- The reptile skin trade is a controversial issue, with some experts saying that harvesting programs help conserve species and provide livelihood benefits, while others say that the trade is fraught with issues and animal welfare concerns.
- From a conservation standpoint, there is evidence that the reptile skin trade is sustainable for some species and in some contexts, but other research suggests that the trade could be decimating wild populations and doing more harm than good.
- Exotic leather is falling out of favor in the fashion industry: Numerous companies and brands have banned products made from reptile skin as well as fur, replacing them with products made from materials such as apple, grape or mushroom leather.
- Experts connected with the IUCN have written open letters and op-eds to lament the decisions of companies to ban exotic leather, arguing that these bans have damaged conservation efforts, but other experts question the IUCN’s unfailing support of an imperfect trade.
Shoes, watches, wallets and bags — anything made from exotic reptile skins — were plucked from the shelves in Selfridges, a high-end department store in the U.K., in February 2019. The move, according to the company, was motivated by a desire to “improve supply chain transparency and implement high standards of animal welfare” at a time when customers were demanding humane alternatives to animal skin products. Now, in place of reptile leather, the store sells boots made from apple leather, and has launched a line of products using vegan wildflower down, grape leather and eucalyptus and seaweed fiber. In 2005, Selfridges also banned products made from fur.
“The challenge of achieving transparency, particularly in python supply chains, presents a significant risk of inhumane practices in both the keeping and culling of animals,” Daniella Vega, Selfridge’s director of sustainability, tells Mongabay in an emailed statement. “Inhumane animal husbandry practices contravene Selfridges’ Ethical Trade Requirements.”
Selfridges isn’t the only store to make big changes like this. In September 2020, luxury department store chain Nordstrom announced that it would phase out exotic skins by the end 2021. Fashion giants such as Chanel, Mulberry, Victoria Beckham, and Tommy Hilifiger, have also given reptile skins the boot.
While reptile skin bans are being hailed a positive move for wildlife by some conservationists and animal welfare advocates, including renowned primatologist and anthropologist Jane Goodall, others say that stripping exotic skins away from the fashion industry is actually doing more harm than good. In this counterargument, proponents of exotic skins say that scientific evidence shows that the reptile skin industry is sustainable, contributes to wildlife recovery, and even supports local communities. Still, the issue is anything but straightforward, with others pointing to research that reveals unsustainable practices, illegal trade, and a plethora of animal welfare concerns.
Those against the trade also question why the exotic skin industry is being supported by the International Union for Conservation of Nature (IUCN), the organization responsible for cataloging the conservation statuses of the world’s most threatened species. Goodall says she’s “disappointed” by the IUCN’s support of the trade, and others have suggested that some members of IUCN specialist groups are stepping over the line to support a questionable industry.
‘The trade is actually assisting conservation’
If you delve into research about the reptile industry and species involved in the trade, you’ll likely stumble upon Daniel Natusch’s name. Natusch, a biodiversity expert who is a member of several IUCN species survival commission (SSC) groups, including the IUCN-SSC Boa and Python Specialist Group has co-authored more than 50 pieces on the subject published in the past 10 years. He says the reptile skin trade can help, rather than hinder, conservation efforts.
“Counterintuitively to a lot of folks, the trade in exotic skins is actually assisting conservation of many wildlife species, but certainly for reptiles,” Natusch tells Mongabay in an interview. “It has been the reason for a lot of the conservation success that we’ve seen.”
According to Natusch, most people don’t want large, potentially dangerous, reptiles like crocodiles or pythons in their backyards, and they might get rid of them to protect their livestock and their families. But when the skins of these animals can be sold for profit to the fashion industry, people suddenly have incentive to protect them and their habitats, he says.
The reptile trade is a multimillion-dollar industry, with the trade of raw skins accounting for about $295 million in 2019, according to the Observatory of Economic Complexity (OEC), an authority on international trade data. Between 2005 and 2013, global wildlife trade regulator CITES granted permits for more than 24 million individual reptile skins, of which more than half originated from wild-caught species, according to a report by the United Nations Office on Drugs and Crime.
A wide range of species is used in the reptile skin trade — from spectacled caimans (Caiman crocodilus) to reticulated pythons (Malayopython reticulatus) and oriental rat snakes (Ptyas mucosa) to Asian monitor lizards (Varanus salvator). While some reptile skin programs rely completely on captive animals, others take eggs or individual animals from the wild and then rear them in captivity until it’s time for them to be skinned and sold. Or sometimes they simply take wild individuals and directly harvest their skins.
Programs that use some wild stock are actually preferable to closed-cycle captive breeding, as long as they’re carefully managed to ensure sustainability, Natusch says. This is because captive breeding can create a dissociation between captive and wild stocks, he says, and makes people less likely to care about conserving wild populations. He adds there are “hundreds of peer-reviewed journal articles” that support the sustainability of these methods.
“In reality, it’s the species that are not being used that are threatened with extinction,” he says. “And without exception, it’s the species that are being used by the luxury industry that will be the ones that persist in future simply because of the years and years of management that’s gone into those species and the conservation systems that have been set up around their use.”
Advocates of the trade tend to point to the American alligator (Alligator mississippiensis) as proof that the industry can work to aid conservation. In the 1950s and 1960s, alligator numbers dropped below 100,000 in the state of Louisiana due, in fact, to unregulated hunting and trade, according to Jeb Linscombe, a biologist at the Louisiana Department of Wildlife and Fisheries. But when a state-run ranching program began in 1972, numbers went up.
“We conservatively estimate the population [to currently be] at 2 million,” Linscombe tells Mongabay in an email. “There is no doubt the program has been successful in conserving the American alligator. In fact, it is the quintessential example of a conservation success story.”
Christy Plott, owner of a family-run leather and tannery business in Louisiana and member of the IUCN-SSC Crocodile Specialist Group, says alligator eggs don’t have a high survival rate in the wild.
“Only 5% of those eggs would hatch, and have a chance to become a breeding adult, which is next to nothing,” Plott tells Mongabay in an interview. “Because the populations were already seriously depleted, they [state biologists] said, ‘Well, what can we do?’”
Working closely with state biologists, landowners began to harvest wild-laid eggs and sell them to farmers, who, in turn, would make sure as many eggs as possible would hatch. Then some hatchlings would be raised in captivity for their skins, while others were released back into the wild.
“While for some people, it might not be palatable to kill an animal, we have to look at a broader picture of some of these things, because a predatory species like an alligator is not something that people tend to be friendly about in their backyard,” Plott says.
Cord Eversole, a biologist at Texas A&M International University who is not connected to the IUCN or the exotic leather industry, but has researched the American alligator trade extensively, agrees that the industry has helped the species in states such as Louisiana and Texas.
“A lot of people are a little uneasy with species — especially wild species — being exploited for commercial purposes,” he tells Mongabay in an interview. “And [for] a lot of species [it] doesn’t necessarily work as well as it does with the American alligator, but fortunately, in a lot of those states where we’ve got large alligator populations, it’s worked really, really well.”
Grahame Webb, an Australian biologist and long-standing chairman of the IUCN-SSC Crocodile Specialist Group, says wild populations of the saltwater crocodile (Crocodylus porosus) in Australia have also benefited from the exotic skin trade. In the 1970s, these crocodiles were nearly hunted to extinction, but with the introduction of ranching programs and public acceptance of reinstated wild populations, the species recovered. In 1971, there were only about 5,000 saltwater crocodiles and 500 adults in Australia’s Northern Territory (NT), but now there are now about 100,000 in the NT and 175,000 nationwide, Webb says.
“Every time the consumer buys a product made from one of these skins from this program … they’re the ones that are driving the whole program,” Webb tells Mongabay in an interview. “Without that, the conservation collapses.”
‘We’re not supporting death’
Last year, Natusch, Webb and three other experts connected with the IUCN, wrote an open letter to the luxury fashion industry, urging companies to continue using the skins of wild animals such as crocodiles, alligators, snakes, and lizards as a way to support wildlife conservation and recovery, as well as local communities. They also say there is no evidence that reptiles can transmit diseases like the novel coronavirus, despite organizations like World Animal Protection (WAP) suggesting in a recent report that reptiles do have the ability to pass on dangerous pathogens to people, especially when kept in crowded, stressful conditions.
“This trade is one of the great conservation success stories of our time. Species once close to extinction have recovered and are now subject to meticulous management,” they write in the letter.
The sentiments in this letter aren’t new. In 2018, Natusch and Webb co-authored an op-ed after Chanel announced it would no longer be using reptile skins, arguing that the decision would “adversely affect the conservation of wild animals and the livelihoods of the people who live with and depend on that wildlife.” And in 2019, Natusch published another open letter on the IUCN website that ran along the same lines.
Natusch says it’s important to express these views since “negative rhetoric … lies and misinformation” from animal rights groups are threatening to overturn the reptile skin trade, and consequently harm conservation efforts connected with the industry.
“People are like, why is the world’s largest and most reputable conservation organization supporting animal deaths?” he says. “We’re not supporting the death, but we’re supporting what it can achieve for conservation overall, and basically there’s no conservation model that stacks up and has the successes that this does, especially for such dangerous animals.”
‘Grounds for concern’
While experts like Natusch, Plott and Webb point to the conservation success of the reptile skin trade, others say the industry is fraught with issues, and that scientific research clearly shows this.
“There are a lot of different opinions,” Jordi Janssen, a herpetologist at Monitor Conservation Research Society, an NGO that works to protect species impacted by trade through evidence-based research, tells Mongabay in an interview. “There are reports that say [sustainability is] feasible, [but] there are plenty of reports that say it’s not feasible.”
Researchers, first off, point out that the success of the skin trade programs for the American alligator and saltwater crocodile in Australia shouldn’t automatically apply to the trade in other species supplying skins to the luxury industry.
“Going from crocodiles to snakes, we have a completely different situation,” Mark Auliya, a herpetologist at the Zoological Research Museum Alexander Koenig, in Bonn, Germany, tells Mongabay in an interview. Not only do crocodiles and snakes belong to different taxonomic groups, but each situation would have differing trade dynamics, management strategies, and cultural considerations that would need to be considered. “All these things you have to put together and then assess anew,” he says.
He adds that assessing the sustainability of trade is a challenging task, and that there are not only “scientific uncertainties” around the legal trade of reptile skins, but a lack of transparency in the documentation of the trade and its regional and global networks.
For instance, a commonly cited report published by the U.N. and WTO’s joint International Trade Centre (ITC), wildlife trade watchdog TRAFFIC and the IUCN says there are “grounds for concern” regarding the harvesting and trade of reticulated pythons — the most heavily traded species in Southeast Asia — due to pythons being caught and slaughtered before they reach sexual maturity, which could destabilize wild populations. There’s also a study co-authored by Natusch himself that found that wild blood pythons (Python brongersmai) in North Sumatra were adversely affected by overharvesting. Another report, also published by the ITC in collaboration with the IUCN and the luxury group Kering, a French-based multinational corporation that owns a number of luxury fashion brands such as Gucci and Saint Laurent, found that a “degree of sustainability” had been achieved in the python trade in Peninsular Malaysia, but acknowledged that “giant snakes” had become less common.
“I think for a lot of species, we have no clue how they’re doing in the wild,” Janssen says.
Michael Starkey, founder and executive director of the NGO Save the Snakes, says snake species are hard to track in the wild, so researching the sustainability of a trade that relies on wild populations is actually quite difficult. As a result, many studies are riddled with “gaps,” he says.
“They [snakes] are cryptic species,” he says. “And working in places like Indonesia or Malaysia [with] dense tropical rain forests, it can be really hard to get accurate counts on these numbers.”
Studies have shown that there’s crime mixed up with the reptile skin industry, too. For instance, a highly publicized study in Ecohealth found that between 2003 and 2013, the United States Fish and Wildlife Service seized 5,607 illegal wildlife products at U.S. ports, 70% of which were exotic leather products. The researchers identified that brands such as Gucci, Ralph Lauren and Michael Kors were among those importing these products.
“We had started seeing these brands being listed as importers or exporters of these goods, which of course immediately drew interest just because there were such recognizable names, and were associated with an industry, which we would all expect to have very strong regulations as it comes to commercial consumption of animal products,” lead author Monique Sosnowski, a wildlife criminologist and doctoral student at the City University of New York (CUNY), tells Mongabay in an interview. “We were honestly very shocked to find that there were the number of seizures … in regards to these brands.”
Natusch recently published a paper that specifically questions the accuracy of Sosnowski’s study, arguing that most instances of “noncompliance” to the law are usually the result of unintentional “paperwork errors” rather than criminal intent. But Sosnowski says her study looks exclusively at legal violations rather than clerical issues.
Janssen also says that traceability is a key issue, along with the fact that many animals said to be bred in captivity are actually not.
“Even though trade is documented as captive-bred, it [can be] very unlikely that the animals have actually been bred in captivity,” Janssen says. “A snake skin, for instance … does not weigh up against the amount of money you need to spend to actually breed the animal. So it’s … much more financially interesting to catch them from the wild and then pretend like they’ve been bred in captivity.”
CITES restricts trade of certain wild species, but traders can simply claim that their skins come from captive sources, and usually get away with it, Janssen says. He adds that one of Natusch’s own studies — a 2014 report published as part of the Python Conservation Partnership, a collaboration between Kering, the ITC, and the IUCN-SSC Boa and Python Specialist Group — says that illegally collected skins are mingled with legal skins.
“It’s very easy to mix legal skins with illegal skins in the trade,” Janssen says. “Things like weak monitoring and enforcement, fraudulent source declarations and also how, for instance, stockpiling can facilitate laundering of illegal skins.”
There’s also the question of whether the reptile skin industry actually supports local communities, as Natusch and his colleagues say in their open letter. In certain parts of the world, trade does seem to have livelihood benefits. For instance, the harvesting of Nile crocodiles (Crocodylus niloticus) in Kenya’s Tana River county was said to provide 100 part-time jobs, with harvesters earning $9,162 in 2018, according to a 2019 CITES case study. But Janssen says the issue, once again, is a bit more nuanced, with some studies showing that these jobs are not only thing local people are doing to bring in income.
“I’m most familiar with the trade in skins from Southeast Asia, and there, you see that the harvesting of snakes for this sort of trade is mostly the type of activity that people do on the side,” he says. “It’s part of their livelihoods strategy, but only a small group completely depends on it.”
In general, Janssen says, supporters of the reptile skin industry tend to make trade look a little better than it is, when in reality, there are plenty of issues that need to be addressed.
‘There are many people with high influence’
P.J. Smith, the fashion policy director at the Humane Society of the United States (HSUS), says he believes that some companies and luxury brands “have been working to influence the IUCN” to keep the trade running.
“If you really want to dig into the IUCN, look at some of their stances on trophy hunting because they are very similar to the exotic skin trade where they are heavily influenced by the trophy hunting industry,” Smith tells Mongabay in an interview. “That’s something that … I wish more people knew about the IUCN.”
In 2020, an investigation by BuzzFeed News scrutinized the potential ties between the IUCN and the trophy hunting and exotic leather industries. It also suggested that numerous members of IUCN species survival groups have conflicts of interest. For instance, the article says Webb owns a large crocodile farm in Australia, and that up until two years ago, he sold skins to brands such as Louis Vuitton. Yet Webb claims in the article not to have made any profit from these sales, but that the money helped finance local conservation efforts.
The investigation also tells the story of two German herpetologists, Sabine and Thomas Vinke, who were removed from the IUCN-SSC Boa and Python Specialist Group, due, in part, to their “radical anti-use, anti-trade” position, according to a letter written by the group’s chair, Tomas Waller, that was published in the article. The Vinkes had been working to get better protection for the red tegu (Tupinambis rufescens), a species endemic to Argentina’s Gran Chaco that’s harvested for leather. They argued then, and still do now, that the species is endangered. But Sabine Vinke tells Mongabay that IUCN members ignored their data that supported the red tegu’s conservation status, and chose not to publish the IUCN assessment for the species.
“This species still counts as not assessed, and therefore it can be exploited, and Argentina does it in a huge amount,” Sabine Vinke tells Mongabay in an interview.
She adds that some members of IUCN specialist groups are stepping over the line to support the fashion industry.
“The problem is that there are many people with high influence, [who have] strong connections with [fashion brands],” she says. “The same people who make the assessment of species are receiving a lot of money for investigations [as consultants]. But of course, if you are paid by a fashion firm, you will not say, ‘Okay, fashion and exploiting the animals is a danger.’ So, it’s not very honest at the moment.”
Natusch says some members of IUCN specialist groups do act as consultants for luxury brands, and when doing this, they’re paid for their work. For example, Natusch refers to the Python Conservation Partnership, which was funded not just by the IUCN and the U.N.-affiliated ITC, but also by Kering. The scientists in the group conducted research on the python trade and published multiple reports that ultimately found the reptile trade to be both “ecologically sustainable” and to provide “socioeconomic benefits for poor households in South-East Asia.”
“If one of our members goes and does something in their professional capacity, they get paid, and that money will come from a pot that includes some United Nations money, some IUCN money, some luxury group money,” Natusch says.
Natusch himself acts as the director of a global consulting company called EPIC Biodiversity, which has the U.N., CITES, TRAFFIC, IUCN, and corporate brands like Gucci parent company Kering and Louis Vuitton parent company LVMH among its clients.
‘They can experience pain’
There are also a number of animal welfare concerns associated with the reptile skin industry, according to some experts. A 2006 PETA investigation showed workers at a crocodile farm in Vietnam that supplied reptile leather to LVMH skinning crocodiles that appeared to still be alive. Another investigation, by conservationist Karl Ammann, documented workers hitting pythons and water monitors over the heads with hammers and skinning them alive, as well as large-scale laundering efforts in Laos, Malaysia and Vietnam to pass off wild-caught species as captive-bred.
Renowned primatologist and conservationist Jane Goodall says she was “shocked and disappointed” to see that the IUCN openly opposed the reptile skin ban that big fashion houses have implemented.
“For one thing, there is plenty of evidence of zoonotic diseases spilling over from reptiles to people,” Goodall tells Mongabay in an emailed statement. “But more importantly (for me) is the fact that a good deal of research, as well as anecdotal reports, suggest that reptiles have emotions similar to those of mammals and birds. [The] IUCN is thus endorsing continued cruelty to millions of sentient beings, as well as exposing people who deal with them to a variety of diseases.”
She adds, “I, for one, lament the decision of IUCN.” (Goodall is a member of Mongabay’s advisory council.)
There are a growing number of studies that suggest reptiles are sentient beings, says Melissa Amarello, a conservation biologist and executive director of the NGO Advocates for Snake Preservation.
“On a physiological level, non-avian reptiles … have all the parts in their brain to do the same sort of thinking that other animals do,” Amarello tells Mongabay in an interview. “They can experience pain the same way that other animals do — and fear.”
A recent study found that garter snakes (Thamnophis spp.) prefer to spend time socializing with other snakes rather than being alone. There is even evidence that female snakes care not only for their own young, but also for the offspring of others, according to Amarello.
“When we look, we keep finding more complex behavior in this area,” she says.
Clifford Warwick, a biologist and medical scientist with an interest in reptile welfare, says there are considerable issues with keeping reptiles in ranches or farms. In most cases, the conditions are “bare, understimulating, often dirty, or cramped,” and handling is “at best inconsiderate and more usually nonchalant or brutal,” he says.
“To say that reptile welfare is ‘overlooked’ in skin production is nowhere near the truth,” Warwick tells Mongabay in an email. “I should say that good welfare is at best peripheral, and most commonly absent.”
Webb of the IUCN-SSC Crocodile Specialist Group tells Mongabay that most reptiles can actually be killed swiftly and humanely with a blow to the head, which renders them “brain dead” and unable to feel pain.
“They continue to move because their physiology is different, and the tissues can continue to move,” he says. “So they [animal rights activists] always film that … and make it look like everyone’s skinning them … alive. But they’re not alive — they’re completely dead.”
Yet Warwick says reptiles have “highly dynamic metabolic rates” that enable them to deal with dramatic fluctuations in oxygen levels. This means that it takes a long time for them to die when they’re decapitated, he says.
“[R]eptilian brains do not quickly die when blood pressure and blood oxygen supply is terminated,” he says. “Instead they (the head) remain conscious and alive and suffering for long periods.”
Natusch himself has acknowledged there are some animal welfare concerns in the industry. For instance, he says he once encountered a farm in Vietnam where workers were killing snakes inhumanely, but adds that he and other experts worked extensively with the group to help them improve their methods. Overall, Natusch says documented instances of animal cruelty are not representative of the entire industry, and there are still “overwhelming benefits” to the reptile skin industry, both for the animals themselves and for the people whose livelihoods depend on them.
‘The real future of the fashion industry’
The reptile skin industry may be a polarizing issue, but one thing is clear: interest in reptile leather is going down as stores clear it from their shelves. One data source shows that between 2012 and 2019, the reported import of raw skins into the U.S. dropped by 88.4%, going from $2.3 million to just over $273,000. Global trade did not experience as significant of a drop, but there was still a 1.88% decrease between 2018 and 2019, going from $301 million to $295 million, according to official data from the OEC.
While interest in reptile skin wanes, it grows for alternative materials. Companies like Pangaia are working to develop products made from natural materials such as grape leather and eucalyptus pulp and seaweed powder fiber, teaming up with department stores like Selfridge’s to sell their products. Another company, Bolt Threads, has created a natural leather product from mycelium from the roots of mushrooms, and has already developed partnerships with fashion brands such as Adidas, Kering, Lululemon and Stella McCartney.
Natusch says he worries that conservation efforts for certain species will be entirely lost if the reptile skin trade disappears. But Smith of HSUS, who has already helped seven major fashion companies phase out reptile skin, sees things differently. He says banning exotic leather is the way of the future.
“It’s fascinating to watch these big luxury companies now banning exotic skins,” Smith says. “These are huge announcements on social media, earning the [respect of the] generation that really will have the buying power in the next five years.
“I think that’s going to be the real future of the fashion industry,” he adds. “What is now considered luxury are companies that are socially responsible [and] taking a stand on social issues.”
Lambert, H., Carder, G., & D’Cruze, N. (2019). Given the cold shoulder: A review of the scientific literature for evidence of reptile sentience. Animals, 9(10), 821. doi:10.3390/ani9100821
Natusch, D., Aust, P., & Shine, R. (2021). The perils of flawed science in wildlife trade literature. Conservation Biology. doi:10.1111/cobi.13716
Natusch, D. J., & Lyons, J. A. (2014). Assessment of Python Breeding Farms Supplying the International High-end Leather Industry (50). Retrieved from IUCN website: https://portals.iucn.org/library/sites/library/files/documents/SSC-OP-050.PDF
Natusch, D. J., Lyons, J. A., Mumpuni, Riyanto, A., & Shine, R. (2019). Harvest effects on blood pythons in North Sumatra. The Journal of Wildlife Management, 84(2), 249-255. doi:10.1002/jwmg.21790
Nossal, K., Mustapha, N., Ithnin, H., Kasterine, A., Khadiejah Syed Mohd Kamil, S., Lettoof, D., & Natusch, D. J. (2016). Trade In Python Skins: Impact on Livelihoods in Malaysia. Retrieved from International Trade Centre website: https://www.intracen.org/uploadedFiles/intracenorg/Content/Publications/Trade_Impact_Python_Skin_Trade_Malaysia_Low-res.pdf
Skinner, M., & Miller, N. (2020). Aggregation and social interaction in garter snakes (Thamnophis sirtalis sirtalis). Behavioral Ecology and Sociobiology, 74(5). doi:10.1007/s00265-020-2827-0
Sosnowski, M. C., & Petrossian, G. A. (2020). Luxury fashion wildlife contraband in the USA. EcoHealth, 17(1), 94-110. doi:10.1007/s10393-020-01467-y
UNODC. (2016). World Wildlife Crime Report: Trafficking in protected species. Retrieved from UNODC website: https://www.unodc.org/documents/data-and-analysis/wildlife/World_Wildlife_Crime_Report_2016_final.pdf
Vinke, T., & Vinke, S. (2019). Decline in the population of the red Tegu, Salvator rufescens (Gunther, 1871): Preliminary results of a threats analysis. Russian Journal of Herpetology, 26(3), 123. doi:10.30906/1026-2296-2019-26-3-123-134
World Animal Protection. (2020). Suffering in Silence: Uncovering the cruelty of the global trade in Ball pythons. Retrieved from World Animal Protection website: https://dkt6rvnu67rqj.cloudfront.net/cdn/ff/gR-Lap0GcsjrvRBi6U6Cw1BUOjbH-50UJVmqMmsn3Ic/1584727547/public/media/Ballpythonreport-march20.pdf
Banner image caption: Alligators grouped according to age in small pools of shallow water at a facility in Louisiana in 2011. Image by Jo-Anne McArthur / We Animals.
Elizabeth Claire Alberts is a staff writer for Mongabay. Follow her on Twitter @ECAlberts.
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