Kansas Wrongful Death: A Northern Virginia Family’s Guide

By Anthony I. Shin, Esq., Shin Law Office

1. Why Northern Virginia Families End Up With Kansas Wrongful Death Cases

Northern Virginia and Kansas are tied together by aerospace, the military, and agriculture. Wichita calls itself the air capital of the world. Boeing has a major presence there. Spirit AeroSystems is headquartered there. Textron Aviation, Bombardier Learjet, and other big aerospace companies run large Wichita facilities. McConnell Air Force Base near Wichita is home to the 22nd Air Refueling Wing, which runs KC-135 and KC-46 tanker operations. Aerospace contractors and DOD personnel from Northern Virginia travel there often. Fort Riley, near Manhattan, Kansas, is home to the 1st Infantry Division and about 18,000 active-duty soldiers. Northern Virginia military families rotate through Riley regularly. Kansas City International Airport is a major Midwest hub. The airport itself is in Kansas City, Missouri, but much of the metro area is in Wyandotte, Johnson, and Leavenworth Counties on the Kansas side.

In my practice, Kansas wrongful death cases involving Northern Virginia families come from a few recurring patterns. An aerospace contractor flies to Wichita for Boeing or Spirit AeroSystems work and dies in a crash on I-35 or I-135, in a hotel incident, or at a worksite. A military family at Fort Riley loses someone in a crash on Kansas Highway 18 or Interstate 70. A student at the University of Kansas in Lawrence, Kansas State in Manhattan, or Wichita State dies in an off-campus incident. A business traveler dies in a tornado-related building collapse during spring storm season. A retired federal worker who moved to Johnson County (Overland Park, Olathe, Leawood) dies of medical negligence at a Kansas City hospital. A grandparent visiting relatives in Topeka, Hutchinson, or Salina dies of a delayed cardiac response. A family on an Interstate 70 cross-country drive crashes near Salina, Hays, or Goodland.

Kansas wrongful death law has been in flux since the Hilburn decision in 2019. The old cap on non-economic damages limited recovery for decades. Now the personal injury cap is gone, and the wrongful death cap is on uncertain ground. Don’t assume the cap will apply automatically. Be ready to argue against it if the non-economic damages in the case exceed it.

2. Where Kansas Sits on the Wrongful Death Map

Kansas wrongful death law is an older statute that has been reshaped by a recent constitutional decision. The current rules reflect the 1859 wrongful death tradition, the 1976 switch to comparative fault, the 1988 non-economic damages cap, the 2008 recodification, and the 2019 Hilburn decision that changed how the cap is viewed.

The statute. K.S.A. 60-1901 and following is the Kansas Wrongful Death Act. Section 60-1901 creates the claim. Section 60-1902 controls who can bring it. Section 60-1903 controls damages and contains the cap. Section 60-1904 covers procedure, including how the recovery is split.

What you can recover. Kansas allows recovery for the money side of the loss (lost income, lost services, lost benefits, lost inheritance, reasonable funeral expenses) and for the non-money side (grief, suffering, bereavement, loss of society, loss of comfort and companionship, loss of marital care, loss of parental care, loss of filial care). Kansas is broader on the categories than the pecuniary-only states like New York.

The K.S.A. 60-1903 cap. K.S.A. 60-1903 caps non-economic damages in wrongful death at $250,000. The cap has not been amended since it was enacted and is not adjusted for inflation. It applies to the total non-economic damages in the case, not per defendant or per beneficiary. It does not apply to the money-side damages.

The Hilburn problem. In Hilburn v. Enerpipe Ltd., 309 Kan. 1127 (2019), the Kansas Supreme Court held that the parallel personal injury non-economic damages cap at K.S.A. 60-19a02 violated Section 5 of the Kansas Bill of Rights, which protects the right to a jury trial. The court said the cap improperly limited the jury’s role in setting damages. The wrongful death cap at K.S.A. 60-1903 does the same job in the same way. The reasoning in Hilburn fits it. The Kansas Supreme Court has not yet ruled on the wrongful death cap directly, but most Kansas practitioners treat it as vulnerable and build a constitutional challenge into cases where the non-economic damages would exceed it.

The K.S.A. 60-1801 survival statute. The Kansas Survival Statute at K.S.A. 60-1801 keeps the decedent’s own personal injury claim alive. The estate (through the personal representative) brings the survival action and recovers for the decedent’s pre-death damages. Pre-death conscious pain and suffering, pre-death medical expenses, and pre-death lost wages are all recoverable. Before Hilburn, non-economic damages in survival actions were capped under the personal injury cap. That cap is gone. Common-law and constitutional excessiveness review still apply.

Statute of limitations. K.S.A. 60-513(a)(5) sets a 2-year deadline for wrongful death, running from the date of death. K.S.A. 60-513(c) gives a discovery rule if the cause of death was not reasonably ascertainable at the time. The general personal injury 2-year SOL under K.S.A. 60-513(a)(4) governs the survival action. Medical malpractice cases have a 2-year SOL under K.S.A. 60-513(a)(7) with a 4-year statute of repose, with exceptions for foreign objects and a few other situations.

Modified comparative fault. K.S.A. 60-258a sets modified comparative fault with a 50-percent bar. Recovery is barred if the plaintiff’s fault is 50 percent or more. Recovery is reduced proportionally for fault under 50 percent. The strict 50-percent rule is the same one Colorado uses and is tougher than the 51-percent rule most other states use.

Joint and several liability. Kansas has largely eliminated joint and several liability under K.S.A. 60-258a. Each defendant is severally liable based on its fault percentage. The plaintiff carries collection risk in multi-defendant cases.

The Kansas Tort Claims Act. K.S.A. 75-6101 and following governs claims against the State of Kansas, counties, municipalities, school districts, and other governmental bodies. K.S.A. 75-6105 caps governmental liability at $500,000 per occurrence, no matter how many victims or claims. That is one of the lower governmental caps in this series. K.S.A. 12-105b requires written notice for claims against municipalities before suit can be filed. Notice rules vary by government type.

Punitive damages cap. K.S.A. 60-3702 caps punitive damages at the lesser of (a) $5 million or (b) the defendant’s highest gross annual income earned in any of the five years before the act giving rise to liability. The cap is one of the more complex in the country. The court bifurcates punitive damages from compensatory damages under K.S.A. 60-3701.

3. Virginia’s Lex Loci Delicti Rule Applied to Kansas

For a Northern Virginia family with a Kansas wrongful death case, Virginia’s choice-of-law rule controls.

The McMillan rule. Under McMillan v. McMillan, 219 Va. 1127 (1979), Virginia courts apply the substantive law of the state where the wrong happened. For a Kansas wrongful death case, that means Kansas substantive law: the Kansas Wrongful Death Act, the K.S.A. 60-1903 cap (subject to the Hilburn challenge), the survival statute, the modified comparative fault rule, the Kansas Tort Claims Act, and the punitive damages framework.

The Hilburn issue across forums. A Virginia court applying Kansas substantive law has to deal with the Hilburn constitutional challenge to the K.S.A. 60-1903 cap. The challenge is based on the Kansas Constitution (Section 5 of the Kansas Bill of Rights), so the Virginia court has to apply Kansas constitutional doctrine. Federal courts sitting in diversity in Kansas have wrestled with this since 2019. The analysis is fact-intensive.

Virginia procedural law if Virginia is the forum. Virginia procedural rules apply if the case is filed in Virginia. The 2-year SOL is the same under Virginia (Va. Code Section 8.01-244) and Kansas (K.S.A. 60-513(a)(5)). Virginia’s contributory negligence rule does not apply; Kansas’s 50-percent modified comparative fault applies as substantive law.

Filing in Kansas versus Virginia. Most Kansas wrongful death cases I work for Northern Virginia families end up filed in Kansas. The evidence, witnesses, and defendants are there. Kansas state district courts (the trial court of general jurisdiction) handle wrongful death cases in Sedgwick County (Wichita), Johnson County (Overland Park), Shawnee County (Topeka), Riley County (Manhattan), Douglas County (Lawrence), and others. The U.S. District Court for the District of Kansas (Kansas City, Topeka, and Wichita courthouses) handles federal diversity cases.

Personal jurisdiction. Kansas long-arm jurisdiction under K.S.A. 60-308 reaches most out-of-state defendants for in-state torts. Virginia courts have personal jurisdiction over Virginia defendants for any conduct, but Kansas businesses and hospitals usually do not have enough Virginia contacts for Virginia personal jurisdiction.

Federal Tort Claims Act. Federal employee cases (Fort Riley personnel, McConnell AFB personnel, federal contractors at federal facilities, VA hospital personnel) follow FTCA. Kansas substantive law governs damages. Administrative claim within 2 years.

Practical takeaway. The choice-of-law analysis points to Kansas substantive law no matter the forum. Forum usually points to Kansas state district court or U.S. District Court for the District of Kansas. I work with Kansas local counsel admitted to practice for filing and court appearances.

4. Hilburn v. Enerpipe and the Constitutional Status of the K.S.A. 60-1903 Cap

Hilburn is the most important Kansas tort decision in a generation. Understanding what it held and what it means for the wrongful death cap is the central question in any Kansas case with serious non-economic damages.

The Hilburn decision. Hilburn v. Enerpipe Ltd., 309 Kan. 1127 (2019), came out of a crash with a commercial truck. The jury awarded non-economic damages well above the K.S.A. 60-19a02 cap of $250,000 (later increased to $300,000 and then to $325,000 by amendment). The trial court reduced the award to the cap. The plaintiff appealed and argued the cap violated Section 5 of the Kansas Bill of Rights, which says “the right of trial by jury shall be inviolate.” The Kansas Supreme Court agreed and held the cap unconstitutional.

The Section 5 analysis. The court reasoned that the right to a jury trial includes the right to have the jury decide damages, not just liability. A statutory cap that limits what the jury can award interferes with that constitutional role. The court overruled earlier decisions (notably Miller v. Johnson, 295 Kan. 636 (2012), which had upheld a similar cap) and held the cap unconstitutional.

What this means for the wrongful death cap. The K.S.A. 60-1903 wrongful death cap does the same job and uses the same mechanism as the K.S.A. 60-19a02 cap that Hilburn struck down. The reasoning fits it. The Kansas Supreme Court has not yet ruled directly on the wrongful death cap, but several Kansas district courts have already refused to apply it, citing Hilburn. Federal courts in diversity in Kansas have addressed the issue with mixed results.

What this means for strategy. For pending or future Kansas wrongful death cases, treat the cap as constitutionally vulnerable. Plaintiff strategy should: (a) build the non-economic damages presentation as if the cap were not there; (b) preserve the constitutional challenge in pleadings, motions, and the trial record; (c) coordinate with Kansas counsel on the procedural and substantive constitutional arguments; (d) expect the cap question may be the basis for an appeal that eventually reaches the Kansas Supreme Court.

The defense response. Defendants in Kansas wrongful death cases continue to argue that K.S.A. 60-1903 remains valid until the Kansas Supreme Court rules on it directly. They plead the cap as an affirmative defense and ask for reduction of any verdict to the cap amount. The argument has been getting harder to sustain since Hilburn, but it is still alive until the Kansas Supreme Court resolves it.

Settlement implications. The uncertainty has shifted settlement positions. Defendants who used to rely on the cap as a known ceiling are now negotiating with the real possibility that a jury could award much more. Plaintiff settlement positions have moved up to match.

5. The K.S.A. 60-1801 Survival Action

The Kansas Survival Statute keeps the decedent’s pre-death claims alive and runs alongside the wrongful death claim.

The statute. K.S.A. 60-1801 says every cause of action existing in favor of or against a decedent survives death and can be brought or continued by the personal representative of the estate. The decedent’s personal injury claim becomes a claim of the estate.

What you can recover. Pre-death conscious pain and suffering. Pre-impact terror if there is evidence of awareness. Pre-death mental anguish. Pre-death medical expenses. Pre-death lost wages. The survival action recovers for the decedent’s losses, not the family’s.

Hilburn’s effect on survival action damages. Before Hilburn, survival action non-economic damages were capped under K.S.A. 60-19a02. That cap is gone. Common-law and constitutional excessiveness review still apply.

Statute of limitations. The survival action follows the personal injury SOL under K.S.A. 60-513(a)(4) (2 years), running from the date of the underlying injury. Medical malpractice cases follow the 2-year SOL with the 4-year statute of repose under K.S.A. 60-513(c).

Beneficiary distribution. The survival action recovery belongs to the estate and is distributed under the decedent’s will or under intestate succession (Kansas Probate Code, K.S.A. 59-501 et seq.).

Personal representative. The survival action is brought by the personal representative. Kansas probate in the District Court (probate division) of the county where the decedent was domiciled qualifies the personal representative. For a Northern Virginia family, Virginia probate qualifies the personal representative first, with ancillary Kansas administration for the survival action.

6. Heirs at Law Under K.S.A. 60-1902

Kansas wrongful death standing runs through the heirs-at-law framework at K.S.A. 60-1902.

Heirs at law. K.S.A. 60-1902 limits standing to the heirs at law of the decedent who have sustained a loss by reason of the death. Heirs at law are figured out under the Kansas intestate succession statute at K.S.A. 59-501 and following: the surviving spouse and children first, then parents if there is no spouse or children, then siblings, then more distant relatives in priority order. The recovery flows to the heirs in proportion to their loss.

The loss requirement. Only heirs who have sustained a loss by reason of the death have standing. An adult child who was not financially dependent on the decedent and did not have a meaningful ongoing relationship may end up with a smaller share than a minor child or surviving spouse with direct dependence. In extreme cases, that share can be zero.

Apportionment under K.S.A. 60-1905. The recovery is split among the heirs by the court (after a hearing if the parties cannot agree) based on each heir’s actual loss. The court looks at financial dependence, closeness of the relationship, and similar factors. Apportionment is fact-specific.

Who brings the action. Any one of the heirs at law may bring the wrongful death action for the benefit of all (K.S.A. 60-1902). The personal representative of the estate can also bring it. Only one wrongful death action can be brought; multiple-action attempts get consolidated.

Same-sex spouses. Kansas recognizes same-sex marriage under federal constitutional requirements (Obergefell v. Hodges, 576 U.S. 644 (2015)). Same-sex spouses are heirs at law on the same terms as opposite-sex spouses.

Common-law marriage. Kansas recognizes common-law marriage with proof of cohabitation, a present marital agreement, and holding out as married. A common-law spouse has wrongful death standing as an heir at law if the marriage is established.

7. Statute of Limitations and the Kansas Tort Claims Act

Kansas procedural traps include the 2-year SOL, the 4-year medmal repose, and the Kansas Tort Claims Act notice and cap regime.

The 2-year wrongful death SOL. K.S.A. 60-513(a)(5) sets a 2-year deadline for wrongful death, running from the date of death. K.S.A. 60-513(c) gives a discovery rule if the cause of death was not reasonably ascertainable at the time. The SOL then runs from the date the cause was or should have been ascertained.

The 2-year personal injury SOL. K.S.A. 60-513(a)(4) sets a 2-year deadline for personal injury. It governs the survival action and runs from the date of the underlying injury.

The 2-year medmal SOL with 4-year repose. K.S.A. 60-513(a)(7) and (c) set a 2-year deadline for medical malpractice with a 4-year statute of repose. Claims must be filed within 4 years of the act, no matter when the injury was discovered. Narrow exceptions for foreign objects and a few other circumstances.

The Kansas Tort Claims Act notice. K.S.A. 12-105b requires written notice for claims against municipalities before suit can be filed. Notice goes to the municipal clerk and the municipal attorney. It has to include certain content (name and address of the claimant, name and address of any attorney representing the claimant, the factual basis of the claim, the names of any public employees involved if known, the amount of damages claimed). The municipality has a set period to respond before suit can be filed.

The KTCA damages cap. K.S.A. 75-6105 caps governmental liability at $500,000 per occurrence. The cap covers all claims arising from a single occurrence, including multiple victims. It is one of the lower governmental caps in this series and limits recovery against public defendants.

Public entities under the KTCA. The State of Kansas, every county, every municipality, every school district, the University of Kansas, Kansas State, Wichita State, public hospitals, the Kansas Highway Patrol, and other governmental bodies. Many cases involving Kansas highway design (KDOT), state parks, and similar contexts implicate the KTCA.

The medmal expert requirement. Kansas does not require a pre-suit affidavit of merit like New Jersey or Maryland. K.S.A. 60-3502 requires expert testimony at trial in medmal cases, but the rule is a trial requirement, not a pre-suit gatekeeping device.

Federal Tort Claims Act. Federal employee cases (Fort Riley, McConnell AFB, federal hospitals, federal contractors at federal facilities) follow FTCA. Administrative claim within 2 years. Kansas substantive law governs damages.

8. Modified Comparative Fault and the 50-Percent Bar

Kansas uses a strict 50-percent fault bar, the same one Colorado uses, and tougher than the 51-percent rule used by most other states.

The K.S.A. 60-258a rule. The plaintiff can recover only if the plaintiff’s fault is less than the combined fault of all defendants. If the plaintiff’s fault equals 50 percent (or more), recovery is barred. If the plaintiff’s fault is under 50 percent, recovery is reduced proportionally.

The 50-50 case bar. A decedent who is exactly 50 percent at fault recovers nothing in Kansas. This is the same strict rule Colorado uses. It is different from the 51-percent rule in Texas, New Jersey, and many other modified-comparative-fault states.

Comparison with Virginia. Virginia’s contributory negligence rule bars recovery if the decedent was at all at fault. Kansas’s 50-percent rule allows recovery up to 49 percent decedent fault. The difference can be the whole case.

Apportionment among defendants. The plaintiff’s fault is compared to the combined fault of all defendants. K.S.A. 60-258a(d) lays out procedures for joining tortfeasors who were not initially named so the comparison is fair. It can get complex in multi-defendant cases.

Several-only liability. Kansas has largely eliminated joint and several liability. Each defendant is severally liable based on its fault percentage. The plaintiff carries collection risk on each defendant’s share separately. In multi-defendant cases with some defendants short on assets, recovery may be incomplete even with full liability findings against all of them.

9. Punitive Damages Under K.S.A. 60-3702

Kansas has one of the more complex punitive damages cap structures in the country.

The standard. K.S.A. 60-3701(c) requires clear and convincing evidence of willful, wanton, fraudulent, or malicious conduct. It is a high bar. Ordinary negligence does not support punitive damages.

Bifurcation. K.S.A. 60-3701 requires the court to split punitive damages from compensatory damages. The jury first decides compensatory damages and liability. If punitive damages are appropriate, the court (not the jury) sets the amount in a separate proceeding, looking at the K.S.A. 60-3701 factors: likelihood of serious harm, degree of awareness, profitability of the misconduct, financial condition of the defendant, and other mitigating or aggravating circumstances.

The cap. K.S.A. 60-3702 caps punitive damages at the lesser of (a) $5 million or (b) the defendant’s highest gross annual income earned in any of the five years before the act giving rise to liability. The cap can be raised to the gross income from the wrongful conduct if the misconduct generated profit (K.S.A. 60-3702(e)). The framework scales punitive damages to the defendant’s ability to pay.

Carve-outs. The cap does not apply to certain claim categories, including some asbestos and product liability claims.

Not available against the State. K.S.A. 75-6105(c) says punitive damages are not available against governmental entities under the KTCA.

10. How I Work Kansas Wrongful Death Cases for Northern Virginia Families

When a Northern Virginia family calls me about a death in Kansas, the work focuses on a few things: catching every deadline, evaluating the Hilburn cap challenge, finding any possible KTCA defendants, qualifying the personal representative, and coordinating with Kansas counsel.

The deadline check. The first call sets out every deadline. The 2-year wrongful death SOL under K.S.A. 60-513(a)(5). The 2-year personal injury SOL under K.S.A. 60-513(a)(4) for the survival action. The 4-year medmal repose under K.S.A. 60-513(c). The K.S.A. 12-105b notice for municipal defendants. The FTCA 2-year administrative claim deadline.

The Hilburn cap analysis. In the first conversation, I look at where the non-economic damages are likely to land against the K.S.A. 60-1903 cap. For cases where the non-economic damages would clearly exceed $250,000, I plan the constitutional challenge from the start and preserve it in pleadings, motions, and the trial record.

KTCA defendant identification. In the first week, I list every possible KTCA defendant: the State of Kansas, the Kansas Highway Patrol, the Kansas Department of Transportation, state universities (KU, K-State, Wichita State), counties (Sedgwick, Johnson, Shawnee, Riley, Douglas, others), municipalities, school districts. Any possible KTCA defendant triggers the notice requirement and brings the $500,000 per-occurrence cap into the picture.

Personal representative qualification. Open Virginia probate for the Northern Virginia decedent. Get Kansas ancillary administration in the appropriate Kansas District Court for the survival action.

Evidence preservation. Kansas evidence preservation needs immediate action. Police reports (Kansas Highway Patrol for state highway cases, county sheriff or municipal police for other cases). Medical records. Vehicle reconstruction. Premises maintenance records. Surveillance footage. Aerospace incident records for aviation cases. Military incident records for Fort Riley or McConnell AFB cases.

Kansas counsel coordination. I work with Kansas counsel admitted to practice for filing, expert disclosure, the constitutional cap challenge, and court appearances. Kansas state district court and the federal District of Kansas both require local expertise on the post-Hilburn framework and the KTCA.

Damages workup. A Kansas-licensed economist for lost earnings. Household services experts. Medical experts for pre-death pain and suffering. The workup builds the non-economic damages presentation without holding back, so that if the constitutional challenge wins, the full damages recovery is supported by the evidence on the record.

The settlement framework. Most Kansas wrongful death cases resolve in settlement. The post-Hilburn uncertainty has moved settlement positions. Defendants can no longer count on the cap as a defined ceiling and are negotiating with the real chance of unconstrained non-economic damages awards.

The litigation timeline. Most Kansas wrongful death cases take 18 to 30 months from filing to resolution. Sedgwick County District Court (Wichita), Johnson County District Court (Olathe), Shawnee County District Court (Topeka), and other state district courts handle most of them. The U.S. District Court for the District of Kansas runs federal diversity cases on tighter schedules.

Summary

Kansas wrongful death law is changing. The Kansas Wrongful Death Act at K.S.A. 60-1901 et seq. allows recovery for the money side of the loss (uncapped) and for the non-money side (grief, suffering, loss of companionship, loss of consortium) historically capped at $250,000 under K.S.A. 60-1903. The Kansas Supreme Court in Hilburn v. Enerpipe Ltd., 309 Kan. 1127 (2019), struck down the parallel personal injury cap at K.S.A. 60-19a02 as a violation of Section 5 of the Kansas Bill of Rights. The reasoning fits the wrongful death cap, and the cap should be treated as vulnerable in any case where non-economic damages would exceed it. Several Kansas trial courts have refused to apply the cap citing Hilburn. A final ruling from the Kansas Supreme Court is still pending.

The Kansas Survival Statute at K.S.A. 60-1801 keeps the decedent’s pre-death claims alive. Before Hilburn, survival action non-economic damages were capped under K.S.A. 60-19a02. That cap is gone. The wrongful death SOL is 2 years from the date of death under K.S.A. 60-513(a)(5), with a discovery rule if the cause was not reasonably ascertainable. The survival action follows the personal injury SOL under K.S.A. 60-513(a)(4). Medical malpractice has a 2-year SOL with a 4-year statute of repose under K.S.A. 60-513(c).

The Kansas Tort Claims Act at K.S.A. 75-6101 et seq. caps governmental liability at $500,000 per occurrence under K.S.A. 75-6105 and requires written notice for municipal defendants under K.S.A. 12-105b. Wrongful death standing runs through the heirs-at-law framework at K.S.A. 60-1902 (intestate distributees who have sustained a loss), with apportionment under K.S.A. 60-1905 based on each heir’s actual loss. Kansas uses modified comparative fault with a strict 50-percent bar under K.S.A. 60-258a (the same strict rule Colorado uses). Joint and several liability has largely been eliminated.

Punitive damages are available on clear and convincing evidence of willful, wanton, fraudulent, or malicious conduct under K.S.A. 60-3701. The court (not the jury) sets the amount in a bifurcated proceeding, capped at the lesser of $5 million or the defendant’s highest gross annual income from any of the five years before the act, with carve-outs for some product liability and asbestos claims under K.S.A. 60-3702. Punitive damages are not available against governmental entities under the KTCA.

Virginia courts apply Kansas substantive wrongful death law under McMillan v. McMillan, 219 Va. 1127 (1979). Most Northern Virginia families with Kansas cases file in Kansas state district court or U.S. District Court for the District of Kansas. I work with Kansas local counsel for filing, the Hilburn cap challenge, and court appearances while leading strategy and damages workup.

For the framework that runs through every state guide in this series, see my cornerstone guide for multi-state wrongful death.

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Anthony I. Shin, Esq.

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