Introduction
Satellite communication services in Turkey are becoming increasingly important as digital connectivity, broadband access, maritime communications, aviation connectivity, disaster response, defense-related communications, IoT, remote industrial operations, smart agriculture, connected vehicles, LEO satellite constellations and cross-border data transmission continue to expand. Satellite technology can provide communication services in areas where terrestrial infrastructure is insufficient, unavailable, damaged or economically impractical. It is therefore a strategic part of Turkey’s electronic communications ecosystem.
However, satellite communication services are not ordinary technology services. In Turkey, they are regulated within the electronic communications framework. Companies providing satellite-based voice, data, image transmission, satellite internet, satellite terminals, satellite ground station services, GMPCS mobile satellite services or satellite-based corporate connectivity may need authorization from the Information and Communication Technologies Authority, known as BTK.
BTK is the main authority regulating and supervising the telecommunications sector in Turkey. It is Turkey’s first sectoral regulatory authority and operates under the framework introduced by Law No. 5809 on Electronic Communications. BTK defines authorization as registration of companies with the Authority for providing electronic communications services and/or networks, or granting specific rights and obligations to those companies after registration.
Satellite communication services create several legal questions. Does the service require BTK authorization? Is the service classified as Uydu Haberleşme Hizmeti, Uydu Platform Hizmeti, GMPCS Mobil Telefon Hizmeti, Internet Service Provider activity or infrastructure operation? Are frequencies, numbers or satellite positions involved? Must a satellite ground station be located in Turkey? Are user terminals subject to radio equipment conformity rules? How should traffic data, subscriber data and cross-border data transfers be handled? What happens if the operator provides services without authorization?
This guide explains the legal and regulatory framework for satellite communication services in Turkey from the perspective of telecom operators, satellite service providers, foreign investors, technology companies, maritime and aviation service providers, IoT platforms, satellite internet providers and corporate customers.
Legal Framework of Satellite Communications in Turkey
The primary legislation governing satellite communication services in Turkey is Law No. 5809 on Electronic Communications. Law No. 5809 regulates electronic communications services, networks, infrastructure, authorization, numbering, spectrum, consumer rights, service quality, audits and administrative sanctions.
Satellite communication services are also shaped by BTK secondary regulations, authorization decisions, CEVHER application procedures, spectrum management principles, the National Frequency Plan, usage right fee rules, radio equipment rules, network and information security obligations, personal data protection law, consumer protection legislation and Law No. 5651 where internet access or hosting-related activities are involved.
BTK’s official authorization page states that authorization aims to increase the number of market players, create a competitive environment, establish reliability in the sector, encourage domestic and foreign investment, ensure efficient use of national resources, provide services widely, ensure service quality and protect consumers. These policy goals are especially relevant to satellite communications because satellite services may improve connectivity in rural, maritime, aviation and emergency contexts.
The regulatory framework therefore combines two dimensions. The first is market-entry regulation: whether a company may lawfully provide satellite communication services in Turkey. The second is operational compliance: whether the company continues to comply with spectrum, consumer, privacy, cybersecurity, technical and reporting obligations after authorization.
What Is Satellite Communication Service under Turkish Regulation?
Turkish sectoral classification distinguishes satellite communication services from other electronic communications services. BTK’s published “Definition, Scope and Durations of Electronic Communication Services, Networks and Infrastructures” defines Uydu Haberleşme Hizmeti, or Satellite Communication Service, as a service provided through satellites and satellite ground stations and/or satellite terminals, in one-way or two-way form, by electromagnetic waves, between geographically distant points, for voice, data and image communication except telephone service, including establishment and operation of the related infrastructure.
This definition is important because it shows that satellite communication authorization is not limited to traditional satellite TV. It may cover data transmission, broadband connectivity, corporate satellite links, remote site connectivity, disaster communication, video transmission, maritime connectivity, aviation connectivity and other communication services provided through satellite systems.
The same BTK classification separately defines Uydu Platform Hizmeti, or Satellite Platform Service, as a service involving conversion of voice, data and image signals received from different transmission media into digital form through encoder and multiplexer groups on a digital satellite platform, sending them to satellite via satellite ground stations and delivering received digital signals to subscribers through appropriate terminal devices.
The distinction matters. A company providing satellite broadband to remote corporate sites may fall under satellite communication service. A company operating a digital satellite broadcasting platform may fall under satellite platform service. A company providing direct mobile satellite telephone-type services may need to consider GMPCS classification. Correct classification is the first step in legal compliance.
Satellite Communication Service vs. GMPCS
GMPCS, or Global Mobile Personal Communications by Satellite, is another important regulatory category. BTK’s sectoral definition describes GMPCS mobile telephone service as direct voice, data, fax and similar services provided to users/subscribers through a satellite system whose position and working frequencies are coordinated and allocated by the ITU, including fixed or mobile, wideband or narrowband, global or non-global and geostationary or non-geostationary satellite systems.
This classification is relevant for mobile satellite services, handheld satellite phones, emergency satellite devices, global satellite communication terminals and certain non-terrestrial connectivity models. A satellite internet provider, a satellite phone provider and a satellite broadcasting platform may therefore fall into different regulatory categories even though all use satellites.
From a legal perspective, the difference affects the authorization path, technical requirements, frequency usage, terminal equipment, radio fee contracts, subscriber rules and network security obligations. A company entering Turkey’s satellite market should not assume that one satellite-related authorization covers all possible services.
BTK Authorization for Satellite Communication Services
Satellite communication services in Turkey generally require BTK authorization where they fall within electronic communications service, network or infrastructure activities. BTK’s authorization framework requires companies to follow the CEVHER System for initial authorization, additional authorization, authorization renewal, adequacy control and operator information updates.
A company planning to provide satellite communication services should analyze whether its activity falls under notification-based authorization, usage right authorization or another regulated category. If the service uses scarce resources such as frequency, number or satellite position, usage rights may become relevant. BTK’s usage rights page defines usage right as the right granted by the Authority for use of scarce resources such as frequency, number and satellite position.
This is especially important for satellite operators because satellite services usually involve frequency coordination, satellite terminal operation, ground station links, uplink/downlink spectrum, interference management and sometimes satellite orbital resources. Even where the service does not require a Turkish satellite position allocation, use of frequencies and terminals inside Turkey may require regulatory review.
The safest approach is to determine the exact technical architecture before applying. The legal position may differ depending on whether the company operates a satellite, leases capacity from a satellite operator, operates a ground station in Turkey, sells user terminals, resells satellite internet, provides maritime or aviation connectivity, or offers a managed satellite network to corporate customers.
CEVHER Application Process
BTK authorization applications are conducted through the CEVHER System. According to BTK guidance, applications for initial authorization, additional authorization, renewal and adequacy procedures are carried out through BTK’s CEVHER System. Changes in information submitted by authorized operators must also be notified through the Operator Information Update tab, and supporting documents must be uploaded where required.
For satellite communication providers, the CEVHER process requires careful preparation. BTK’s guidance states that the applicant company must generally be established as a limited liability company or joint-stock company solely for activities subject to authorization or activities necessary to provide the authorized service. The company’s articles of association must include electronic communications or telecommunications service activities and should not include unrelated business fields such as food, automotive, tourism or construction.
BTK also identifies specific satellite-related documents in its application page, including an operator guide for electronic communication services provided via satellite and a frequency band usage document in satellite communication services. This confirms that satellite communication applications require not only ordinary corporate documents but also satellite-specific technical and regulatory documentation.
A satellite service provider should therefore prepare the following before filing:
A clear service description.
Technical network architecture.
Satellite system information.
Ground station information, where relevant.
Terminal equipment information.
Frequency band analysis.
Subscriber model.
Corporate documents.
Articles of association.
Shareholder and management eligibility documents.
Paid-in capital proof.
Data protection and cybersecurity documentation.
Regulatory fee and reporting planning.
Corporate Structure and Capital Requirements
BTK imposes corporate structure and eligibility requirements on companies applying for authorization. For notification or usage-right authorization, the applicant must satisfy conditions relating to company form, articles of association, shareholder and management eligibility, minimum paid-in capital and documentation.
The paid-in capital requirement is particularly important. BTK guidance states that, pursuant to the Board Decision dated 10 March 2026 and numbered 2026/DK-YED/71, the paid-in capital must be TRY 2,500,000 for OKTH authorization and TRY 10,000,000 for other authorizations.
Satellite communication companies should not treat this as a minor formal requirement. Satellite market entry may require significant investment in equipment, ground systems, terminal procurement, capacity leasing, regulatory fees, customer support, cybersecurity, technical staff and compliance processes. Insufficient capital may delay authorization and weaken commercial credibility.
BTK also requires that certain shareholders and persons authorized to manage and represent the company must not have specified criminal convictions, including information systems crimes, crimes against state security, crimes against constitutional order, privacy offences, embezzlement, bribery, fraud, forgery, money laundering, tax evasion and certain violations under Law No. 5809.
Foreign investors should therefore conduct regulatory due diligence on shareholders, board members, managers, signatories and ultimate beneficial ownership structures before applying.
Frequency, Spectrum and Satellite Position Usage Rights
Frequency regulation is one of the most critical parts of satellite communications law. Satellite services rely on radio spectrum for uplink and downlink communication. Incorrect frequency use may create interference with other operators, public systems, aviation, maritime, military, emergency or broadcasting services.
BTK’s spectrum management page explains that some parts of the spectrum can be used with BTK permission under national and international rules, while others may be used without permission only if legislative conditions are met. It also states that unauthorized use or harmful interference may be subject to sanctions and that it should be investigated before purchase and use whether devices using frequencies require permission.
Satellite companies should therefore examine:
Which frequency bands are used.
Whether the frequency band is permitted for the intended satellite service.
Whether a frequency usage right is required.
Whether the system creates harmful interference.
Whether the satellite terminal is exempt or licensed.
Whether ground station operation requires approval.
Whether the National Frequency Plan permits the use.
Whether international coordination is required.
BTK’s National Frequency Plan page includes a specific “Frequency Band Usage Document in Satellite Communication Services” among related documents. This shows that satellite services require dedicated frequency analysis, not a generic telecom review.
Ground Stations and Satellite Terminals
Satellite services may involve different physical components. These include satellites, satellite ground stations, gateways, VSAT systems, maritime terminals, aviation terminals, mobile terminals, fixed user terminals, teleport facilities, antennas, modems, routers and network management systems.
From a legal perspective, the most important distinction is between the satellite system, the ground station and the user terminal. A satellite may be foreign-operated. A ground station may be located in Turkey or abroad. User terminals may be installed on buildings, vessels, vehicles, aircraft or remote industrial sites. Each layer may create different regulatory obligations.
BTK’s sectoral definitions include satellite terminal as a fixed and/or mobile satellite terminal device enabling satellite electronic communications between satellites and subscribers or end users. This means that terminals are not irrelevant consumer devices; they are part of the regulated satellite communication environment.
Satellite providers should review installation permissions, radio equipment conformity, electromagnetic compatibility, spectrum permissions, customer-site responsibilities, maintenance, interference prevention, safety, technical support and liability for unauthorized terminal use.
Satellite Internet Services
Satellite internet is one of the most commercially important satellite communication services. It may provide broadband access to rural areas, vessels, aircraft, mining sites, construction projects, energy facilities, military-adjacent non-classified operations, disaster zones and temporary event sites.
The legal classification of satellite internet depends on the service model. A company may be a satellite communication service provider, an internet service provider, a reseller of authorized services, a terminal distributor, a corporate connectivity provider or a managed network operator. In some cases, more than one authorization or regulatory classification may need to be considered.
Satellite internet contracts should address:
Service speed.
Latency.
Data limits.
Fair usage.
Coverage.
Terminal ownership.
Installation and maintenance.
Power and location requirements.
Weather-related performance limits.
Service interruption.
Emergency use.
Cybersecurity.
Data processing.
Official requests.
Termination and equipment return.
Consumer-facing satellite internet services must also comply with consumer protection rules, including transparent pricing, cancellation, refund, service quality disclosure and complaint handling.
Maritime, Aviation and Mobility-Based Satellite Services
Satellite communication is especially important for maritime and aviation connectivity. Ships, aircraft, offshore platforms, cruise vessels, cargo fleets and remote logistics operations often require satellite-based voice, data and internet services.
Mobility-based satellite services create additional legal issues. Maritime services may involve vessel flag state rules, port state requirements, international maritime safety obligations and Turkish telecom authorization. Aviation services may involve civil aviation permissions, aircraft registration, onboard connectivity rules and coordination with the Directorate General of Civil Aviation where applicable.
BTK’s sectoral document includes provisions concerning electronic communication services provided on aircraft and refers to the submission of an information form, after which service may begin if BTK does not object within 45 days in the relevant framework.
Therefore, satellite service providers should not treat aircraft and vessel connectivity as ordinary fixed-site connectivity. Mobility services require a specific review of telecom law, aviation/maritime rules, equipment compliance, cross-border operation and official request handling.
Satellite Services and Law No. 5651
Satellite internet services may also trigger obligations under Law No. 5651 if the operator provides internet access, acts as an access provider or participates in internet-related service delivery. Law No. 5651 obligations may include content-related processes, access blocking, traffic data, cooperation with competent authorities and legal responsibilities of internet actors.
BTK’s Internet Directorate is responsible for operations relating to content, hosting, access providers and other internet actors, monitoring their legal obligations, implementing sanctions, and managing relations with the Access Providers Union within the scope of access blocking and content removal operations.
For satellite internet providers, the key legal question is whether they are treated as access providers, whether the upstream service structure allocates Law No. 5651 obligations, and how traffic records and official requests will be handled. A satellite internet reseller should not assume that all responsibilities belong to the foreign satellite network operator. Turkish-facing customer relationships may create local compliance responsibilities.
Personal Data Protection and KVKK
Satellite communication services often process personal data. This may include subscriber identity data, contact information, IP addresses, device identifiers, terminal identifiers, billing data, location information, traffic data, customer service records, installation addresses and corporate user data.
KVKK defines personal data as any information relating to an identified or identifiable natural person, and defines processing broadly to include collection, recording, storage, protection, alteration, disclosure, transfer and retrieval. KVKK requires personal data to be processed lawfully and fairly, for specified and legitimate purposes, in a proportionate manner and only for the period required by law or processing purpose.
Satellite communication services may create heightened privacy risks because location and terminal data can reveal sensitive operational patterns. For example, satellite terminal usage may show the location of a ship, aircraft, mining site, energy facility, construction site or emergency response unit. Even where the customer is a company, data may relate to individuals such as crew members, passengers, employees or end users.
KVKK also requires data controllers to take technical and organizational measures to prevent unlawful processing, prevent unlawful access and ensure protection of personal data. Therefore, satellite operators should implement access controls, encryption, role-based permissions, logging, secure customer portals, vendor controls, incident response and data retention policies.
Cross-Border Data Transfers
Cross-border data transfer is a major issue for satellite communication services. Satellite networks are often global or regional. Traffic may pass through foreign satellites, foreign ground stations, foreign network operation centers, foreign cloud systems or foreign group company systems. Customer support, billing, network monitoring, telemetry, cybersecurity and analytics may also be handled outside Turkey.
KVKK Article 9 regulates transfer of personal data abroad. The amended text provides that personal data may be transferred abroad where processing conditions are met and there is an adequacy decision; in the absence of an adequacy decision, transfers may be made with appropriate safeguards such as binding corporate rules, standard contracts or written commitments approved by the Board, subject to statutory conditions.
Satellite operators and foreign satellite service providers should therefore analyze:
Where subscriber data is stored.
Where traffic data is routed.
Where customer support is provided.
Where network monitoring takes place.
Whether foreign group companies access Turkish user data.
Whether standard contracts or other safeguards are required.
Whether technical data includes personal data.
Whether onward transfers occur.
A foreign satellite company entering Turkey should not treat global network routing as purely technical. Where personal data is accessible abroad, KVKK compliance must be assessed.
Cybersecurity and Network Security
Satellite communication services are part of critical connectivity infrastructure. They may be used for disaster recovery, maritime safety, aviation communications, energy operations, public services, corporate networks and remote industrial systems. Therefore, cybersecurity is a central legal and operational risk.
BTK’s network and information security page states that Law No. 5809 and authorization regulations include obligations related to network and information security. It also explains that the Regulation on Network and Information Security in the Electronic Communications Sector imposes certain obligations on all operators and additional obligations on operators holding specific authorization types, including satellite communication service, where the annual net sales threshold determined by BTK is met.
Satellite operators should prepare for risks such as:
Terminal compromise.
Unauthorized access to customer portals.
Ground station cyberattacks.
DDoS attacks.
Signal interference.
Spoofing and jamming.
Weak device authentication.
Insecure remote management.
Firmware vulnerabilities.
Unauthorized configuration changes.
Supply-chain vulnerabilities.
Network monitoring failures.
A satellite service provider should maintain an incident response plan, DDoS mitigation strategy, encryption standards, terminal authentication rules, patch management procedures, vendor security controls and audit-ready records.
Technical Equipment and Radio Device Compliance
Satellite terminals, antennas, modems, radio devices and related communication equipment may be subject to technical regulation and market surveillance. Equipment used in Turkey should comply with applicable radio equipment, electromagnetic compatibility and safety requirements.
This is particularly important for foreign satellite terminal manufacturers, distributors and operators. A terminal that is certified in another jurisdiction may still require Turkish conformity review before being placed on the Turkish market or operated within Turkey. Importers and service providers should review CE marking, user manuals, technical files, frequency band compatibility, radio equipment rules, installation obligations and after-sales support.
Unauthorized or non-compliant terminals may create harmful interference, safety risks, service disruption and regulatory sanctions. BTK’s spectrum guidance expressly warns that devices using frequencies should be checked before purchase and use, and permission must be obtained where required.
Foreign Investors in Satellite Communications
Foreign satellite companies may enter Turkey through different models. They may establish a Turkish subsidiary, partner with an authorized Turkish operator, provide wholesale capacity, operate a ground station, sell satellite terminals, provide corporate satellite connectivity, offer maritime/aviation services or support IoT satellite networks.
Turkey generally permits foreign investment, but satellite communication services remain regulated. Foreign investors must examine whether BTK authorization requires a Turkish legal entity, whether the articles of association meet BTK conditions, whether paid-in capital is sufficient, whether shareholders and managers satisfy eligibility rules, whether frequencies or satellite positions require usage rights, and whether cross-border data flows comply with KVKK.
Foreign operators should also examine local tax, customs, equipment import, customer contract, support center, regulatory correspondence, KEP address and Turkish-language documentation issues.
A foreign satellite provider should not assume that a license or approval obtained in another country automatically permits commercial satellite communication services in Turkey.
Commercial Contracts for Satellite Communication Services
Satellite communication contracts require careful drafting because the service depends on technical, regulatory and environmental factors. A standard telecom contract or ordinary SaaS agreement is usually insufficient.
A satellite communication agreement should regulate:
Service scope.
Authorization responsibility.
Satellite capacity.
Ground station responsibility.
Terminal supply and ownership.
Installation obligations.
Frequency compliance.
Service levels.
Latency and availability.
Coverage limitations.
Weather or obstruction risks.
Maintenance windows.
Cybersecurity obligations.
Data processing roles.
Cross-border transfers.
Traffic data and official requests.
Customer-site responsibilities.
Interference prevention.
Equipment return.
Termination.
Regulatory change.
Liability limitation.
Force majeure.
For corporate customers, service level agreements should be realistic. Satellite communication may involve latency, coverage and environmental limitations that differ from fiber or terrestrial mobile services. Misleading service promises may create contractual disputes and consumer or corporate claims.
Administrative Sanctions and Enforcement Risks
BTK has broad audit and enforcement authority in the electronic communications sector. BTK may supervise operators for compliance with license conditions, equipment standards, sector legislation and spectrum usage, and may impose sanctions where operators fail to comply.
For satellite communication providers, common sanction risks include:
Providing services without authorization.
Operating outside authorization scope.
Using unauthorized frequencies.
Creating harmful interference.
Failing to submit CEVHER updates.
Failure to pay regulatory fees.
Using non-compliant terminals.
Failure to protect personal data.
Failure to comply with network security obligations.
Failure to manage Law No. 5651 access obligations.
Misleading consumers about service quality.
Failure to respond to BTK information requests.
Administrative sanctions may include monetary fines, corrective measures, restriction of operations, cancellation of authorization or other regulatory consequences depending on the violation.
Practical Compliance Checklist
A company planning to provide satellite communication services in Turkey should follow this checklist:
Define the exact satellite service model.
Determine whether the activity is Uydu Haberleşme Hizmeti, Uydu Platform Hizmeti, GMPCS, ISP activity or infrastructure operation.
Check whether BTK authorization is required.
Determine whether notification or usage right applies.
Analyze frequency bands and satellite position issues.
Review National Frequency Plan and satellite frequency band documents.
Prepare CEVHER application documents.
Establish a Turkish limited or joint-stock company where required.
Draft telecom-specific articles of association.
Ensure paid-in capital compliance.
Review shareholder and management eligibility.
Prepare technical architecture and ground station information.
Review terminal equipment conformity.
Analyze Law No. 5651 status for satellite internet services.
Prepare KVKK privacy notices and data inventories.
Analyze cross-border transfers.
Prepare cybersecurity and incident response procedures.
Draft customer contracts and SLA terms.
Prepare consumer complaint procedures where relevant.
Create regulatory reporting and fee payment calendar.
Maintain audit-ready evidence files.
Conclusion
Satellite communication services in Turkey offer major opportunities for broadband access, corporate connectivity, maritime and aviation communications, disaster recovery, IoT, smart agriculture, remote industry, emergency services and non-terrestrial network development. However, they are heavily regulated because they involve electronic communications services, spectrum, satellite terminals, ground stations, user data, cross-border routing and critical connectivity infrastructure.
The core legal framework includes Law No. 5809, BTK authorization rules, CEVHER application procedures, usage rights for scarce resources such as frequency and satellite position, the National Frequency Plan, network and information security obligations, KVKK, Law No. 5651, radio equipment rules and consumer protection principles.
The most important legal step is correct classification. A satellite internet provider, satellite platform operator, GMPCS provider, terminal distributor and corporate satellite connectivity reseller may face different authorization and compliance obligations. Misclassification may lead to unauthorized operation, administrative sanctions, contract disputes and data protection exposure.
Companies entering Turkey’s satellite communication market should combine regulatory, technical, data protection, cybersecurity and commercial legal analysis from the beginning. A well-structured authorization strategy, compliant technical design, secure data-processing model and carefully drafted customer contracts will reduce legal risk and support sustainable market entry.
Frequently Asked Questions
What is satellite communication service under Turkish telecom law?
BTK’s sectoral definition describes Satellite Communication Service as voice, data and image communication provided through satellites and satellite ground stations and/or satellite terminals, one-way or two-way, by electromagnetic waves, between geographically distant points, excluding telephone service, including establishment and operation of related infrastructure.
Does a satellite communication provider need BTK authorization?
Yes, where the activity falls within electronic communications service, network or infrastructure provision. BTK authorization is generally required before regulated satellite communication services are offered in Turkey.
What is the role of BTK in satellite communication services?
BTK regulates and supervises the telecommunications sector in Turkey and handles authorization, spectrum, technical standards, audits, consumer protection and sanctions in the electronic communications sector.
What is CEVHER?
CEVHER is BTK’s system for initial authorization, additional authorization, renewal, adequacy procedures and operator information updates for electronic communications services.
What paid-in capital is required for satellite communication authorization?
BTK guidance states that, under the Board Decision dated 10 March 2026 and numbered 2026/DK-YED/71, the paid-in capital must be TRY 2,500,000 for OKTH authorization and TRY 10,000,000 for other authorizations.
Are frequencies and satellite positions regulated?
Yes. BTK defines usage right as the right granted for scarce resources such as frequency, number and satellite position, and operators holding usage rights must pay relevant fees.
Does satellite internet trigger Law No. 5651 obligations?
It may. Satellite internet providers may need to analyze whether they are access providers or otherwise subject to internet actor obligations under Law No. 5651. BTK’s Internet Directorate monitors legal obligations of content, hosting, access providers and other internet actors.
Does KVKK apply to satellite communication providers?
Yes. Satellite providers may process subscriber data, IP addresses, device identifiers, terminal data, location data, billing data and traffic-related information. KVKK applies where personal data of identified or identifiable individuals is processed.
Are cross-border data transfers important for satellite services?
Yes. Satellite networks often involve foreign satellites, foreign ground stations, foreign support centers or foreign cloud systems. KVKK Article 9 regulates cross-border transfers and may require adequacy, appropriate safeguards or limited statutory transfer grounds.
What are the main legal risks in satellite communication services in Turkey?
The main risks include lack of BTK authorization, incorrect service classification, unauthorized frequency use, harmful interference, non-compliant terminals, weak data protection, unlawful cross-border data transfers, cybersecurity failures, Law No. 5651 non-compliance, misleading service promises and failure to update BTK records.
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