Walsh,
J:—This
action
was
joined
for
hearing
on
common
evidence
with
that
bearing
No
T-5911-79
Paul
H
Serson
v
Her
Majesty
The
Queen,
the
only
difference
between
the
two
being
the
amounts
involved.
Doctor
Dauphinee
received
$5,336.32
in
1976
in
relation
to
six
inventions,
declared
none
of
this
for
income,
considering
it
as
capital
gain
so
that
whatever
the
outcome
of
the
appeal
one-half
should
in
any
event
have
been
included
in
his
taxable
income.
Doctor
Serson
for
his
part
received
the
sum
of
$2,591.83
in
1976
which
also
resulted
from
a
payment
made
pursuant
to
the
Public
Servants
Inventions
Act"
and
regulations
thereunder,
and
included
one-half
of
it
in
his
return
as
a
capital
gain
but
the
Minister
contends
the
entire
amount
Should
have
been
included.
Except
for
the
amounts
in
question
the
facts
are
identical
and
the
legal
issues
to
be
decided
are
the
same.
The
aforementioned
Public
Servants
Inventions
Act
provides
in
section
3
as
follows:
The
following
inventions,
and
all
rights
with
respect
thereto
in
Canada
or
elsewhere,
are
vested
in
Her
Majesty
in
right
of
Canada,
namely,
(a)
an
invention
made
by
a
public
servant
(i)
while
acting
within
the
scope
of
his
duties
or
employment,
or
(ii)
with
facilities,
equipment
or
financial
aid
provided
by
or
on
behalf
of
Her
Majesty,
and
(b)
an
invention
made
by
a
public
servant
that
resulted
from
or
is
connected
with
his
duties
or
employment.
Section
9
provides
that
the
administration
and
control
of
any
invention
so
vested
in
Her
Majesty
is
vested
in
the
appropriate
Minister
who
may
transfer
such
administration
and
control
to
any
other
Minister
or
to
any
corporate
agency
of
Her
Majesty—in
this
case
the
Canadian
Patents
and
Development
Limited.
Section
10
reads
as
follows:
Subject
to
the
regulations,
the
appropriate
Minister
may
authorize
the
payment
of
an
award
to
a
public
servant
who
makes
an
invention
that
is
vested
in
Her
Majesty
by
this
Act,
in
such
amount
as
the
appropriate
Minister
and
the
public
servant
may
agree
upon
or
as
the
appropriate
Minister
determines.
Paragraph
12(c)
provides:
The
Governor
in
Council
may
make
regulations
for
carrying
out
the
purposes
and
provisions
of
this
Act,
and
without
restricting
the
generality
of
the
foregoing,
may
make
regulations.
(c)
prescribing
the
amount
of
and
the
method
of
calculating
and
determining
the
awards
to
be
paid
under
this
Act
and
the
manner
and
time
of
payment.
The
Public
Servants
Inventions
Regulations,
SOR/73-104
February
28,
1973,
provides
in
subsection
13(2)
as
follows:
(2)
Where
any
money
is
received
by
Her
Majesty
upon
the
sale,
licence
or
other
disposal
of
an
invention
vested
in
Her
Majesty
by
the
Act,
an
award
or
awards
may
be
paid
to
the
inventor,
based
on
the
total
amount
from
time
to
time
so
received,
but
such
award
or
awards
shall
not
in
the
aggregate
exceed
fifteen
per
cent
of
the
amount
so
received.
It
is
by
virtue
of
these
sections
of
the
Act
and
Regulations
that
the
payments
were
made
to
the
plaintiff.
The
statements
of
claim
set
out
the
allegations
on
the
basis
of
which
it
is
contended
that
the
amounts
received
should
not
be
treated
as
income
received.
The
statement
of
claim
of
Doctor
Dauphinee,
after
referring
to
the
amount
received
by
virtue
of
the
Public
Servants
Inventions
Act
in
1976,
and
pointing
out
that
that
legislation
gives
the
Minister
a
discretionary
right
to
make
payments
to
persons
for
inventions
taken
by
the
Crown
states
in
Paragraph
4:
The
award
related
to
six
general
inventions,
but
especially
one
which
was
a
liquid
conductivity
apparatus
known
as
a
laboratory
salinometer,
used
for
measuring
temperature
electrical
conductivity
in
the
depths
of
the
world’s
oceans.
Paragraphs
6
to
10
of
the
statement
of
claim
read
as
follows:
6.
The
taxpayer
is
director
of
the
Heat
and
Thermatology
Section
of
the
National
Research
Council.
The
taxpayer
is
a
research
officer
for
the
employer
in
the
sense
of
carrying
out
physical
measurements,
and
designing
experimental
projects
for
the
purpose
of
answering
specific
measurement
questions
posed
by
the
employer.
The
taxpayer
is
expected
to
carry
out
these
measurements
using
known
technology,
and
is
not
expected
to
perform
general
or
theoretical
research.
The
taxpayer
also
is
required
to
maintain
measurement
standards
for
Canada,
and
to
perform
general
administrative
duties.
7.
It
is
not
within
the
scope
of
the
taxpayer’s
duties
of
employment
to
the
employer
to
“invent”.
8.
Once
an
invention
has
been
made
by
the
taxpayer,
taxpayer
generally
utilizes
the
facilities
and
equipment
of
the
employer
to
test
his
inventions.
9.
Any
payment
to
the
taxpayer
by
Canadian
Patents
and
Development
Limited
is
discretionary.
The
crown
agency
acts
on
instructions
from
the
Minister
of
the
department
holding
the
invention
patent,
who
authorizes
the
payments
to
the
taxpayer.
10.
An
invention
is
recognized
in
law
to
be
a
property
right,
and
any
taking,
vesting,
or
other
dealing
with
such
property
right
may
be
compensated
by
payments
to
the
inventor,
in
appropriate
circumstances.
In
the
case
of
Serson
who
was
employed
by
the
Department
of
Energy
Mines
and
Resources
identical
allegations
are
made.
Although
the
evidence
before
the
Tax
Review
Board
was
by
agreement
made
part
of
the
record
and
portions
of
the
transcript
of
the
evidence
of
Walter
Gordon,
Secretary
of
Canadian
Patents
and
Development
Limited,
a
Crown
corporation
was
referred
to,
Dr
Dauphinee
also
testified
in
Court
that
he
is
a
physicist
working
for
the
National
Research
Council
and
a
principal
research
officer.
He
has
made
about
15
inventions
all
of
which
he
admits
come
under
the
Act.
The
payment
of
$5,336.32
received
in
1976
related
to
royalties
received
in
that
year
by
the
Canadian
Patents
and
Development
Limited
for
six
of
his
inventions
and
he
concedes
that
he
received
similar
payments
in
subsequent
years
based
on
15%
of
the
royalties
earned
by
these
inventions
which
amount
was
awarded
to
him
pursuant
to
the
Act
and
Regulations.
He
was
head
of
the
Heat
and
Thermometries
Section
and
his
expertise
is
in
physical
measurements
and
more
recently
in
connection
with
oceanography
such
as
measurements
of
salinity
of
water
at
substantial
depths.
All
his
inventions
related
in
a
general
way
to
this
work.
He
stated
that
sometimes
equipment
and
design
can
be
based
on
known
technology
and
on
occasion
it
is
necessary
to
develop
new
equipment.
He
conceded
that
it
is
part
of
his
job
function
to
put
together
a
system
which
will
work
by
deciding
what
equipment
to
use
to
solve
problems
submitted.
Inventions
do
not
always
arise
as
the
result
of
a
specific
inquiry
however
but
have
been
made
in
some
cases
because
he
became
aware
of
a
need
and
devised
something
to
be
used
when
it
occurred.
In
most
cases
only
he
himself
and
a
technician
were
involved
in
developing
the
equipment.
He
described
the
process
of
his
inventions
as
Stating
that
normally
he
gets
an
idea,
becomes
interested
in
it
and
works
on
it
himself,
frequently
in
his
spare
time.
It
is
only
after
the
idea
has
come
to
him,
as
he
stated
suddenly,
that
he
brings
in
his
assistants
to
prove
and
develop
or
confirm
the
idea,
which
may
eventually
be
abandoned.
He
stated
that
it
is
not
part
of
his
duties
with
the
National
Research
Council
to
invent
and
that
many
scientists
there
never
do
so.
The
fact
is
that
many
of
his
ideas
occur
to
him
when
at
home,
perhaps
lying
in
bed,
when
there
is
no
interruption
of
his
mental
process
by
daily
work
requirements.
He
described
some
of
his
inventions
such
as
a
potentiometer,
in
which
he
got
the
idea
that
by
merely
exchanging
and
rearranging
the
positions
of
the
second
and
third
dials
on
a
commercial
potentiometer
readily
available
he
was
able
to
get
an
instrument
which
would
give
readings
in
five
or
six
figures
instead
of
three.
He
is
now
working
on
barometers,
the
existing
instruments
not
being
stable
enough
for
reliable
use
on
ocean
buoys.
It
occurred
to
him
that
by
adapting
a
vapour
pressure
thermometer
operated
on
low
current,
since
vapour
pressure
at
constant
temperature
is
fixed,
he
could
then
relate
these
readings
to
barometric
pressure.
He
is
now
working
on
an
idea
to
make
ocean
buoys
right
themselves,
as
some
of
them
turn
upside
down
becoming
invisible
to
radar
and
a
danger
to
navigation.
He
was
aware
when
he
commenced
working
for
the
National
Research
Council
in
1945
that
any
inventions
he
made
during
the
course
of
such
employment
would
be
vested
in
the
Crown
and
that
he
would
be
likely
to
get
some
compensation
for
them.
This
was
not
the
motivation
of
his
inventions.
He
admits
that
some
of
his
inventions
are
a
spin-off
from
his
work
in
connection
with
con-
ductivity
of
sea
water.
He
designed
a
thermometer
using
an
electrical
patent
which
he
already
has
for
use
in
place
of
a
liquid
thermometer.
Salinity
can
be
measured
since
if
the
pressure
and
temperature
are
known
conductivity
of
sea
water
can
be
measured
electrically.
He
devised
a
continuous
flow
system
and
his
salinometer
is
now
used
throughout
the
world.
He
conceded
that
it
is
extremely
difficult
to
draw
a
line
between
practical
development
and
the
idea
itself.
He
stated
that
flashes
of
insight
can
occur
at
any
time.
It
is
of
some
interest
to
note
what
exactly
constitutes
an
invention,
although
that
is
not
the
issue
in
the
present
case,
since
the
mere
fact
that
patents
were
obtained
indicates
that
Doctor
Dauphinee’s
ideas
were
inventions.
Fox
in
Canadian
Patent
Law
and
Practice,
Fourth
Edition
at
page
62
States:
It
involves
nothing
more
or
less
than
an
individual
decision
of
mind,
influenced
by
the
knowledge,
experience,
training,
education,
perceptions,
emotions
and
prejudices
of
the
individual
who
is
called
upon
to
decide
whether
invention
does
or
does
not
exist.
and
Black's
Law
Dictionary,
4th
Edition
defines
it
inter
alia
as—
the
process
of
contriving
and
producing
something
not
previously
known
or
existing,
by
the
exercise
of
independent
investigation
and
experiment.
Mr
Gordon
in
his
evidence
before
the
Tax
Review
Board
merely
explained
the
method
of
calculation.
The
Ministry
is
advised
by
Canadian
Patents
and
Development
Limited
of
the
amounts
of
revenue
received
during
the
year
and
that
15%
may
be
paid
to
inventors
and
the
Minister
authorizes
the
payment.
It
is
the
Minister
for
whom
the
inventor
works
who
has
to
authorize
the
payment
and
on
occasion
the
Minister
has
failed
to
so
authorize.
The
payment
and
amount
thereof
up
to
15%
is
discretionary,
the
employee
making
the
invention
having
no
right
to
it.
It
is
paid
out
of
receipts
received
by
Canadian
Patents
and
Development
Limited
for
the
use
of
patents
by
others.
Sections
of
the
Income
Tax
Act
in
question
are
as
follows:
5.(1)
Subject
to
this
Part,
a
taxpayers’
income
for
a
taxation
year
from
an
office
or
employment
is
the
salary,
wages
and
other
remuneration,
including
gratuities,
received
by
him
in
the
year.
6.
(1)
There
shall
be
included
in
computing
the
income
of
a
taxpayer
for
a
taxation
year
as
income
from
an
office
or
employment
such
of
the
following
amounts
as
are
applicable:
(a)
the
value
of
board,
lodging
and
other
benefits
of
any
kind
whatever
(except
the
benefit
he
derives
from
his
employer’s
contributions
to
or
under
a
registered
fund
or
plan,
group
sickness
or
accident
insurance
plan,
private
health
services
plan,
supplementary
unemployment
benefit
plan,
deferred
profit
sharing
plan
or
group
term
life
insurance
policy)
received
or
enjoyed
by
him
in
the
year
in
respect
of,
in
the
course,
of
or
by
virtue
of
an
office
or
employment.
Defendants
rely
heavily
on
the
case
of
MNR
v
Laurent
Gagnon,
[1965]
CTC
423;
65
DTC
5268,
in
which
an
employee
of
the
Dominion
Bureau
of
Statistics
was
awarded
a
sum
for
a
suggestion
that
was
estimated
to
save
another
department
of
the
Government
a
substantial
amount.
The
award
was
made
by
virtue
of
the
Suggestion
Award
Plan
of
the
Public
Service
of
Canada
which
provided
that
no
award
could
be
given
for
a
suggestion
arising
from
the
day
to
day
duties
for
which
the
employee
was
paid
or
for
a
suggestion
from
an
employee
whose
normal
duties
included
the
making
of
suggestions.
It
was
contended
by
the
appellant
however
that
the
suggestion
for
which
the
award
was
not
the
result
of
his
daily
work.
Jackett,
P,
as
he
then
was,
pointed
out
that
the
Suggestion
Award
Plan
regulations
permitted
the
payments
to
be
made
“notwithstanding
the
Civil
Servant
Act”.
He
points
out
that
the
character
of
the
award
is
determined
by
the
terms
of
the
statute
by
which
it
is
offered
and
concludes
at
425
[5270]:
...
In
my
view
also,
the
creation,
and
formulation
in
usable
form,
of
a
suggestion
for
the
improvement
in
business
or
governmental
operations,
is
a
service
of
the
kind
that
an
employer
may
obtain
either
from
officers
of
servants
or
from
independent
contractors
(eg
accountants,
efficiency
experts,
etc).
It
follows
that,
in
my
view,
a
payment
for
a
suggestion
is
a
payment
for
a
service.
While
there
may
be
exceptions,
I
am
of
opinion
that
a
payment
for
a
service
is
ordinarily
“income’’
from
one
of
the
recipient’s
“sources’’
within
the
meaning
of
those
words
in
section
3
of
the
Income
Tax
Act
whether
the
recipient
receives
the
payment
as
an
employee,
as
a
person
who
operates
a
business
of
supplying
services
or
as
a
person
who
has
performed
a
service
on
an
isolated
occasion.
Compare
the
judgment
of
Noel,
J
in
Steer
v
MNR,
[65
DTC
5155].
Whether
or
not
that
view
is
too
wide,
there
is
no
doubt
in
my
mind
that
awards
under
the
Suggestion
Award
Plan
Regulations
are
income
from
an
employment
and
fall
within
section
5
of
the
Income
Tax
Act
because
they
are
payable
to
employees
of
the
Government
of
Canada
for
services
performed
for
that
Government.
It
is
immaterial,
in
my
view,
that
the
particular
services
are
not
performed
in
the
course
of
the
execution
of
the
normal
duties
of
their
positions.
Parliament
has
expressly
authorized
awards
as
extra
reward
or
compensation
to
be
paid
to
public
servants
for
services
performed
in
addition
to
their
normal
duties.
Such
awards
are,
in
my
view,
clearly
within
the
words
“other
remuneration’’
in
the
introductory
words
of
subsection
(1)
of
section
5.
Plaintiff
contends
that
this
case
should
be
distinguished
however
as
it
dealt
with
a
mere
suggestion
resulting
in
an
award
to
be
paid
out
of
the
Financial
Administration
Act,
which
it
was
contended
is
a
quite
different
payment
from
a
portion
of
royalties
received
from
sources
outside
the
Government
for
the
use
of
an
invention
by
a
Government
employee
compulsorily
taken
from
him,
in
a
sense,
as
a
result
of
his
employment
by
virtue
of
the
provisions
of
the
Public
Servants
Inventions
Act.
Plaintiffs
rely
on
the
Tax
Appeal
Board
case
of
Arthur
Mansfield
v
MNR,
28
Tax
ABC
404;
62
DTC
134,
as
being
directly
in
point.
The
appellant
in
the
employ
of
the
Department
of
National
Defence
invented
a
piece
of
mine
sweeping
equipment,
largely
on
his
own
time,
as
a
result
of
which
an
award
was
made
to
him
for
his
invention.
It
had
been
determined
by
the
Department
of
National
Defence
however
in
that
case
that
his
invention
did
not
come
within
the
scope
of
his
duties
of
employment.
It
has
held
that
the
amount
received
was
a
payment
to
him
in
respect
of
the
compulsory
transfer
to
the
Crown
of
his
rights
to
his
invention
and,
as
such,
constituted
a
non-taxable
capital
receipt.
It
was
not
a
gratuity
nor
could
it
be
considered
as
coming
within
the
description
of
“other
benefits
of
any
kind
whatever
.
.
.
received
.
.
.
in
the
course
of
his
employment
as
used
in
what
is
now
subsection
6(1)
(supra),
as
these
words
have
to
be
read
ejusdem
generis
with
the
preceding
words
and
form
part
of
the
phrase
“the
value
of
board,
lodging
and
other
benefits
of
any
kind
whatever”
and
merely
indicate
the
receipt
of
some
benefit
in
a
form
other
than
cash.
While
there
is
considerable
force
to
this
argument
it
must
be
pointed
out
that
this
judgment
was
rendered
before
that
of
the
Exchequer
Court
in
the
case
of
MNR
v
Laurent
Gagnon
(supra).
Furthermore
in
subsequent
cases,
including
the
Tax
Review
Board
decision
in
the
present
case
the
judgment
in
the
Mansfield
case
has
not
been
followed,
although
most
of
the
judgments
to
which
the
Court
was
referred
refer
to
merit
awards,
which
is
an
entirely
different
matter.
Grant,
DJ
for
example,
in
Her
Majesty
The
Queen
v
Elizabeth
Joan
Savage,
[1980]
CTC
103;
80
DTC
6066,
decided
that
an
amount
of
$300
awarded
to
a
defendant
by
her
employer
in
recognition
of
her
success
in
a
Life
Office
Management
Association
ex-
amination
was
an
award
by
the
employer
because
she
had
improved
her
knowledge
and
efficiency
in
her
field
of
employment
and
that
is
must
be
considered
as
having
been
received
“in
respect
of,
in
the
course
of,
or
by
virtue
of,
her
employment”.
It
is
true
that
the
facts
are
substantially
dissimilar
from
the
present
case,
in
that
the
amount
received
by
plaintiffs
had
nothing
to
do
with
awards
for
courses
they
had
taken
to
improve
their
knowledge.
It
is
of
some
interest
to
note
that
in
the
Tax
Review
Board
case
of
George
W
Offley
v
MNR,
[1974]
CTC
2139;
74
DTC
1101,
a
decision
rendered
after
the
Gagnon
case,
although
no
reference
to
it
is
made
therein,
an
award
of
$1,500
given
to
a
member
of
the
Royal
Canadian
Mounted
Police
under
the
federal
Merit
Award
Programme
in
recognition
of
services
he
had
rendered
in
assisting
in
the
drafting
of
a
revised
statute
in
the
Province
of
Alberta
concerning
the
Livestock
Inspection
Act
was
held
to
be
taxable
as
income.
The
decision
was
based
on
the
fact
that
the
award
had
been
won
by
him
while
employed
as
an
RCMP
officer
and,
while
it
had
no
direct
connection
with
his
official
duties,
his
special
efforts
reflected
favourably
on
the
corps
to
which
he
belonged
and
that
it
fell
clearly
within
the
concept
of
“benefits
of
any
kind
whatsoever”
found
in
what
was
then
paragraph
5(1)(a)
of
the
Act
which
was
substantially
similar
to
the
present
paragraph
6(1)(a)
(supra).
In
the
Gagnon
judgment
the
learned
President
found
that
the
award
came
within
the
words
“other
remuneration”
the
introductory
words
of
subsection
(1)
of
section
5
and
hence
it
was
not
necessary
for
him
to
consider
the
application
of
paragraph
(a)
of
subsection
(1)
of
section
5
(now
6(1)(a)).
While
it
might
perhaps
still
be
open
to
argument
whether
an
invention
made
by
an
inventor
in
the
employ
of
a
Government
department
made
entirely
outside
the
scope
of
his
employment,
and
in
no
way
related
to
it
would
remain
his
property
and
not
be
subject
to
vesting
in
the
Crown
pursuant
to
the
provisions
of
the
Public
Servants
Inventions
Act,
that
is
not
the
case
here,
nor
do
plaintiffs
so
contend.
In
such
an
event
royalties
received
from
it
would
enter
into
his
taxable
income
but
if
he
disposed
of
it
to
a
third
party
or
to
the
Crown
and
it
was
a
one
time
invention
not
made
by
him
as
a
professional
inventor
the
proceeds
of
the
sale
might
well
be
treated
as
a
capital
receipt.
That
is
clearly
not
the
case
here
however
so
this
question
does
not
have
to
be
dealt
with,
nor
does
the
fact
that
plaintiffs
had
no
option
but
to
vest
inventions
with
which
we
are
dealing
here
in
the
Crown
and
had
no
right
to
demand
any
compensation
for
so
doing,
which
compensation
is
entirely
discretionary,
alter
the
situation.
It
was
simply
a
condition
of
their
employment
of
which
they
were
well
aware.
It
is
not
even
suggested
that
the
inventions
in
issue
in
the
present
cases
did
not
vest
in
the
Crown
and
eventually
in
Canadian
Patents
and
Development
Limited,
and
the
words
of
section
3
of
the
Public
Servants
Inventions
Act
(supra)
are
very
broad
so
that
even
if
they
did
not
come
within
subparagraph
(a)
as
having
been
made
“within
the
scope
of
his
duties
or
employment”,
nor
“with
facilities,
equipment
or
financial
aid
provided
by
Her
Majesty”
since,
as
Doctor
Dauphinee
contended
the
invention
or
idea
came
first
and
the
testing
and
development
of
it
with
facilities
or
equipment
of
Her
Majesty
only
follows,
they
clearly
come
within
paragraph
(b)
as
they
“resulted
from
or
were
connected
with
his
duties
or
employment”.
Similarly
the
wording
of
the
sections
of
the
Income
Tax
Act
in
question
are
very
comprehensive.
Even
if
the
argument
is
accepted
that
these
payments
do
not
constitute
“benefits
of
any
kind
whatever”
pursuant
to
paragraph
6(1)(a)
of
the
Act
on
a
strict
interpretation
of
that
section
by
the
ejusdem
generis
rule
as
“benefits
of
any
kind’’
similar
to
board
or
lodging,
which
may
well
be
a
valid
argument,
it
nevertheless
appears
that
they
do
come
within
the
words
“other
remuneration’’
in
subsection
5(1)
as
Jackett,
P
found
in
the
Gagnon
case.
While
there
is
certainly
a
distinction
between
bonus
or
incentive
awards
paid
out
of
the
Financial
Administration
Act
under
the
Suggestion
Award
Plan
or
federal
Merit
Award
Programme
and
the
partial
payment
to
the
inventor
of
royalties
received
from
a
third
party
arising
from
inventions
compulsorily
transferred
to
Her
Majesty
by
virtue
of
the
Public
Servants
Inventions
Act
I
do
not
find
that
this
can
affect
the
taxability
of
the
said
amounts
as
income.
While
it
may
seem
unfair
to
award
the
inventors
by
sharing
a
comparatively
small
proportion
of
the
royalties
received
from
third
parties
for
the
use
of
these
inventions
with
them
only
to
have
the
Minister
of
National
Revenue
then
take
back
a
substantial
amount
of
the
payments
so
made
as
taxable
income,
this
is
a
question
of
policy
for
Parliament
to
decide.
If
it
were
desired
that
the
amounts
so
paid
should
be
treated
as
capital
gain
by
the
inventor
it
would
be
a
simple
matter
to
amend
the
Income
Tax
Act
to
so
state,
but
this
has
not
been
done,
and
it
must
therefore
be
deemed
that
it
was
intended
that
the
amounts
so
received
would
be
treated
as
taxable
income
in
the
same
manner
as
regular
remuneration
received
by
the
inventors
in
the
course
of
their
employment.
For
the
above
reasons
the
appeal
must
therefore
be
dismissed
with
costs
if
so
demanded
by
defendant
but
since
the
two
actions
were
joined
for
hearing
and
the
issues
raised
were
identical
only
one
set
of
costs
will
be
allowed.
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