grassroots Infrastructure: Crisis Pregnancy Centers (CPCs) The legislative and judicial strategies were complemented by a vast, national cultural infrastructure of Crisis Pregnancy Centers (CPCs), also known as "pregnancy resource centers". These organizations are predominantly affiliated with evangelical Christian networks and national anti-abortion organizations, offering counseling and material support (diapers, formula) from a strictly anti-abortion perspective. The operation of CPCs demonstrates a nuanced strategic understanding that legal restriction alone is insufficient to reduce abortion rates; cultural momentum and direct intervention with potential patients are necessary. The centers often employ deliberately misleading practices to convey legitimacy and credibility. These include layperson volunteers wearing white coats, establishing sophisticated, difficult-to-differentiate websites, and using names similar to comprehensive clinics. Specific strategic tactics employed include: Co-location: The purposeful opening of CPCs near legitimate reproductive health clinics, often just across the street or within a few blocks, to intercept abortion-seeking patients. Targeted Advertising: Concentration of advertising efforts (e.g., billboards, online ads) on groups identified as "abortion-minded," including young women, women of color, and those of lower socioeconomic classes. Care Net, for example, runs an “Urban Initiative” that advertises on platforms like the Black Entertainment Network (BET). Legal Protection: The movement secured a major legal victory in 2018 (NIFLA v. Becerra) when the Supreme Court ruled that a California law requiring licensed CPCs to post information about affordable state-provided abortion and contraception services violated the centers' First Amendment free speech rights. This decision effectively legitimized their ability to operate without fully disclosing their ideological mission. This dual investment in high-level litigation and cultural infiltration ensures that even in areas where abortion remains accessible, the movement has a robust, localized system for reducing demand and discouraging access. V. The Apex: Dobbs v. Jackson Women’s Health Organization (2022) and Post-Roe Dynamics The culmination of five decades of legal, political, and cultural organizing arrived with the 2022 Supreme Court ruling in Dobbs v. Jackson Women’s Health Organization. V.A. Overturning the Constitutional Right In June 2022, the Supreme Court, considering the constitutionality of Mississippi’s Gestational Age Act, delivered a monumental victory to the pro-life cause. The Court determined that the U.S. Constitution does not confer a right to abortion, thereby explicitly overturning Roe v. Wade and Planned Parenthood v. Casey. Chief Justice John Roberts agreed to uphold the Mississippi law but criticized the majority for using the case to decide the broader question of overruling Roe entirely, preferring to leave the issue to a future case. The immediate consequence of the Dobbs decision was the return of abortion regulation entirely to the elected branches of the states. Pre-passed trigger laws took effect rapidly, leading to heavy restrictions or outright bans. As a result, an estimated 22 million women and girls of reproductive age in the U.S. now live in states where abortion access is severely restricted, often rendering it totally inaccessible. The dissenting justices criticized the majority for unsettling nearly five decades of precedent, arguing the decision breached a core rule-of-law principle and undermined the Constitution's promise of freedom and equality for women. They expressed concern that the ruling placed other rights—such as contraception, same-sex intimacy, and marriage—in jeopardy. Table V.1: Key Pre-Dobbs Legal Strategies and Milestones Legal/Legislative Action Year Objective from Pro-Life Perspective Result/Impact Source Reference Hyde Amendment 1977 Restriction of federal funds (Medicaid) for abortion services Limited access for low-income populations; established funding mechanism control Webster v. Reproductive Health Services 1989 Upheld viability testing and state funding limitations Affirmed greater state regulatory power within Roe/pre-Casey framework Trigger Laws Enactment 2005-2007 (onward) Automatic state ban/restriction upon the overturning of Roe Ensured immediate state action post-Dobbs and demonstrated long-term planning Gonzales v. Carhart 2007 Upheld federal ban on specific abortion procedures (D&X) Confirmed Congressional power to regulate procedures, weakening Casey limits NIFLA v. Becerra (Protecting CPCs) 2018 Protected Crisis Pregnancy Centers’ right to non-disclosure Major victory for the cultural/service arm of the movement; solidified operational model V.B. Political and Cultural Recalibration Post-Dobbs The overturning of Roe was celebrated as an "astonishing spiritual and legal victory". However, the legal triumph immediately exposed a profound gap between the movement's political achievements and the actual public sentiment. The decision revealed that a significant portion of the American public remains committed to abortion as a component of "reproductive freedom". This political environment necessitated a strategic pivot. While some states imposed immediate restrictions, others moved quickly to enshrine abortion protections. The Republican Party, historically aligned with the movement, began to strategically obfuscate their specific abortion positions in campaigns, especially in states where full bans were in effect, suggesting a cautious response to shifting public opinion. The future of the movement relies on securing popular adherence and political consolidation, challenging the notion that restriction is sufficient alone. Pro-life leaders have since called for increased "radical solidarity," urging the movement to be "courageously 'pro woman'" by promoting true alternatives and supportive choices, rather than relying exclusively on legal prohibition. V.C. Third-Order Effects: Healthcare and Enforcement Crises The shift of the regulatory battle to the states has generated several negative externalities, creating a new crisis for the movement to address. The consequences of the Dobbs decision extend far beyond abortion access. The restrictions have placed women’s lives and health at risk, contributing to a climate of fear among healthcare providers and potentially leading to increased maternal mortality and morbidity. Evidence strongly suggests that severe restrictions are impacting healthcare infrastructure. In the year immediately following the Dobbs decision, states with the most stringent restrictions experienced a 3.0% decrease in overall residency applicants, with a dramatic 10.5% decrease specifically among OB/GYN applicants compared to previous cycles. This significant decline, driven by medical students choosing to practice in less-restrictive states, foreshadows a potentially critical shortage of physicians in restriction-heavy states, affecting specialized care as well as general medical services. Furthermore, the decision opens the door to the penalization and criminalization of healthcare decisions, placing providers, patients, and even third parties at risk of prosecution. This legal environment also raises serious concerns regarding privacy rights, as digital surveillance may expand to detect violations of new abortion regulations. The harms resulting from Dobbs disproportionately affect marginalized populations, including women of color, people with disabilities, and low-income individuals, exacerbating existing health and equality disparities. VI. The Global Pro-Life Movement and Transnational Conflict The conflict over abortion is not confined to the United States; it is a transnational phenomenon characterized by ideological export and localized counter-movements. Global anti-abortion movements are frequently initiated as counter-responses to efforts aimed at liberalizing elective abortion laws. VI.A. Global Context and Ideological Export In Europe, abortion law varies widely, having been legalized by parliamentary acts in some countries while remaining constitutionally banned or heavily restricted in others. For instance, in France, the first specifically anti-abortion organization, Laissez-les-vivre-SOS futures mères, was created in 1971 in response to the looming Veil Law. Historically, Catholic nations like Ireland and Poland have been central to fierce anti-abortion advocacy, though liberalization has occurred in many parts of Western Europe. The US movement's political and legal expertise, honed over five decades, provides tactical models (e.g., incremental legislation, large-scale marches) that are leveraged globally. The success in overturning Roe provides ideological justification and political momentum for groups fighting liberalization worldwide, reinforcing the international dimension of this conflict. VI.B. Human Life International (HLI) and Transnational Strategy The leading global entity of the movement is Human Life International (HLI). Founded in 1972 by Fr. Paul Marx, O.S.B., HLI is recognized as the world’s largest pro-life and pro-family Catholic apostolate. HLI operates a massive global mission, working in over 100 countries on six continents and carrying out more than 1,500 missions. The organization’s strategy goes beyond merely opposing abortion; it seeks to build a comprehensive "Culture of Life and Love" by addressing related issues such as chastity, marriage, and end-of-life concerns. The methodology emphasizes long-term capacity building, training local leaders—including doctors, teachers, and clergy—to embed the movement ideologically within communities and ensure a lasting, fundamental societal shift. VI.C. Regional Conflict: Latin America and the Green Wave Counter-Movement Latin America represents a significant contemporary battleground where intense conflict exists between established conservative forces and the burgeoning "Green Wave" reproductive rights movement. The pro-life opposition groups have accentuated their presence in the region, compelling pro-choice organizations to strengthen their capacity for legal defense in the face of persistent threats from anti-choice groups. The global strategy ensures that resources are allocated to help families choose life through counseling and healthcare, actively confronting attempts to expand abortion access across the continent. Table VI.1: Selected Global Pro-Life Efforts and Focus Areas Geographic Region Key Organizations/Affiliates Primary Strategy/Focus Local Legal Status Trend Source Reference Global Missions Human Life International (HLI) Training local leaders (doctors/teachers); promoting "Culture of Life"; addressing chastity, marriage, end-of-life Building foundational societal shifts in 100+ countries Europe (e.g., France, Poland) Laissez-les-vivre-SOS futures mères; March for Life Organized public protest; legislative campaigns to restrict access through constitutional or parliamentary means Historically successful restrictions, now facing strong liberalization counter-movements Latin America HLI affiliates, local religious groups Direct opposition to "Green Wave" liberalization efforts; engaging in local legal challenges Intense social and legislative conflict against legal expansion of abortion access ## VII. Conclusion and Future Trajectories The history of the pro-life movement is defined by its strategic patience, its deep religious conviction, and its relentless focus on both legislative incrementalism and judicial reversal. The overturning of Roe v. Wade in 2022 represents the successful culmination of a strategy involving sustained grassroots pressure (March for Life, NRLC) and precise judicial targeting (trigger laws, procedure bans). The movement effectively leveraged seemingly secondary legal mechanisms, such as the Hyde Amendment, to constrain access and normalize restriction long before the constitutional right was dismantled. VII.A. Persistent Goals and Strategic Pivot Despite achieving its ultimate legal objective—removing the federal constitutional protection for abortion—the movement's work is far from over. The stated goal remains the complete elimination of legalized abortion. This indicates that the strategic focus must now pivot from legal conquest to cultural legitimation and political consolidation. The future agenda will likely involve several key areas of conflict: The Pursuit of National Personhood: The movement will continue to seek the establishment of federal fetal personhood, likely via constitutional amendment or national legislation. If successful, this could outlaw abortion nationwide and have significant legal ramifications for adjacent reproductive rights, including IVF and specific forms of contraception. Interstate Conflict and Funding: State legislatures will remain a primary battleground, dealing with issues such as the criminalization of interstate travel for abortion and interpretation of the Hyde Amendment’s scope regarding activities that may "facilitate abortion access". The Culture War and Support Systems: Having achieved its legal floor (state regulation), the movement now faces the challenge of the political ceiling (public opinion). To secure popular adherence to restrictive laws, the strategy must place greater emphasis on the "pro-woman, pro-life" framework and the expansion of the social safety net provided by CPC networks. The movement is now contending with documented adverse outcomes stemming from its success, particularly the documented decrease in OB/GYN residency applicants and the associated risks to maternal health in states with severe restrictions. How the movement reconciles the moral imperative of life protection with the tangible deterioration of regional healthcare access will define its political sustainability in the post-Roe era. AI Generated (always verify) Works cited 1. Abortion-rights movement - Wikipedia, https://en.wikipedia.org/wiki/Abortion-rights_movement 2. 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