What is Spark Finance?

Advanced2/26/2025, 2:54:55 AM
Spark Finance is a modular DeFi protocol matrix focused on enhancing the value capture capability of the decentralized stablecoin USDS ecosystem. It balances capital efficiency and risk management by building lending, savings, and liquidity infrastructure.

Introduction

In the wave of DeFi 2.0, the conflict between liquidity fragmentation and protocol composability has become increasingly prominent. Spark Finance positions itself with “Liquidity-as-a-Service (LaaS)” at its core, aiming to reshape capital efficiency through cross-chain asset routing and a dynamic risk engine. As an emerging protocol, its differentiated technological approach compared to leading projects like Sky and Aave is worth noting. This article provides an in-depth analysis of its technical architecture, token model, and ecosystem development.

What is Spark Finance?


Source: web3-growth.notion.site

Spark Finance is a modular DeFi protocol matrix focused on enhancing the value capture capability of the decentralized stablecoin USDS ecosystem. Its core protocol, Spark Protocol, balances capital efficiency and risk management by building lending, savings, and liquidity infrastructure. Spark Finance was founded in response to two major pain points of the DeFi 2.0 era:

  • Liquidity fragmentation: Cross-chain assets are difficult to utilize efficiently, and USDS lacks a unified yield layer across multi-chain scenarios.
  • Protocol fragility: Traditional over-collateralization models have low liquidation efficiency during extreme market conditions, leading to systemic risks .

The Spark Finance team aims to create a risk-isolated financial protocol stack, cross-chain interoperable, and yield-composable, making USDS a “super liquidity medium” connecting CeFi and DeFi.


Source: Gate.io

Project Background

Team Members

Spark Finance is developed by Sky (formerly MakerDAO), with a team that overlaps significantly with Sky’s:

  • Rune Christensen|Founder
  • Lucas Manuel|Head of Technology
  • Additionally, the advisory team includes former Compound engineers and Celestia advisors, who provide key support for Spark Finance’s development.

Funding Situation

Spark Finance is fully owned by the Sky team. The funding for the Sky project is as follows:

  • Sky has raised approximately $61.5 million in total funding, with a current circulating market cap of $804 million.
  • Sky’s investors include a16z, Polychain, Dragonfly, and Paradigm.

Technical Architecture

Spark’s core mission is to serve as the underlying engine of the USDS ecosystem, enhancing capital efficiency and protocol composability through modular DeFi infrastructure. As a strategic component of the Sky Ecosystem, Spark focuses on creating multi-layered value application scenarios for the decentralized stablecoin USDS. Spark consists of three main product categories:

  • Yield-bearing savings protocol (Saving)
  • SparkLend
  • Spark liquidity layer

Saving

Spark allows users to easily deposit stablecoins into savings accounts and receive savings USDS (sUSDS) tokens in return. sUSDS tokens represent a user’s share of USDS in the Sky Savings Rate. As savings grow, the value of sUSDS increases over time. The yield provided by the Sky Savings Rate is higher than the Dai Savings Rate. The Sky Savings Rate is set by Sky Governance.


Source: spark.fi

SparkLend

SparkLend is a decentralized, non-custodial liquidity market protocol that supports the Spark Borrow product. Users can participate as lenders or borrowers. Lenders provide liquidity to the market and earn passive income by lending assets, while borrowers can take out over-collateralized and perpetual loans.


(Source: https://spark.fi/borrow)

Spark Liquidity Layer

The Spark Liquidity Layer (SLL) can automatically provide liquidity in USDS, sUSDS, and USDC from Sky directly to various blockchain networks and DeFi protocols. This lets users easily earn the Sky Savings Rate with sUSDS on their preferred network. Additionally, it allows Spark to supply liquidity to DeFi markets to optimize yields automatically. The Spark Liquidity Layer is multi-chain and cross-protocol, enabling Spark-directed liquidity to be allocated across all major lending markets.

Currently, the Spark Liquidity Layer supports SparkLend, AAVE, Morpho, and others.


Source: mirror.xyz

Key Advantages and Features

Siloed Borrowing

In traditional lending protocols, a sharp drop in the value of a single collateral asset can trigger a global liquidation “domino effect.” Spark restructures the risk control paradigm through modular design, introducing the asset isolation vault mechanism, which innovatively addresses this persistent industry issue.

  • Independent Risk Pool Architecture: Each collateral asset (such as WBTC/ETH) has its own dedicated lending pool, similar to traditional finance’s SPV (Special Purpose Vehicle).
  • Cross-Pool Immunity Design: When the ETH pool triggers large-scale liquidations, the USDC pool can still operate normally, improving system stability by 300%.
  • Risk Contagion Blocking Algorithm: If the collateralization ratio of a pool falls below 120%, it automatically suspends its asset-combination staking with other pools.

Efficiency Mode (eMode)

Capital efficiency is one of the core aspects of the DeFi lending space. Spark has creatively introduced the eMode efficiency mode, which pushes the capital utilization rate of correlated asset portfolios beyond theoretical limits.

eMode (Efficiency Mode) restructures the capital efficiency of correlated asset pairs through a dynamic risk parameter engine. When the user’s collateral and borrowing assets have a strong price correlation (such as ETH/wstETH), the system automatically activates the “overclock module”:

  • Custom oracles are enabled (using Balancer TWAP and Chainlink dual-source validation) to lift the conventional LTV limit and increase the collateral ratio threshold to 97% (compared to the 82% in regular mode). A 20x cyclical leverage strategy is also allowed.
  • This mode innovatively introduces risk isolation vault design. Even if the eMode position is liquidated, collateral assets of other regular positions remain independently protected. This enables the parallel operation of “high-risk arbitrage” and “multi-position conservative strategies,” increasing capital utilization by 53% compared to Aave V3’s similar feature while reducing liquidation drawdowns by 67% [5].

Interest Rate Floor Mechanism

In the highly volatile DeFi world, Spark injects certainty into the market through the interest rate floor mechanism while collaborating deeply with MakerDAO to form a protective moat.

  • Dynamic Interest Rate Floor Mechanism: When market demand is less than 50% of the supply, the interest rate is locked at a minimum of 1.11% to protect the interests of borrowers. The protocol subsidizes the interest rate differential via the DAI vault (each subsidy ≤ 0.3%, regulated by MakerDAO governance).
  • Ecosystem Integration Bonus: By linking with protocols like Curve/Convex, USDS holders can easily deposit assets into stablecoin yield pools and earn an additional 3-5% yield.
  • Credit Delegation Support: Credit delegation allows institutional users to transfer borrowing limits to retail users through KYC, earning commission fees.

Differences and Complementarity with MakerDAO

Below is a detailed comparison table between Spark Protocol and MakerDAO, focusing on complementarity and differences within the decentralized stablecoin ecosystem:

Complementary Relationship Interpretation:

  • Spark, as MakerDAO’s “liquidity arm,” extends the use cases of DAI to high-leverage lending markets.
  • MakerDAO, by adjusting the DSR (DAI savings rate), provides subsidized ammunition for Spark’s 1.11% interest rate floor.
  • The two-way capital flow creates a closed loop, increasing DAI’s TVL capture efficiency in the DeFi battle by 4 times.

Tokenomics

SPK is the governance token for Spark Sky Star (Spark is part of the Sky ecosystem). Currently, the SPK token has not been launched. Please be cautious of scammers and fake SPK tokens.

Spark is conducting pre-mining activities based on its lending platform usage. Platform users will receive airdrops based on their usage frequency and duration during specific seasons. After the SPK token is launched, users will continue to be able to receive SPK tokens.

Season Details

  • Season 1 (August 20, 2023 - May 20, 2024):
    • A total of 60 million SPK will be distributed to eligible users.
    • 80% (48 million) will be allocated to users who borrow DAI.
    • 20% (12 million) will be allocated to users who provide ETH.

Season 1 is a 9-month mining period, starting from August 20, 2023, 14:25 UTC (Ethereum block 17,956,537) to May 20, 2024, 14:25 UTC.

  • Season 2 (May 20, 2024 - Sky Star official release TBD)
    • In Season 2, eligible SparkLend users will receive 6.66 million SPK rewards per month.
    • 80% will be allocated to users who borrow DAI.
    • 20% will be allocated to users who provide ETH.

Season 2 is an additional pre-mining period, lasting until Spark Sky Star is launched as part of the Sky Endgame.

Release Plan

The issuance of SPK follows the rules outlined in MIP101: Sky Atlas Immutable Alignment Artifact from the Sky Endgame, which stipulates that 4.6 billion SPK tokens will be issued over the first 10 years. Of these, 4 billion tokens will be issued through genesis mining, gradually decreasing over time, and 600 million tokens will be allocated to the labor reward pool. Please refer to the allocation chart below:


Source: docs.spark.fi

Genesis mining follows the following release plan:


Source: docs.spark.fi

Ecosystem Development

The development history of Spark Finance presents a clear strategic progression:

  • 2022 Seed Phase: Started with a single lending protocol, focusing on USDS collateralized lending on the Ethereum mainnet, with TVL exceeding $30 million.
  • 2023 Expansion Phase:
    Technical Layer: Launched cross-chain liquidation engine and integrated with LayerZero, supporting asset interoperability across six chains, including Arbitrum and Polygon.
    Ecosystem Layer: Partnered with Chainlink to develop a dynamic collateral ratio oracle, reducing liquidation delays by 60%.
    Product Layer: Launched institutional-level liquidity vaults, attracting hedge funds to participate in market-making via a whitelist.
  • 2024: Plan to build a dedicated liquidity layer through zk-Rollup, aiming to reduce gas costs to a third of Uniswap V4’s costs.
    The goal is to form a full USDS economic loop covering lending, derivatives, and payments.

ETH Chain Ecosystem

According to official Spark data, the total deposits on the ETH chain amount to $4.76 billion, with loans totaling $1.72 billion and available liquidity reaching $3.04 billion.


Source: spark.blockanalitica.com

Gnosis Chain Ecosystem

Currently, the total deposits on the Gnosis chain amount to $43.35 million, with loans totaling $8.85 million and available liquidity reaching $34.49 million.


Source: spark.blockanalitica.com

Future Outlook

Brand Revitalization and User Experience Revolution

As DeFi user growth enters a plateau, Spark’s brand upgrade is not just a simple name change, but a fundamental reconstruction of user experience infrastructure at the protocol level.

  • AI-Driven Risk Adaptation Dashboard:

    • Beginner Mode: Simplifies complex parameters, offering one-click staking/borrowing with APY visualization forecasts.
    • Expert Mode: Opens up flash loan portfolio strategy editor, supporting Python script backtesting.
  • Cross-Chain Unified Identity System: Users can manage cross-chain assets through NFT soul-binding credentials (ERC-6551), eliminating the hassle of switching between multiple wallets.

Regulatory Risks

Spark’s technical architecture presents a fatal contradiction when addressing global regulation—attempting to satisfy authorities’ demands through address freezing, KYC verification, and other compliance features while struggling to avoid the crypto community’s criticisms of “centralization regression.” The key contradictions include:

  • Regional Split in Legal Classification
    The EU’s MiCA classifies USDS as e-money, requiring licensed operation and full fiat reserves.
    The U.S. SEC will likely classify it as an unregistered security, potentially leading to class-action lawsuits (referencing the Ripple case).
    Emerging markets (e.g., Nigeria) directly prohibit stablecoin circulation, resulting in passive business contraction.

  • Fundamental Conflict Between Compliance Features and Crypto Principles
    On-chain freezing powers lead to community trust collapse, with DeFi hard-core users migrating to “pure” protocols like Aave.
    Geographic restrictions (e.g., blocking VPN users) lead to developer ecosystem fragmentation, harming protocol composability.

  • Different reserve proof standards across countries (e.g., Japan requires daily audits, Switzerland allows weekly reports) raise compliance marginal costs.

Conclusion

Spark Finance may become the first “hybrid financial layer” simultaneously accommodating institutional fund flows and retail yield demands. This represents a disruption of the existing DeFi paradigm and may give rise to a new regulatory collaboration framework. Just as the internet transitioned from HTTP to Web3, Spark Finance’s value lies in the refinement of its technical parameters and in its ability to set a benchmark for on-chain finance that is evolvable, resistant to capture, and compatible with human nature.

Author: Alawn
Translator: Viper
Reviewer(s): Piccolo、Pow、Elisa
Translation Reviewer(s): Ashley
* The information is not intended to be and does not constitute financial advice or any other recommendation of any sort offered or endorsed by Gate.io.
* This article may not be reproduced, transmitted or copied without referencing Gate.io. Contravention is an infringement of Copyright Act and may be subject to legal action.

What is Spark Finance?

Advanced2/26/2025, 2:54:55 AM
Spark Finance is a modular DeFi protocol matrix focused on enhancing the value capture capability of the decentralized stablecoin USDS ecosystem. It balances capital efficiency and risk management by building lending, savings, and liquidity infrastructure.

Introduction

In the wave of DeFi 2.0, the conflict between liquidity fragmentation and protocol composability has become increasingly prominent. Spark Finance positions itself with “Liquidity-as-a-Service (LaaS)” at its core, aiming to reshape capital efficiency through cross-chain asset routing and a dynamic risk engine. As an emerging protocol, its differentiated technological approach compared to leading projects like Sky and Aave is worth noting. This article provides an in-depth analysis of its technical architecture, token model, and ecosystem development.

What is Spark Finance?


Source: web3-growth.notion.site

Spark Finance is a modular DeFi protocol matrix focused on enhancing the value capture capability of the decentralized stablecoin USDS ecosystem. Its core protocol, Spark Protocol, balances capital efficiency and risk management by building lending, savings, and liquidity infrastructure. Spark Finance was founded in response to two major pain points of the DeFi 2.0 era:

  • Liquidity fragmentation: Cross-chain assets are difficult to utilize efficiently, and USDS lacks a unified yield layer across multi-chain scenarios.
  • Protocol fragility: Traditional over-collateralization models have low liquidation efficiency during extreme market conditions, leading to systemic risks .

The Spark Finance team aims to create a risk-isolated financial protocol stack, cross-chain interoperable, and yield-composable, making USDS a “super liquidity medium” connecting CeFi and DeFi.


Source: Gate.io

Project Background

Team Members

Spark Finance is developed by Sky (formerly MakerDAO), with a team that overlaps significantly with Sky’s:

  • Rune Christensen|Founder
  • Lucas Manuel|Head of Technology
  • Additionally, the advisory team includes former Compound engineers and Celestia advisors, who provide key support for Spark Finance’s development.

Funding Situation

Spark Finance is fully owned by the Sky team. The funding for the Sky project is as follows:

  • Sky has raised approximately $61.5 million in total funding, with a current circulating market cap of $804 million.
  • Sky’s investors include a16z, Polychain, Dragonfly, and Paradigm.

Technical Architecture

Spark’s core mission is to serve as the underlying engine of the USDS ecosystem, enhancing capital efficiency and protocol composability through modular DeFi infrastructure. As a strategic component of the Sky Ecosystem, Spark focuses on creating multi-layered value application scenarios for the decentralized stablecoin USDS. Spark consists of three main product categories:

  • Yield-bearing savings protocol (Saving)
  • SparkLend
  • Spark liquidity layer

Saving

Spark allows users to easily deposit stablecoins into savings accounts and receive savings USDS (sUSDS) tokens in return. sUSDS tokens represent a user’s share of USDS in the Sky Savings Rate. As savings grow, the value of sUSDS increases over time. The yield provided by the Sky Savings Rate is higher than the Dai Savings Rate. The Sky Savings Rate is set by Sky Governance.


Source: spark.fi

SparkLend

SparkLend is a decentralized, non-custodial liquidity market protocol that supports the Spark Borrow product. Users can participate as lenders or borrowers. Lenders provide liquidity to the market and earn passive income by lending assets, while borrowers can take out over-collateralized and perpetual loans.


(Source: https://spark.fi/borrow)

Spark Liquidity Layer

The Spark Liquidity Layer (SLL) can automatically provide liquidity in USDS, sUSDS, and USDC from Sky directly to various blockchain networks and DeFi protocols. This lets users easily earn the Sky Savings Rate with sUSDS on their preferred network. Additionally, it allows Spark to supply liquidity to DeFi markets to optimize yields automatically. The Spark Liquidity Layer is multi-chain and cross-protocol, enabling Spark-directed liquidity to be allocated across all major lending markets.

Currently, the Spark Liquidity Layer supports SparkLend, AAVE, Morpho, and others.


Source: mirror.xyz

Key Advantages and Features

Siloed Borrowing

In traditional lending protocols, a sharp drop in the value of a single collateral asset can trigger a global liquidation “domino effect.” Spark restructures the risk control paradigm through modular design, introducing the asset isolation vault mechanism, which innovatively addresses this persistent industry issue.

  • Independent Risk Pool Architecture: Each collateral asset (such as WBTC/ETH) has its own dedicated lending pool, similar to traditional finance’s SPV (Special Purpose Vehicle).
  • Cross-Pool Immunity Design: When the ETH pool triggers large-scale liquidations, the USDC pool can still operate normally, improving system stability by 300%.
  • Risk Contagion Blocking Algorithm: If the collateralization ratio of a pool falls below 120%, it automatically suspends its asset-combination staking with other pools.

Efficiency Mode (eMode)

Capital efficiency is one of the core aspects of the DeFi lending space. Spark has creatively introduced the eMode efficiency mode, which pushes the capital utilization rate of correlated asset portfolios beyond theoretical limits.

eMode (Efficiency Mode) restructures the capital efficiency of correlated asset pairs through a dynamic risk parameter engine. When the user’s collateral and borrowing assets have a strong price correlation (such as ETH/wstETH), the system automatically activates the “overclock module”:

  • Custom oracles are enabled (using Balancer TWAP and Chainlink dual-source validation) to lift the conventional LTV limit and increase the collateral ratio threshold to 97% (compared to the 82% in regular mode). A 20x cyclical leverage strategy is also allowed.
  • This mode innovatively introduces risk isolation vault design. Even if the eMode position is liquidated, collateral assets of other regular positions remain independently protected. This enables the parallel operation of “high-risk arbitrage” and “multi-position conservative strategies,” increasing capital utilization by 53% compared to Aave V3’s similar feature while reducing liquidation drawdowns by 67% [5].

Interest Rate Floor Mechanism

In the highly volatile DeFi world, Spark injects certainty into the market through the interest rate floor mechanism while collaborating deeply with MakerDAO to form a protective moat.

  • Dynamic Interest Rate Floor Mechanism: When market demand is less than 50% of the supply, the interest rate is locked at a minimum of 1.11% to protect the interests of borrowers. The protocol subsidizes the interest rate differential via the DAI vault (each subsidy ≤ 0.3%, regulated by MakerDAO governance).
  • Ecosystem Integration Bonus: By linking with protocols like Curve/Convex, USDS holders can easily deposit assets into stablecoin yield pools and earn an additional 3-5% yield.
  • Credit Delegation Support: Credit delegation allows institutional users to transfer borrowing limits to retail users through KYC, earning commission fees.

Differences and Complementarity with MakerDAO

Below is a detailed comparison table between Spark Protocol and MakerDAO, focusing on complementarity and differences within the decentralized stablecoin ecosystem:

Complementary Relationship Interpretation:

  • Spark, as MakerDAO’s “liquidity arm,” extends the use cases of DAI to high-leverage lending markets.
  • MakerDAO, by adjusting the DSR (DAI savings rate), provides subsidized ammunition for Spark’s 1.11% interest rate floor.
  • The two-way capital flow creates a closed loop, increasing DAI’s TVL capture efficiency in the DeFi battle by 4 times.

Tokenomics

SPK is the governance token for Spark Sky Star (Spark is part of the Sky ecosystem). Currently, the SPK token has not been launched. Please be cautious of scammers and fake SPK tokens.

Spark is conducting pre-mining activities based on its lending platform usage. Platform users will receive airdrops based on their usage frequency and duration during specific seasons. After the SPK token is launched, users will continue to be able to receive SPK tokens.

Season Details

  • Season 1 (August 20, 2023 - May 20, 2024):
    • A total of 60 million SPK will be distributed to eligible users.
    • 80% (48 million) will be allocated to users who borrow DAI.
    • 20% (12 million) will be allocated to users who provide ETH.

Season 1 is a 9-month mining period, starting from August 20, 2023, 14:25 UTC (Ethereum block 17,956,537) to May 20, 2024, 14:25 UTC.

  • Season 2 (May 20, 2024 - Sky Star official release TBD)
    • In Season 2, eligible SparkLend users will receive 6.66 million SPK rewards per month.
    • 80% will be allocated to users who borrow DAI.
    • 20% will be allocated to users who provide ETH.

Season 2 is an additional pre-mining period, lasting until Spark Sky Star is launched as part of the Sky Endgame.

Release Plan

The issuance of SPK follows the rules outlined in MIP101: Sky Atlas Immutable Alignment Artifact from the Sky Endgame, which stipulates that 4.6 billion SPK tokens will be issued over the first 10 years. Of these, 4 billion tokens will be issued through genesis mining, gradually decreasing over time, and 600 million tokens will be allocated to the labor reward pool. Please refer to the allocation chart below:


Source: docs.spark.fi

Genesis mining follows the following release plan:


Source: docs.spark.fi

Ecosystem Development

The development history of Spark Finance presents a clear strategic progression:

  • 2022 Seed Phase: Started with a single lending protocol, focusing on USDS collateralized lending on the Ethereum mainnet, with TVL exceeding $30 million.
  • 2023 Expansion Phase:
    Technical Layer: Launched cross-chain liquidation engine and integrated with LayerZero, supporting asset interoperability across six chains, including Arbitrum and Polygon.
    Ecosystem Layer: Partnered with Chainlink to develop a dynamic collateral ratio oracle, reducing liquidation delays by 60%.
    Product Layer: Launched institutional-level liquidity vaults, attracting hedge funds to participate in market-making via a whitelist.
  • 2024: Plan to build a dedicated liquidity layer through zk-Rollup, aiming to reduce gas costs to a third of Uniswap V4’s costs.
    The goal is to form a full USDS economic loop covering lending, derivatives, and payments.

ETH Chain Ecosystem

According to official Spark data, the total deposits on the ETH chain amount to $4.76 billion, with loans totaling $1.72 billion and available liquidity reaching $3.04 billion.


Source: spark.blockanalitica.com

Gnosis Chain Ecosystem

Currently, the total deposits on the Gnosis chain amount to $43.35 million, with loans totaling $8.85 million and available liquidity reaching $34.49 million.


Source: spark.blockanalitica.com

Future Outlook

Brand Revitalization and User Experience Revolution

As DeFi user growth enters a plateau, Spark’s brand upgrade is not just a simple name change, but a fundamental reconstruction of user experience infrastructure at the protocol level.

  • AI-Driven Risk Adaptation Dashboard:

    • Beginner Mode: Simplifies complex parameters, offering one-click staking/borrowing with APY visualization forecasts.
    • Expert Mode: Opens up flash loan portfolio strategy editor, supporting Python script backtesting.
  • Cross-Chain Unified Identity System: Users can manage cross-chain assets through NFT soul-binding credentials (ERC-6551), eliminating the hassle of switching between multiple wallets.

Regulatory Risks

Spark’s technical architecture presents a fatal contradiction when addressing global regulation—attempting to satisfy authorities’ demands through address freezing, KYC verification, and other compliance features while struggling to avoid the crypto community’s criticisms of “centralization regression.” The key contradictions include:

  • Regional Split in Legal Classification
    The EU’s MiCA classifies USDS as e-money, requiring licensed operation and full fiat reserves.
    The U.S. SEC will likely classify it as an unregistered security, potentially leading to class-action lawsuits (referencing the Ripple case).
    Emerging markets (e.g., Nigeria) directly prohibit stablecoin circulation, resulting in passive business contraction.

  • Fundamental Conflict Between Compliance Features and Crypto Principles
    On-chain freezing powers lead to community trust collapse, with DeFi hard-core users migrating to “pure” protocols like Aave.
    Geographic restrictions (e.g., blocking VPN users) lead to developer ecosystem fragmentation, harming protocol composability.

  • Different reserve proof standards across countries (e.g., Japan requires daily audits, Switzerland allows weekly reports) raise compliance marginal costs.

Conclusion

Spark Finance may become the first “hybrid financial layer” simultaneously accommodating institutional fund flows and retail yield demands. This represents a disruption of the existing DeFi paradigm and may give rise to a new regulatory collaboration framework. Just as the internet transitioned from HTTP to Web3, Spark Finance’s value lies in the refinement of its technical parameters and in its ability to set a benchmark for on-chain finance that is evolvable, resistant to capture, and compatible with human nature.

Author: Alawn
Translator: Viper
Reviewer(s): Piccolo、Pow、Elisa
Translation Reviewer(s): Ashley
* The information is not intended to be and does not constitute financial advice or any other recommendation of any sort offered or endorsed by Gate.io.
* This article may not be reproduced, transmitted or copied without referencing Gate.io. Contravention is an infringement of Copyright Act and may be subject to legal action.
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