Bush v. Blink Charging Company et al
Federal Civil Lawsuit Florida Southern District Court, Case No. 1:20-cv-23527-KMW
District Judge Kathleen M. Williams, presiding

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Last Updated April 20, 2021 at 4:49 PM DT (3.6 weeks ago) Request Update Request UpdateSpaceE-Mail Alert Get E-Mail Alerts

No Logo Richard Maurice Bush, Plaintiff

Toggle Switch Represented by Block & Leviton LLP

Name Phone Fax E-Mail
Space Jeffrey Craig Block +1 617 398 5600 +1 617 507 6020 jeff@blockleviton.com
Space Jacob A Walker +1 617 398 5600 +1 617 507 6020 jake@blockleviton.com

Toggle Switch Represented by Cullin O'Brien Law, PA

Name Phone Fax E-Mail
Space Cullin Avram O'Brien +1 561 676 6370 +1 561 320 0285 cullin@cullinobrienlaw.com
v.
Blink Charging Co. Blink Charging Co., Defendant
Officially listed as "Blink Charging Company"
Disclosed Consulting Vendor, Balance Labs, Inc.

Toggle Switch Represented by Holland & Knight, LLP

Name Phone Fax E-Mail
Space Tracy Ann Nichols +1 305 374 8500 +1 305 789 7799 tracy.nichols@hklaw.com
Space Stephen Patrick Warren +1 305 349 2256 +1 305 789 7799 stephen.warren@hklaw.com
No Logo Farkas, Michael D., Defendant
Officially listed as "Michael D. Farkas"
Chairman, CEO and Director, Wealthhound Com Inc
Beneficial Owner, Atlas Equity Group Inc
Shareholder, Schoolwurks, Inc.
President, Farkas Group Inc
No Logo Michael P. Rama, Defendant
No Logo Alexander Yu, Movant

Toggle Switch Represented by Buckner+Miles

Name Phone Fax E-Mail
Space David Buckner +1 786 523 0480 +1 786 523 0485 David@bucknermiles.com
No Logo H. Marc Joseph, Movant

Toggle Switch Represented by Buckner+Miles

Name Phone Fax E-Mail
Space David Buckner +1 786 523 0480 +1 786 523 0485 David@bucknermiles.com
No Logo Hamit Tamer Adiguzel, Movant

Toggle Switch Represented by Cullin O'Brien Law, PA

Name Phone Fax E-Mail
Space Cullin Avram O'Brien +1 561 676 6370 +1 561 320 0285 cullin@cullinobrienlaw.com
No Logo Mark J. Friedman, Movant

Toggle Switch Represented by Rosen Law Firm PA

Name Phone Fax E-Mail
Space LAURENCE M. ROSEN +1 973 313 1887 +1 212 202 3827 lrosen@rosenlegal.com
No Logo Tianyou (Steven) Wu, Movant

Toggle Switch Represented by Shepherd, Finkelman, Miller & Shah, LLC

Name Phone Fax E-Mail
Space Jayne A. Goldstein +1 954 515 0123 +1 954 515 0124 jgoldstein@sfmslaw.com
No Logo Gina F. Vittoria, Consol Plaintiff

Toggle Switch Represented by Shepherd, Finkelman, Miller & Shah, LLC

Name Phone Fax E-Mail
Space Jayne A. Goldstein +1 954 515 0123 +1 954 515 0124 jgoldstein@sfmslaw.com
Office Miami
Filed 8/24/2020
Jury Demand Plaintiff
Demand
Nature of Suit 850 - Other Statutes: Securities/Commodities/Exchange
Cause Section 12 U.S.C. § 0022 Securities Fraud
Jurisdiction Federal Question
Disposition
County Miami-Dade (Office - Miami)
Terminated
Origin 1
Reopened
Lead Case
None
Related Case
None
Other Court Case None
Defendant Custody Status
Flags CONS_LEAD,EGT,REF_PTN
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Legal Document 47 Filed: 4/20/2021, Entered: None Dismiss for Failure to State a Claim
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Legal Document (Payment Possibly Required) 45 Filed: 4/13/2021, Entered: None Notice (Other)
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    Legal Document (Payment Possibly Required) 43 Filed: 4/12/2021, Entered: None Notice of Change of Address, Email or Law Firm Name
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      Legal Document (Payment Possibly Required) 42 Filed: 4/9/2021, Entered: None File Excess Pages
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        Legal Document (Payment Possibly Required) 41 Filed: 3/4/2021, Entered: None Notice of Attorney Appearance
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          Legal Document 40 Filed: 2/19/2021, Entered: None Amended Complaint/Amended Notice of Removal
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            Legal Document (Payment Possibly Required) 38 Filed: 1/19/2021, Entered: None Appear Pro Hac Vice - aty
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              Legal Document (Payment Possibly Required) 36 Filed: 1/4/2021, Entered: None Appear Pro Hac Vice - aty
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                Legal Document 34 Filed: 12/28/2020, Entered: None Extension of Time to Amend
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                  Legal Document (Payment Possibly Required) 31 Filed: 12/23/2020, Entered: None Appear Pro Hac Vice - aty
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                    Legal Document 29 Filed: 12/21/2020, Entered: None Order on Motion to Appoint Lead Plaintiff
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                      Legal Document 28 Filed: 11/13/2020, Entered: 11/13/2020 Reply to Response to motion
                      REPLY to Response to Motion re [21] MOTION to Appoint Lead Plaintiff Alexander Yu and H. Marc Joseph MOTION to Appoint Lead Counsel Hagens Berman Sobol Shapiro LLP , [23] MOTION to Appoint Lead Plaintiff Tianyou (Steven) Wu MOTION to Appoint Lead Counsel Jayne A. Goldstein filed by H. Marc Joseph, Alexander Yu. (Buckner, David)
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                        Legal Document (Payment Possibly Required) 27 Filed: 11/6/2020, Entered: 11/6/2020 Response in Support of Motion
                        RESPONSE in Support re [21] MOTION to Appoint Lead Plaintiff Alexander Yu and H. Marc Joseph MOTION to Appoint Lead Counsel Hagens Berman Sobol Shapiro LLP , [23] MOTION to Appoint Lead Plaintiff Tianyou (Steven) Wu MOTION to Appoint Lead Counsel Jayne A. Goldstein filed by H. Marc Joseph, Tianyou (Steven) Wu, Alexander Yu. (Attachments: # (1) Affidavit Declaration of David M. Buckner with Exhibits)(Buckner, David)
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                          Legal Document 26 Filed: 11/6/2020, Entered: 11/6/2020 Notice - other
                          NOTICE by Mark J. Friedman re [20] MOTION to Appoint Lead Plaintiff Mark J. Friedman MOTION to Appoint Lead Counsel The Rosen Law Firm, P.A. NOTICE OF NON-OPPOSITION OF MOVANT MARK J. FRIEDMAN TO COMPETING MOTIONS TO APPOINT LEAD PLAINTIFF AND APPROVE SELECTION OF COUNSEL (Rosen, Laurence)
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                            Legal Document 25 Filed: 11/6/2020, Entered: 11/6/2020 Notice - other
                            NOTICE by Hamit Tamer Adiguzel re [20] MOTION to Appoint Lead Plaintiff Mark J. Friedman MOTION to Appoint Lead Counsel The Rosen Law Firm, P.A. , [24] Affidavit in Support of Motion, [22] Memorandum, [21] MOTION to Appoint Lead Plaintiff Alexander Yu and H. Marc Joseph MOTION to Appoint Lead Counsel Hagens Berman Sobol Shapiro LLP , [23] MOTION to Appoint Lead Plaintiff Tianyou (Steven) Wu MOTION to Appoint Lead Counsel Jayne A. Goldstein , [19] MOTION to Appoint Lead Plaintiff Hamit Tamer Adiguzel MOTION to Appoint Lead Counsel Levi & Korsinsky LLP (O'Brien, Cullin)
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                              Legal Document (Payment Possibly Required) 24 Filed: 10/23/2020, Entered: 10/23/2020 Affidavit in Support of Motion
                              AFFIDAVIT in Support re [23] MOTION to Appoint Lead Plaintiff Tianyou (Steven) Wu MOTION to Appoint Lead Counsel Jayne A. Goldstein filed by Tianyou (Steven) Wu. (Attachments: # (1) Exhibit A - Press Release, # (2) Exhibit B - Certification, # (3) Errata C - Loss Chart, # (4) Exhibit D - Wu Declaration, # (5) Exhibit E - Pomerantz Resume, # (6) Exhibit F - SFMS Resume)(Goldstein, Jayne)
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                                Legal Document (Payment Possibly Required) 23 Filed: 10/23/2020, Entered: 10/23/2020 Motion to Appoint Lead Plaintiff
                                MOTION to Appoint Lead Plaintiff Tianyou (Steven) Wu ( Responses due by 11/6/2020), MOTION to Appoint Lead Counsel Jayne A. Goldstein by Tianyou (Steven) Wu. Attorney Jayne Arnold Goldstein added to party Tianyou (Steven) Wu(pty:mov). (Attachments: # (1) Text of Proposed Order, # (2) Memorandum)(Goldstein, Jayne)
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                                  Legal Document (Payment Possibly Required) 22 Filed: 10/23/2020, Entered: 10/23/2020 MEMORANDUM
                                  MEMORANDUM in Support re [21] MOTION to Appoint Lead Plaintiff Alexander Yu and H. Marc Joseph MOTION to Appoint Lead Counsel Hagens Berman Sobol Shapiro LLP by H. Marc Joseph, Alexander Yu. (Attachments: # (1) Appendix Declaration of David M. Buckner in Support of Motion of Alexander Yu and H. Marc Joseph for Appointment as Lead Plaintiff and Approval of Selection of Counsel)(Buckner, David)
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                                    Legal Document (Payment Possibly Required) 21 Filed: 10/23/2020, Entered: 10/23/2020 Motion to Appoint Lead Plaintiff
                                    MOTION to Appoint Lead Plaintiff Alexander Yu and H. Marc Joseph ( Responses due by 11/6/2020), MOTION to Appoint Lead Counsel Hagens Berman Sobol Shapiro LLP by Alexander Yu, H. Marc Joseph. Attorney David Buckner added to party Alexander Yu(pty:mov), Attorney David Buckner added to party H. Marc Joseph(pty:mov). (Attachments: # (1) Text of Proposed Order Granting Motion of Alexander Yu and H. Marc Joseph for Appointment as Lead Plaintiff and Approval of Selection of Counsel)(Buckner, David)
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                                      Legal Document (Payment Possibly Required) 20 Filed: 10/23/2020, Entered: 10/23/2020 Motion to Appoint Lead Plaintiff
                                      MOTION to Appoint Lead Plaintiff Mark J. Friedman ( Responses due by 11/6/2020), MOTION to Appoint Lead Counsel The Rosen Law Firm, P.A. by Mark J. Friedman. Attorney Laurence Matthew Rosen added to party Mark J. Friedman(pty:mov). (Attachments: # (1) Declaration of Laurence M. Rosen, # (2) Exhibit 1 - PSLRA Notice, # (3) Exhibit 2 - PSLRA Certification, # (4) Exhibit 3 - Loss Chart, # (5) Exhibit 4 - Firm Resume, # (6) Text of Proposed Order)(Rosen, Laurence)
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                                        Legal Document (Payment Possibly Required) 19 Filed: 10/23/2020, Entered: 10/23/2020 Motion to Appoint Lead Plaintiff
                                        MOTION to Appoint Lead Plaintiff Hamit Tamer Adiguzel ( Responses due by 11/6/2020), MOTION to Appoint Lead Counsel Levi & Korsinsky LLP by Hamit Tamer Adiguzel. Attorney Cullin Avram O'Brien added to party Hamit Tamer Adiguzel(pty:mov). (Attachments: # (1) Memorandum MEMORANDUM OF LAW IN SUPPORT OF HAMIT TAMER ADIGUZELS MOTION FOR CONSOLIDATION OF THE RELATED ACTIONS, APPOINTMENT AS LEAD PLAINTIFF, AND APPROVAL OF SELECTION OF COUNSEL, # (2) Affidavit DECLARATION OF CULLIN OBRIEN IN SUPPORT OF MOTION OF HAMIT TAMER ADIGUZEL FOR CONSOLIDATION OF THE ACTIONS, APPOINTMENT AS LEAD PLAINTIFF, AND APPROVAL OF SELECTION OF COUNSEL, # (3) Exhibit Exhibit A to Declaration - PSLRA Certification, # (4) Exhibit Exhibit B to Declaration - Loss Chart, # (5) Exhibit Exhibit C to Declaration - PSLRA Notice, # (6) Exhibit Exhibit D to Declaration - Firm Resume of Levi & Korsinsky, LLP, # (7) Exhibit Exhibit E to Declaration - Firm Resume of Cullin O'Brien Law, P.A., # (8) Text of Proposed Order [PROPOSED] ORDER GRANTING MOTION OF HAMIT TAMER ADIGUZEL FOR CONSOLIDATION OF THE ACTIONS, APPOINTMENT AS LEAD PLAINTIFF, AND APPROVAL OF SELECTION OF LEAD COUNSEL)(O'Brien, Cullin)
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                                          Legal Document 18 Filed: 9/30/2020, Entered: 10/1/2020 Order on Motion to consolidate casesCourt Filing
                                          ORDER granting [14] Motion to Consolidate Cases for all purposes, including pretrial proceedings and Trial. Case 20cv23643-KMW is hereby consolidated. Signed by Judge Kathleen M. Williams on 9/30/2020. See attached document for full details. (lk)
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                                            Legal Document (Payment Possibly Required) 17 Filed: 9/30/2020, Entered: 9/30/2020 Response to order to show cause
                                            RESPONSE TO ORDER TO SHOW CAUSE re [15] Order to Show Cause,, by Richard Maurice Bush. (Attachments: # (1) Exhibit PSLRA Notice)(O'Brien, Cullin)
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                                              Legal Document (Payment Possibly Required) 16 Filed: 9/30/2020, Entered: 9/30/2020 Notice of Attorney Appearance
                                              NOTICE of Attorney Appearance by Tracy Ann Nichols on behalf of Blink Charging Company. Attorney Tracy Ann Nichols added to party Blink Charging Company(pty:dft). (Nichols, Tracy)
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                                                Blank 15 Filed: 9/30/2020, Entered: 9/30/2020 Order to Show Cause
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                                                  Legal Document 14 Filed: 9/30/2020, Entered: 9/30/2020, Terminated: 9/30/2020 Motion to consolidate cases
                                                  Joint MOTION to Consolidate Cases and Schedule to File Amended Complaint by Blink Charging Company. Attorney Stephen Patrick Warren added to party Blink Charging Company(pty:dft). Responses due by 10/14/2020 (Attachments: # (1) Text of Proposed Order)(Warren, Stephen)
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                                                    Legal Document (Payment Possibly Required) 13 Filed: 9/22/2020, Entered: 9/22/2020 waiver of service executed
                                                    WAIVER OF SERVICE Returned Executed by Richard Maurice Bush. Michael P. Rama waiver sent on 9/21/2020, answer due 11/20/2020. (O'Brien, Cullin)
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                                                      Legal Document (Payment Possibly Required) 12 Filed: 9/22/2020, Entered: 9/22/2020 waiver of service executed
                                                      WAIVER OF SERVICE Returned Executed by Richard Maurice Bush. Michael D. Farkas waiver sent on 9/21/2020, answer due 11/20/2020. (O'Brien, Cullin)
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                                                        Legal Document (Payment Possibly Required) 11 Filed: 9/21/2020, Entered: 9/21/2020 summons returned executed
                                                        SUMMONS (Affidavit) Returned Executed on [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Richard Maurice Bush. Blink Charging Company served on 9/14/2020, answer due 10/5/2020. (O'Brien, Cullin)
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                                                          Blank 10 Filed: 8/27/2020, Entered: 8/27/2020 Order on Motion to appear pro hac viceCourt Filing
                                                          PAPERLESS ORDER granting [8] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Jeffrey Block; granting [9] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Jacob Walker. The Court finds that the applications satisfy the requirements of S.D. Fla. Local Atty. R. 4. Therefore, the Clerk is directed to add Jeffrey Block and Jacob Walker as counsel of record for Plaintiff and allow counsel to be noticed electronically on CM/ECF. Signed by Magistrate Judge Edwin G. Torres on 8/27/2020. (js02)
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                                                            Legal Document (Payment Possibly Required) 9 Filed: 8/26/2020, Entered: 8/26/2020, Terminated: 8/27/2020 Motion to appear pro hac vice
                                                            MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Jacob A. Walker. Filing Fee $ 200.00 Receipt # AFLSDC-13417587 by Richard Maurice Bush. Responses due by 9/9/2020 (Attachments: # (1) Certification CERTIFICATION OF JACOB A. WALKER, # (2) Text of Proposed Order [PROPOSED] ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING)(O'Brien, Cullin)
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                                                              Legal Document (Payment Possibly Required) 8 Filed: 8/26/2020, Entered: 8/26/2020, Terminated: 8/27/2020 Motion to appear pro hac vice
                                                              MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Jeffrey C. Block. Filing Fee $ 200.00 Receipt # AFLSDC-13417566 by Richard Maurice Bush. Responses due by 9/9/2020 (Attachments: # (1) Certification CERTIFICATION OF JEFFREY C. BLOCK, # (2) Text of Proposed Order [PROPOSED] ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING)(O'Brien, Cullin)
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                                                                Legal Document (Payment Possibly Required) 7 Filed: 8/25/2020, Entered: 8/25/2020 Order Referring Case to Magistrate JudgeCourt Filing
                                                                ORDER OF REFERRAL AND NOTICE OF COURT PRACTICES AND PROCEDURES. REFERRING CASE to Magistrate Judge Edwin G Torres for all discovery disputes and non-dispositive pretrial motions. Notice of Court Practice. Signed by Judge Kathleen M. Williams on 8/25/2020. See attached document for full details. (mee)
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                                                                  Legal Document (Payment Possibly Required) 6 Filed: 8/25/2020, Entered: 8/25/2020 Bar Letter
                                                                  Bar Letter re: Admissions sent to attorney Jeffrey C. Block and Jacob A. Walker, mailing date August 25, 2020, (pt)
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                                                                    Legal Document (Payment Possibly Required) 5 Filed: 8/25/2020, Entered: 8/25/2020 Summons issued
                                                                    Summons Issued as to Michael P. Rama. (mee)
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                                                                      Legal Document (Payment Possibly Required) 4 Filed: 8/25/2020, Entered: 8/25/2020 Summons issued
                                                                      Summons Issued as to Michael D. Farkas. (mee)
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                                                                        Legal Document (Payment Possibly Required) 3 Filed: 8/25/2020, Entered: 8/25/2020 Summons issued
                                                                        Summons Issued as to Blink Charging Company. (mee)
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                                                                          Blank 2 Filed: 8/24/2020, Entered: 8/25/2020 Clerk's Notice of Judge AssignmentCourt Filing
                                                                          Clerks Notice of Judge Assignment to Judge Kathleen M. Williams. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Edwin G. Torres is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (mee)
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                                                                            Legal Document 1 Filed: 8/24/2020, Entered: 8/24/2020 Complaint
                                                                            COMPLAINT against All Defendants. Filing fees $ 400.00 receipt number BFLSDC-13403533, filed by Richard Maurice Bush. (Attachments: # (1) Civil Cover Sheet Civil Cover Sheet, # (2) Summon(s) Summons to Defendant Blink Charging Company, # (3) Summon(s) Summons to Defendant Michael D. Farkas, # (4) Summon(s) Summons to Defendant Michael P. Rama, # (5) Certification Plaintiff Certification)(O'Brien, Cullin)
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