Introduction
Mr Sylvester Udemezue has published, in City Lawyer Magazine of 1 August 2026, a courteous and carefully arranged reaction to the article “My Lord” or “My Lady”? The Correct Mode of Addressing Female Judges. His civility deserves thanks, and his seriousness deserves a serious answer. But a serious argument is not the same thing as a sound one. His conclusion, that the correct form of address in Nigeria for a Judge of either sex is My Lord or Your Lordship, is, with the greatest respect, wrong. This reply will show why, taking his ten numbered propositions as he arranged them.
Boiled down, his case stands on three legs. The first is his central claim, made in his opening paragraphs and repeated at his close, that My Lord is “a professional designation attached to the judicial office” rather than a description of the person: a technical term of the law, like consideration or equity, supported by his comparisons with the female Professor, the corporation that counts as a person, the reasonable man of the law of negligence, and the Book of Genesis. The second leg is that Nigeria is a sovereign country with its own settled courtroom convention, and is not bound by later changes in England. The third is that any change must come from the competent Nigerian institutions, not from individual preference. This reply will show that the first leg is broken by the very examples he offers in its support; that the second confuses control over laws with control over language, and collapses in any event on simple dates; and that the third, far from defeating the original article, concedes the whole field. Along the way, every one of his remaining points will be answered, one by one.
- An Office Cannot Be Spoken To; Only a Person Can (His Paragraphs 1, 2 and 10)
Start with plain sense. An office is an idea, not a being. It has no ears. It wears no robe, sits in no chair, and delivers no ruling. When counsel rises and speaks in court, the words do not travel to an idea; they travel to the human being on the Bench. And every form of direct address in English, Sir, Madam, My Lord, My Lady, Your Majesty, Your Excellency, is by its very nature aimed at a person and shaped to fit that person. The word Madam proves the point by itself. Madam comes from the French ma dame, which means, literally, my lady. Every lawyer who has ever said Madam to a woman has already accepted the whole argument without noticing.
Nor is there any escape in the longer forms. Your Lordship and Your Ladyship carry gender just as plainly as My Lord and My Lady do. English simply has no neutral version of these words. A speaker who claims to be addressing “the office” in a sexless way is not doing so, because the language gives him no tool for doing it. He is applying a man’s title to a woman and calling the mistake neutrality. Notice, too, that Your Lordship, which appears in the learned author’s very title, offers no way out. Your Lordship is simply My Lord said more politely, and its female partner is Your Ladyship. Nobody escapes the masculine by choosing its politer form. If the address is to change at all for a female Judge, the natural destination is Your Ladyship, not another version of the same gender.
The learned author observes that calling a female Justice My Lord does not turn her into a man. Of course it does not. Nobody said it did. A wrong description never changes the thing described; it only discredits the person describing it. Calling the sun the moon leaves the sky exactly as it was. It merely tells the listener that the speaker is not looking.
The decisive answer, however, lies in the learned author’s own third paragraph, and the reader should mark it well. There he records, correctly, that when women were first appointed to the English Bench, English practice adapted: My Lady and Your Ladyship for the women, My Lord and Your Lordship for the men. Now pause on that. If the address truly belonged to the office and not to the person, no adaptation would ever have been needed, because the office had not changed at all. Only the persons had. The adaptation he himself concedes is therefore the proof of the very point he is resisting: at the source of this tradition, the address followed the person the moment the persons changed.
And the source says the same thing at every level above the Bench. The Crown of the United Kingdom is the one office in the English legal tradition that is said never to die. If any office on earth could keep one style regardless of who holds it, it is that one. Yet for a thousand years its style has changed with its holder: Rex or Regina, King or Queen, His Majesty or Her Majesty. On 8 September 2022 the office theory was disproved in a single afternoon. On the death of Queen Elizabeth II of the United Kingdom, the Queen’s Bench Division of the English High Court became the King’s Bench Division. The letter R on every criminal case changed its meaning from Regina to Rex. Every Queen’s Counsel (QC) went to bed a QC and woke up a King’s Counsel (KC), automatically, with no new letters patent. The anthem of the United Kingdom moved from God Save the Queen to God Save the King. And the Crown lost nothing by any of it. Come nearer to the Bench. In England, on appointment to the very same office of Judge of the High Court, a man is made a Knight Bachelor and a woman is made a Dame Commander of the Order of the British Empire. One office; two styles; Sir for him and Dame for her; and nobody has ever suggested that the unity of the office requires the woman to be called Sir. Brenda Hale led the final court of the United Kingdom as its President, and the whole common law world knows her as Lady Hale. Nobody has ever called her Lord Hale. An office takes its dignity from the law and from the oath, not from the masculine gender of its style. If the sovereign, the King’s Bench, the silk gown and the English Bench all bend their style to the person, on what possible principle would the Nigerian courtroom, alone in the world, stand outside grammar? - A Term of Art Needs an Authority Behind It, and This One Has None (His Paragraphs 2 and 7)
The learned author’s most interesting argument runs like this. Courtroom language is not everyday English; it is the technical language of the law, in which words such as consideration, issue, execution, service, charge, equity, possession and injunction carry special meanings; and My Lord has likewise become a technical, gender free title meaning simply “the Judge”. The premise is entirely correct, and it destroys the conclusion. What separates a technical term from a mere habit is precisely that a technical term has an authority behind it. Consideration means what it means because centuries of binding judgments say so. Service, charge and injunction mean what they mean because statutes and rules of court say so. Every special meaning on his list can be traced to a source that fixed it. And note something else about his list: every word on it is a noun of doctrine, a word used to describe legal ideas. Not one of them is a form of address, words spoken to a living person’s face.
Take his best example, the corporation that counts as a person. Why does a corporation count as a person in law? Because the legislature expressly said so. The Interpretation Act, in section 18(1), defines person to include any body of persons, corporate or unincorporate. The special meaning exists because an instrument of authority created it. Very well: let the learned author produce the instrument that defines My Lord to mean a Judge of either sex. He cannot. And to his credit, he does not pretend otherwise. His own fourth paragraph concedes that no Nigerian statute, no constitutional provision, no Rule of Court and no binding Practice Direction touches the question at all. But a term of art with no defining authority is not a term of art. It is a habit dressed up in a Latin phrase. His own examples, each resting on statute or precedent, prove the very requirement his theory cannot meet.
His remaining comparisons do no better. The reasonable man of the law of negligence is an imaginary figure, spoken about, never spoken to. No counsel has ever stood up and addressed a woman in the witness box as “reasonable man”, and if he did, everyone in the room would recognise the mistake at once, which is exactly the point about My Lord. Worse for the analogy, the law itself has been quietly retiring the phrase in favour of “the reasonable person”, precisely because the profession came to accept that the masculine form no longer described the world. In other words, the learned author has cited, in defence of keeping a masculine form, an example in which the law corrected one. As for Genesis, the statement that God created man uses man in its general sense, meaning humankind, and the very same verse then divides into the pair: “male and female created he them”. Scripture uses the general word for the species and the paired words for the persons, which is exactly the distinction being urged here; and nowhere in Scripture is Eve addressed as Sir. Speaking about a class in general is one thing. Calling a particular woman, present and identifiable, by a man’s title to her face is another. It is the second that the universal My Lord commits.
Finally, the term of art theory destroys itself by its own consequences. If My Lord had genuinely become a sexless technical title meaning “the presiding Judge”, then My Lady would be an error in every courtroom: the female Judges of Lagos who accept and expect it would be presiding daily over a mistake, and the entire practice of England, South Africa and Ghana would be wrong. Nobody believes any of that. There is a human test as well. If My Lord were truly neutral, its defenders would not care whether counsel said My Lord or My Lady, since on their own theory nothing would turn on the choice. But they do care. They resist My Lady with real energy, which shows that they still hear the masculine in My Lord perfectly well. The heat of the defence gives the meaning away.
And if any further proof were needed that the universal masculine is a loose habit rather than a term of office, ordinary professional life supplies it. The present writer has seen a vacation greeting, circulated among female Judges themselves, which saluted “Dear Sisters” and hoped, in the same breath, that “my Lords” were all enjoying the holiday. With the greatest respect, that sentence cannot be right, and for three simple reasons. First, it contradicts itself in a single breath: it calls the same people Sisters and Lords, and English cannot hold both, because a Sister is by definition a Lady. Second, it defeats the office theory on its own: in a holiday greeting no court is sitting and no office is being addressed; only persons are, and the persons are Ladies. If the masculine style really belonged to the office, it would have no work to do in a vacation message among Sisters. Its appearance there shows a habit that has come loose from both office and grammar. Third, it repeats the very contortion the English threw out a generation ago. “Dear Sisters, I hope my Ladies are all enjoying the vacation” is not only correct English; it is the more gracious sentence. The habit, in short, no longer remembers the office it claims to serve. - Some Titles Have No Feminine Form; Lord Has Had One for a Thousand Years (His Paragraph 2)
The learned author argues that calling a female Justice My Lord is no different from calling a female academic Professor, because professional titles often rise above grammatical gender. The comparison fails because it mixes up two different families of words. Professor, Doctor, Judge, Justice, Counsel, President, Chief Justice: these are common gender words. English never created feminine versions of them, so the one form serves both sexes and no error is possible. Lord does not belong to that family and never did. English has kept its pair for a thousand years: Lord and Lady, just as it keeps King and Queen, Sir and Dame, Mr and Mrs. The rule of the language is simple and has no exception. Where no pair exists, the single form is neutral: a female professor is Professor. Where the pair exists, using the masculine for a woman is an error: a female sovereign is a Queen, not a King; a female knight is a Dame, not a Sir; and a female lord is a Lady. That is why the world says Madam President and Madam Speaker, never Mister President to a woman. It is why unease with Chairman produced Chairperson and Chair, rather than a decree that Chairman was now neutral. And it is why, in eight centuries of the peerage, no woman has ever been addressed as My Lord. Professional titles rise above grammatical gender only where the language gave them no gender in the first place. My Lord is not such a title, and no theory can make it one.
The pair, in fact, is older than the courtroom itself. Strip away the old spellings and Lord and Lady were born together, in the same ancient English household, and both were named after bread. The Old English hlafweard, which became Lord, meant the keeper of the loaf. The hlaefdige, which became Lady, meant the one who kneaded and made it. Two titles, one kitchen. Where a word comes from is only its history; what it means is settled by how it is used today, and by whom. But the history matters here, because it shows that the pairing is no modern fashion. Lord and Lady entered the language together, have travelled ten centuries together, and no courtroom habit has the authority to divorce them now. If humble beginnings could shut My Lady out of the courtroom, they would shut My Lord out first, for he began as a keeper of bread just as she began as its maker. And if the lingering worry is that My Lady has been cheapened by the “milady” of the costume drama, the answer is that of the two parent titles it is my lord that lives the larger life outside the courtroom: in everyday prayer, in the butler of every period film, in every novel of knights and castles. Nobody suggests that those uses make My Lord unsafe for court. And even the age of chivalry assists the usage rather than embarrassing it: the knight’s “my lady” was the language of devotion and of service to a superior, which is precisely the posture in which counsel stands before the Bench. The cure for street corruption is correct usage from the Bar, not surrender of the correct feminine form. And a style which England has installed at the very summit of its judiciary, in the person of the Lady Chief Justice, is in no danger of ridicule. - Nigeria Is Sovereign Over Its Laws, Not Over the English Language (His Paragraphs 4 and 5)
The learned author’s fourth and fifth paragraphs argue that Nigeria is a sovereign nation, that later English changes do not automatically apply here, and that Nigeria has developed its own settled convention of the universal My Lord. Three answers dispose of all of this.
First, the argument answers a claim that was never made. The original article did not say that the English Practice Note, or any other English instrument, binds Nigeria as law. It said that the English language means what it means, and it offered the English materials as evidence of correct usage, not as sources of legal obligation. Nigeria is sovereign over its laws. No nation on earth is sovereign over the English language. And the Supreme Court of Nigeria has confirmed what nobody disputes, that English is the official language of the superior courts of record in this country: Ojengbede v Esan (2001) 18 NWLR (Pt. 746) 771 at 790, per Iguh, JSC. Having chosen to keep the language, Nigeria kept its grammar with it. A sovereign legislature can redefine person; it cannot redefine Lady, because the meanings of English words belong to the entire community of English speakers, not to any parliament, and certainly not to a courtroom habit. The rules on the reception of English law are therefore beside the point. A form of address is not a rule of law that reception preserves or excludes. It is a use of language, and language is judged by correctness, not by the date of a reception statute.
Second, the claim of a settled Nigerian convention collapses on simple dates. A convention about addressing female Judges could not have existed in Nigeria before Nigeria had female Judges, and the first, Hon. Justice Modupe Omo-Eboh, was elevated in 1969. By that date the tradition had already spoken at its source. England’s first female High Court Judge sat from 1965 and was addressed as My Lady, and the English Practice Note of 1994 records, as settled history, that female Judges of the English High Court were so addressed, condemning the contrary contortion as “plainly absurd”. In other words, at the very first moment the question could possibly arise in Nigeria, the correct answer already existed in the tradition Nigeria claims to follow. The universal masculine for women is therefore no ancient Nigerian inheritance. It is a local drift that began after 1969, younger than the correct usage, and it has never even been uniform within Nigeria, because in Lagos, home to the largest Bar on the continent, My Lady is accepted and expected. A drift that is recent and contested is not a convention that commands reverence.
Third, there is something odd about the patriotism of this argument. It invokes Nigerian sovereignty in order to preserve, as national heritage, a colonial masculine form which the coloniser itself has thrown out as absurd. That is not legal nationalism. It is the careful preservation of another country’s discarded mistake. Genuine Nigerian independence in this field would look like what every self respecting jurisdiction has done: either match the address accurately to the person, or fashion an honestly neutral Nigerian form. It cannot look like defending wrong English on the ground that the error is now locally owned. - The Demand for Institutional Change Concedes the Field (His Paragraph 9)
The learned author’s ninth paragraph insists that reform should come from the Supreme Court, the National Judicial Council (NJC), the Body of Benchers or some other competent authority, not from individual preference. Examined closely, this argument surrenders the case.
Consider what he has admitted. No instrument of any competent Nigerian institution ever established the universal masculine either. On his own account the field is completely empty of authority: nothing prescribes My Lord for women, and, as he equally accepts, nothing prohibits My Lady. Where the law is silent, the question falls to be decided by correctness, and the burden of producing authority rests on the side defending the wrong description, not on the side speaking accurate English. Counsel who says My Lady to a female Judge breaks no statute, no rule and no practice direction, even on the learned author’s own framework, and speaks correct English besides. What, then, is left of the claim in his title that My Lord is the correct, professional and legal form for every Judge? Legal, yes, in the thin sense that no law forbids it; but many things are lawful and still wrong. Correct is a claim about language, and on language the authorities, from the dictionary, to the official guidance of the Judiciary of England and Wales, to the practice of the entire common law world, all point one way. At its highest, his argument shows that the universal My Lord is tolerated. It cannot show that it is correct, and correctness was the question.
As for institutional reform, the learned author is pushing at a door the original article holds open. That article never proposed that any advocate should innovate against institutional authority. On the contrary, it set out, in full, the very machinery by which such matters are settled. In the English story it told, it was a direction of the Master of the Rolls, the Practice Note of 1994, that cured the absurdity, and Parliament came nine years later, by the Courts Act 2003, merely to complete what the direction had begun. Legislation followed the direction; it did not lead it. In Ghana, a single memorandum of the Chief Justice settled the matter for the whole country. And the article recorded one reported Nigerian use of that very instrument: a direction said to have been given by a former Chief Justice of Nigeria that all Judges, male and female alike, be addressed as My Lord, in the very name of equality. The pen has been used before, once, and in the wrong direction. So the question was never whether the pen of the head of a judiciary can settle the matter. The question is what that pen should write, and it is to that question, and to that question alone, that these submissions are addressed. It is not the place of an advocate to prescribe to the Bench. An advocate states the problem, marshals the authorities and persuades. His directions are properly addressed only to himself and to the Bar, and advocacy ends where the court’s discretion begins. What an advocate must never do is tell a judge what to do. What he must always do is give the judge every reason to do it. That is the office these pages perform. The learned author’s procedural point therefore concerns how the conclusion would be carried out, not whether it is sound. And in the meantime his closing advice and the article’s converge, since he fairly accepts that the profession should comply with whatever is prescribed: at the Bar, follow the preference of the Judge before you, for respect for the Bench admits of no exception. But where a female Judge has expressed no preference, the default position of a learned profession must be correct English, not inherited error. - “We Are All Gentlemen at the Bar” (His Paragraph 6)
The learned author suggests that the old saying that all members of the Bar are gentlemen was never meant to exclude women, but only to express the unity and equality of one honourable profession. The historical record will not carry that reading. For roughly six centuries the English Bar was closed to women, not by sentiment but by law. The medieval treatise called the Mirror of Justices declared that the law would not allow women to be attorneys; Coke adopted the rule; Blackstone enshrined it; and as late as Bebb v Law Society [1914] 1 Ch 286 the English Court of Appeal held that a woman was not a “person” within the meaning of the Solicitors Act 1843. In a profession from which women were shut out by force of law, “we are all gentlemen” was not a courtesy extended to anyone. It was simply a description of who was in the room. When the Sex Disqualification (Removal) Act 1919 opened the door, women were admitted to the profession, not to the fiction, and a fiction whose factual basis died in 1919 cannot dictate anyone’s grammar in 2026. One further observation, offered with a smile rather than a sting: the learned author’s own defence describes the women of 1919 as having been admitted into the professional “fraternity”. Fraternity comes from frater, a brother. The vocabulary of the contrary school keeps confessing its gender in the very act of denying it. - His Own Survey of Other Countries Contains No Ally (His Paragraph 8)
The learned author’s eighth paragraph looks around the common law world, and his survey is accurate as far as it goes. The United Kingdom keeps My Lord and My Lady for its senior judges. Australia, Singapore and the American courts generally prefer Your Honour or Judge. India is debating respectful alternatives. But look at what the survey actually establishes. Every jurisdiction he mentions has done one of two honest things: matched the address accurately to the person, or adopted a genuinely neutral form. Add to his list South Africa, where My Lady is the settled address for a female judge; Ghana, where the Chief Justice directed the accurate pairing by memorandum; and British Columbia in Canada, whose superior courts retired My Lord and My Lady in 2021 in favour of the simple Justice. Not one jurisdiction in his survey, and not one anywhere else in the common law world, has adopted the position he defends: that the masculine shall be universal and that women on the Bench shall answer to a man’s title. The learned author has, in short, conducted a world tour and come home without a single companion. The universal masculine is not tradition anywhere. It is an innovation in error, and it stands alone. - A Learned Profession Cannot Plead Convention Against Grammar
There remains the learned author’s general plea that professional usage should prevail over literal meaning. At bottom, that is the plea of convention: this is how it has been done, therefore this is how it should be done. Let the profession’s own proudest title answer that plea.
Lawyers call one another learned. Why? In the medieval world there were only three learned professions: divinity, law and medicine, so called because they alone required the long university training in letters. And the foundation of that training was the seven liberal arts, of which the first three, known as the trivium, had to be mastered before anything else; and the first of those three, before logic and before rhetoric, was grammar. The learned professions are, in the most literal historical sense, the grammatical professions. The English serjeants at law were described as learned in the law. The courtesy of “my learned friend” comes down from that world. In the Parliament at Westminster, a member who was a senior barrister was traditionally styled the honourable and learned Member. The title was never a boast of technical cleverness alone. It was a claim to precision in language, for the simple reason that language is the entire medium of the lawyer’s craft. Lawyers construe statutes by grammar. The canons of interpretation, the literal rule, and the rules with Latin names such as ejusdem generis and noscitur a sociis, are nothing but grammar in a gown. Fortunes and liberties have turned in court on the position of a comma. A profession that decides other people’s disputes by their grammar cannot, without giving up its own name, insist in open court that a lady is a lord, and then, when corrected, plead convention. To do the wrong thing and to answer, when challenged, “there is a convention, that is why I am doing it”, is not reasoning. It is habit pleading its own cause, and it does not sit well in the mouth of a profession whose duty is to uphold the law, whose calling is to lead by example, and whose proudest boast is its learning. Nigeria cannot build the foundation and practice of its legal system on defended bad English.
And there is a final answer, which ties back to the gentlemen of the Bar. Every plea of convention in this debate rests, in the end, on a world that no longer exists. The exclusively male Bar that coined the saying that all its members are gentlemen is extinct, and the saying was true only for as long as the room it described. Forms of address have always moved to fit social reality. That is why England adapted the moment women reached its Bench. It is why Nigeria itself, as the original article showed, retired the old style The Honourable Mr Justice within a few years of the elevation of its first female Judges, and adopted the neutral The Honourable Justice that stands today. At the beginning of Nigeria’s legal history there were no female Judges, and the masculine style described the world as it then stood. That world has changed, fundamentally and forever. Women now sit throughout the Nigerian judicature, and the mode of address must change with the world it speaks to. The change requires no invention. It is already written, in correct English, on the face of the language itself: My Lady. - Equality, and What His Closing Line Concedes (His Paragraphs 9 and 10)
The learned author urges that this debate should not be seen as a contest between tradition and gender equality, and up to a point that is right, because the question is decided before equality ever enters the room. It is decided on grammar. But the equality dimension cannot simply be waved away, because the universal masculine, however innocently defended, sets the man up as the measure of the office and admits the woman only on condition that she answer to his title. The profession has walked this road before, to its lasting shame. In Bebb v Law Society, the Court of Appeal refused in 1914 to read “person” as including a woman, in order to keep her out of the profession, and it did so even though the very statute before it said that the masculine included the feminine. Today, some would read “Lord” as including a woman, in order to make her invisible within the profession. The two readings run in opposite directions, and they rest on the identical premise: that the standard occupant of the law’s dignities is male. The Act of 1919 buried that premise in law. It is past time it was buried in speech as well. Consider, too, the Bench before which Nigerian lawyers now appear. Women preside in every tier of the Nigerian judicature. Women have led the Court of Appeal. And a woman, Hon. Justice Kudirat Kekere-Ekun, GCON, presides at this moment over the Judiciary itself as Chief Justice of Nigeria, the second woman to hold that exalted office. A mode of address designed for a Bench without women cannot be the measure of a Bench that a woman leads.
The learned author closes by observing that the strength of the judiciary has never depended on the words of salutation, but on the independence, integrity, learning and courage of those who wear the robe. Every word of that is true, and it leads exactly where he does not want it to go. If nothing of judicial substance turns on the salutation, then accuracy costs the judiciary nothing and error buys it nothing, and the only remaining reason to choose between the two forms is that one is correct English and the other is not. If, on the other hand, the salutation matters enough to defend across ten considered paragraphs, then it matters enough to get right. Either way, My Lady wins. My Lady is not a lesser form of My Lord, and it is not a concession to sentiment. It is its exact equal, different only as the person differs. To insist that a woman must answer to My Lord is to declare that the judicial office can be imagined only in male form. That, and not My Lady, is the position that diminishes the Bench.
Conclusion
Total up what the learned author’s own reaction has conceded. He concedes that England, the source of the tradition, pairs the address, My Lord for the man and My Lady for the woman, and adapted its practice the moment women reached the Bench. He concedes that no Nigerian statute, constitutional provision, Rule of Court or binding Practice Direction prescribes the universal masculine, and that none prohibits My Lady. He concedes that the competent institutions of the profession are free to settle the matter, and that the profession should comply when they do. And his own survey of the common law world is unable to produce one jurisdiction that does what he defends. Subtract all of that, and what remains of the contrary case is a single sentence: this is how it has been done for some decades. That is not an argument; it is an autobiography. Habit is not correctness. Convention cannot repeal grammar. And a learned profession, of all professions, cannot offer its own repetition as authority.
The office cannot be addressed, because offices have no ears. The tradition, traced honestly to its source, fits its style to the person at every level: the Crown, the King’s Bench, the silk gown, the Bench itself. The proper mode of addressing a female Judge is My Lady or Your Ladyship, and the proper mode of addressing a male Judge is My Lord or Your Lordship. This reply closes, deliberately, without calling on anyone to act, because it is not the place of an advocate to direct the institutions of the profession, still less the heads of court, in the discharge of their offices. The advocate’s part ends where their discretion begins. The anomaly has been exposed, the authorities marshalled, and the whole laid respectfully at the feet of those whose business it is to act, who, if persuaded, will need no prompting as to the instrument or the moment. History shows, in any event, how lightly the remedy moves once the case is made: in England, a Practice Note; in Ghana, a memorandum. To the Bar, which an advocate may properly counsel, prudence remains what it has always been: follow the preference of the Judge before you, for respect for the Bench admits of no exception. But no one should mistake forbearance for agreement, or convention for correctness. It is the person who wears the robe, and it is the person the Bar addresses. Let the proper thing be done.
* Dr. Eyimofe Atake, SAN, PhD (Cantab) writes from Lagos.
* The views expressed in this article are entirely those of the author.
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