Re: [Declude.JunkMail] OT: Message Storage

2006-12-18 Thread Matt

Karl,

We were specifically talking about SOX (Sarbanes-Oxley) compliance, 
which have no legal applicability to your own needs.  Your needs are 
governed by Florida's Government-in-the-Sunshine laws which allow for 
public inspection of most records.


Matt



IS - Systems Eng. (Karl Drugge) wrote:

EXACTLY why we have the city attorney and another legal specialist
helping to formulate our own new policy. Best to invest some real $$$
now, before we get sued for our ignorance ( and  )
later.


Karl Drugge
 
 
 
 
 
 
-Original Message-

From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of
Sanford Whiteman
Sent: Sunday, December 17, 2006 1:46 PM
To: Matt
Subject: Re[2]: [Declude.JunkMail] OT: Message Storage

/snip

In  summary: you still don't know about e-mail archival for compliance
purposes.

Thanks for sharing.

--Sandy



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RE: [Declude.JunkMail] OT: Message Storage

2006-12-18 Thread IS - Systems Eng. \(Karl Drugge\)
True, I'm covered by different laws..

But in regards to keeping 'legal', in all senses of the word, especially
when you are discussing 'home grown' versus 'off the shelf' solutions,
it would be best to consult legal advisors before implementing anything.
If you aren't sure, get advice. If you are sure, get it in writing.

I was private sector long before I converted to government, and still
keep some of those clients. Most of my clients would much rather have a
lawyers sign off, especially if it's going to help them avoid a lawsuit
later.

Karl Drugge
 
 
 
 
 
 

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Matt
Sent: Monday, December 18, 2006 12:48 PM
To: declude.junkmail@declude.com
Subject: Re: [Declude.JunkMail] OT: Message Storage

Karl,

We were specifically talking about SOX (Sarbanes-Oxley) compliance, 
which have no legal applicability to your own needs.  Your needs are 
governed by Florida's Government-in-the-Sunshine laws which allow for 
public inspection of most records.

Matt



IS - Systems Eng. (Karl Drugge) wrote:
 EXACTLY why we have the city attorney and another legal specialist
 helping to formulate our own new policy. Best to invest some real $$$
 now, before we get sued for our ignorance ( and  )
 later.


 Karl Drugge
  
  
  
  
  
  
 -Original Message-
 From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of
 Sanford Whiteman
 Sent: Sunday, December 17, 2006 1:46 PM
 To: Matt
 Subject: Re[2]: [Declude.JunkMail] OT: Message Storage

 /snip

 In  summary: you still don't know about e-mail archival for compliance
 purposes.

 Thanks for sharing.

 --Sandy



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Re: [Declude.JunkMail] OT: Message Storage

2006-12-18 Thread Matt
chiving scheme
using some form of copy-all functionality.

One should look for guidance from all applicable sources, but one
should also understand that others may be in an extreme risk-adverse
mindset, may be in a position to profit from certain solutions, or may
not understand what is really required. As consultants, service
providers, and direct staff, we all must keep in mind that we don't
want to become part of the problem.




Matt




IS - Systems Eng. (Karl Drugge) wrote:

  True, I'm covered by different laws..

But in regards to keeping 'legal', in all senses of the word, especially
when you are discussing 'home grown' versus 'off the shelf' solutions,
it would be best to consult legal advisors before implementing anything.
If you aren't sure, get advice. If you are sure, get it in writing.

I was private sector long before I converted to government, and still
keep some of those clients. Most of my clients would much rather have a
lawyers sign off, especially if it's going to help them avoid a lawsuit
later.

Karl Drugge
 
 
 
 
 
 

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] On Behalf Of Matt
Sent: Monday, December 18, 2006 12:48 PM
To: declude.junkmail@declude.com
Subject: Re: [Declude.JunkMail] OT: "Message" Storage

Karl,

We were specifically talking about SOX (Sarbanes-Oxley) compliance, 
which have no legal applicability to your own needs.  Your needs are 
governed by Florida's "Government-in-the-Sunshine" laws which allow for 
public inspection of most records.

Matt



IS - Systems Eng. (Karl Drugge) wrote:
  
  
EXACTLY why we have the city attorney and another legal specialist
helping to formulate our own new policy. Best to invest some real $$$
now, before we get sued for our ignorance ( and  )
later.


Karl Drugge
 
 
 
 
 
 
-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] On Behalf Of
Sanford Whiteman
Sent: Sunday, December 17, 2006 1:46 PM
To: Matt
Subject: Re[2]: [Declude.JunkMail] OT: "Message" Storage

/snip

In  summary: you still don't know about e-mail archival for compliance
purposes.

Thanks for sharing.

--Sandy



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RE: [Declude.JunkMail] OT: Message Storage

2006-12-18 Thread IS - Systems Eng. \(Karl Drugge\)
Gotta love that picture Keeping it for my personal laptop back
ground.

 

I'll agree with you 99%.. I hate lawyers with a passion, and excepting
the miniature French poodle and HR personnel, they are loathed beyond
all else. 

 

But, in doing a risk assessment, factors like the possible cost of a
possible law suit is something that should be considered. A hospital is
a good example. Regardless of what the I.T. team is doing ( for good or
ill ), it's a good idea to get the advice of a legal professional. Just
one suit will offset the cost of hundreds of consultations. It's not
always possible, especially in the smaller firms, to CYA in this
fashion, but a sign off from above works just as well.

 

As IT management, I stress that we offer the company technical
solutions. What we CAN do is very different in most cases, from what we
SHOULD do. The SHOULD do part comes from written company policy.
Written company policy needs impartial review, from as many perspectives
as possible. Medical/Legal/Financial records all have different
retention requirements. This includes emails which pertain to these
records ( or even have them imbedded ). So, how do you handle your
archives then ? Keeping ALL the emails will get you fried if you have
expunged records in your archives ( if you're an attorney ). Who sorts
these emails for relevant information to determine if they even should
be stored ? SOX doesn't require I keep emailed pictures of my 5 year old
nieces B'day party.. So do you check each one individually ?! Yargh !
Leave it up to the end users ? Oh boy...

 

So, why do ( or don't ) you have these records ? Company policy will be
the only thing that keeps you as the email admin from getting thrown
under the bus. Easy, company policy dictates it. You're off the hook.
Remember, when the witch hunt ends, you don't want to be the one wearing
the pointy hat.

 

Apologies for the hijacked thread...

 

Karl Drugge

 

 

 

 

 

 

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Matt
Sent: Monday, December 18, 2006 2:36 PM
To: declude.junkmail@declude.com
Subject: Re: [Declude.JunkMail] OT: Message Storage

 

Karl,

The problem is assuming that keeping it 'legal' involves lawyers for
instance.  The Sarbanes-Oxley Act of 2002 was enacted by Congress and
the responsibility for clarifying the law into workable practices was
assigned to PCAOB (The Public Company Accounting Oversight Board,
created by Sarbanes-Oxley), and signed off on by the SEC.  It is the
responsibility of independent auditors to verify compliance and report
it's findings to the board of directors, who are ultimately responsible
for the companies in question.
.

.

 Lots of good stuff 

.

.

.

Matt




IS - Systems Eng. (Karl Drugge) wrote: 

True, I'm covered by different laws..
 
But in regards to keeping 'legal', in all senses of the word, especially
when you are discussing 'home grown' versus 'off the shelf' solutions,
it would be best to consult legal advisors before implementing anything.
If you aren't sure, get advice. If you are sure, get it in writing.
 
I was private sector long before I converted to government, and still
keep some of those clients. Most of my clients would much rather have a
lawyers sign off, especially if it's going to help them avoid a lawsuit
later.
 
Karl Drugge
 
 
 
 
 
 
 
-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Matt
Sent: Monday, December 18, 2006 12:48 PM
To: declude.junkmail@declude.com
Subject: Re: [Declude.JunkMail] OT: Message Storage
 
Karl,
 
We were specifically talking about SOX (Sarbanes-Oxley) compliance, 
which have no legal applicability to your own needs.  Your needs are 
governed by Florida's Government-in-the-Sunshine laws which allow for 
public inspection of most records.
 
Matt
 
 
 
IS - Systems Eng. (Karl Drugge) wrote:
  

EXACTLY why we have the city attorney and another legal
specialist
helping to formulate our own new policy. Best to invest some
real $$$
now, before we get sued for our ignorance ( and
 )
later.
 
 
Karl Drugge
 
 
 
 
 
 
-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf
Of
Sanford Whiteman
Sent: Sunday, December 17, 2006 1:46 PM
To: Matt
Subject: Re[2]: [Declude.JunkMail] OT: Message Storage
 
/snip
 
In  summary: you still don't know about e-mail archival for
compliance
purposes.
 
Thanks for sharing.
 
--Sandy
 
 
 
---
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unsubscribe, just send an E-mail to [EMAIL PROTECTED], and
type unsubscribe Declude.JunkMail.  The archives can be found
at http

Re: [Declude.JunkMail] OT: Message Storage

2006-12-18 Thread Matt

Karl,

If you want to buy the poster, you might try this link:

   http://www.thinkgeek.com/homeoffice/posters/58fc/

BTW, I wasn't suggesting that you hijacked the thread, rather I and 
others did from William Stillwell when he asked about E-mail archiving 
that doesn't cost an arm and a leg.


Your point about keeping baby pictures is a valid one.  Technically you 
are not required to keep such things under SOX...only business 
communications and more specifically, ones that pertain to the finances 
and operation of the business, are covered.  There are even solutions 
that do filtering to determine if a message should or shouldn't be 
archived, though being somewhat risk adverse, and knowing that such 
filtering isn't perfect, I would not recommend such a solution.  At the 
same time though, keeping unnecessary messages can be a detriment to a 
company as these things can come out and burn you years in the future.  
How many times have we heard side comments from Microsoft execs that 
their competition or detractors used against them.  Here's one such 
example where a MS executive told others that he would be using a Mac if 
he didn't work for Microsoft.  Here's the blog that tries to explain 
what he meant...


   
http://windowsvistablog.com/blogs/windowsvista/archive/2006/12/12/title.aspx


People are caught having affairs with others in the office, partying, 
and other things that represent private comments.  The fact is that none 
of that stuff is required to be kept and it shouldn't be archived if one 
can help it.  The SEC doesn't care about such things and they are the 
ones requiring retention, but having a massive stash of E-mail covering 
anything and everything actually increases the possibility of needing to 
spend money fulfilling a court order to produce such things.  You can 
likely blanket exclude certain classes of employees since they never 
deal with anything the SEC is concerned with, and that is wise.  
Retaining all such E-mails is another example of risk-aversion as well 
as complication, but the retention itself should be approached with some 
degree of risk-aversion as well.


Matt




IS - Systems Eng. (Karl Drugge) wrote:


Gotta love that picture Keeping it for my personal laptop back ground.

 

I'll agree with you 99%.. I hate lawyers with a passion, and excepting 
the miniature French poodle and HR personnel, they are loathed beyond 
all else.


 

But, in doing a risk assessment, factors like the possible cost of a 
possible law suit is something that should be considered. A hospital 
is a good example. Regardless of what the I.T. team is doing ( for 
good or ill ), it's a good idea to get the advice of a legal 
professional. Just one suit will offset the cost of hundreds of 
consultations. It's not always possible, especially in the smaller 
firms, to CYA in this fashion, but a sign off from above works just as 
well.


 

As IT management, I stress that we offer the company technical 
solutions. What we CAN do is very different in most cases, from what 
we SHOULD do. The SHOULD do part comes from written company policy. 
 Written company policy needs impartial review, from as many 
perspectives as possible. Medical/Legal/Financial records all have 
different retention requirements. This includes emails which pertain 
to these records ( or even have them imbedded ). So, how do you handle 
your archives then ? Keeping ALL the emails will get you fried if you 
have expunged records in your archives ( if you're an attorney ). Who 
sorts these emails for relevant information to determine if they even 
should be stored ? SOX doesn't require I keep emailed pictures of my 5 
year old nieces B'day party.. So do you check each one individually ?! 
Yargh ! Leave it up to the end users ? Oh boy...


 

So, why do ( or don't ) you have these records ? Company policy will 
be the only thing that keeps you as the email admin from getting 
thrown under the bus. Easy, company policy dictates it. You're off the 
hook. Remember, when the witch hunt ends, you don't want to be the one 
wearing the pointy hat.


 


Apologies for the hijacked thread...

 


Karl Drugge

 

 

 

 

 

 


-Original Message-
*From:* [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] *On Behalf Of 
*Matt

*Sent:* Monday, December 18, 2006 2:36 PM
*To:* declude.junkmail@declude.com
*Subject:* Re: [Declude.JunkMail] OT: Message Storage

 


Karl,

The problem is assuming that keeping it 'legal' involves lawyers for 
instance.  The Sarbanes-Oxley Act of 2002 was enacted by Congress and 
the responsibility for clarifying the law into workable practices was 
assigned to PCAOB (The Public Company Accounting Oversight Board, 
created by Sarbanes-Oxley), and signed off on by the SEC.  It is the 
responsibility of independent auditors to verify compliance and report 
it's findings to the board of directors, who are ultimately 
responsible for the companies in question.

.

.

 Lots of good stuff

Re: [Declude.JunkMail] OT: Message Storage

2006-12-15 Thread Matt
Ok, I'll add another few cents due to popular demand.  I do wish however 
for this to not become a thread with personal attacks or charges, which 
I why I tend to step away from such discussions.


I had a client who is a publically traded bank complete their annual 
FFIEC audit today.  Two of my systems were included in this audit, and 
the bank's lead IT consultant is a 20 year good friend who is also my 
own network and security guru who is my own emergency backup.  He also 
services other financial firms that are audited annually.


Just to be clear, I did not participate directly in the audit, though 
the regulations are a constant topic of conversation.  There is no doubt 
that banks are held to a higher standard than others.


The technical phase of the audit is carried out by examiners.  These 
people are merely consultants hired by the feds to conduct these 
audits.  The primary part of the audit is carried out by regulators 
who are the accounts that go over the books.  The examiners are often 
times less experienced and the IT staff and their own IT consultants.  
They come in and inspect systems according to checklists, and sometimes 
go further.  They use tools such as ISS scanners to go over a network 
looking for vulnerabilities.


In this particular audit the customer was flagged for running E-mail 
servers on every one of their desktops.  The E-mail servers were 
reported as being Symantec Security Suite, and was the result of 
running the scanner from a laptop that had Symantec Security Suite 
installed on it (they bank clients did not run this).  Even though this 
was pointed out to them, they still included it in their report and 
flagged it as a possible false positive because they said they were just 
following directions and using the tools they were given.  They also 
claimed that the bank was potential insecure because they had IP space 
listed in ARIN (which is RFC/ARIN required).  They then claimed that 
their E-mail server, which is fully firewalled from outside connections, 
was insecure because it exposed it's own IP address in Received headers 
for outgoing E-mail.  These were both bogus and short-sighted issues.


This client always gets rave marks on their audits, but the examiners 
alway point out something just to prove that they were doing their job.  
They send a report to the board of directors for the client, and then it 
is the job of the IT staff to address all of those items to the board.  
They are not required to change anything, or at least there has never 
been an issue that was required to be changed, and nit-picky stuff like 
ARIN records for IP space are merely explained and not changed.


In another place that I am aware of, the examiners recommended changing 
to a commercial IT security package because they did not understand the 
security as it was implemented.  This was an issue with the examiners 
and not the financial institution.  While this does confirm that the 
examiners prefer commercial packages, it does not justify the use of 
commercial packages since this is not a requirement, and it is merely a 
consultant examiner that is not fully versed in network security.  For 
instance, they may be uncomfortable with a hardened linux kernel running 
SNORT for IDS, but if you buy a commercial package with a fancy name 
that is merely a hardened linux kernel running SNORT, they may be happy 
since they know the product name.


Regarding SOX compliance, this never came up, and according to my friend 
that has done several dozen FFIEC audits, it never has.  SOX is 
primarily covered by traditional audits and to the best of my knowledge, 
it is overseen by the PCAOB (which was created by Sarbaines-Oxley for 
compliance purposes).  They deal with independent auditors, and it is 
apparently the responsibility of the independent auditors to verify SOX 
compliance, including E-mail archiving.  I can't claim that FFIEC 
examiners or regulators won't look at SOX E-mail archiving, and the 
examiners do look at other systems for record retention regarding 
security, but it is clearly not universal, and FFIEC audits are the 
fiercest audits of them all.


For publically traded non-financial corporations, FFIEC audits don't 
apply.  They are clearly covered by SOX, and it's E-mail retention 
rules, but they do not go to the same extent in examining systems.  SOX 
compliance as far as E-mail retention is not defined as far as the 
technical implementation goes, and it appears that fines for this to 
date result from other activities besides audits.  I have also found 
documentation showing that E-mail retention procedures (technical 
implementations) are not a one-size-fits-all  situation and should be 
approached according to the size of the business.  Some smaller 
companies merely retain backups of systems like Exchange in order to 
meet compliance, while larger ones must use more complicated solutions 
in order to create a situation where the communications are 

RE: [Declude.JunkMail] OT: Message Storage

2006-12-14 Thread Craig Edmonds

I know you said that catch all does not work but something I do for certain
clients is make two email accounts.

[EMAIL PROTECTED]
[EMAIL PROTECTED]

Then I make a rule in Imail that sends a copy of all incoming to the
incoming address and then a copy of the outgoing mail to the outgoing email
address.

The file sizes can get huge if it's a busy domain but I also run a vbscript
every couple of days that moves the main.mbx to our backup server and
renames the file 12142006main.mbx.

Its not the most elegant solution but its free.

I would be interested in a paid solution though if there is one out there.

Kindest Regards
Craig Edmonds
123 Marbella Internet
W: www.123marbella.com


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of William
Stillwell
Sent: Thursday, December 14, 2006 7:26 PM
To: declude.junkmail@declude.com
Subject: [Declude.JunkMail] OT: Message Storage


Does anybody know of a product (that doesn't cost a arm, and three legs)
that will archive all email for a specific domain for x number of years?
Imail CopyAll Will not work.. No way to orginize all the email, and I
don't want to archive the spam...



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RE: [Declude.JunkMail] OT: Message Storage

2006-12-14 Thread John T \(Lists\)
The Imail CopyAll account will work, along with Imail Rules on that account.

John T
eServices For You

Life is a succession of lessons which must be lived to be understood.
Ralph Waldo Emerson (1802-1882)



 -Original Message-
 From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of
William
 Stillwell
 Sent: Thursday, December 14, 2006 10:26 AM
 To: declude.junkmail@declude.com
 Subject: [Declude.JunkMail] OT: Message Storage
 
 
 Does anybody know of a product (that doesn't cost a arm, and three legs)
 that will archive all email for a specific domain for x number of years?
 Imail CopyAll Will not work.. No way to orginize all the email, and I
 don't want to archive the spam...
 
 
 
 ---
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 unsubscribe, just send an E-mail to [EMAIL PROTECTED], and
 type unsubscribe Declude.JunkMail.  The archives can be found
 at http://www.mail-archive.com.




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RE: [Declude.JunkMail] OT: Message Storage

2006-12-14 Thread William Stillwell

I will keep ya posted, We are looking into some third party products and
other solutions. Your solution would work, however, But when given a request
to have all of the email of a certain person for x months is not easy to do
when you have to sift thru gigs of email. 


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Craig
Edmonds
Sent: Thursday, December 14, 2006 2:18 PM
To: declude.junkmail@declude.com
Subject: RE: [Declude.JunkMail] OT: Message Storage
Importance: High


I know you said that catch all does not work but something I do for certain
clients is make two email accounts.

[EMAIL PROTECTED]
[EMAIL PROTECTED]

Then I make a rule in Imail that sends a copy of all incoming to the
incoming address and then a copy of the outgoing mail to the outgoing email
address.

The file sizes can get huge if it's a busy domain but I also run a vbscript
every couple of days that moves the main.mbx to our backup server and
renames the file 12142006main.mbx.

Its not the most elegant solution but its free.

I would be interested in a paid solution though if there is one out there.

Kindest Regards
Craig Edmonds
123 Marbella Internet
W: www.123marbella.com


-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of William
Stillwell
Sent: Thursday, December 14, 2006 7:26 PM
To: declude.junkmail@declude.com
Subject: [Declude.JunkMail] OT: Message Storage


Does anybody know of a product (that doesn't cost a arm, and three legs)
that will archive all email for a specific domain for x number of years?
Imail CopyAll Will not work.. No way to orginize all the email, and I
don't want to archive the spam...



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Re: [Declude.JunkMail] OT: Message Storage

2006-12-14 Thread Matt
Brand it with a fancy name and they should be happy.  IMail stores 
messages in an open format, and as long as you catch all of it, and 
archive it as required, that should be all that counts.  Naturally I'm 
simplifying, but in reality, all of these other products are programmed 
by people too.


Matt



Sanford Whiteman wrote:

... and it should be acceptable to the feds.



Which feds?

The regulatory agencies I know would scoff at such a solution. But the
OP  didn't  mention  this  being done for external regulatory reasons,
anyway.

--Sandy



Sanford Whiteman, Chief Technologist
Broadleaf Systems, a division of
Cypress Integrated Systems, Inc.
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Re: [Declude.JunkMail] OT: Message Storage

2006-12-14 Thread Matt

Sanford Whiteman wrote:

Unlike...  um,  anyone on this list, it seems... I know firsthand what
SEC and NASD think of homegrown compliance solutions.
That's why you pay someone else to do it and insist that they slap on a 
fancy name like Perfect Super Uber E-mail Compliance Archive System.


But seriously, the baseline test is whether or not it works, and no one 
should invest in something that doesn't meet regulations.


I do have some experience with the feds, and I did work for a 
multi-billion dollar corporation where my immediate boss was in charge 
of E-mail for the entire company, and we were always being sued by 
someone.  That was pre-SOX though, but we all knew it was coming and 
that it mostly just clarified retention policies by better defining what 
was classified as a covered communication.  I also have a good friend 
deals with bank audits on a regular basis as well as SOX compliance.  
When audited, they will always point a list of things out, and they can 
find fault with anything that they choose to find fault with.  The real 
trick is ensuring that you aren't grossly negligent.


Also note that congress didn't even specify retention periods within SOX 
or methods of retention, this was all inferred after the fact by 
combining aspects of various laws and regulations, and they certainly 
didn't endorse a particular product for providing a solution.


With all of that said, I believe that what one does should be compatible 
with the dynamics of one's business.  For a single location entity with 
less than 200 employees, clearly a less robust solution could manage the 
task, and it could be home grown.  Those that have many more employees 
and multiple locations would likely find a commercial solution more 
beneficial overall.  There are even situations with multi-national 
companies where it is pretty much impossible to be in compliance with 
every regulation that applies to them.  For instance, some countries 
require removing certain records for privacy, while others require 
retaining all such records for oversight and legal reasons.


Matt


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