Child Support Enforcement and The Common Law Theory

Source: National

Source: National Council of Juvenile and Family Court Judges

By:  Kenya N. Rahmaan

The child support system is one that sparks controversy.  No matter what the setting, there will undoubtedly be several opinions, some facts, heightened emotions, and maybe, and sadly, violence.  There are many unanswered questions that people ask about the child support system, as to its legality and constitutionality.   This concerning everything from initiating the child support complaint to how the non-custodial parents are punished when the child support payments are not paid timely and in full.  The child support system and the Temporary Assistance for Needy Families (TANF), formerly Aid to Families with  Dependent Children (AFDC) systems are intertwined and can, realistically, be summarized as one in the same based on the interaction that takes place once a TANF application is initiated by a custodial parent.


The welfare program in the United States has held many titles since grants were authorized for needy children in the mid 1930s.  The State Aid of Dependent Children (ADC) were grants that were authorized in the original Social Security Act of 1935 for the purpose of enabling each State to furnish financial assistance as far as practicable under the conditions in such State, to the needy dependent children, (Vee Burke, 1984).  While statutes were being aggressively debated by state and Federal legislators, the program originally created to aid poor children, grew into the maze of regulations and exorbitant budgets,   Reimbursement by the Federal government to the states have always been a cornerstone of the welfare system. 

The Social Security Act authorized the Secretary of the Treasury to reimburse each state, with an approved ADC plan for one-third of the benefit payments, up to a maximum Federal payment of $6 for the first child in the family, plus $4 each for additional dependent children in the family, (Burke, 1984).  The Department of Health and Human Services reported in 1935 that individual maximums of $18 for the first child and $12 for additional children were paid to families with needy children.  There have always been criteria that the recipient must meet prior to being approved for cash benefits. According to Burke, the Act left the State to determine the definition of “need”, but specified that to be eligible for ADC, a child must be:

  • under the age of 16,
  • have been deprived of parental support or care by reason of death, continued absence from the home, or physical or mental incapacity of a parent,
  • and living with and in the home of a specified relative, namely his father, mother, grandfather, grandmother, brother, sister, stepfather, stepmother, stepbrother, stepsister, uncle or aunt.

As the program expanded over the years so did the criteria and guidelines used to administer and govern the program.  By the 1950s, there was a private child support program implemented that imposed regulations by the Federal government requiring that the state became more aggressive in the lives of non-custodial or ‘absent’ parents.  According to Burke, states were required, effective July 1, 1952, to give “prompt notice” to appropriate law enforcement officials of the furnishing of welfare to an abandoned or deserted child (the NOLEO amendment–Notification of Law Enforcement Officials).  By enacting this mandate, the introduction of the police involvement into family court issues materialized.

The program was costly, poorly managed, and recovered very little information concerning these absent parents in the early years of the child support program.  However, over the years, the monthly benefits increased, as did the overall mission of the ADC program. By 1956, the mission evolved and the government added a goal which claimed to be more interested in maintaining and strengthening family life and helping parents and relatives of needy children to attain the maximum self-support and personal independence consistent with the maintenance of continuing parental care and protection… (Burke).  The government set about ensuring that this part of the mission was met by authorizing reimbursements for other programs.  Consistent with the 1956 law authorized 50 percent Federal reimbursement for rehabilitation services and authorized grants for demonstration projects to reduce dependency and (for four years) for training public welfare personnel, (Burke).

This was not the first time that the Federal government had authorized reimbursement for public assistance programs, but this reimbursement program would shape the future of the modern day child support system in the United States of America.  To further assist the government in trying to locate and hold responsible parents deemed ‘absent’ from the home, more legislation was passed in the mid and late 1960s.  The enacted laws allowed states to request addresses of absent parents from federal social security records and tax records, (Irwin Garfunkel).  During the same period, the government established work programs that were aimed to assist mothers and fathers in getting training and finding employment in preparation to leave welfare. The Work Incentive Program (WIN) was included in the Amendments of 1967.  

There were many financial regulations that included a disregard.  A disregard refers to the amount of income that is not considered when a parent is receiving ADC benefits, and deduction amounts that were to be considered for full and part-time students.  One major provision concerned unemployed fathers, in that and according to Burke, the law required unemployed fathers to have a previous substantial connection to the workforce in order to be eligible for AFDC.  The Federal government froze matching incentive money during this time, as well, in order to minimize the growth of the welfare program. Mothers were required to enroll in WIN too, unless they had children under the age of six living in the home.  Even at this point in the welfare programs, there is no mention, let alone, proposed legislation that suggested that either parent would be held responsible for repayment of the AFDC, now named the Aid for Families with Dependent Children of Unemployed Fathers (AFDC-UF).  

By this moment in child support history, the tone was set and the government had established that unemployed fathers were, singularly, the blame for the living conditions of poor children.  This was, of course, after he had abandoned his wife, children, all familial responsibilities. The narrative was transformed to vilify these fathers and question, morally, how they had left financial responsibilities for their poor and destitute families to the community and the government.  More importantly, how could they be forced to pay for their financially and morally egregious actions. 

Source: Naijaa Parents

During that time, the plan was hatched that fathers had to be forced to pay for their supposed abandonment.  To make it worse, they would be forced to pay even if ‘abandonment’ was not the situation that led to the mother needing financial assistance or the for the father living outside of the home.  In order to strengthen previous child support provisions, the 1974 amendments, effective July 1, 1975, established a new part D to Title IV—Child Support and Establishment of Paternity, (Burke).  States were required to have a child support program in place or face financial penalties, which included, but were not limited to, the loss of Federal incentive monies. 

One key component within the newly implemented child support establishment program concerned how recipients of AFDC (the title had changed yet back) were mandated to participate with the child support program.  Along with the participation mandate, every applicant or recipient was required to “cooperate” in identifying and locating the alleged father, as well as assigning her rights to any child support payments received on her behalf, over to the state.  By signing her rights away to the state, the mother (or custodial parent) forfeits their rights to any child support payments. In exchange, mothers received the monthly stipend and medicaid benefits at the expense of taxpayers.

Source: North Dakota Department of Human Services

According to EveryCRSReport (2018), the primary purpose of the child support program was to reduce public expenditures for recipients of cash assistance by obtaining ongoing support from non-custodial parents that could be used to reimburse the state and federal governments for their part of that assistance.  To be clear, these benefits are awards or grants, and technically do not require repayment by the mothers.  However, the government discovered that by incorporating an old English law, the expenditures spent on providing for poor children and their mothers could be recovered through the filing of a lawsuit and obtaining a judgment through the legal system.  Before the government could justify punishing fathers who allegedly deserted their offspring and who had left all financial burden in the hands of a third party, the government first had to amend the 1975 Child Support Act so that it would include stronger enforcement measures relating to child support collections.  

In 1984, H.R. 4325 was passed that amended part D of title IV of the Social Security Act to:

assure through mandatory income holding, incentive payments to states, and other improvements in the child support enforcement program, that all children in the United States who are in need of assistance in securing financial support from their parents will receive such assistance regardless of their circumstances, and for other purposes.

Financial support from non-custodial parents would initially be gained through income withholding or wage garnishments, however, collections would soon extend to bank seizures, income tax interceptions, and several other sources of income.  All new collection tactics were justified from reimbursement declarations brought forth by the state and federal government.  Welfare programs were initiatives set up by the government to support the poor, developmentally challenged, and disadvantaged group of a country, (Investopedia, 2019).  One of the initial mentions of the idea of repayment by either parent in exchange for public benefits occurred during and after the welfare system in America was ‘reformed’ under Former President Bill Clinton.  Along with bipartisan support, the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1986 was passed and forever changed the dynamics of the welfare and child support systems.  

To be clear, all states require that rights to child support collections be assigned to the government in exchange for cash benefits and Medicaid.  But there are only a handful of states require the same cooperation for other social programs such as the Supplemental Nutritional Assistance Program (SNAP) or food stamps, child care, etc.  This reimbursement for welfare is quite new, however, the idea of reimbursement claims date from hundreds of years ago.  These claims stem from Sir William Blackstone’s commentaries concerning English law which become prevalent in the 1800s. 

Blackstone, in his reference to fathers and their children, determined that there were certain natural responsibilities that should always be fulfilled, despite the relationship (or lack thereof) with the wife.  ‘Wife’ is the only reference that is appropriate when considering common law and third party reimbursement because Blackstone’s laws were written, and only applied to, legitimate children or children born to married parents.  According to Blackstone (1766), the duty of parents to provide maintenance for their children is a principle of natural law.  English and US courts greatly credit Blackstone in the use of the common law remedy as a way for mothers, or the government, to recover monies from fathers when they have allegedly abandoned their offspring.


Source: Jacob from SlideServe

Based on the Guide for Judges in Child Support Enforcement authored by Michael R. Henry and Victoria S. Schwartz (1987), in the late 1300s, English law courts were applying an agency theory to require a father to repay third persons who provided necessaries to the father’s legitimate children.  Initially, there had to be express or specific proof provided of those payments in order to justify the recovery of the money spent on the children.  But the judiciaries in both America and England expanded the actions by allowing third parties to recover for necessaries provided to a man’s wife and for this action, no showing of express agency was necessary, (Henry & Schwartz).  This theory would be implemented, although rather silently, in how the modern day child support and welfare systems operated.

One issue concerning the reimbursement of welfare benefits is that the benefits, as previously mentioned, are grants and not loans, and technically, do not require repayment.  Public assistance programs are funded mostly by taxpayer dollars.  Based on the child support and welfare reimbursement formula, the government, and not the taxpayers, collect and retain the child support payment when rights are assigned to the state.  This means that the government, although charged with facilitating the welfare system and disbursement of benefits, is not completely responsible for funding the programs. If any third party should be repaid for the expenditures spent on providing for the most vulnerable American families, it should be the taxpayers.

The PRWORA implemented strict time limits for which a custodial parent could receive welfare benefits and it required work in exchange for those benefits.  Even with the sweeping changes, there was never any mention of the custodial parent repaying the government for any of the received benefits.  These significant changes were added to the bill, although, there was an absence of an individual mandate or law to require the repayment of the public benefits by the non-custodial parent to a third party.  Instead, the states began filing lawsuits for child support orders, on behalf of the custodial parent, against the man named as the father.

The common law remedy laid the foundation for the US to attempt to recover the costs for the government providing for the so-called ‘abandoned’ children.  According to Henry and Schwartz, many U.S. courts merged these two-statutory remedy and the common law remedy-to create a cause of action on behalf of the mother, as well as on behalf of the third parties, for reimbursement of necessaries provided for children.  Statutory remedies are questionable as they are not uniform across the U.S.  For instance, some states utilize the administrative and hearing process when determining child support, while others use the common law theory.  Both pose equal problems when welfare reimbursement concerns are addressed.

But this method causes a problem, in that, the non-custodial parent (typically the father) is usually ignored when he provides proof of  financially supporting his child(ren) without the need for government interference.  Unfortunately for the defendant or non-custodial parent, (fortunate for the state), the money provided for the child is considered as a gift instead of actual support.  The parent is, essentially, found guilty of failing to provide support. Contrary to the common rhetoric expressed concerning deserting fathers, the custodial parent can apply for and qualify for public benefits, even when the father is financially providing for their child.  

Source: Alen Gabe Law, PC

No matter the circumstances, the custodial parent is still required, minus a ‘good cause’ waiver, to assign their rights to child support over to the state.  There is no requirement that the potential father sign any documentation agreeing to repay any benefits prior to the lawsuit being filed on their behalf for child support collection recovery.  The declaration of support outside of the court system as a gift will be discussed in more detail later.  By ignoring any proof of support during initial child support hearings, the non-custodial parent  is almost always guaranteed to find himself indebted to the government and owing arrears for public benefits already distributed to the custodial parent.  This debt is now owed to the state. 

Child support debt is usually calculated retroactively and the court ordered judgment is usually effective on the birth day of the child.  This occurs whether the alleged father was made aware of the existence of the child by the mother or not.  In many states, no statutory treatment of this issue exists, and the issue rests on common law principles, (Henry & Schwartz).  No matter what remedy a state applies, the fact remains that welfare benefits are grants and do not require repayment by either parent.

Next, as declared in the opinion of the Supreme Court of Georgia in Hooten v. Hooten (1929), under the common law theory, a claim for reimbursement of necessities occurs against a child’s father, to any person, who has provided the child with food, shelter, clothing, medical attention, or education, (Henry & Schwartz).  The keyword in this decision, and in any subsequent use of the common law theory in recovering monies from a third-party, is the word ‘person’.  Since government agencies are legally not considered to be a person, there is no justification for pursuing recovery of welfare benefits on behalf of the government, whether for cash or otherwise.  This rule should be in effect even while the state is collecting and retaining child support payments on behalf of the custodial parent.

As most are aware, the concept of the government filing lawsuits against citizens in an effort to recover monies on behalf of that same government, is not new in the U.S.  As early as the 1800s, the government has filed civil lawsuits against citizens in an effort to recover, mainly, tax debt. According to the Federal Judicial Center (FDJ), the government filed common-law debt actions to recover unpaid taxes and asked courts to condemn and sell goods seized by officials to settle debt due to the government.  Of course, the recovery of a tax debt versus the recovery of a child support debt are, and should be, two completely different recovery processes. 

While paying of taxes are, arguably, mandatory (depending on who you ask), participation in the child support program is (despite some controversy), voluntary.  The Internal Revenue Service (IRS) is clear in that paying taxes is not voluntary.  Any taxpayer who has received more than a statutorily amount of gross income in a given tax year is obligated to file a return for the tax year, (IRS, 2018).  Non-payment means that the government can, and will, pursue the debtor for repayment of the owed taxes.  

In contrast, the creation of a child support debt, especially in Title IV-D cases, is just that, created.  The creation of the child support debt, or arrears, is based not on the laws of taxation, as explained in 26 U.S. Code § 6151-Time and Place for Paying Tax Shown on Returns, but on natural and common law based mostly on Blackstone.  Every jurisdiction has been tasked with deciding its own child support guidelines.  There is a U.S. Code concerning child support, however, nothing is written particularly for the recovery of ‘debt’ accumulated when the government ( and not an individual person) provides for a father’s children.  

The closest reference to debt collection for children receiving welfare benefits can be found in 42 U.S. Code § 652-Duties of Secretary.  Under this section, Certification of Child Support Obligations to Secretary of the Treasury for Collection, it states, in part and according to Legal Information Institute, that,

the Secretary of Treasury, for collection pursuant to the provisions based on Section 6305 of IRS code 1986, the amount of any child support obligation (including any support obligation with respect to a parent who is living with the child and receiving assistance under a state program funded under part A which is assigned to such State or is undertaken to be collected by such state pursuant to Section 454(4) of this title.


Even when reading the IRS code, there is no specific statute or law that mandates that an ‘absent’ or non-custodial parent repay any public benefits provided on behalf of his/her children. If anyone were attempting to justify reimbursement in reference for public benefits through the child support debt collection process, a more believable part of the code can be found in continuing with 42  U.S. Code § 454.  The reasoning supporting this payback theory is that the child support debt must first be certified before collection actions may be initiated.  According to the Legal Information Institute,

no amount may be certified for collection under this subsection except the amount of the delinquency under a court or administrative order for support and upon a showing by the state that such state has made diligent and reasonable efforts to collect such amounts utilizing own collection mechanisms, and upon an agreement that the state will reimburse the Secretary of the Treasury for any costs involved in making the collection.

Even using that part of the legislation is a stretch, to say the least.  There is, again, no direct language that mentions the requirement that either parent to repay public benefits.  Additionally, if one were to be obligated to repay the benefits, the custodial parent is the only one who has entered into an agreement with the government.  Even this agreement requires cooperation with child support enforcement in exchange for public benefits, and mentions nothing concerning repayment of those benefits.  Simply declaring that a policy become policy without executing the proper steps that are required to implement the policy, such a repaying grant money to the government, is both immoral and unconstitutional.   

As mentioned by Henry and Swartz when discussing the use of the common law theory in child support orders to recover welfare benefits, it is not always clear whether the decisions infer the existence of an agreement, or whether the agreement is merely a legal fiction the courts employ to enforce moral duty.  The latter is more plausible when considering the agreement and the volunteer aspect and who is the receiver of the benefits.  The custodial parents, most often mothers, are the consenter to the terms and conditions required to receive benefits. Make no mistake, a parent in need of financial assistance for themselves and their children should be able to receive public benefits, but if anyone should be sued for reimbursement, it should be the receiver.  And since ADC was revamped to TANF and requirements were tightened substantially, custodial parents, in large part, are already paying for those benefits.

Custodial parents were forced to work in exchange for the benefits, which meant that the roles transferred from welfare provider and recipient to employer and employee.  For the government to then force the non-custodial parent to pay for those same benefits that the custodial parent has worked in order to receive, constitutes double payment for a supposedly free taxpayer paid benefit.  These benefits are meant to provide a safety net for low-income and poor parents and children, but has been transformed into a means for the government to profit from the unfortunate circumstances of the most vulnerable citizens.  With the current child support officials claiming that it has a right to collect child support as a third party for providing welfare benefits for needy children, there are other issues besides the absence of statutes and regulations that present a problem.

Source: Twitter

Concerning the cause of action in the common law cases, the basis for launching such a claim are pretty cut and dry when compared to other aspects of the child support program.  According to Henry and Schultz, the elements of the cause of action were as follows:

  • Paternity in the defendant
  • No court order for support ordered by the court
  • His failure to provide support
  • Provision of support by the plaintiff
  • Necessity
  • Reasonableness of the support provider

A conundrum with the causes of action, particularly with his failure to provide support, occurs when the non-custodial parent is not made aware of the birth or existence of the child.  This situation mainly occurs when children are born to unmarried parents and Blackstone’s law of nature, as aforementioned, applied to children born within the contract of marriage.  Because common law remedy allows for the third party to recover expenses already spent by a third party on the wife and children, the recovery of welfare benefits on this basis only apply for costs previously accrued and not for future expenditures.  

After the alleged father has been notified about the child and his possible moral duty to financially provide for the child, the issue arises in that the potential father must be granted the opportunity to provide before any recovery actions can be initiated by the mother or the government.  Based on the case of McSwain v. Holmes, which was decided by the South Carolina Supreme Court, this is a requirement that the plaintiff first demand that the absent parent meet the obligation prior to assuming it and seeking reimbursement, (Henry & Schultz).  By notifying the man, establishing paternity, and allowing him the opportunity to provide both money and medical insurance, there is no need for the initiation of the lawsuit resulting in the judgment to recover the welfare benefits in the first place.  The government justifies the need for court involvement and child support judgments because the father has allegedly, abandoned his child and, therefore, must be legally bound to provide for their children.  

This is contradictory if the father is unaware of the child at all.  State government officials have identified a way to force child support orders and the repayment of the welfare bill onto the shoulders of the non-custodial parent even when the non-custodial parent does provide for their child and provides proof.  Cleverly or deceitfully, whichever satisfies the narrative, judges have been ordered to ignore any money or items such as diapers, clothing, or ever cars for the custodial parents to transport their children, and deem any form of providing for non-residential children  as a gift. Child support paid directly to the custodial parent being considered as a gift by court officials, as mentioned earlier, has a reason that is overwhelmingly beneficial to the state.

Although, child support officials declare that by establishing a child support order and receiving payments through the state, the parent is more likely to receive steady and full child support payments.  However, one of the clear motives that judges have for ignoring payments made outside of the court order is that the welfare benefits can be calculated and added to the total amount of arrears that the non-custodial parent will be forced to pay.  According to the Administration for Children and Families or ACF, many states consider in-kind payments or cash paid directly to the child as gifts, and therefore, do not credit these payments against the child support obligation.  Remember that in order to invoke the common law theory, the financial assistance provided for the child only applies on money already spent.  It cannot apply to current or future spending.

There are several problems with ignoring the money spent on children as it applies to whether or not a child support complaint should filed, let alone ordered.  First, in reference to a parent receiving welfare benefits, a custodial parent can apply and receive public benefits while, simultaneously, receiving money and items from the non-custodial parent on behalf of their child.  Because there is no accountability within the system, there are no child support case workers tasked with verifying that the non-custodial parent is actually failing to provide.  By not having a reliable system in place to track whether this is occurring, there is no actual way to determine if the non-custodial parent is and has been taking care of their children.

It is more beneficial to the custodial parent to withhold the information concerning whether the other parent is providing or not.  Why?  Because he or she can both receive the public benefits and direct child support payments (and items) from the other parent and face no repercussions.   Remember, by law, public benefits are grants and not loans and unless they are found guilty of welfare fraud, there is no requirement that they have to repay the benefits.  

The government has invoked the common law theory in an attempt to recover money from alleged deserters where the only law that is applicable is natural or moral law.  Neither have a standing in the court where child support is concerned and that is the reason that there are no statutes mandating welfare recovery. Additionally, the plaintiff, i.e. the government, must notify the possible defendant that it expects repayment for providing cash, medical benefits, food stamps, child care, etc. for their children.  As it stands, previously and currently, custodial parents are permitted to apply for, and receive, public benefits without the consent of the non-custodial parents.  

Source: CPG Tool Box

There is no need for the non-custodial parent to agree to or even acknowledge that their children will receive public benefits.  If the government is to uphold the common law or even the statutory remedies when attempting to recover welfare costs, the non-custodial parents MUST be made aware of the welfare contract and be offered the opportunity to pay for the offered benefits.  Accordingly, he or she should be required to enter into a contract agreeing to repay said benefits received on behalf of their child. Take for instance the mandate that all custodial parents, minus a good cause waiver, must assign their rights to child support payments over to the state in exchange for TANF and Medicaid benefits.

It is essential to identify not only what the custodial parent is receiving when forfeiting their rights to child support payments, but more importantly, how much the non-custodial parent will be forced to pay for those benefits.   In 2014, a custodial parent receiving benefits in Alabama would receive $215 per monthly cash for herself and two children. Add to that, $215 per child in Medicaid benefits. Excluding any Medicaid that she may receive for herself, the recipient would be forced to sign her rights to child support payments over to the state for a monthly grant of $835 or $8,410 over a six month period.  

Based on the common law theory, after the six months and without all of the other causes of action requirements, the non-custodial parent would be required to repay this money.  Due to the government charging the parent retroactively, he will begin the child support obligation indebted to the state based on a fictitious debt.  The ACF explains in reference to child support collections that,  two parties have claims on child support collections made by the State. If the non-custodial parent does not provide then the child support belongs to the taxpayers.  In the case of families that have received public aid, taxpayers who paid to support the destitute family by providing a host of welfare benefits also have a legitimate claim on the money, (ACF). 

Once again, there is no agreement between the non-custodial parent and the government, either by way of the child support agency or the presiding judge, that justifies a repayment.  Simply by stating that the government has legitimate claim to child support money without implementing actual law, means that there is no legitimate law.  This further verifies that there should never be a child support order issued against the defendant based on the common law theory.  Keep in mind that that all subsequent payments that are supposed to “repay” the government for welfare benefits are now government owned and will be retained by the state.  

This occurs even after the family has left the welfare system.  Because any support that could have been provided has been considered a gift, the full amount of the debt will be due immediately.  Since it would be considered past-due to the state, based on our earlier example in Alabama, the state will be permitted to charge 12% on the newly established and now delinquent, child support debt.  Not only will the non-custodial parent eventually pay for the welfare benefits, since the government has declared itself a third party, in most cases, the state will continue to collect and retain the child support monies paid on that particular Title IV-D case after the custodial parent has exited the welfare system.

Since this has been declared recovery for taxpayer money and the same taxes are being collected for these programs that are not spent the same, where are the tax dollars going?  This is a question that government officials have been reluctant for decades to answer.  In reality, when the government owns the child support case and the arrears, the child is not the true beneficiary of the money collected for child support.  This is true no matter which remedy is used in an effort to collect money from an absent parent.  

By continuing to punish and collect money from non-custodial parents under the common law theory, the government continues to violate the rights of parents by using an already unconstitutional child support system.  If government officials believe that the moral obligation can somehow be made a legal obligation, it should introduce legislation so that it might be passed and implemented. Until that day, all child support debt owed under the Title IV-D program should be erased immediately.  We will continue to fight for justice and reform or The Child Support Hustle will be a problem for future generations.


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EveryCRSReport. (2018, February 14). Child support enforcement annual user fee: In brief. Retrieved from

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Henry, M. R., & Schwartz, V. S. (1987). A Guide for judges in child support enforcement. Retrieved from National Institute for Child Support Enforcement website:

Internal Revenue Service. (2018, March). The truth about frivolous arguments – Section I (a to c). Retrieved November 10, 2019, from

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