AuthorTitleCitationSummaryYearKey Terms
Sarah M. Manchak , Jennifer L. Skeem, Karen S. Rook , University of Cincinnati School of Criminal Justice, University of California, Irvine Care, Control, or Both? Characterizing Major Dimensions of the Mandated Treatment Relationship 38 Law and Human Behavior 47 (2014) Current conceptualizations of the therapeutic alliance may not capture key features of therapeutic relationships in mandated treatment, which may extend beyond care (i.e., bond and affiliation) to include control (i.e., behavioral monitoring and influence). This study is designed to determine whether mandated treatment relationships involve greater... 2014  
Karen Zivi Chapter 9 the Practice and the Promise of Making Rights Claims: Lessons from the South African Treatment Access Campaign 29 IUS Gentium 173 (2014) What does the new South Africa tell us about the state of African legal theory in the twenty-first century? Is this post-apartheid nation a political miracle? Is it evidence of the triumph of the human spirit and a revolution in law and practice? Is it a model to be followed by other African nations? For those who focus on the fact that South... 2014  
  China Guidance on Cross-border Reorganizations Subject to Special Tax Treatment 25 Journal of International Taxation 11 (April, 2014) On December 12, 2013, China's State Administration of Taxation (SAT) released Announcement [2013] No. 72, which provides additional guidance and clarification on cross-border reorganization transactions subject to special tax treatment, i.e., deferral of capital gains tax. It also clarifies cross-border share transfer transactions of a Chinese... 2014  
Won Kidane, Weidong Zhu China-africa Investment Treaties: Old Rules, New Challenges 37 Fordham International Law Journal 1035 (May, 2014) INTRODUCTION. 1036 I. CHINESE AND AFRICAN CONCEPTIONS OF THE ORDERING OF ECONOMIC AFFAIRS BY LAW. 1041 A. The Conception of Law and Legal Obligations in China. 1041 B. The Conceptions of Law and Legal Obligations in Africa. 1043 C. The Ordering of China-Africa Economic Relations by Law: Contemporary Efforts. 1045 II. THE DOCTRINAL FOUNDATION AND... 2014  
John King Gamble , Lauren Kolb, Casey Graml Choice of Official Text in Multilateral Treaties: the Interplay of Law, Politics, Language, Pragmatism and (Multi)-nationalism 12 Santa Clara Journal of International Law 29 (2014) I. Introduction. 31 II. The Legal, Political and Historical Contexts of Language. 36 III. Language Behavior as Seen Through the CSDMT. 43 IV. Summary and Prognostications. 52 This article examines all multilateral treaties signed from 1500 until 2000 (more than 6,000) in order to analyze trends and patterns in choice of official texts (languages).... 2014  
Michalyn Steele Comparative Institutional Competency and Sovereignty in Indian Affairs 85 University of Colorado Law Review 759 (Summer 2014) While vigorous debate surrounds the proper scope and ambit of inherent tribal authority, there remains a critical antecedent question: whether Congress or the courts are ultimately best situated to define the contours of inherent tribal authority. In February 2013, Congress enacted controversial tribal jurisdiction provisions as part of the... 2014 Yes
Jean Galbraith Congress's Treaty-implementing Power in Historical Practice 56 William and Mary Law Review 59 (October, 2014) Historical practice strongly influences constitutional interpretation in foreign relations law, including most questions relating to the treaty power. Yet it is strikingly absent from the present debate over whether Congress can pass legislation implementing U.S. treaties under the Necessary and Proper Clause. Drawing on previously unexplored... 2014  
Sarah Longhofer Contracting Away Sovereignty: the Case of Brazil, Fifa, and the Agreement for the Right to Host the 2014 World Cup 23 Transnational Law & Contemporary Problems 147 (Spring 2014) I. Introduction. 147 II. Factual Background: The Hosting Agreement in Context. 149 A. The Fédération Internationale de Football Association. 149 B. Brazil. 151 C. The World Cup. 152 III. Analysis of the Hosting Agreement. 155 A. Formation of the Agreement. 155 B. Structure of the Agreement. 157 C. Impact of the Agreement - Current Controversies.... 2014  
Ashley R. Fiest Defining the Wingspan of the Migratory Bird Treaty Act 47 Akron Law Review 587 (2014) I. Introduction. 587 II. Background of the MBTA. 589 A. Early History of Bird Conservation. 590 B. The MBTA as the Solution. 591 III. The Problem. 594 A. Conflict Among the Courts. 594 B. Two Cases with Two Different Interpretations. 596 IV. Solving the MBTA Issue. 599 A. Interpretation of the MBTA. 599 1. Strict Liability. 600 2. Incidental... 2014  
Ronald Turner Disparate Treatment: Justice Clarence Thomas's Conspicuously Nonoriginalist Affirmative Action Jurisprudence 19 Texas Journal on Civil Liberties & Civil Rights 251 (Spring, 2014) I. Introduction and Overview. 251 II. The Moral and Constitutional Equivalence Argument. 256 III. The Stigma Argument. 267 IV. Invoking Icons. 273 V. Conclusion: Clarence Thomas and Justice Clarence Thomas. 280 2014  
Edward N. Krakauer Divergent Paths, Similar Results: How African Asylum Seekers Have Been Failed in Both Israel and Malta Despite Varying Procedures and Treatment 21 University of Miami International and Comparative Law Review 265 (Spring, 2014) I. The Troubles in Eritrea, Sudan, and Somalia. 267 II. The Relevant Provisions of the United Nations Convention and Protocol Relating to the Status of Refugees. 271 III. The History of Refugees in Israel. 273 IV. The Present Status of Refugees in Israel. 279 V. Overturning of Amendment No. 3 to the PreBvention of Infiltration Law. 282 VI.... 2014  
Adam J. Adler Dual Sovereignty, Due Process, and Duplicative Punishment: a New Solution to an Old Problem 124 Yale Law Journal 448 (November, 2014) The Double Jeopardy Clause prohibits the government from prosecuting or punishing a defendant multiple times for the same offense. Double jeopardy protections, however, come with a major exception. Under the dual sovereignty doctrine, different sovereign states can prosecute a defendant multiple times for the same offense. This Note argues that the... 2014  
Michael H. Davis Excluding Patentability of Therapeutic Methods, Including Methods Using Pharmaceuticals, for the Treatment of Humans under Trade Related Aspects of Intellectual Property Rights Article 27(3)(A) 43 Hofstra Law Review 185 (Fall, 2014) The Agreement on Trade Related Aspects of Intellectual Property Rights (TRIPS), the General Agreement on Tariffs and Trade (GATT), and the World Trade Organization (WTO) debacle has radically altered the traditional ability of nations to adopt whatever patent regime seems appropriate to them. Instead, TRIPS requires all member nations, even... 2014  
  Federal Indian Law--Tribal Sovereign Immunity-- Michigan v. Bay Mills Indian Community 128 Harvard Law Review 301 (November, 2014) Courts have long held that Native American governments enjoy tribal sovereign immunity from suit, subject only to Congress's plenary authority. Sixteen years ago, in Kiowa Tribe of Oklahoma v. Manufacturing Technologies, Inc., the Supreme Court affirmed that tribes retain sovereign immunity when engaged in off-reservation commercial activity.... 2014 Yes
Curtis A. Bradley, Of the Board of Editors Federalism, Treaty Implementation, and Political Process: Bond v. United States 108 American Journal of International Law 486 (July, 2014) In Bond v. United States, the U.S. Supreme Court disallowed the prosecution of a domestic poisoning case under legislation that implements the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction. In doing so, a majority of the Court declined to address constitutional issues... 2014  
Eteena J. Tadjiogueu Fifty Shades of Black: Challenging the Monolithic Treatment of "Black or African American" Candidates on Law School Admissions Applications 44 Washington University Journal of Law & Policy 133 (2014) Law school applicants who identify as Black or African American are afforded little opportunity to identify more specifically their ancestral or cultural heritage, if it is known, on law school admissions applications. Seemingly, some law schools have not found it necessary to allow certain groups, such as Haitian Americans, Black Britons,... 2014  
Y. Frank Ren Fixing Fourteenth Amendment Enforcement Power: an Argument for a Rebuttable Presumption in Favor of Congressional Abrogation of State Sovereign Immunity 94 Boston University Law Review 1459 (July, 2014) Introduction. 1459 I. The Congruence and Proportionality Test. 1461 A. The Scope of Congress's Fourteenth Amendment Enforcement Power. 1462 B. The Tiers of Scrutiny and Their Effect on Congruence and Proportionality. 1464 C. The Relationship Between State Sovereign Immunity and Congruence and Proportionality. 1468 II. The Pitfalls of the Congruence... 2014  
Nora Y.S. Ali For Better or for Worse? The Forced Marriage of Sovereignty and Self-determination 47 Cornell International Law Journal 417 (Spring 2014) Introduction. 417 I. The Struggle for Independence in Somaliland. 420 A. Creation of Greater Somalia . 420 B. Collapse of Somalia and Rise of Somaliland. 423 II. Sovereignty. 424 A. Origins of Sovereignty. 424 B. Modern Approach to Sovereignty in Globalized World. 425 III. Right to Self-Determination. 426 A. Development of the Right to... 2014  
James Blacksher , Lani Guinier Free at Last: Rejecting Equal Sovereignty and Restoring the Constitutional Right to Vote Shelby County v. Holder 8 Harvard Law & Policy Review 39 (Winter 2014) The Supreme Court's decision in Shelby County v. Holder revitalizes the oldest and most demeaning official insult to African Americans in American constitutional history. Written by Chief Justice Roberts, the majority opinion relies on an unwritten principle that Roberts calls states' equal sovereignty to justify the Court's decision to topple a... 2014  
Jonathan Guss Gaming Sovereignty? A Plea for Protecting Worker's Rights While Preserving Tribal Sovereignty 102 California Law Review 1623 (December, 2014) Tribally owned gaming facilities have become an increasingly popular vehicle for economic development throughout Indian Country. As an incidental consequence of this industry's growth, many non-tribal members now come into contact with tribal-gaming enterprises as either customers or employees. Consequently, tribal gaming establishments have become... 2014 Yes
Oliver T. Gilbert Global Analytical Lessons for Evaluating a Myanmar Sovereign Wealth Fund 23 Pacific Rim Law & Policy Journal 579 (June, 2014) Abstract: After decades of international condemnation, Myanmar, also known as Burma, has initiated rapid political, economic, and legal reforms. In recognition of these reforms, Western governments have broadly curtailed longstanding sanctions against investing in Myanmar. This sudden opportunity for foreign companies to extract Myanmar's plentiful... 2014  
Ann Woolhandler Governmental Sovereignty Actions 23 William & Mary Bill of Rights Journal 209 (October, 2014) In Arizona v. United States, the federal government sued to enjoin enforcement of Arizona's immigration laws on preemption grounds. And in Virginia ex rel. Cuccinelli v. Sebelius, the state attorney general argued that the state had standing to challenge the Affordable Care Act because it would unconstitutionally preempt a state law disallowing... 2014  
Matthew Steffes Implications for the Mille Lacs Lake Fishery with Continued Enforcement of the 1837 Treaty of St. Peters 35 Hamline Journal of Public Law and Policy 367 (Spring, 2014) Mille Lacs Lake, which spans three counties in central Minnesota, has a long tradition of being one of the best lakes in Minnesota for catching walleye. Mille Lacs Lake has gained national recognition for being a fishing destination for the large quantity and size of walleye the lake produces. Yet recent reports from the Minnesota Department of... 2014  
Ryan Seelau In Defense of Tribal Sovereign Immunity: a Pragmatic Look at the Doctrine as a Tool for Strengthening Tribal Courts 90 North Dakota Law Review 121 (2014) Although the doctrine of tribal sovereign immunity was recently upheld by the Supreme Court in Michigan v. Bay Mills Indian Community, its existence continues to be attacked as antiquated and leading to unfair results. While most defenses of tribal sovereign immunity focus on how the doctrine is a necessary part of sovereignty or how the... 2014 Yes
Dan Sarooshi Investment Treaty Arbitration and the World Trade Organization: What Role for Systemic Values in the Resolution of International Economic Disputes? 49 Texas International Law Journal 445 (Summer 2014) Introduction. 445 I. Systemic Values in the WTO. 446 II. Dispute Settlement and National Regulations Relating to the Environment. 450 III. The Applicable Law Used to Resolve Disputes. 454 IV. The Issue of Remedies Before ICSID Tribunals and the WTO. 460 V. The Issue of Amicus Curiae Submissions. 464 Conclusion. 466 The World Trade Organization... 2014  
Peter Jan Honigsberg Linguistic Isolation: a New Human Rights Violation Constituting Torture, and Cruel, Inhuman and Degrading Treatment 12 Northwestern Journal of International Human Rights 22 (Winter, 2014) Sixteen-year-old Uzbek, Sunnat (not his real name), was seized in Afghanistan following the attacks on September 11, 2001. He was transported to the detention center in Guantanamo Bay, Cuba in 2002. After interrogating him over a period of several months, the United States government understood that he was not a threat. Nevertheless, the U.S. could... 2014  
Alexander K. Obrecht Migrating Towards an Incidental Take Permit Program: Overhauling the Migratory Bird Treaty Act to Comport with Modern Industrial Operations 54 Natural Resources Journal 107 (Spring 2014) In 1918, Congress passed the Migratory Bird Treaty Act (MBTA) to curb mass avian extermination caused by hunting and poaching. Despite Congress's initial concern with these activities, the U.S. Fish and Wildlife Service (FWS) expanded the scope of MBTA enforcement to include bird deaths caused by industrial activities. This created a glaring split... 2014  
Nathaniel Koppel Nails in the Coffin of the Vampire: Personal Sovereign Immunity and its Timely but Incomplete Death 2014 University of Illinois Law Review 1293 (2014) Judicial power has been a major factor in the curtailing of individual rulers being criminally immune for their actions. Such power has been exercised by courts of both nation and international origin, such as the International Criminal Tribunal for Rwanda or the International Criminal Court. The immunity this Note discusses must be differentiated... 2014  
Jennifer H. Weddle Nothing Nefarious: the Federal Legal and Historical Predicate for Tribal Sovereign Lending 61-APR Federal Lawyer 58 (April, 2014) Indian tribes are exercising their sovereignty. They continue to provide for their citizens, using the resources available to them to subsist and build their economies. This is nothing new, yet, a controversy exists because some do not like one particular mechanism of tribes' sovereign action--in this case making short-term, small-denomination... 2014 Yes
Matt Kalthoff Out of Sight, out of Mind: Confronting the Legal, Economic and Social Issues Raised by Major League Baseball's Peculiar Treatment of Foreign Talent 29 Connecticut Journal of International Law 353 (Spring, 2014) The drama that unfolds each year on big league baseball diamonds is enabled by an equally dramatic process behind the scenes. Champions are built by front offices that identify and acquire premier talent without overspending. To this end, Major League Baseball teams have dispatched scouts to the Dominican Republic for the last six decades to load... 2014  
Lorelei Laird Paper Terrorists 100-MAY ABA Journal 52 (May, 2014) the Atta family locked up their Temecula, Calif., home and went on vacation in 2012. While they were gone, Victor Cheng moved in. Cheng had owned the home before the Attas, but he lost it in foreclosure. Nonetheless, he filed a fraudulent deed with the county recorder's office, transferred the utilities into his name and even tried to evict the... 2014  
Lucy E. Salyer, University of New Hampshire Patrick Weil, the Sovereign Citizen: Denaturalization and the Origins of the American Republic, Philadelphia: University of Pennsylvania Préss, 2013. Pp. 296. $34.95 Paper (Isbn 978-0-8122-2212-8). Doi:10.1017/s0738248014000388 32 Law and History Review 724 (August, 2014) In 1933, Emma Goldman observed that the essential significance of the idea of country, of citizenship was the possession of a certain guarantee of security, the assurance of having some spot you can call your own and that no one can alienate from you. Divested of that, it becomes sheer mockery (2). Goldman spoke from bitter experience. In 1909,... 2014  
Sanford Levinson Popular Sovereignty and the United States Constitution: Tensions in the Ackermanian Program 123 Yale Law Journal 2644 (June, 2014) The very title of Bruce Ackerman's now three-volume masterwork, We the People, signifies his commitment to popular sovereignty and, beyond that, to the embrace of democratic inclusion as the leitmotif of American constitutionalism. But popular sovereignty, not to mention democracy, has many conceptions, and there is a tension within Ackerman's... 2014  
Brook Thomas Reconstructing the Limits of Schmitt's Theory of Sovereignty: a Case for Law as Rhetoric, Not as Political Theology 4 UC Irvine Law Review 239 (March, 2014) The act of metaphor then was a thrust at truth and a lie, depending where you were: inside, safe, or outside, lost. Oedipa did not know where she was. I.. 239 II.. 243 III.. 248 IV.. 254 V.. 257 VI.. 268 An essay written in the United States today with sovereignty in the title is almost obligated to mention, as I am about to, Carl Schmitt. That... 2014  
Jeremiah Chin Red Law, White Supremacy: Cherokee Freedmen, Tribal Sovereignty, and the Colonial Feedback Loop 47 John Marshall Law Review 1227 (Summer, 2014) I. Introduction. 1228 II. Conflict in Context: Historical origins of Cherokee Freedmen and Pending Litigation. 1230 A. Slavery and Reconstruction in the Cherokee Nation and the United States. 1231 1. Slavery in the Cherokee Nation and the beginnings of African enslavement. 1231 2. Removal and Civil War Alliances. 1234 3. Cherokee by Blood and the... 2014 Yes
Jacqueline Neumann Redefining the Modern Circus: a Comparative Look at the Regulations Governing Circus Animal Treatment and America's Neglect of Circus Animal Welfare 36 Whittier Law Review 167 (Fall, 2014) All of us have an inherent love of the circus. It awakens in our prosaic hearts memories of childish excursions into the enchanted realms of Sawdust Land. - Percy W. White Circuses are not as they seem. Dancing elephants are heart-broken mothers whose babies were stripped from them just seconds after they gave birth. The tasseled batons of circus... 2014  
Jennifer Ann Drobac , Jill L. Wesley Religion and Employment Antidiscrimination Law: Past, Present, and Post Hosanna-tabor 69 New York University Annual Survey of American Law 761 (2014) Introduction. 762 I. Causes of Action Available to Employees. 764 A. First Amendment Employment Discrimination Claims. 765 1. Possible Court Bias Against Minority Religious Adherents and the Tension with the Establishment Clause Implicated in Free Exercise Claims. 768 2. Free Exercise and Establishment Clause Issues in Unemployment Benefits Cases.... 2014  
Stephanie Hall Barclay Retained by the People: Federalism, the Ultimate Sovereign, and Natural Limits on Government Power 23 William & Mary Bill of Rights Journal 257 (October, 2014) Brewing tensions between state governments and the federal government have reached a boiling point unmatched since the civil rights debates of the 1960s. In light of the rapid expansion of federal power combined with colliding views on various policies, the call for states' rights has increasingly become a rallying cry for lawmakers that has gained... 2014  
Michael S. Kirsch Revisiting the Tax Treatment of Citizens Abroad: Reconciling Principle and Practice 16 Florida Tax Review 117 (2014) In an increasingly mobile world, the taxation of citizens living abroad has taken on increased importance. Recent international administrative developments-most notably, the weakening of foreign bank secrecy and expansion of global information sharing norms-have further raised the profile of this issue. While U.S. law traditionally has taxed U.S.... 2014  
K-Sue Park, Department of Rhetoric, University of California, Berkeley Shadow Nations: Tribal Sovereignty and the Limits of Legal Pluralism. By N. Bruce Duthu. New York: Oxford University Press, 2013. 234 Pp. $35.00 Cloth 48 Law and Society Review 692 (September, 2014) American Indian tribal sovereignties and U.S. constitutional democracy do coexist, however fraught their relationship, as institutions, communities, and practices. In relation to one another, the United States is the dominant power; its law paradoxically recognizes that tribal sovereignty predates that of the United States, yet claims plenary, or... 2014 Yes
Simanti Dasgupta , University of Dayton Sovereign Silence: Immoral Traffic (Prevention) Act and Legalizing Sex Work in Sonagachi 37 PoLAR: Political and Legal Anthropology Review 109 (May, 2014) Drawing upon ethnographic work with a grassroots sex workers' organization in Calcutta, Durbar Samanwaya Samiti (Durbar), this article analyzes the relationship between subalternity and silence. I discuss how sex workers, especially new entrants, use silence as a subaltern strategy to resist state and non-state surveillance intended to oppose... 2014  
Christian Hofmann Sovereign-debt Restructuring in Europe under the New Model Collective Action Clauses 49 Texas International Law Journal 385 (Spring 2014) The Article introduces the Common Terms of Reference (CTR) for Collective Action Clauses (CACs) that have been a mandatory part of the contract terms for all sovereign-bond issues of all eighteen euro-zone members since 2013. This includes all bond issues by economic and financial heavyweights such as Germany and France. By harmonizing these CTRs,... 2014  
Patrice H. Kunesh Sovereignty Gravitas 61-APR Federal Lawyer 30 (April, 2014) The experience of tribal sovereignty and the manner in which it is exercised, the gravitas of sovereignty, is the best indicator of the future of Indian Country. While all tribes have the authority to govern, many may not have realized the gravitas of that sovereignty. Tribes can enhance gravitas and provide prosperity using a four-pronged... 2014  
Polly J. Price Sovereignty, Citizenship, and Public Health in the United States 17 NYU Journal of Legislation and Public Policy 919 (2014) Sovereign boundaries, state borders, and distinctions between citizens and non-citizens undermine public health in the United States in a number of ways. For historical reasons, we are prone to view immigration and public health as separate interests, but they are in fact convergent. Historically, federal authority over immigration alleviated costs... 2014  
Matthew Deisen State v. Jim: a New Era in Washington's Treatment of the Tribes? 38 American Indian Law Review 101 (2013-2014) I. Introduction. 101 II. Background. 105 A. The Treaty. 107 B. Treaty Interpretation. 112 C. Fishing Sites and the Right of Access. 114 III. Enemy of the State: A History of Washington and Its Tribes. 117 A. Washington, Tribes, and Fish. 118 B. State v. Jim. 122 IV. Criminal Jurisdiction in Indian Country. 124 A. The Federal/Tribal Relationship.... 2014 Yes
Anthea Roberts State-to-state Investment Treaty Arbitration: a Hybrid Theory of Interdependent Rights and Shared Interpretive Authority 55 Harvard International Law Journal L.J. 1 (Winter 2014) Most investment treaties contain two dispute resolution clauses: one permitting investor-state arbitration for investment disputes and the other permitting state-to-state arbitration for disputes concerning the treaty's interpretation and/or application. Despite this duality, the potential role of state-to-state arbitration, and its proper... 2014  
David Y. Kwok Taxation Without Compensation as a Challenge for Tribal Sovereignty 84 Mississippi Law Journal 91 (2014) Introduction. 92 I. Background on State and Tribal Taxation of Commodities. 95 A. State Taxation of an Indian Tribe on Indian Land Is Generally Impermissible. 96 B. State Taxation of Non-Indian Parties on Indian Land May Be Permissible. 100 C. State Taxation of a Non-Indian Party on Non-Indian Land Is Permissible. 102 II. The Limits of Legal... 2014 Yes
Sonya Baskerville, Charles R. Sensiba, Gabriel Tabak The Columbia River Treaty at 50: Looking Back, Looking Ahead 45 ABA Trends 13 (July/August, 2014) Fifty years ago, the United States and Canada transformed power production and flood control in the Columbia River Basin. Following two decades of studies and negotiations, as well as devastating flooding in 1948, the Columbia River Treaty (CRT or Treaty) authorized the construction and operation of a series of storage dams and established an... 2014  
Henok Gabisa The Fate of International Human Rights Norms in the Realm of Bilateral Investment Treaties (Bits): Has Humanity Become a Collateral Damage? 48 International Lawyer 153 (Fall 2014) Since the end of 1950s, Bilateral Investment Treaties (BITs) have become the most important legal instrument in the orb of international investment law. These treaties offer the highest legal protection to investors' property rights. They do so by listing out standards, e.g., substantive rights of investment treatment, in foreign countries. While... 2014  
Travis Gunn The Fourteenth Amendment: a Structural Waiver of State Sovereign Immunity from Constitutional Tort Suits 35 Northern Illinois University Law Review 71 (Fall, 2014) Abstract. 72 Introduction. 73 I. State Sovereign Immunity and the Constitution. 76 A. A TRUNCATED REVIEW OF SOVEREIGN IMMUNITY, THE STATES, AND THE CONSTITUTION. 79 B. INTERPRETING AND APPLYING THE ELEVENTH AMENDMENT. 82 C. THE MODERN IMMUNITY THEORY. 85 1. Seminole Tribe of Florida v. Florida. 86 2. Alden v. Maine. 89 3. Central Virginia Community... 2014  
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