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11 Can there be a global historiography of citizenship? • Kathryn L. Wegner

11 Can there be a global historiography of citizenship? • Kathryn L. Wegner

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Kathryn L. Wegner



many works, especially those published after 2000, explore intersections between citizenship,

gender, and race, often in a postcolonial context.



What is called citizenship?

The first question historians of citizenship must confront is: what is called citizenship? (Isin,

2009, p. 369). Defining citizenship is problematic, as the concept is socially constructed and

historically contingent, and thus historians often rely on the explanatory constructs theorized by

political scientists. Twentieth-century political theorists such as John Pocock, Quentin Skinner,

and the Cambridge School, Jurgen Habermas, John Rawls, Adrian Oldfield, Will Kymlicka,

Derek Heater, and sociologist T. H. Marshall are some of those most often cited by historians.

Excerpts of these theorists’ writings on citizenship have been edited and assembled in two collections by Ronald Beiner (1995) and Gershon Shafir (1998). Derek Heater’s (2006) list of the

most common ways citizenship has been defined has also been frequently utilized. In showing

that citizenship has been defined as a status; identity; civil, political, or social idea; as a set of

rights and duties; as a local, national, or supranational idea; as a legal status; or as a theory and

practice, Heater (2006, p. 2) provides a place to start for the historian of citizenship.

In addition to relying on one of these definitions of citizenship, historians of North America

and Europe also often utilize political theorists’ characterizations of citizenship as a tension

between the Greek and Roman traditions. A familiar historical narrative describes Greek citizenship as participation and Roman citizenship as the possession of legal rights, both of which

include an emphasis on the development of civic virtue in youth through education. The

Habermasian view is that the Greek tradition offered civic republicanism, which proposed that

people were inherently political, that they practise citizenship through public spheres, and that

participation was the central element of citizenship. John Rawls described the legacy of Roman

citizenship as liberal-individualist, or a liberal citizenship, one that emphasizes an individual’s

rights and duties. Derek Heater (2004a) in A Brief History of Citizenship and historians of the

United States such as Noah Pickus (2005) and Gary Gerstle (2002) use the tension between

republican and liberal conceptions of citizenship as their framework.

The ways in which the early modern and modern worlds drew on these notions of classical citizenship, especially the Spartan model of citizenship training, the best example of state

provision of citizenship education before revolutionary France, is considered by Heater (2004b,

p. 3), but is otherwise unexplored. How did educational theorists appropriate the language of

classical philosophers in advocating mass education or education for citizenship? How have

these classical models of citizenship influenced its development in Europe, North America, and

the parts of the world that do not consider themselves descendants of Greece and Rome? These

questions require answers.

Historians have also taken up the idea of social citizenship as proposed by British sociologist

T. H. Marshall (1950). In a series of lectures at the University of Cambridge in 1949, Marshall

(1950, p. 10) laid out a teleological view of British citizenship in which citizens first achieved

civil citizenship, consisting of the ‘rights necessary for the individual freedom – liberty of the

person, freedom of speech, thought and faith, the right to own property and to conclude valid

contracts, and the right to justice … [through] … institutions like Parliament and local government councils’. The political element of citizenship developed later with the expansion of

suffrage, where political citizenship provided the ‘right to participate in the exercise of political

power, as a member of a body invested with political authority or as an elector of the members

of such a body’ (Marshall, 1950, p. 11). Finally, social citizenship, the concept of Marshall’s

that garnered the most attention, was explained as the ‘economic welfare and security to the

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right to share to the full in the social heritage and to live the life of a civilized being’, which

he saw as developing alongside mass education and the modern welfare state (Marshall, 1950,

p. 11). Marshall has been criticized for his teleological views and the absence of women and

ethnic minorities in his theoretical framework. Others have noted that his theory developed in

the wake of mass secondary education and the establishment of national health care, a moment

that redefined the relationship between the state and its people. In spite of criticism, Marshall’s

English model has been a starting point for many historians.

Relying on Western models of citizenship, such as Marshall’s, is problematic for a historiography of global citizenship. In this post-orientalist moment historians must take care not

to suggest that citizenship is necessarily a Western idea, or worse that some people or nations

are incompatible with citizenship (Isin, 2005). For historians who feel compelled to start with

a working definition of citizenship, the conceptual frameworks borrowed from the Western

tradition have proven useful; however, a global history of citizenship must not assume that citizenship is uniform and European.



Citizenship and liberty during revolutions

Central to a historiography of global citizenship should be an analysis of political revolutions

in the modern world. In revolution, assertions of individual desires for liberty redefine the

relationship between the people and their ruler(s) and forge new citizenships. Historians of the

French Revolution were the first to take seriously citizenship as a topic of historical inquiry,

and they did so by centring citizenship in the historical narrative of the French Revolution.

The narrative turned away from its dramatic and complex events, the ways that revolutionaries and counter-revolutionaries acted out ideologies, and its elements of class struggle when

the citizenship historians intervened to show how revolutionaries saw citizenship and how ‘a

citizen’, over the course of the revolution, came to mean a socially useful person endowed with

civic virtue, and the opposite of ‘privileged, aristocrat, member of faction, [or] troublemaker’

(Dawson, 1993, pp. xiv, xvi). For French historians, French revolutionaries invented modern

citizenship and state-funded citizenship education, but whether the struggle for citizenship was

a cause of the revolution, as Simon Schama (1989) argued, or an outcome of the revolution,

remains a central question for these historians. To Eli Sagan (2001, p. 7) the disappointment of

the revolution was the failure of French revolutionaries to create Aristotelian citizens who were

capable of ruling and being ruled. To be a real citizen, argued Sagan (2001), is thus to accept,

allow, and be part of, when necessary, the loyal democratic opposition. French historiography is

still preoccupied with understanding citizenship, although more recently it has turned towards

the family, nation and citizenship, and the citizenship status of foreigners and Jews (Birnbaum,

2000; Ngaire Heuer, 2005; Rapport, 2000).

Across the Atlantic in a parallel revolution, citizenship also proved central to revolutionaries,

but historians of the American Revolution are newer to its exploration. As in France, the term

‘citizen’ in the British colonies was defined by its opposite, meaning to the American revolutionaries the state of not being a ‘subject’.



The American Revolution and citizenship

During the American Revolution, revolutionaries afforded the ‘citizen a crucial and heady

status, one distinct from the inequality required and expected of subjecthood’ (Bradburn, 2009,

pp. 10–11). Citizenship in a democratic republic would be very different from its status in a

monarchy. In fact according to Douglas Bradburn’s research ‘subjecthood and citizenship were

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understood to be polar opposites, with subjecthood representing a feudal status of perpetual allegiance and inferiority, and citizenship representing a “modern” status of equality and freedom,

a mark of “a new order”’ (Bradburn, 2009, p. 11).

Bradburn’s book is one of many in the past fifteen years on citizenship, a factor partially

attributable to the inspirational American Historical Association conference’s Presidential

Address in 1997 by Linda Kerber titled ‘The Meanings of Citizenship’, in which she proposed

an American ‘braided citizenship’, a definition of citizenship as an idea full of inconsistencies and

contradictions, albeit inherently American ones (Kerber, 1997). To Noah Pickus (2005), these

particulars of American citizenship were forged in the unique debates between the Republicans

and Federalists in the first few decades after independence, when Republicans regarded the

nation as held together by citizens’ shared belief in liberalism and self-government, and the

Federalists who saw the nation as united by citizens’ shared national origin and language. These

two components of American citizenship – sharing of civic principles and sharing a national

identity were moulded into a tenuous civic nationalism that, he argued, has essentially defined

American citizenship until the present day.

The long histories of citizenship in the United States draw on faith in American exceptionalism, an idea from Alexis de Tocqueville’s 1835 Democracy in America that claimed that the

American nation was qualitatively unique (Wood, 2011). Historians of citizenship have found

American exceptionalism unavoidable, tending towards explanations of how American democracy, liberty, and a civic nationalist citizenship are one of a kind.

In an influential article in 1992, Nancy Fraser and Linda Gordon asked the exceptionalist

question: why is there no social citizenship in the United States?2 Many historians since have

explored how United States’ citizenship is exceptional given the nation’s limited welfare state.

One way that historians of American citizenship might escape the search for American exceptionalism is to place the United States in a global, or at least European, narrative, something

that this essay hopes to inspire.

In American historiography, citizenship also appears in work on the Progressive Era.

Citizenship as defined as a legal construct and sometimes as a social identity is an important

topic in Progressive Era (1890–1920) history, and is often discussed as it relates to democratic

theory at the turn of the twentieth century. Scholarship on John Dewey, Walter Lippmann,

Theodore Roosevelt, and other Progressives often asks what the role of the citizen in a democracy should be. Immigration historians also discuss citizenship to varying degrees, as immigrants are the perfect case for testing the inclusiveness of citizenship in a particular era. Martha

Gardner’s (2009) book on women immigrants and the barriers they faced in acquiring legal

citizenship is a good example. Mae Ngai’s (2005) fantastic Impossible subjects: illegal aliens and the

making of modern America describes how immigration law created the category of illegal aliens,

one that had not existed before the 1920s. Gary Gerstle (2002) and Desmond King (2005) also

write long immigration history narratives that discuss the significance of access to citizenship

for immigrants.

Historians of education and schooling also naturally engage with these debates and have

contributed to our understandings of the connections between citizenship and the nation’s

intention to teach it through state-funded public schooling (Zimmerman, 2005; Selig, 2008;

Steffes, 2012; Moss, 2009). The consensus here is changing, as historians now see the issue as

more complicated than the revisionist take that has mostly held sway since the 1970s and argued

that citizenship education was the state’s approach to indoctrinating its youth in a notion of citizenship that emphasized docility, obedience, and a submission to the capitalist social order and

status quo (Spring, 1976). Historians of education are now joining the larger historiographical

trend of exploring citizenship in local contexts.

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Other histories of American citizenship explain types of citizenship. Kerber’s (1976) epublican motherhood’ described American women’s special role as citizens in educating and

preparing their sons for republican self-rule. Others like Gary Cross (2002), Lizbeth Cohen

(1998), and Meg Jacobs (2006) write about the development of consumer citizenship in the

early and mid-twentieth century, in part to explain how consumer citizenship supplanted

an emerging workers’ rights conception of citizenship that was emerging in the 1930s. In

short, the historiography of citizenship in the US has focused on the revolutionary period,

the Progressive Era at the dawn of the twentieth century, and 1930s New Deal period of

state-building and social welfare, and seems to be turning from long narratives of citizenship

to explorations of local citizenship in particular historical moments. Histories of citizenship in

the new century more often than not focus on gender and citizenship, and partial or quasicitizenships, such as the state of African Americans in the Jim Crow post-bellum American

South, the state of the physically and mentally disabled, or cases of partial citizenship status

for gay or lesbian people.



Subjects or citizens in British history?

Perhaps American exceptionalism is not that exceptional, given that the historiography of

British citizenship seems also fixated on understanding the unique status of British citizens in a

constitutional monarchy. The central paradox in British history is that in what has always been

a monarchy (with the exception of the 11-year republican period), it has also been the site of

widespread electoral franchise, the birth of political parties, and arguably deep political participation. Furthermore, British common law established a definition of citizenship that defines

international law, that is, that citizenship is determined by jus sanguinis or jus soli, by right of

blood or place of birth (Heater, 2006, p. 164).

Regardless of these contributions to the development of citizenship, historians of Britain

have emphasized the fact that British law does not discuss citizenship. Heater (2006) traced citizenship’s history from its humanist origins in Locke, Hobbes, and John Stuart Mill to the present day, and argued that not only does British law not discuss citizenship, but in a state without

personal sovereignty it cannot really exist; in other words ‘no republic, no citizenship’. Rieko

Karatani (2003, p. 2), a historian of the modern commonwealth, agreed, noting that existing

work emphasizes the absence of British citizenship, claiming that nothing in British common

law actually defines who ‘belongs’ or what it means to ‘belong’ to the British state. Karatani

(2003) tries to rectify this reading of Britain as lacking citizenship with his book on British

citizenship and the empire.

Although the interpretations of Britain as lacking citizenship do exist, even more historians

have searched for what forms of citizenship were present. For the early modern historian Patrick

Collinson (1987), Britons should be regarded as ‘citizens concealed within subjects’. He was

responding to a central question in the historiography of British political history that sought

explanations for the rise of republicanism prior to the Civil War. Collinson found that the

ideas of self-government were present in a variety of places existing, for the most part, harmoniously within the monarchial system. Men participated on local councils, and in guilds, and

were increasingly familiar with classical scholarship on republicanism. Phil Withington (2005)

showed how freeman or ‘citizens’ of towns possessed rights and duties such as holding property,

levying taxes, and voting for members of Parliament.

In the British Empire citizenship takes on a larger meaning. Citizenship is not located in

the citizen-state relationship, but in the affective connections between individuals and their

nation-state. Guy Goodwin-Gill (2003, p. vii) wrote that citizenship was in the ‘personal

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link between subject and sovereign – the bonds of loyalty and allegiance’. In the nineteenth

century this shared loyalty to, and protection by, the sovereign is what united the people of

the empire. How this ‘imperial citizenship’ was constructed and promoted is explored as an

ideological history in Daniel Gorman’s (2006) Imperial citizenship: empire and the question of

belonging. The implications of ‘imperial citizenship’ for women in the British Empire, and in

particular how suffrage are achieved in the early twentieth century are topics taken up in a

new edited collection titled Women’s suffrage in the British Empire: citizenship, nation, and race

(Fletcher et al. 2000).

Gender again makes an appearance in Matthew McCormack’s (2006) Independent man:

citizenship and gender politics in Georgian England where he explores the intersections between

masculinity and politics and the ‘manly’ ideal of independence in the political world. In

the later nineteenth century Lydia Murdoch (2006) uses the case of orphans to show how

conflicts between middle- and working-class notions of citizenship created an anti-poverty

sentiment amongst the middle class that contributed to the development of a minimalist

welfare state.

The post-war story of British citizenship is also told as the refashioning of belonging for

the post-empire and increasingly multicultural nation-state. This scholarship parallels that of

modern Germany, where five recent books (Mushaben, 2008; Klopp, 2002; Mandel, 2008;

Nathans, 2004; Eley and Palmowski, 2008) discuss national unity and the integration of ethnic

minorities, the Turkish community in particular. In Britain, Ann Dummett and Andrew Nicol

(1990), Randall Hansen (2000), and Sonya Rose (2004) represent a new British historiography

that is increasingly interested in what immigration history illuminates about the meaning of citizenship and Britishness. Karatani (2003) showed that the post-war era is in some ways the richest

for the study of British citizenship, given that British subject and Commonwealth citizen were

proclaimed to have the same meaning in the 1948 British Nationality Act. It was not until 1981

that a Nationality Act in Britain declared British citizenship a legal category. From discussions of

citizenship as weak, the historiography has moved in the last few years to exploring the multiple

and overlapping citizenships of supranational EU citizenship, national, regional e.g Scottish, or

local e.g Greater London Authority.



A Chinese citizenship?

The exceptional citizenships in the United States and the United Kingdom were almost always

presumed to be present, which is not the case in other historiographies.While there are certainly

political histories exploring the relationship between citizens and their rulers which we might

broadly see as citizenship history, the historical scholarship that specifically positions its narrative in a longer history of citizenship rarely imagines the presence of non-Western versions of

citizenship. Citizenship in the East is either a clear import from the West or absent and unimaginable. Chinese historian Peter Zarrow (1997) found that in the late-Qing constitutionalist state,

citizenship with the right of suffrage was offered to educated and propertied men, who drew

on a Western citizenship discourse in their discussions of modernization and state-building, and

led to the growth of the Republican Party in the decade leading to the Revolution (p. 16).

Zarrow’s discussion of the influence of Western ideas on Chinese republicans is unsurprising

given the interconnected histories of the East and West.

In R. Bin Wong’s (1999) history of the Chinese twentieth-century communist state, citizenship is shown to be absent. Wong writes, that ‘Chinese subjects lack the institutional

foundation to be citizens’, for he assumes that, without a public sphere or civil society,

citizenship is nonexistent (p. 112). In its place the state relied on mass movements, and so

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Chinese citizens in the Communist state became part of social movements, not ‘citizens in

a representative political system’ (Wong, 1999, p. 12). In applying a Western definition of

citizenship, Wong fails to imagine what a distinctively Chinese citizenship might look like,

instead bemoaning the lack of a particular Western citizenship in China. Historians of the

non-Western world would complicate our understanding of citizenship by showing how

citizenship, differently defined, developed in the East. Ultimately, the limited yet emerging

historiography of Chinese citizenship suggests the continued persistence of orientalist interpretations of Eastern history. A global historiography of citizenship must demonstrate the

influence of Western conceptions of citizenship without essentializing citizenship by assuming a singular Western model.



African, Asian, South American, and Eastern European citizenships

The historiographies of citizenship in Africa, Asia, South America, and Eastern Europe are in

development, and their mostly national narratives help complicate the historiographies of citizenship in western Europe and the United States. For example, recent work on the Ottoman

Empire tied the instability of Ottoman citizenship to the empire’s lateness in establishing infrastructure and economic development, suggesting that what the Chinese republicans believed – that

citizenship and modernization are linked – might be one way to understand modern citizenship

(Salzmann, 1999, p. 38). A recent book on postcolonial India helps us see a more cynical legacy

of the English legal system and the liminal and contested citizenship within India in the years

following partition (Roy, 2010). Alastair Davidson’s (1997) book on postcolonial Australian

citizenship advances a definition of citizenship that does not require national belonging and

shows how citizenship manifests in a multicultural state. In Brazil the growth of settlements on

the peripheries of the megacities of São Paulo and Rio de Janeiro have inspired many to consider what access to citizenship poor, often transient residents possess. James Holston’s book on

‘insurgent citizenship’ based its claims on discussions with people on the fringe, and he found

that citizenship can be universally inclusive and generally inegalitarian; one can feel fully a part

of the nation, yet lacking the rights of membership (2008, p. 40). Recent scholarship (Robins,

2005; Nyamnjoh, 2006; Werbner, 2004) on Africa explores the limitations of citizenship in

modern South Africa, and the postcolonial challenges for the continent in Making nations, creating strangers: states and citizenship in Africa (Dorman et al. 2007).The paucity of scholarship on the

history of citizenship (in English), particularly on South America remains (Fischer, 2010). These

contributions, however small, on the origins of citizenship, development in multicultural states,

the challenges of postcolonialism, and citizenship’s contestability by marginal subjects challenge

the Western citizenship narrative.

On Eastern Europe the historiography is leaning towards explorations of gender and disability, a trend following American and British historiography. Recent books on citizenship

and gender in Czechoslovakia and on gender in contemporary Russia, and a study of disability

in post-socialist Ukraine round out the most recent scholarship (Phillips, 2010; Feinberg, 2006;

Calazza, 2002), each illustrating how citizenship is contested by national minorities.

Finally, global or transnational histories help us see commonalities across many citizenships.

Gender and the antislavery movement, race in post-emancipation societies, the impact of masculinity in creating Western political culture, and memory in Japan, Germany, and the US

are examples of connections citizenship historians have made between nation-states or regions

(Zaeske, 2003; Cooper, Holt, and Scott, 2000; Clark, Dudink, and Hagemann, 2012; Hein

and Selden, 2000). Rogers Brubaker (1992) compares the invention of national citizenship in

France and Germany, carrying it through to the present day to show how each nation integrates

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immigrants. Kamal Sadiq’s (2010) Paper citizens: how illegal immigrants acquire citizenship in developing countries is a good introduction to the concept of ‘documentary citizenship’, where newly

arrived migrants easily acquire citizenship papers allowing them to pass as citizens of a nation

without belonging or sometimes even permanently living there. These international perspectives are places to start, but the historiography is still emerging.



Conclusion

All of the histories of citizenship struggle with similar challenges, starting with how to define

citizenship – as a legal construct, as a social category, an identity, or an idea, or something else

altogether. Because citizenship is an inherently positive term, there is a danger in describing

citizenship in a teleological narrative, which is obviously problematic, since the extension of citizenship rights is often selectively applied, quickly reversed, transitory, or fleeting. The few studies that draw on or help build transnational, comparative, or global narratives have the difficult

act of balancing the national particularities with the global commonalities. These conceptual or

theoretical concerns call for more consideration.

The task for historians of citizenship is first to show how citizenship has been constructed as

natural in the West and weakly imported or impossible elsewhere. Then we can begin to draw

together histories of citizenship across time and space to denaturalize modern citizenship’s origin

in European nation-states. It helps us see how citizenship is and is not necessarily a Western

idea, and more research into the history of citizenship in the non-Western world can help us

see how Africans and Asians have drawn on Western ideas of citizenship, but have also crafted

their own ways of thinking about peoples’ rights and duties to nation-states and empires. In this

way, a historiography of global citizenship is a bold mission – one that might decentre the West

as the foundation of liberalism and republicanism. Histories of citizenship can illuminate how

peoples around the world have worked out living together and governing themselves, and show

how ordinary people in many places and times have used, if not the particular term, then the

language of citizenship, to demand better lives. Thus a global historiography of citizenship, one

that we are only beginning to construct, has the possibility of showing how citizenship is both

universal and historically contingent.



Notes

1 Bibliographies created by the Center for the Study of Citizenship at Wayne State University in the United States (http://clasweb.clas.wayne.edu/citizenship) and the book review archive of H-Citizenship, an

H-Net listserve (www.h-net.org/~citizen/) are useful places to start.

2 Fraser and Gordon (1992) expanded T. H. Marshall’s analysis to explore how gender inequality has

contributed to a dismissal of social citizenship in the United States.



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Calazza, A. (2002) Mothers and soldiers: gender, citizenship, and civil society in Contemporary Russia, New York:

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12

Regimes of citizenship

Xavier Guillaume



When in March 2004 the French parliament adopted a law banning the veil, or any obvious

religious signs, from public schools, one could see in this national legislation a specific domestic

answer to the so-called ‘veil affairs’ which started in France as early as 1989. For almost fifteen

years, teenage Muslim girls were constructed as a threat to the unity and stability of the French

Republic because their (assumed) attachments, loyalties, and goals were seen as incompatible

with the values, principles, and common project expressed by a Republican ideal.

Yet, what the ‘issue’ of the veil uncovers is rather the multiple sites from which citizenship

can be engaged with, as to think about the veil in France is to engage with the contemporary

and historically constituted interlinks between citizenship and migration (as most of these girls

are considered to be issus de l’immigration whether or not they hold French citizenship), religion

(as these girls are Muslim), secularism (as it is the normative European standard posited), postcolonialism (as an origin and factor for the specific relations between some migrants or French

citizens issus de l’immigration and French ‘natives’), urbanization (as it is the specific, often imagined, space of the relations between outsiders and insiders), integration (as the specific political

issue at stake), or security (as this ‘issue’ has been presented and constructed as a threat to French

society), and so on. As is obvious from this non-exhaustive list, these interlinks are not limited

to the territorially defined boundaries of France (see Guillaume 2007: 751–7), and thus require

a conception of citizenship that goes beyond a static, institutional and formal understanding.

Citizenship is in effect still widely considered a domestic institution that may have international ramifications depending on the legal frameworks states may be bound to. This

understanding of citizenship, however, puts emphasis, if not solely concentrates, on this formal

picture of citizenship’s institutional dimension, whether domestic or international. From a global

perspective, however, citizenship has not only to be read in the diverse dynamics of its multiple

spatialities, from local municipalities to international agreements, but also in the multiple ways

in which it is legislated and enacted at both the domestic and international levels. Citizenship in

that respect is also a site and a source of struggles over what being a citizen means. Issues over,

and the repertoires through, which institutions, procedures, practices, and acts are meeting do not

limit themselves any more to the confines of the (nation-)state. In other words, citizenship is a

globalizing process that is constituted by global and globalized institutions, procedures, practices,

and acts participating in the constitution of citizens and non-citizens alike. To offer a reflection

150



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