Principal, Xamax Consultancy Pty Ltd, Canberra
Visiting Fellow, Department of Computer Science, Australian National University
Version of 22 May 1998
© Xamax Consultancy Pty Ltd, 1997, 1998
This paper comprises one previously published segment, followed by a progress report drafted in June 1997 and completed in December 1997
This document is at http://www.anu.edu.au/people/Roger.Clarke/EC/SVCSwitz.html
I've conducted a considerable amount of field-work in Switzerland. This has been done for the several reasons that I lived there in 1979-82, re-visit frequently, have many contacts there, and speak German; because the patterns of card applications in Switzerland provide an excellent example of the technical and political complexities of advanced financial services marketplaces; and because Switzerland has been an early and effective mover in several areas of electronic commerce.
Prior publications arising from this body of work include:
This present document leverages off the two earlier studies, and examines the implementation of the Proton stored-value card technology by Europay Switzerland.
The document comprises two segments, both based on interviews and visits conducted in Switzerland:
The PTT had commenced a regionally limited trial of stored-value cards in the city of Biel in 1991. When this was completed at the end of 1993, the scheme was left in place, pending a decision on the roll-out of a national scheme. However, when the cards' expiry date was reached at the end of 1994, the scheme was closed.
The Biel trial had confirmed both that a national stored-value card scheme was feasible, and that the architecture and equipment needed to be further developed. The PTT had intended to maintain its momentum towards a national scheme based on a multi-function chip-card, but for two primary reasons, the momentum was lost between 1993 and 1996. These were:
During 1995-96, a company called Telekurs has been preparing to implement a stored-value scheme branded ec-Cash. Telekurs is the joint venture company of the major banks which operates a front-end service for them. Its marketing arm, Europay Switzerland, holds the local franchise for Brussels-based Europay International. Unlike Visa and MasterCard, which are international associations comprising about 20,000 financial institutions from all over the world, Europay is an association of national associations, each of which has financial association members from within a single country. Europay International owns brands, provides international services, and franchises the brands to a company in each European country;
The impulse for the ec-Cash initiative was the opportunity afforded by the re-issue of ec-Direct cards to the entire population of 2.5 million ec-Card holders, during the second half of 1996 and the first half of 1997. All cards are to be re-issued bearing a chip and the appropriate software, ready for use in a nationwide value-card system which is scheduled to commence at the beginning of 1997.
Unlike the approach being taken in all other countries, no field trial is being undertaken, because the product is already proven. An internal trial is scheduled to commence in July 1996, involving Telekurs's 1,350 local employees and its in-house vending machines and restaurants.
The ec-Cash product is an implementation of a Belgian product which is known variously by the name of the company that provides it (EPSys), the name of the software product for the host processing system (Banksys), and the name of the chip on the card (Proton).
The Belgian scheme is to be adopted without any modifications. The reason for this is to achieve a fast launch, without the delays inherent in multilateral negotiation. It is to be a closed system, in the sense that the interface specifications will not be published, and hence the cards and the terminal components will only be available from a single source; and Payserv will be the only transaction acquirer, as well as the scheme operator. Europay Switzerland acknowledges that it is an interim arrangement, in that an open system will be necessary at a later stage, integrated with EFT/POS terminals.
The ec-Cash product involves off-line, PIN-less transactions, which require only 3-4 seconds to complete. There are no communication costs involved at the transaction level, but Europay Switzerland will be collecting commission of 2 cents per transaction plus 0.7% of transaction value.
Three different terminal types are involved:
The interface to electronic cash registers is defined and published.
The terminals are being marketed to merchants directly and exclusively by Europay Switzerland, although banks may at some stage market to their merchant clients. The company is aiming for 10,000 terminals by the end of 1996, and 70,000 by the end of 1998.
The price-list for the terminals involves a significant subsidy by the banking community to retailers. The current indicative cost-price to Europay is SF500 (although that may ease further downwards as volumes increase), whereas the sale-price until July 1997 is SF200 for a single unit, ranging down to SF100 for lots of greater than 100 units. This will be increased after mid-1997, and it is intended that the subsidy cease at the end of 1998.
Transaction data must be downloaded by the merchant at least once per week. This can be performed using a modem and dial-up connection or the national X.25 network, Telepac. An automated download can be arranged, for example each evening. Vending machines without a telephone connection are supported by a serial-connection download to the merchant's own laptop or palmtop, with subsequent transmission to Europay. A bulk credit is to be made to the merchant's account "within a few workdays" of the transaction download.
Data is transferred at the individual transaction level, without consolidation; but no long-term transaction trail is to be kept. It appears that the card may retain a record of the last few transactions, as well as the current balance.
The cards will be issued by financial institutions, and subject to terms and conditions, and one-time and periodic fees, determined by the issuer. Some banks may choose to co-badge the card, for example with a retail chain. Both personalised cards (linked with a specific bank-account) and non-personalised cards will be available (although non-personalised cards may be limited to visitors and children). It is unclear whether it is practicable at this stage for an ATM be used to load value onto a non-personalised card, because that would involve a two-stage process, with first a debit- or credit-card being inserted into and removed from the slot, and then the ec-Cash card inserted and removed.
The scheme is intended to provide comprehensive coverage of points of sale at which small-value transactions are conducted, in particular vending machines of various kinds. Europay Switzerland sees parking houses and public transport as being of particular importance.
The card is to be able to be loaded at any of the ATMs operated by the banks (Bancomat) or the PTT (Postomat). Payserv has indicated a maximum value on the card of SF300 (which is the average value withdrawn at ATM's), although this is subject to decisions by individual issuing banks.
Delays in delivery of the core module by the supplier Ascom Autelca have seen the planned completion of ATM modification ease back from the end of 1996 to mid-1997, but 60-70% are to be converted by the planned launch-date in January 1997. At present, no other loading-points are planned. Telephones are not feasible (because there are vast numbers of them that would require conversion, and they already have a chip-reader in them which supports the Bull card on the PTT's PostCard). However some EFT/POS terminals may be able to be converted at a later stage.
A backload of value from the card to an account will be permitted, but not encouraged. There will be a delay of 7 days before the credit is granted, to ensure that reconciliation can be readily undertaken between the card and the database. This may render the product inconvenient for Switzerland's many short-term visitors.
The product is being positioned as a replacement for coins rather than notes, and early promotional literature uses the expressions 'the electronic purse' and 'better than coins'. The target transactions are those in the SF 0-25 range (Switzerland's largest coin is SF5, and its smallest note SF10, with a Frank approximately at parity with an Australian dollar but with less local purchasing power). There is no intention to cannibalise the well-established business of the ec-Direct debit-card (indicative value-range SF20-150) and the EuroCard credit-card (which is used for transactions whose value ranges upwards from SF20). The pricing has been set such that it breaks even with ec-Direct fees at a transaction-value of SF50, and is more expensive at higher values.
Faced with the Telekurs/Europay initiative, the PTT decided not to respond in a directly competitive fashion, but has instead entered into a strategic alliance with Telekurs in relation to the stored-value scheme. This reflects the PTT's long-standing desire to see a collaborative, chip-based stored-value card scheme launched. Europay Switzerland anticipates that the PTT will issue of the order of 0.5 million non-personalised cards.
Also as part of the alliance, the PTT's 500 Postomat ATMs and the banks' 3,500 Bancomat ATMs will at last all accept one another's cards. This appears to be a greater gain for the PTT than for the banks; but, on the other hand, PostCard withdrawals are gratis at Postomats whereas Payserv will levy SF3 per transaction at Bancomats.
The arrangement is problematical from a technical perspective. The PTT's 1.3 million PostCards already carry an ISO7816 chip, a Bull chip which performs the on-line debit-card and Postomat ATM functions. An additional or alternative PostCard will now need to be issued bearing the Proton chip. The two will, of course, be mutually exclusive; and on the new PostCard, the debit-card and ATM functions, if offered at all, will have to migrate back to the magnetic-stripe.
The existing 4,000 ATMs and 21,000 EFT/POS terminals require modification to support the Proton chip-based stored-value function. The banks and the PTT are committed to a fast conversion of their ATMs to support it. In the case of Postomats, it appears that the modifications will be software-only, and that some of the more recently installed devices may be able to modified by downline-load. The Bancomat ATMs, on the other hand, generally do not currently cater for chip-cards, and will require hardware modifications. This may be difficult and expensive, especially in the case of the older machines, and there has to be doubt that the conversion can be substantially completed by the impending launch-date.
Payment terminals are owned by the merchants, not the financial institutions. The merchants appear to be unenthusiastic about the re-investment necessary to enable them to support the ec-Cash stored-value function. The VEZ has expressed concerns about a number of aspects of the scheme, including its incompatibility with the (emergent) EMV specifications, the relatively closed nature of the scheme (which implies limited competition and hence relatively high prices for equipment), and the pricing.
Even in the case of unattended points of payment, some difficulties exist. In particular, the PTT has no plans to convert its public telephones to accept the new card (because the module is too large and too expensive, the Europay Switzerland charges are too high, and the programme to modify telephone cabins to accept the PostCard is only just being completed). It is not clear that the Swiss Railways (SBB) - also a member of VEZ - will be interested in converting its ticket-issuing terminals, or installing new ones; and it has no plans to install EFT/POS terminals at its points of ticket-sale before the year 2000. Moreover, the largest operator of vending machines in the country, Selecta, is a Migros subsidiary.
For its part, the PTT is wary of the potential for Telekurs, through its Payserv operation, to dominate Switzerland's transaction acquisition and clearance system, by migrating it from the present multi-connection pattern to a central switching mechanism with Payserv as the hub. It is also not clear that the PTT will market its PostCard ec-Cash option particularly aggressively, which makes Europay Switzerland's projection of 0.5 million ec-Cash-enabled PostCards more likely in the medium-term than in 1997.
Telekurs is adopting a 'brute-force' approach to the implementation of the ec-Cash scheme, by flooding the market with cards and, to a lesser extent, with card-accepting terminals. The lessons of earlier pilots have been that 'critical mass' is a more delicate flower than that. It is vital that each card-holder perceives a critical mass of points of payment at which he or she can use the card; and that each merchant perceives a critical mass of card-holders who present at their point of payment. This appears more likely to be achieved through careful market segmentation and targeted promotion than by mass launch.
Once again, Switzerland is providing the world with a highly valuable chip-card pilot that deserves close attention.
Europay (Switzerland) SA is that country's member of the European banking services consortium which provides the international EuroCard/MasterCard credit-card; the EC-card for ATM-withdrawals, debit-card and cheque-guarantee; the EC-Direct debit-card (Switzerland-only); and the Maestro debit-card (international). It is a subsidiary of Telekurs Holding AG, which is owned by the major Swiss banks. Telekurs provides common services, including the online front-end for ATM and EFT/POS networks.
Independently of Europay, Europay (Switzerland) is implementing a stored-value card under the brand-name CASH. It uses the Belgian Proton card and BankSys software. The project was conceived in 1995, prepared in 1996, and launched on 29 January 1997. The project was decribed in this author's 'Chip-Based Payment Schemes' publication of September 1996, at pp. 68-72, reproduced above.
This document is based on:
It commences by summarising the organisation's original plans, and then presents information on card-issue, value-loading devices, card-accepting devices, and the business politics aspects of promotion, and alliances.
Europay (Switzerland) has adopted a strategy of up-front, breakthrough investment. During 1996-97, all of the country's 2.5 million ec-Cards, which support ATM-withdrawals and can be used as a cheque-guarantee cards, were due to be replaced. This was perceived as a rare opportunity to place an SVC in the hands of 50% of the people aged between 15 and 65 years of age, throughout the country.
The target was cash transactions up to 25 Swiss Franks (SF), especially coin-based transactions. (The largest coin is SF5, and the smallest note SF10). Europay's market research had suggested that consumers are most interested in using cards for telephones, public transportation tickets, parking, and vending machines.
The card-loading devices were to be ATMs only, but all ATMs in the country. Card-accepting devices were to be sold to merchants, initially at substantial discounts. The stated targets were 10,000 card-accepting terminals installed by the time of intended launch at the end of 1996, 20,000 by the end of 1997, and 70,000 by the end of 1998. Transactions were to be downloaded at least once per week, by direct-dialup or via the national X.25 network, Telepac (which uses the same French technology as Austpac). Automaten (vending machines) were to be unloaded onto portables by the same staff who loaded and serviced them.
Merchants were to be charged a fee of SF0.02 per transaction plus 0.7% of the transaction-value. This produces a fee of SF0.09 for a transaction of SF10 (0.9%), and SF0.027 for a transaction of SF1 (2.7%). This was designed so as to overtake the cost of debit-card transactions at SF50 (SF0.37 or 0.74%), and hence establish a disincentive against the cannibalisation of debit-card volumes.
The cards differ in appearance from their predecessors to the extent that they carry the chip, and a small CASH logo, additional to the EC and bank logos. In some cases the CASH logo appears only on the back of the card, and in others it appears on both sides. The re-issue cycle for the existing base of multi-function ec-Cards (cheque-guarantee card, ATM-card, debit-card) is being completed in December 1997, and there are now 2.5 million chip-bearing ec-Cards in the field. Financial institutions have made personal balance-readers available to their customers.
The PTT has also adopted the scheme, and, in October 1997, commenced the issuing of an additional kind of PostCard (a blue one), which includes the CASH capability. There are 1.6 million PostCards in circulation, (predominantly in the hands of relatively less well-off people). The blue PostCard is intended to complement the PTT's mainstream white PostCard (which is an ATM and debit-card, both on chip) and black PostCard (which is a credit-card on magnetic-stripe).
A special issue of 70,000 CASH cards was prepared for the Montreux Jazz Festival in July. The Festival has previously used a special Jazz coinage rather than Swiss cash. In 1997, this was complemented by the ec-CASH card, which achieved 30% market share. In 1998 and 1999, the coinage is no longer being used, and the ec-CASH card will be the official payment mechanism of the event.
A further set of cards exists. Europay printed 100,000 simple blue cards, which are current until the end of 1999. A small number have been used in promotions and demonstrations. A commitment has now been made to over-print 15,000 of them and issue them as a regional card in the upper-crust resort of Gstaad. Europay will be the scheme-operator, but will share the proceeds with the local government sponsor. This approach is being investigated with other resorts, as a means of overcoming the difficulties involved in co-branding between large, nationally operating financial institutions on the one hand, and regional governments on the other.
The sole means of loading value onto cards is by by transfer from debit-cards or credit-cards at ATMs. There are about 3,600 bank ATMs, which use the trademark `Bancomat', and which are supported by Telekurs on behalf of all banks. Conversion of all Bancomats was completed in mid-1997.
The loading procedure is straightforward, at least in the normal case of cross-loading from a debit- or credit-function within the same card. The Bancomat terminals also support unloading of value from the chip, and the display of card-balance and of the most recent transactions,
The PTT also has ATMs, which go under the brandname 'Postomat'. There are about 500 of them, and their conversion is under way at present. When this is completed, all ATMs will accept both ec-Cards and PostCards, primarily for cash-withdrawals. (The fee for 'foreign' withdrawals is to be SF3, considerably more than in Australia). This represents a considerable change in the relationship between the banks and the PTT, which was previously directly confrontationist.
Three card-accepting terminal devices are being sold to merchants:
Volume discounts reduce the price for more than 100 terminals by 50%, 20% and 10%.
Europay (Switzerland) has (15?) staff on the road signing contracts for the installation of card-accepting devices. A company associated with BankSys (Belgium), EPSys, is responsible for installation.
By launch-date on 29 January 1997, close to 5,000 terminals were in operation. At 13 March the count was 5,368, at the end of May 8,500 (the original plan was 11,000), and at the end of November about 14,000 (compared with an original commitment of 20,000, reduced in mid-1997 to 15-20,000).
Technical difficulties were encountered, particularly with the vending-machine version, and this was one factor in the slower-than-planned rate of installation. Another important factor was that almost all of the sales have been for a single terminal, or for a small number of them. The reason why large merchants have withheld their support is discussed later, under the heading of business politics.
The terminals are widely distributed, with far greater acceptance within the French-speaking third of the country than in German-speaking areas. The distribution among types of merchants is similarly very broad.
The procedure involved in payment is that the card is placed in the slit in the terminal, the value of the sale is selected or calculated, a key is depressed by the card-holder to approve the deduction from the card-balance, the amount is deducted, the goods are delivered or the services performed, and the card is retrieved. The terminals also provide the capability for card-holders to display the remaining balance on the chip.
The large Glatt shopping centre, 10km out of Zürich, and close by Europay's head office was mentioned by both Europay staff and SBG/UBS as having a high concentration of terminals. The statistics provided suggested 164 terminals in 133 merchant locations. A walk around two of the three floors located only a single sign indicating that CASH was accepted (an upmarket flower-shop), and no terminals were visible.
In June 1997, Europay stated that a number of associations and communities have committed to general implementation of CASH. Examples included a taxi cooperative in Zürich (Taxi 2000, with 330 cabs), the small community of Schüpfheim near Luzern, and several other towns and villages including Rieden (also near Luzern), and Thalwil (near Zürich). Resorts (very up-market Gstaad and Leukerbad were mentioned) were also interested in making the application of CASH general within their areas.
In December 1997, the following were mentioned as being market segments in which significant progress had been made:
At this stage at least, there are no plans for the existing 3,500 off-line debit petrol-station terminals to be modified to accept the card, nor for the large and still-growing population of EFT/POS terminals (over 30,000 of them) to be converted. Debit-card volumes are continuing to explode, in a manner similar to the recent experience in Australia (e.g. the transaction-count at Migros increased by 66% from 1995 to 1996, and a further 876 terminals were installed during 1996, bringing the count to 3,000).
At this stage at least, there also appear to be no plans for the PTT to convert its public telephones. Nor is there any evidence of the country's primary rail services provider, SBB, planning to adopt the scheme. Moreover, the major vending-machine operator, Selecta, which also holds the Coca-Cola distribution licence, is a Migros subsidiary. It has, however, modified machines installed on Telekurs premises.
A campaign was run in early 1997 to familiarise the public with the concept and product. It used humour, and focused heavily on the inconvenience of coins and change. The current focus of promotion is the Montreux Jazz Festival (4-19 July). CASH has been established as the festival's "official electronic payment mechanism", and a special card has been designed, to service the needs of visitors (and to be attractive to card-collectors).
A further promotional campaign is to be anticipated after people return from the summer holidays of July/August. This is likely to feature continued stress on the inconvenience of coins and the counting and handling of change, and the relevance of CASH to daily purchases. It may include some form of incentive or reward scheme. A current idea is to create a roadshow that depicts a day in the life of two people, one of whom uses CASH and the other cash. It is also intended to establish a page on the Internet that identifies locations where the card can be used (see http://www.telekurs.com or http://www.europay.ch).
Europay made available some preliminary statistics on volumes during the first 10 weeks after the scheme's launch, to 11 April 1997. These showed that 75,000 of the (maximum 2.5 million, perhaps actually 1 million?) chip-based cards that were by then on issue had been loaded with value, averaging SF90 per load. Allowing for, say, 20-30% of these being re-loads, this suggests that perhaps 2-5% of the cards had been loaded with value.
389,000 transactions were recorded during the period, for a total value of SF1.2 million, and an average transaction-value of SF3 (which probably reflects careful experimentation on the part of consumers, with low-value transactions initially). The fees arising from this volume would have been SF16,180.
On the basis of very limited sampling, there would appear to be a modest level of awareness among consumers of the existence and availability of the capability. Among those people who are aware of the scheme, there would appear to be small proportions of enthusiasts and active opponents, a larger proportion of sceptics who are waiting to see whether the scheme takes off, and a majority who are apathetic about it.
Reactions among the media and the general public have varied considerably. Some fairly negative reports have been published, but so have positive ones. Europay staff depicted public attitudes as being primarily cautious and sceptical. No major fire-fighting exercises appear to have been undertaken.
An article in a consumer magazine, KTip, in November 1996 summed up consumers' concerns and criticisms as follows:
Understanding about the scheme would appear to be held back by the considerable public confusion about the range of payment cards and services. To many people, even the difference between deferred-payment charge-cards, revolving-credit credit-cards, and pay-now debit-cards is not clear. Added to this is the fact that the term in common use for the most common card, 'ec-Card', does not describe any of the card's existing functions (cheque-guarantee, authentication at ATMs, and debit-card).
The enhancement of the ec-Card's functions to include a fourth, 'pay-before'/'stored-value'/'electronic cash' capability, despite the inclusion of a small 'CASH' logo on the card, and the visibility of the chip, is not easily communicated to the public. One further small element of confusion is that the first general appearance of a chip on cards was on the PTT's 1.6 million PostCards, which do not provide an SVC, but rather ATM and debit-functions. Moreover, the PostCard has the image of a 'working-class' card, rather than being perceived as the card of a high-spender or an early-adopter.
Europay staff are candid that they have been to date largely unable to address the kinds of payments that the market research suggested as being of the greatest importance to consumers. Among vending machines, mention was made of a pilot in Morges and Yverdon relating to newspapers, and another in Lausanne relating to car-parking (involving both a parking-house and parking-meters).
A powerful merchants' association exists, the VEZ (Verband Elektronischen Zahlungsverkehr - association for electronic payment traffic). Chaired by an executive of the largest retail conglomerate, Migros, VEZ comprises the major merchant chains, the PTT, the railways (SBB), and a significant number of smaller merchants and associations.
The VEZ's position has been unequivocal opposition to the scheme, and none of its members are participating. As reported in my 'Chip-Based Payment Schemes' study (p.68), the VEZ, in combination with the banks, is working on a future payment scheme, intended for implementation in 2000, which would encompass pay-before, pay-now and pay-later capabilities, and would support a very wide range of cards, all of which would be supported by every POS terminal. It seeks to limit confusion, and exploit the investments made to date, by avoiding any further interim measures.
The VEZ claims that Europay have undertaken the CASH project without any consultation with the merchants, and are using it as a means of wresting control of payment and clearing systems back to the banks. An article in a consumer magazine, KTip, in November 1996 summed up the merchants' concerns and criticisms as follows:
It appears that, in an endeavour to address the perception of excessively high fees, Europay may have adjusted the tariff downwards, at least for very large merchant chains, by scaling the SF0.02 fixed charge per transaction downwards to SF0.01, or perhaps even as low as SF0.003, depending on volumes.
VEZ was originally formed to represent merchants' interests in relation to EFT/POS. SVCs generally, and the CASH-function of the ec-Card in particular, are targeted at transactions whose values are significantly lower than the average purchase at an EFT/POS terminal. It may therefore be feasible for Europay to perform an 'end-run' around VEZ's opposition, if they are successful in gaining acceptance from merchants who deal in small-value transactions.
That endeavour is, however, confronted by significant difficulties, including the concentration of many of these businesses in large conglomerates (PTT for telephones and regional buses; SBB for trains; Migros for a variety of stores and vending machines; and kiosks, i.e. small newsagencies), and the dispersion of others among many small enterprises that are not experienced in using payment technologies (e.g. fast-food outlets or Imbissstuben; cafés; and perhaps taxis).
A press report suggested that the cards cost SF22 each compared with SF12 for the non-chip card. Across a card-base of 2.5 million, this is an investment of SF25 million, up-front in 1996-97. The ATM conversion was reported to cost SF5,500 per machine (this sounds high; but Ascom Autelca does enjoy a monopoly position in ATM security-module provision). If it is correct, then the 4,000 ATMs will have cost over SF22 million to convert, up-front in 1996-97. If the terminals actually cost SF500-700, and 15,000 are installed by the end of 1997, that will be about SF9 million in 1997, and a further SF33 million for 55,000 more in 1998.
On the above assumptions, the total investment during 1996-97 would be about SF50 million by the banks, SF3 million by the PTT, and SF3 million by merchants. Investment in 1998 would be SF33 million by merchants. [This back-of-the-envelope analysis cheerfully assumes that the running costs are negligible in comparison with the set-up costs].
If the average fee per transaction paid to the banks were SF0.025, then simple payback on the banks' investment would be of the order of 2 billion transactions, or more like 3 billion to allow for progressive take-up and interest costs; and this assumes that the PTT and merchants justify their own investments in other ways. A volume of less than 400,000 transactions during the first 10 weeks, or perhaps 4-6 million in the first year; the active opposition of the major merchants; and limited consumer awareness of and interest in the scheme; all suggest that this volume will not be simple to achieve.
In Australia, despite the enthusiastic way in which consumers have adopted some new forms of technology (e.g. ATMs, faxes, and mobile phones), debit-cards were little-used until an 'any-card/any-terminal' capability was achieved. A study of the Migros EFT/POS scheme that I published in 1992 identified that the key factors associated with the debit-card's breakthrough in Switzerland were a close understanding of consumer needs, and a win-win-win arrangement among the participants in the scheme.
On the basis of the information available to date about the Europay Switzerland CASH project, the same messages would appear to apply to the conception and implementation of stored-value schemes. A mass release / 'flood the market' approach appears, by itself, to be insufficient to assure breakthrough.
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Created: 22 May 1998
Last Amended: 22 May 1998
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