Volume VII · Ethics and the Situation of Wild Animals · chapter 31
The Issue of Predation
Before you read study layer, not part of the original text
The chapter examines the arguments about predation and concludes that there are good reasons to reduce it in the world, as long as doing so does not bring worse consequences, and that certain interventions, such as reducing primary productivity, would probably have a positive net result.
Being hunted and eaten is one of the worst things that can happen to an animal. It is not easy to change that without causing other problems, but the book shows there are reasons to think about careful ways to reduce this suffering over time.
We already expect a dog not to attack the cats in the house, and we protect cattle from wolves. It is not absurd to ask whether, with care, we could reduce the suffering caused by predation in other cases.
- P1 Predation causes intense suffering and death to an enormous number of animals.
- P2 The objections (it is not an ethical matter, predators are not to blame, it is neutral, it is absurd, it is fascism, it is sentimentalism) do not hold up.
- P3 Interventions in predation are already widely accepted when they protect humans and exploited animals.
- P4 Interventions that worsen the consequences should not be carried out; but some, such as reducing primary productivity, probably have a positive net result.
- C So there are good reasons to reduce predation in the world, with caution.
The chapter’s central argument in logical form. If the premises are true, the conclusion follows. To disagree, you have to show which premise is false.
They say “Wanting to end predation is going against nature and destroying ecosystems.”
Answer No one is proposing interventions that make things worse. The proposal is to investigate careful approaches, such as reducing primary productivity, that lower the number of animals born to suffer.
More objections and answers in Debunking objections.
Original text Luciano Carlos Cunha · Volume VII, p. 93 of the PDF edition · English translation
31.1. The prevailing view
The prevailing view is that it is wrong to intervene in cases of among . However, a growing number of authors have questioned this view in recent decades141. This chapter examines the main arguments in this debate.
31.2. The idea that predation is not a matter for ethics
It is sometimes argued that predation is not a matter for ethics because predators cannot be held responsible, since they do not understand ethical questions142. However, this fact does not stop predation from being a matter for ethics, because the question of whether we should intervene in predation is not posed to predators, but rather to us, as responsible agents.
It is curious that the claim "predation is not a matter for ethics" is invoked in an attempt to establish that it is morally wrong to intervene in predation, since the one claim contradicts the other. That is, it makes no sense to say "action X is not subject to ethical evaluation" and then to say "it is morally wrong to do action X."
Whenever it is possible to ask whether an action (whether an act or an omission) should be prohibited, required or permitted, it is a matter of ethics. Therefore, the decision about what to do in cases of predation is a matter of ethics.
31.3. The idea that it is wrong to intervene because predators are not to blame
Another similar argument holds that the fact that predators cannot be held responsible makes it wrong to intervene in cases of predation. Underlying this position is the idea that, if someone is not morally responsible for the harm they cause, we should not prevent that harm.
However, the one does not imply the other. For example, it makes no sense to hold responsible a small child who hits another child on the head with a stick; but the victim's suffering is something negative, and that is a reason to prevent such an outcome from taking place. Our moral responsibilities can go beyond redressing the wrongs of other responsible agents (they can involve, for example, making the world a place with less suffering and death)143.
It could be claimed that one difference between the case of predation and the example above is that predators die if they do not prey. However, this is already a different argument, since it appeals to the need to prey in order to survive, not to the fact that the predator cannot be held responsible. We will discuss this other argument in sections 31.10, 31.11 and 31.12.
31.4. The claim that predation is neutral because it results from amoral agents
Another similar argument holds that, because predators cannot be held responsible, the harms they cause are neutral, and that, therefore, there is no reason to prevent them. However, the one does not imply the other. For example, suffering is negative because of its intrinsic characteristics, and these do not depend on whether or not whoever causes it can be held responsible. Therefore, the suffering resulting from predation is negative, not neutral144.
31.5. Absurd because impossible to accomplish
Another argument against intervening in predation points out that we will never manage to end all predation in the world. However, the fact that we cannot end all cases of a problem does not show that we should not act in the cases where we could do so145. Nor can we prevent all the harms that humans suffer, much less all the harms that humans cause to animals, but this does not imply that we should not try to prevent as many as we can. The same applies to predation.
31.6. The accusation of fascism
Another claim holds that intervening in predation is wrong because it would be an act of fascism for not accepting differences (it would be like homophobia and racism). However, this analogy does not work. Someone's race and sexual orientation do not entail the death of other individuals. Predation, by contrast, entails the death (usually with extreme suffering146) of a gigantic number of individuals. Wanting the world to contain less suffering and death is very different from discriminating against someone on account of their race or sexual orientation.
31.7. The accusation of sentimentalism
Another objection holds that intervention in predation is motivated by sentimentalism (compassion for the prey), and that it should therefore be rejected. It is true that someone's having a strong feeling about an issue does not show that the position they defend is necessarily correct. For example, their feeling may be the product of a prejudice; it may violate justice; or their compassion may be selective. However, neither does it show that the position is wrong. It is possible that what someone concludes, motivated by their feelings, is the same as what they would conclude from an impartial perspective, weighing all the arguments for and against a certain action. We will only find out whether or not this is the case if we carry out an impartial analysis of the issue.
31.8. Speciesism and interventions in predation
Another objection holds that intervening in predation is a attitude. However, this accusation only makes sense in situations in which whoever is deciding: (1) is concerned only with predation on or by members of certain species or; (2) weighs harms arbitrarily according to the species of those involved.
For example, the standard position is that, when humans are the victims of predation, it is always right to intervene regardless of the consequences, and that when nonhuman animals are the victims, it is always wrong to intervene, even if the consequences of not intervening are worse. This is speciesism, pure and simple. Curiously, this is the most common position among those who accuse the proposal to intervene in predation of speciesism.
Intervening in predation is not necessarily speciesist. For example, if someone gives equal weight to each of those affected (whether predators or prey) and claims that the right action (whether intervening or not intervening) is the one that results in the least total harm, they are not being speciesist147. Favoring an individual belonging to a species is not necessarily speciesist (it is speciesist only if the favoring is biased).
31.9. Is intervening in predation partial?
A similar objection holds that intervening in predation means being partial in favor of the prey (whatever species it belongs to). However, this accusation would only make sense if intervening necessarily meant favoring the prey in a biased way. But there is at least one way of defending intervention that could not be accused of favoring the attacked or the attacker in a biased way: the goal of seeking the best outcome, while holding that the good of each being affected has the same weight. According to this view, when not intervening would have worse consequences, we should intervene, regardless of who is the prey and who is the predator. Analogously, this position will advocate not intervening when intervening would have worse consequences. This position is certainly impartial.
31.10. The appeal to the need to prey
Another argument frequently used to claim that it is wrong to intervene in predation involves pointing out that predators die if they do not prey. Below we will look at four problems with this argument.
The first problem is that it is biased: it takes into account only the deaths of predators.
The second is that the argument completely disregards the number of deaths. For example, a predator kills many prey over its lifetime, usually with intense suffering. It could be objected that predation minimizes the total number of deaths, since in the absence of predation the prey would reproduce even more. However, this is not the case with all predation. For example, large herbivores consume a great deal of vegetation, and this drastically reduces the number of insect births. Thus, a decrease in the rate of
predation on large herbivores, precisely by increasing the population of these herbivores, would probably decrease the total number of deaths by decreasing the total number of births. In other words, if the concern is to reduce the number of deaths, then one has to admit that intervening in predation is right when it results in fewer deaths.
The third problem is that intervening in predation does not necessarily entail the death of the predator. There are some plant-based foods that use synthesized nutrients that meet the physiological needs of certain predators, such as cats. Sterilizing or genetically modifying a predator also does not necessarily entail its death148. Regardless of whether or not such practices are right, their existence shows that it is false that intervening in predation necessarily entails the death of the predator.
The fourth problem is that, even if preying were currently necessary for each and every predator, this does not show that it would be wrong to make it unnecessary (for example, through genetic change). What the argument says is that, where there is a need, we should not prevent its fulfillment. However, this does not imply that it is wrong to make that need cease to exist.
31.11. The appeal to lesser harms to the predator
Another possible objection would be to say that the predator is harmed by having to eat plant-based food, or by being sterilized or genetically reprogrammed.
The first possible response to this objection is to deny that some of these actions harm predators. Eating a different food is not necessarily a harm. The same applies to genetic change. Suppose that a genetic change is made in certain predators so that they become herbivores. The animals of the future generation who were born herbivores would lose nothing by the fact that their ancestors were carnivores. Even the animals of the current generation do not seem to lose anything by having their nutritional needs modified. Another example of intervention in predation that causes no harm is preventing predation by carnivorous plants, since they are not sentient.
The second response is to point out that, even if predators are harmed by such actions, the harm to them is much smaller than the harm that will take place if predation is allowed. Thus, the objection is guilty of arbitrariness, since a lesser harm to the predator is treated as a trump over much greater harms to the prey (being eaten alive). On such a view, the harm resulting from intervention, however small, is seen as more serious than the far greater harms that would result from non-intervention.
When humans are at risk of being preyed upon, the standard position is simply that it is right to kill the predators, period. Suppose it were argued, out of concern for the predators of humans, that instead of killing them we should genetically reprogram them, sterilize them, or create a plant-based food that meets their needs. Such a proposal would probably not be accepted, but not out of concern for the predators, rather because resources would be spent on members of other species. However, the judgment is reversed when predation occurs on nonhuman animals: proposals such as sterilization, genetic reprogramming and the creation of plant-based food for predators are rejected out of concern for a possible harm to the predators. This is speciesism.
31.12. The appeal to the right to secure one's survival
It could be argued that the predator has the right to secure its survival, and that we should protect this right, whatever the consequences. Therefore, according to this position, it is always wrong to prevent cases of predation.
Note that this position implies that it is also wrong to defend oneself or other humans from predation. This is something its proponents would hardly accept. But if they do not accept it, they are being speciesist. However, suppose for the sake of argument that someone argues that it is always wrong to prevent a predation from occurring, even if it is on other humans or on oneself. Even in that case, there are other reasons to reject this position, which we will look at below.
The first is that it assumes that we should follow certain rules, whatever the consequences. So anyone who believes that the right action coincides with the one that results in the best consequences could never accept what this view proposes.
The second is that even the perspective which holds that there are rights that must be guaranteed regardless of the consequences does not support this position. This is because, if predators have rights, so do prey, and the position in question is arbitrary in defending only the rights of predators. At this point it could be objected that both predators and prey have the right to try to survive, and that this implies letting each fight with its own strength. One problem with this is that, if guaranteeing rights amounts to the same thing as everyone fighting for themselves, then there is no point whatsoever in claiming that rights exist.
Recognizing a right to survival, by contrast, would imply protecting the interest in living of both the predator and the prey. For example, it would imply research into securing the survival of predators with another kind of food, not non-intervention.
Moreover, the position in question holds that rights must be protected whatever the consequences. So it cannot appeal to the risk of negative consequences of preventing predation. That is, contrary to what may initially seem to be the case, this position would have to advocate always preventing predation, whatever the consequences.
It could be objected that predators, because they have no sense of right and wrong, do not violate rights149. There are two possible responses here. The first is to argue that the violation of a right is characterized by the type of act, and this does not depend on whether or not whoever performed it has a sense of right and wrong. The second is to argue that, even if it is true that predators do not violate rights, this is irrelevant, since the question is whether we, who have a sense of right and wrong, violate a right if we do not intervene in predation.
Another objection would be to argue that there are only negative rights, which imply that agents must refrain from doing certain harmful things, but that there is no right to be rescued150. The first problem with this argument is that, even if there were no right to be rescued, this does not imply that it would be wrong to rescue victims of predation. Rescuing could be permissible and even praiseworthy. The second problem is that, if the reason
for attributing rights to someone is to protect that someone151, it makes no sense to say that rights are limited to negative rights, since threats to someone's good are not limited to the acts of (they can result from omissions).
Thus, an appeal to rights does not show that it is wrong to intervene in cases of predation.
31.13. Widely accepted interventions in predation
There are a number of interventions in predation that are widely accepted and practiced. For example, to defend oneself, other humans, or the animals who live with us. Another example is interventions in predation motivated by reasons, such as the ecology of fear (the reintroduction of predators where they had gone extinct152) and interventions to kill predators if they are threatening a rare species153.
Thus, people seem to consider it wrong to intervene in predation only when it occurs among wild animals and the goal of the intervention is concern for the good of the nonhuman animals themselves (and not or environmentalist goals) – what we will call here the specific arrangement. These people therefore need to explain why intervening in predation would be wrong only in the specific arrangement.
None of the arguments we have discussed so far could explain this difference. For example, in the widely accepted cases of intervention in predation, the predators are also not responsible agents, they also need to prey, and in these cases the intervention also entails one of these things: killing them, genetically modifying them, sterilizing them or changing the way they feed. Is there, then, some other way of justifying that intervening in predation is wrong only in the specific arrangement? Below we will discuss some attempts.
31.14. The appeal to animal behavior
A first attempt to ground the difference points out that animals of social species defend animals of their own species from predation, but not those of other species, and that we should therefore do the same.
There are two problems with this argument. The first is that it is doubtful that animals defend only members of their own species from predation. However, the main problem with the argument is that the fact that a behavior is exhibited by animals does not imply that it is right154. For example, there are animals who kill the young of rivals and even their own young; who kill in power struggles; who steal; who rape, etc. Cannibalism has even been found in more than 1,300 species, in a wide variety of social and ecological contexts155. The fact that animals do such things does not make them right.
31.15. The argument from the ability to avoid the threat
Another argument holds that there is no need to intervene in predation among wild animals because, if their species still exist, it is because they have the ability to escape predation. In the case of human children, on the other hand, we should intervene because they lack this ability, the argument concludes156.
The main error of this argument is that it uses reasoning based on the species in the case of wild animals and reasoning based on individuals in the human case. The fact that a species has not gone extinct shows only that some of its members managed to reproduce before succumbing to predation. It does not even show that these individuals escaped predation until the end of their lives, much less that all members of the species escaped predation. For example, as the argument itself acknowledges, the fact that the human species still exists does not show that all its members have the ability to escape predation.
31.16. Concern about consequences
One of the main arguments against intervening in predation holds that doing so would cause more suffering and death than it prevents because, in the absence of predators, prey animals will undergo
a population explosion, resulting in a greater number of deaths from starvation (and even from predation, given that in many cases they are also predators of smaller animals).
A first problem with this argument is that it, too, could not explain what the difference is between intervening in predation in the specific arrangement and in the widely accepted cases. For example, we also do not know whether preventing predation on humans has better long-term consequences, since, as we will see in detail in Chapters 36 and 37, it is uncertain whether what has better consequences is a larger or a smaller human population.
Moreover, one implication of concern about consequences is that it could not establish that it is always wrong to intervene in predation, since if in a given case it is not intervening that will result in more suffering and death, such a position would have to accept intervening.
It could be claimed that there are no cases of this kind. But there is currently no basis for this claim, since very few studies have been carried out in this direction. Moreover, there are initial reasons to think that there are in fact many such cases. One example is if the predator species targeted for sterilization are also those with the greatest reproductive potential. Another example is the reduction of predation rates on large herbivores, since these animals consume a great deal of vegetation, thereby reducing the that is the basis of the food chain (which reduces total birth rates). Thus, a decrease in predation on large herbivores would reduce total suffering and death precisely by increasing the population of large herbivores.
At this point it could be objected that, until there are thorough studies on how consequences unfold in this regard, we should adopt a policy against interventions. This is reasonable, but it does not establish that we should set this issue aside and "let nature take its course" (nor does it establish that it is right to intervene only when the victims are human). On the contrary, it establishes that we should carry out these studies – at least, that is what someone with a serious concern about consequences would do. If this is rejected, then it is an indication that concern about consequences was invoked not as a real concern, but as an excuse to keep holding the belief that intervening in predation is always wrong.
31.17. Existing cases and the prevention of new cases
We saw above that there seems to be no way of establishing that it is always wrong to intervene in predation. However, suppose that any intervention in predation were wrong because of some possible harm to the predator. This would tell us nothing about the morality of preventing new births of predators, since in that case what is at stake are mere possibilities of future sentient beings that would never come to be realized (and not beings who already exist and would be harmed). This will be explained in more detail below.
Most people do not argue that there is a duty to produce new individuals. And even those who argue that there is such a duty acknowledge that killing those who already exist is worse than refraining from producing new individuals. There are good reasons to think this way. When someone who already exists is killed, there is an individual who is harmed. On the other hand, with respect to refraining from producing new births, what there are are possibilities of future individuals that are never realized. For example, let us imagine that, if a couple decides to conceive a child now, an individual will be born nine months from now, but that if they decide to wait until next month, a different individual will be born, and so on for the following months. Realizing one of these possibilities means not realizing several of the others. But this is not the equivalent of killing someone who already exists.
Except in cases where the predator would die before managing to prey for the first time, producing new predators would entail the deaths of prey. Of course, many of the individuals who would be killed by predation probably do not exist yet. But this is different from future possibilities of individuals that are never realized. They would be individuals who would come to exist in the future and would then be killed. On the other hand, preventing the birth of new predators would merely mean not realizing future possibilities of individuals. If, as we saw earlier, killing already existing individuals is worse than refraining from producing new individuals, this implies preventing the birth of new predators (provided, of course, that the consequences are not worse than not doing so).
Let us consider an analogy. When we have scarce resources and many people dying of hunger, different people may disagree about who should have priority in receiving the resources. Giving the resources to some people would mean the deaths of others and vice versa But they would not disagree about whether it would be better for everyone to have resources and for us to eradicate hunger. In the same way, different people concerned about sentient beings, even if they disagree about whether we should favor the prey or the predator in this or that case, could not disagree, out of concern for sentient beings, that a world without predation is better (provided that, in this way, the consequences are not worse than those resulting from a world with predation).
It could be objected that this would mean driving species extinct, and that we should therefore not do it even if the consequences of not doing it are worse for sentient beings in general. In the first place, this would not necessarily mean the extinction of species because, as we have seen, there is the possibility of genetic modification. But even if it did, this would be insufficient to show that it is wrong to do it. It would have to be shown that species have , and that this value is more important than the good of sentient beings. But, as we saw in Chapter 20, there are good reasons to think exactly the opposite.
31.18. The goal of reducing primary productivity
Given what we have seen above, contrary to the prevailing belief, there is nothing inherently wrong with intervening in predation. In fact, there are good reasons to bring it about that predation no longer exists (provided that this does not lead to worse consequences than if there is predation).
However, this does not mean that intervening in predation is necessarily the best way of preventing/minimizing . Another option (probably more efficient and safer) would be to reduce primary productivity, which is the amount of energy produced by plants through photosynthesis, which serves as the basis for the entire food chain157.
This is not the same as cutting down plants, since in that case others would probably grow in their place. Instead, it would involve covering an area so that plants do not grow there (by paving, covering the lawn with gravel or something else that blocks sunlight), which would reduce the conversion of light into food energy.
One of the most frequent objections to intervention in predation points to the risk that the prey will reproduce even more, so that the intervention will increase the total amount of suffering and
premature death. The proposal to reduce primary productivity easily escapes this objection, since less available energy leads to a smaller total population of animals.
Moreover, there are also interventions in predation that would probably have a positive balance because they indirectly reduce primary productivity. For example, if there are no predators of large herbivores, there will probably be an increase in their populations. These herbivores consume a large amount of pasture, which in turn reduces primary productivity and, consequently, the total population158.
31.19. Conclusion
Everything we have discussed in this chapter shows that the taboo that has arisen around the issue of predation is probably the result of speciesism, since the prevailing position when humans are the victims of predation is exactly the opposite.
Our main conclusions were that: (1) there are good reasons for us to reduce the incidence of predation in the world (provided this does not lead to worse consequences); and that (2) there are certain interventions in predation that would probably have a positive net impact over time because they indirectly reduce primary productivity.
Practice
Study layer. The answers are based on the chapter’s text.
What is the chapter's first main conclusion?
What intervention goal does the chapter discuss?
Food for thought
Why do so many people feel that predation is "beautiful" in documentaries? What would it be like to see it from the prey's point of view?
Author’s notes 18
- 141 (1996); (2003); (2018, p. 168-88; 2022, p. 156-72); Fink (2005); (2010a, 2010b, 2015); (2009); (1984, 1987) and (2015). ↩
- 142 See (2004 [1983], p. 285); (2004, p. 255, 256); Taylor (1986, p. 178). ↩
- 143 Sapontzis (1987, p. 231); Cowen (2003, p. 176-177); (2006, p. 379). ↩
- 144 On this, see Sapontzis (1987, p. 230-231). ↩
- 145 On this, see Sapontzis (1984, p. 32, 35, 36). ↩
- 146 On how preyed-upon animals die, see Ética Animal (2016). ↩
- 147 See, for example, (2010) and Pearce (2009). ↩
- 148 For a defense of genetic reprogramming, see Pearce (2009). ↩
- 149 See, for example Regan (2004 [1983], p. 285). ↩
- 150 See, for example, (2000). ↩
- 151 This is acknowledged both by Regan (2004 [1983], p. 243) and by Francione (2000, p. 127-129). ↩
- 152 For criticisms of the ecology of fear, see Horta (2017 [2010]). ↩
- 153 Engeman et al., 2009 ↩
- 154 On this see Fink (2005, p. 5), (1909, p. 29, 30). ↩
- 155 On this, see Polis (1981); Mitchell and Walls (2008). ↩
- 156 This argument is offered by Regan (2004 [1983], p. XXXVI-XXXVII.) ↩
- 157 For this proposal, see (2013b). ↩
- 158 On this, see Tomasik, (2016b, 2016c). ↩
Sources cited in this text 20
The full list for the volume is in the Volume VII references.
- BONNARDEL, Y. Contra o apartheid das espécies. Les cahiers antispécistes, v. 14, 1996.
- COWEN, T. Policing nature. Environmental Ethics, v. 25, p. 169-182, 2003.
- CUNHA, L. C. Razões para ajudar: o sofrimento dos animais selvagens e suas implicações éticas. Curitiba: Appris, 2022.
- CUNHA, L. C. Vítimas da natureza: implicações éticas dos danos que os ani- mais não humanos padecem em decorrência dos processos naturais. 2018. Tese (Doutorado em Filosofia) – Universidade Federal de Santa Catarina (UFSC), Florianópolis, 2018.
- FINK, C. The Predation Argument. Between the Species, v. 13. n. 5, p. 1-15, 2005.
- HORTA, O. Animal Suffering in Nature: The Case for Intervention. Environmental Ethics, n.39, 2017. p .261–79.
- HORTA, O. Debunking the Idyllic View of Natural Processes: Population Dynamics and Suffering in the Wild. Télos, v. 17, p. 73-88, 2010.
- MCMAHAN, J. Predators: A response. New York Times, 28 set. 2010b.
- MCMAHAN, J. The Meat Eaters. New York Times, [s.l.], 19 set. 2010a.
- MCMAHAN, J. The Moral Problem of Predation. In: CHIGNELL, A.; CUNEO, T.; HALTEMAN, M. C. (org.). Philosophy Comes to Dinner: Arguments About the Ethics of Eating. London: Routledge, 2015. p. 268-294.
- PEARCE, D. Projeto para um mundo sem crueldade: reprogramar os predadores. The Abolitionist Project, [s.l.], 2009.
- REGAN, T. The Case for Animal Rights. 2. ed. Los Angeles: University of California Press, 2004 [1983].
- SAPONTZIS, S. F. Morals, Reason and Animals. Philadelphia: Temple University Press, 1987.
- SAPONTZIS, S. F. Predation. Ethics and Animals, v. 5, p. 27-38, 1984.
- TAYLOR, P. Respect for nature. Princeton: Princeton University Press, 1986.
- TOMASIK, B. How Cattle Grazing Affects Insect Populations on Pasture Fields. Essays on Reducing Suffering, 02 mar. 2016b.
- TOMASIK, B. How Cattle Grazing Affects Pasture Productivity. Essays on Reducing Suffering, fev./mar. 2016c.
- TOMASIK, B. Speculations on Invertebrate Population Dynamics Relevant to Reducing Suffering. Essays on Reducing Suffering, 11 jun. 2013b.
- TORRES ALDAVE, M. The Case for Intervention in Nature on Behalf of Animals. A Critical Review of the Main Arguments against Intervention. Relations: Beyond Anthropocentrism, v. 3, n. 1, p. 33-49, 2015.
- ÉTICA ANIMAL. Antagonismo na natureza: conflitos interespecíficos. Ética Animal: ativismo e investigação em defesa dos animais, 26 out. 2016.
This chapter in Volume XII
How the author sums up this debate in The Essentials of Animal Ethics.
Intervening in conflicts between animals could make the situation even worse (for example, intervening in predation could cause a population explosion of prey). (VII, ch. 18, 31).
The proposal would entail intervening in conflicts between animals, and this is wrong even when doing so improves the situation. (VII, ch. 18, 31).
There is nothing that can be done on a large scale (VII, ch. 18, 24, 31, 36, 37).
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