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Aktif Makale A Comparative Case Study

Yazan : Altinok Kaya
Juris Doctor Candidate

Makale Özeti
This paper aims to explore the differences and similarities between the American common law system and the Turkish civil law system in the context of a real, pending Florida case.

A Comparative Case Study with References to
The United States and Turkish Laws

Altinok G. Kaya


Toddlers learn by comparison. For instance, by touching cold and hot objects they discover that the hot ones are dangerous. Even adults tend to compare their success, beauty, and intelligence with that of others. Comparison is the first method that human beings use to start the magical journey of intellectual improvement.
Law has an enormous impact on individuals’ lives because, whether overtly or discreetly, law controls everything. For example, a regulation controls the quality of the water that we drink. Another set of rules decides what is inappropriate or criminal. While yet another law protects the rights of those who are unable to defend themselves. Law enables us to live harmoniously under democracy, as it effectively governs our lives. Ever since the first law or legal system came into being, an attempt has been made to protect the harmony of society. In olden days, the objective of the law was to offer protection, generally for the benefit of those in authority and the wealthy members of society. Modern systems, in contrast, aim to preserve the peace for the welfare of the entire society by explicitly safeguarding the rights of the underserved, minorities and the powerless. For this reason, the law must be kept alive; it also must be highly adaptable according to the needs of society. The pace of transformation must be balanced - neither too fast nor too slow. Change is healthy for societies; yet if the legal system reacts too quickly, it may be defeated by a short-lived popular point of view, which may hurt society in the end. However, if it reacts too slowly it may produce victims by failing to address critical issues in good time. To prevent this from happening, all legal practitioners and scholars are required to constantly contemplate the system and to test its regulations against foreign statutes and systems. For this reason comparative law has an enormous importance in today’s contemporary legal environments.
This paper aims to explore the differences and similarities between the American common law system and the Turkish civil law system in the context of a real, pending Florida case. In order to achieve this goal, certain Turkish civil law rules and American common law principles will be applied; outcomes will then be anticipated in regard to each legal system. A comparison of the qualities of both legal systems, including their different rules and procedures, is vital for the improvement of the legal system to which we are subject. This paper asserts that if the plaintiff of the Florida case were subject to the Turkish jurisdiction in regard to such a torts claim, he would face a heavier burden in establishing the elements of his case against the defendant. As a result, he has better chances for compensation in American jurisdiction. The paper concludes that questioning the system to which we are subject, and contemplating it in comparison to others, is instrumental to improving any legal system.
Differences among legal systems reveal themselves in various aspects of the practice of law. In most situations, the conventions of law are created based on similar underlying principles; procedural, structural, and organizational differences, as well as variances in compensations, create significant disparity. Simply put, the legal system of every society faces similar problems, but finds a solution according to its own unique method.
Imagine yourself trying to sell a large piece of scrap metal to a metal yard in Florida, USA. If an accident were to occur while you are on the buyer’s premises, it is likely that you may receive some compensation for your injuries. Yet what if you were in a civil law country and would experience the same problem? How different an experience and outcome should you expect just because you are subject to a different jurisdiction?

General Information About Common and Civil Law Systems

“Some comparative law attorneys assert that there are few major differences between the two law systems judging by their key aspects: case law versus statutory law, the systemization of the law, and the lasting influence of the Roman Law.” On the other hand, there are substantive rules in various areas, ranging from the protection of economic investment to military conscription, that differ drastically between common and civil law systems.
The Roman–Germanic System constitutes the basis of the Continental Civil Law tradition. Today, civil law is the dominant tradition in most of Europe, Central and South America, and some parts of Asia. “The phrase “civil law” comes from the Latin phrase “jus civile,” referring to the Civil Law system of the Roman Republic and the Roman Empire.” Civil law is older, more widespread, and in many ways more influential than the common law. During the time of the Roman Republic, a body of legal experts, or jurists, gained prominence within the legal system. Their rulings were respected, independent of the courts of law. These individuals were mostly comprised of upper class members of society and sought to satisfy their interest in law by providing legal services. Jurists were pro bono lawyers who gained influence and popularity in exchange for their services. They functioned as legal advisors, providing technical advice to judges and contributing to the development of the comprehensive jurisprudence. These judges generally had no legal training and were appointed for a short period of time. As a result, there was little regard for the appropriateness of decisions in individual cases. In such an environment, some jurists were more popular than others and their opinions were treated as more significant. When Corpus Juris Civilis (Code of Justinian) was created, it represented the opinion of those recognized jurists and was given the force of law.
The Byzantine Empire followed the Roman Empire in continuing with the practice of civil law and Corpus Juris Civilis. Corpus Juris constitutes the foundation of the civil law tradition, but also explains the existence of local, substantive differences among civil law countries. The civil law tradition was so broadly practiced that it was impossible for Corpus Juris to address all of the legal issues experienced by extensively diverse populations and nations. Throughout the expansion of civil law tradition, various countries were adopting the principles, while modifying them according to their perspectives and needs. The Italians were at the forefront of interpreting and applying Corpus Juris according to the needs of the locality.
While the continental Europeans were interpreting Corpus Juris, a new legal system called “common law” was developing in Britain. Characteristics of the new system gradually emerged over the centuries. The progression from jury trials to more types of civil cases, reliance by judges on precedent, and inductive reasoning came to create the substance of the law. These legal norms helped to lay the foundation for a new, comprehensive jurisprudence.
Today, these systems exist as two major legal traditions around the world, differing in many aspects. A case analysis is likely to reveal a practical understanding of the implications of such differences.

Some Details about Turkish Legal System and Practice

The Modern Turkish Republic adopted most of its code from such European countries as Switzerland, Germany and Italy. The Turkish system, like many of its predecessors, does not employ the use jury trials. In the Turkish language, the general term for members of the legal profession is “hukukcu.” The term encompasses judges, prosecutors, attorneys, and legal scholars, indicating that a person works within the profession of law. Like many civil law countries, legal education requires four or five years of undergraduate education. Upon successful completion of the coursework, graduates are required to complete a yearlong apprenticeship. For the first six months of the apprenticeship, interns work as agents of a courthouse under the supervision of judges. During this period, they fulfill such duties as conducting legal research, drafting opinions for the judges, and assisting the court clerk; they are required to observe trials during this time as well. Once the first six months are successfully completed, the interns are required to work under the supervision of an experienced attorney for a minimum of six months. This time, they start to represent clients in actual cases with limited representation rights. The second half of the internship includes such additional requirements as the completion of a thesis and a professional responsibility classes. Upon perfect attendance and successful completion of the professional responsibility courses, interns defend their theses in front of a committee consisting of attorneys and legal scholars. In the end, they finally earn the privilege to be sworn into the profession.
Turkey is not a federal state; therefore, there is no dual system of courts. The major organization of the court system consists of the Civil (Justice) and Criminal Courts, Administrative Courts, State Security Courts, Courts of Appeals (Supreme Court), and the Supreme Court (Constitutional Court). The court of appeals is the last occasion for reviving rulings and judgments rendered by the civil and criminal courts.

Facts of the Florida Case

The case being explored is real and pending. An accident occurs on the premises of the defendant corporation in Florida, USA. The plaintiff is a forty-seven year old married man. He is a resident of Florida who dropped out of school after the seventh grade. Defendant is a Florida corporation that buys and sells scrap metal in Florida.
Plaintiff claims that he and his brother-in-law were at the defendant’s junk metal yard having a steal beam unloaded from his vehicle by a forklift. Plaintiff claims that the defendant’s employee negligently instructed that he advance his vehicle, which caused the unloaded beam to fall on him. Defendant, on the other hand, claims that Plaintiff was warned several times against approaching the steel and yet approached anyway. When he was asked to get back and get into his vehicle, Plaintiff stayed standing on the passenger side of the vehicle. At this time, Plaintiff’s brother-in-law was in the driver seat and was directed to pull forward slowly from under the piece of steel. According to Defendant, Plaintiff then approached the piece steel from the passenger side and placed his hand on it.
As a result of the incident, the beam smashed Plaintiff’s left index finger, rendering it unusable. It was necessary for him to undergo an open reduction and internal fixation of the left index proximal phalanx the day after the incident. He is still receiving treatment, undergoing rehabilitation, and faces the risk of amputation of the finger.
The plaintiff filed a complaint against the defendant on September 1st, 2011. Currently the parties are in the phase of discovery, approaching the trial.

Legal Nature of the Claim

Substance of the Law

American Law

The claim falls under the general category of torts law: duties and liabilities of the owners and the occupiers of the land. American common law traditionally treats torts law as a separate field of law.
Restatement of Torts defines the possessor of land as “a person who is in occupation of the land with intent to control it or a person who has been in occupation of land with intent to control it, if no other person has subsequently occupied it with intent to control it, or a person who is entitled to immediate occupation of the land, if no other person is in possession.”
Negligence law is the predominant means of legally redressing unintentionally caused personal injury in the United States. Torts law in the American system is significant; it evolves and grows from case to case. The principle of “stare decisis” and its applications are probably the most important differences between common law and civil law. According to the “stare decisis,” American courts are required to abide by, or adhere to, principles established by decisions in earlier cases. Due to this principle, the codes, and the opinions held by scholars about the codes, have less importance in the common law system. This principle holds that once a court has answered a legal question, the question must produce the same outcome from that court or from the lower court in that jurisdiction. In other words, unlike in the civil law system, the common law judicial precedent has a binding effect on lower courts. As a result, civil law practitioners will typically define common law as “judge-made law.”
American law mandates that a plaintiff bear the burden to prove all elements of the cause of action: duty, breach, causation, and scope of damages. A plaintiff first must prove that the law imposes an obligation on the defendant(s) to act in a way that averts the risk of harm to a plaintiff. The duty to keep the premises safe for invitees extends to all portions of the premises included in the invitation that are necessary, or convenient, for the invitee to visit and/or use in the course of business for which the invitation was extended. According to the American torts law, the duty of the possessor of land depends upon the classification and characterization of the injured party. Entrants upon land are classified as trespassers, licensees or invitees. A trespasser enters the premises without license, invitation, or other right. He intrudes for some definite purpose of his own, at his own convenience, or merely as an idler with no apparent reason other than, perhaps, to satisfy his curiosity. The owner of the premises merely owes to a trespasser the duty of not causing intentional injury by setting a trap or causing wanton injury. Licensees are those persons on the land by the landowner’s express or implied consent, but who are there for their own purposes. For licensees, property owners are required to maintain the property in a reasonably safe manner and repair any unsafe conditions in order to prevent the risk of harm. A person who is on the land with an invitation is an invitee. The invitation is found in the fact that the premises are held open to the public; any conduct showing that the entrant’s presence is desired will indicate the invitee status. Customers and prospective customers of the business are considered invitees for the purpose of premises liability. For these entrants, the owner’s duty is to keep the property in safe condition and, if danger is present, to warn the invitee. In order to ascertain the condition of the property, the owner has a responsibility to regularly inspect the site.
Some states in the United States of America have amended their laws to abolish the traditional categorization of the entrants. Therefore, it is vital to analyze the law carefully to determine whether the classification still exists in a given jurisdiction. The jurisdiction at hand, Florida, preserves the traditional classification.
A plaintiff in the American system must secondly prove that a defendant breached his or her duty and acted in a negligent fashion. American torts law tests the conduct against what a reasonable person would have foreseen and done under the circumstances. This is a purely objective standard; the jury evaluates the defendant’s conduct, not his state of mind.
Finally, a plaintiff would have to show that damages exist and that they are the result of the defendant’s negligent conduct. American torts law recognizes some defenses and immunities that set a bar, or a limit, to a plaintiff’s right of recovery. Defenses and immunities for defendants subject to American law are generally constituted as the following: contributory negligence, comparative fault, assumption of risk, statutes of limitations, as well as charitable, spousal, parental, and governmental immunities.
In premises liability cases the defendant owner or operator might use the business’ invitee’s negligence as a defense. In these limited situations, the question of liability is to be determined by the court. The origin of this defense focuses on the invitee's duty to exercise reasonable care for his or her own safety.

Turkish Law

Unlike the American legal system, Turkish torts law does not constitute a separate and independent field, but is subject to the law of obligations. The Turkish Code of Obligations provides a wide variety of rules about contracts, agency relationship, torts, unjust enrichment, execution of obligations, consequences of default on obligations, and statutes of limitations. The Turkish Republic adopted almost all of its legal code from various European countries; the Code of Obligations was adopted from Switzerland and still preserves its similarity today. In our case, the claim falls under the obligation of torts, and the onus is on the plaintiff to prove that the defendant was at fault when causing an actual injury to him while he was on the defendant’s premises.
According to Article 41 of the Turkish Code of Obligations, the tort must contain an unlawful act, fault, causation and damages. Another striking difference between the Turkish and American tort laws reveals itself in the classification of the entrants; Turkish law does not reference a classification of the injured party.
According to the code, any violation against one’s inherent individual rights, such as an attack on the person and persona, may be considered an unlawful act. In some situations, failure to act may be unlawful; however, affirmative action is not always required. The code does not provide specifications or in-depth factual descriptions about the unlawfulness of an act, but instead frames the general principles. Doctrine and case law, although not binding, possess great significance to fill the gaps in a situation such as this. The unlawfulness of an act is tested against the objective standard, which is determined independently from the fault of the act; the plaintiff must prove this standard as an element of a case. In addition, the act or omission must violate the right that the law aims to protect; there must be a connection between the violation and the object of protection. This threshold requirement imposes a limit to the liability. For instance, if the student of a private tutor dies in a car crash due to the negligence of an unrelated driver, the death of the student will affect the tutor by reducing his income. In this scenario, a law that specifically aims to prevent bodily harm to individuals imposes the liability of the negligent driver; therefore, the tutor will not be able to demand compensation from the driver for his lost income. Another interesting point about Turkish torts law appears in Article 41. According to the Article, intentional acts against morality may also cause tort liability. As a result, if one commits an intentional act that does not violate a specific rule of the law, the tortsfeasor may still face liability if the civil law judge defines the act as against morality.
The most important issue when proving such a torts claim in the Turkish legal system is the issue of “fault.” Fault can be identified as the intent to act in a way that is not recognized by the law, or as the lack of intent to act when the law mandates an action. The concept of “fault” is similar to the “breach of duty” element within American law. In Turkish law, fault is determined subjectively; therefore, the unique qualities of a defendant play an important part when analyzing the fault. A defendant may be found liable due to his affirmative faulty conduct; depending upon the situation, his failure to act may also convict him. Fault, then, may occur intentionally or negligently.
The concept of “direct intent”, however, places a wrinkle into the analyses. Accordingly, a defendant is not required to desire the outcome of his or her actions; it is sufficient that he or she knew, or should have known, the outcome that might occur as a result. Negligence is declared when, despite one’s best effort, he or she is unable to prevent the undesired outcome and eliminate the risk of harm; the act, therefore, was not intentional. Two levels of negligence exist in Turkish law: culpa lata and culpa levis. Culpa lata is the absence of the degree of care that even an inattentive or thoughtless person would exercise under all the circumstances, or severe negligence. Culpa levis, in contrast, means ordinary or slight negligence arising from a failure to exercise appropriate care. Culpa levis may be compared to the attention that a diligent father is accustomed to observing in his own affairs, under all circumstances. The distinction between these two levels is commonly used as a tool by both the court and litigators in an effort to establish fault.
A hypothetical person of average sophistication and intelligence is the standard used for such determinations. Conclusions in this particular issue vary drastically from case to case. In some situations, compliance with the specific regulations of an industry protects defendants from liability. On the other hand, in some industries the expectations are higher than the regulations; in these situations compliance to the regulations alone will not protect the defendants. This is always a question of fact and changes from case to case. As a result, the concept of fault has broad meaning in Turkish law; therefore judges have discretion. The industry characteristics, the facts of the case, the injury itself, and the damages all influence the judges when using their discretion.
Turkish theory recognizes some of the aforementioned defenses, such as action under governmental capacity. This is the exercise of a legally recognized and legitimate right, such as the right of retention, consent, self-defense, and/or necessity.
Similar to American common law, the plaintiff carries the burden to prove his allegations. In some rare cases where the negligence of an actor can be inferred from the nature of the incident, the ability to prove the existence of negligence can be avoided. For example, if a bus hits individuals who are waiting at the bus stop, then the driver’s negligence can be inferred from the outcome; therefore, there is no need to waste the effort to establish it. American common law employs a very similar concept called res ipsa loquitur. In such circumstances, the law recognizes that the act, or inaction, speaks for itself. In our case, Plaintiff is accountable to prove all of the elements of the case.

Procedural Aspect

American Law

In American common law, the jury determines the facts in a particular case; however, in a bench trial, the judge determines both the facts of the case and the applicable law. According to the American common law legal system, a trial takes place as soon as evidence is collected via discovery. At the trial the parties present evidence in an uninterrupted fashion, without any possibility for additional proof after its close. Accordingly, for a litigator subject to common law, a trial occurs over a few consecutive days and heavily emphasizes such verbal procedural tools as opening and closing statements to the jury, witness testimony, and cross-examination.

Turkish Law

In the civil law system, “trial” means something very distinct from the common law system. For a Turkish attorney, “trial” refers to one of the many sessions that he or she will go through while handling a case. In the civil law system, discovery happens progressively as the case proceeds;pieces of evidence accumulate slowly and, consequently, provide the judge with guidance to establish his or her final decision. Trial experience lacks the theatrical aspect and is not traditionally welcomed in civil law tradition.
Turkish evidentiary rules do not have a hearsay policy. As a result, a Turkish judge has a freer hand when collecting evidence. He or she may access any evidence, as long as it is not protected by a privilege;subpoenas are very commonly used to collect evidence.


American Law

American common law generally allows a plaintiff to request compensation for personal injury damages, as well as pain, suffering, emotional distress, and the loss of enjoyment of life. Personal injury damages include past and future earning losses, medical and hospital expenses, in addition to pain and suffering. Courts typically provide for a lump sum recovery in personal injury actions, which makes it difficult to calculate damages. Several factors play an important role in assisting the jury to determine the extent of just compensation. Factors considered are the severity of the injury (permanent versus nonpermanent), the implications for future employment, actual expenses, and the severity of the violation of the regulation. In cases where there is an aggravated circumstance of intentional misconduct, recklessness, fraud, malice or outrage, plaintiffs are permitted to request punitive damages.

Turkish Law

The plaintiff carries the burden of proving the damages to which he or she is entitled. Turkish law does not recognize punitive damages; on the contrary, similar to many continental European civil law countries, it follows the principle that bans enrichment by compensation. Damages would include the plaintiff’s actual damages, including his or her future and past medical expenses; any damage incurred due to the loss of employment, as well as related future financial damages. The compensation for pain and suffering is mainly used symbolically; it is generally a small, if not nominal, amount. The language from the Turkish Code of Obligations, Section 42 states: “The plaintiff proves the damage.” In the case that the actual amount of the damage is unascertainable, the judge determines it considering the ordinary course of the case and the precautions taken by the harmed party.” When determining the extent of damages, the civil law system loads a heavy burden on the judges.


American Law

In our case, the defendant must prove that the plaintiff has an obligation to exercise a certain level of care, yet fell below that level. As a result, the defendant caused harm to the plaintiff by his unreasonable conduct and, thus, the plaintiff suffered legally recognizable losses.
According to the facts of our case, there is no doubt that the defendant owed a duty to the plaintiff. The plaintiff was on the defendant’s premises as a business invitee and, therefore, the defendant owed him a duty to create a safe environment and warn him about the existing risk of harm. In addition to that, the plaintiff maintains that he was in the necessary location for him to complete the business; stating that he was in a specific spot, as directed by the defendant.
The legal issues in this case are likely to be the breach of duty and the causation elements. We are dealing with a defendant who has been in the scrap metal collecting business for several years. A Parent Corporation, owning several other scrap yards across the United States, owns the defendant company. These facts indicate that the defendant has access to some sort of legal advice, if not a large team of legal advisors. In other words, we do have a defendant that is probably more sophisticated than a family-owned scrap yard. Such businesses are likely to try hard to comply with the law in order to avoid the financial consequences of noncompliance. In our case, the defendant most probably knew that there was a duty owed to all customers who entered its premises, and also that there was potential risk of harm due to the nature of the business. So, it is likely that the defendant has a procedure to prevent customers from the risk of harm. The plaintiff may have difficulty proving the breach, especially if more evidence exists on the issue of the warning. Since the accident took place at the defendant’s place of business, it is likely that more than one individual witnessed the incident. The plaintiff may end up trying to prove that the defendant breached its duty of care instead of the proof about the existence of the verbal and written warnings.
The defendant may defend itself by showing that its conduct consistently exceeds the standard owed to its customers. The defendant may also argue that it took all preventive measures required by the “reasonable person standard,” and even had its employees warn the plaintiff several times to stay away from the beam. Accordingly, causation is likely to set a high bar for the plaintiff, unless he can prove that the defendant’s breach of duty caused his injuries instead of his own conduct of staying close to the beam and touching it.
The plaintiff in our case injured his index finger and has already undergone some medical procedures; he is now facing past and future expenses related to those procedures. In this case, the plaintiff may seek to recover for his current and expected medical bills. He may also pursue the loss of income already incurred, as well as any future losses he should experience as a result of the injuries.

Turkish Law

If our case were subject to Turkish law, the plaintiff would not be required to show that the defendant is the owner of the property; ownership of the premise is not an element of the tort. On the other hand, the plaintiff would have to prove that the defendant violated a legal protection of his and, thus by the defendant’s fault, caused damages to the plaintiff. Proving the existence of one of the defenses, or successfully defending the elements of the case, are the only alternatives for a defendant subject to Turkish jurisdiction in order to eradicate the liability.
If the case were subject to the Turkish civil law system, the plaintiff would face a heavier burden in proving elements of the case existed. First of all, he lacks the convenience provided by the business invitee status, which he would enjoy in the American legal system. In the Turkish system, the plaintiff first has to prove the unlawfulness and fault by the defendant; in the American system, he would easily establish his status as a business invitee and automatically establish the existence of duty. In addition, it is most common that, as long as the defendant complies with industry expectations, the unlawfulness of an act would be very hard for the plaintiff to prove. Due to the nature of the scrap metal industry, compliance with industry standards is likely to be widely practiced; in this case, regular, documented adherence to such regulations would serve to prevent the defendant from liability. Most of the time, the legislative body will heavily regulate an industry because of the importance of said industry to society. For these highly regulated industries, it is considered risky to allow private actors to act freely when doing business within the industry.
In the United States, and this area of Florida in particular, the scrap metal industry contributes significantly to the economy; perhaps just as importantly, it helps to conserve the world’s natural resources, which are becoming increasingly scarce (and valuable). Today, by the legislative bodies of the world consider almost anything that relates to the preservation of natural resources to be supremely important. As such, the industry is closely regulated and, most of the time, the laws pertaining to the industry provide very detailed regulations that even extend to the businesses’ standard operating procedure. In a situation like the Florida case, it is likely that the defendant’s exhibited compliance with specific industry standards will enable it to prove its lack of unlawfulness and fault. Furthermore, if the defendant is able to present evidence that protective procedures are in place, combined with the testimony from eyewitnesses about the posted and verbal warnings, this is likely to be condemning enough proof of fault against the plaintiff for a not-guilty verdict to be rendered.


Why do we need to compare? An attempt to create a science of universal law would be too ambitious. Lawyers today are required to develop a better understanding of foreign legal systems. Nowadays, thinking only locally and being ignorant of the legal systems that do not govern us are not optional in the practice of law any longer. Comparative law research and studies are very useful tools for both scholars and practitioners. This comparative approach allows us to develop a better understanding of the similarities and disparities among different jurisdictions. As a result, this approach provides superior, more effective communications and comprehension for the sake of the practice of law. By sharpening our awareness and recognition of the legal environments in which we live and the ones in which we do not, we open the path to improvement. The differences and similarities help develop theories that eventually prevent law from becoming slow, archaic and useless.
Comparing civil law and common law, two major legal systems of the world, is a useful intellectual exercise for legal scholars, in terms of addressing the weaknesses and strengths of both systems. The United States common law system has several superb qualities in comparison to the Turkish civil law, and vice versa. Common law provides flexibility with the system to act faster by the judge-made laws, without forwarding each and every question to the legislative body. It makes law a living, faster moving creature compared to civil law. To do that, however, it relies heavily on the judges’ common sense.
In the Florida case presented, the plaintiff is fortunate that he is subject to American jurisdiction. Under Turkish torts law, any plaintiff maintains the duty to prove the unlawfulness of an act, as well as the fault of the defendant. Due to the generality of the elements of a Turkish tort, it is only able to capture few numbers of incidents; the American tort elements of duty and breach, however, are likely to redress a wide variety of situations due to its diverse nature. Although a comparative approach to law is not always applicable, in instances such as the Florida case explored in this essay, it can provide a superior determination by providing an enlightened point of view.
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