BioDemocracy News #31 (Jan. 2001) America's Food Safety Crisis

News & Analysis on Genetic Engineering, Factory Farming, & Organics
by: Ronnie Cummins
BioDemocracy News is a publication of the Organic Consumers Association
Frankenfoods, Antibiotics, & Mad Cow: America's Food Safety Crisis Intensifies
Quotes of the Month:
"Bad Hair" Year for Biotech & Factory Farming
Biotech Bytes: FDA Says No Labeling, No Safety-Testing Required
Antibiotic Bytes: Factory Farm Practices Threaten Public Health
Mad Cow: Will the Nightmare Spread to the US?
Bogus FDA Feed Ban
Mad Sheep, Deer, & Elk
Another FDA Ban?

Quotes of the Month:

"She is an independent thinker of sound judgment and vast experience. She knows the science,
the politics, and she knows how to make a sound decision on complicated and difficult issues.
We are delighted with her selection, it is hard to imagine a better choice."

Biotechnology Industry Organization <> commenting on the nomination of former
agbiotech executive Ann Veneman as George Bush's Secretary of Agriculture

"The StarLink controversy in the United States could cost the food industry billions of dollars
and has thrown the future of genetically modified foods into doubt... Already, 70 per cent of
Americans told a Reuters poll last year that (genetically modified) GM foods should be treated
with caution." Stuart Laidlaw, "StarLink Fallout Could Cost Billions," The Toronto Star, Jan.
9, 2001

"agribusiness... fight any effort to tell consumers more about how their food is made...
stories about our food system that do get out don't do much for the appetite. There's the one
about how genetically engineered StarLink corn deemed unfit for human consumption somehow found
its way into tacos and breakfast cereal. Then there's the mad-cow story, which brought us the
disquieting news that beef cattle in this country routinely dine not only on hormones and
antibiotics but also on bits of other beef cattle (not to mention pellets made from their own
manure)." Michael Pollan, "Produce Politics," The New York Times Magazine, Jan. 14, 2001

"Bad Hair" Year for Biotech & Factory Farming

Corporate agribusiness and the biotech industry had a "bad hair" year in 2000. After promising
Wall Street that genetic engineering and American-style factory farming were about to conquer
the world and that free trade, monopoly patents on living organisms, and the enforcement powers
of the World Trade Organization were going to whip consumers and the world's 2.4 billion
farmers and rural villagers into line, Year One of the Biotech Century turned out to be
something of a disaster. Behind the bravado of public relations and the reassurances of
government bureaucrats, the food industry and the Gene Giants are in serious disarray. For the
first time in five years the amount of global acreage devoted to biotech crops has leveled off
and appears headed in 2001 for significant decreases. Longstanding industrial agriculture
practices such as feeding antibiotics and rendered animal protein to animals are being banned
in Europe and are generating controversy even in the US. The second wave of the Mad Cow crisis
is sweeping across Europe, prompting a massive decline in beef sales--with recent revelations
suggesting that North America may be heading for a similar crisis of its own. As Andrew
Kimbrell of the Center for Food Safety states, a "funny thing has happened" on the way to the
hi-tech future of industrial agriculture:

"Despite untold billions spent in research and advertising, the public en masse has begun to
reject this vision of industrial food and all that accompanies it. We have begun to understand
that these chemical and biological techno-fixes come with hidden and terrible costs to human
health and to the environment. We have seen cancer epidemics, widespread pollution of water and
air, exponential loss of topsoil and biodiversity, terrible cruelty to animals and, most
directly, tasteless and unhealthy food. Tens of millions of Americans have decided to vote, day
after day, with their food dollars. More of us are eating organic than ever before, and organic
food production is the fastest-growing segment in US agriculture today." (The Kimbrell quote is
from our new book, Genetically Engineered Food: A Self-Defense Guide for Consumers by Ronnie
Cummins & Ben Lilliston).

Biotech Bytes: FDA Says No Labeling, No Safety-Testing Required

On Jan. 17, the Food and Drug Administration issued its long-awaited proposed federal
regulations on genetically engineered foods and crops. As anticipated the FDA refused to call
for mandatory labeling or mandatory safety-testing--despite numerous polls showing 80-95% of
Americans want labeling and safety-testing, or, better yet, no genetically engineered foods at
all. There will now be a 75-day period for the public to comment on the FDA rules, and to
demand a moratorium. Stay tuned to <> or <> for
guidelines on how to send a letter or fax to the feds on this issue. In a Washington, DC press
conference on Jan. 17 the Organic Consumers Association's national coalition, the Genetically
Engineered Food Alert, strongly condemned the FDA for utterly failing to regulate agricultural
biotechnology. Unless rigorous, independent, premarket safety testing can demonstrate that GE
foods and crops are safe, these products must not be allowed on the market.

The FDA's proposed regulations simply throw more fuel on the fire of the Frankenfoods debate.
But of course the additional controversy that this now official FDA "no labeling, no
safety-testing" policy will generate is just part of the growing global food fight. Over the
past few months, things have gone from bad to worse for the agbiotech lobby. Among recent
developments are the following:

* An internal industry study, conducted for Kellogg, ConAgra, Unilever, and Aventis, publicized
in the Toronto Star Jan. 9, flatly predicted up to "billions" of dollars in food industry
losses in the aftermath of the recent StarLink corn scandal (see BioDemocracy News #30). Dr.
Ann Clark, a plant researcher at the University of Guelph (Canada), said StarLink, an illegal
and likely allergenic variety of GE corn found in taco shells and over 300 brand-name products
this fall, could prove to be "the beginning of the end" for genetically engineered crops if
food companies decide the costs outweigh the benefits. "The food companies are not going to
bite the bullet on this one for the industry," Clark said.

* In related news, two potentially massive class-action lawsuits were filed in December in
Illinois and Iowa by farmers against Aventis, the manufacturer of StarLink seeds. According to
the plaintiffs in Iowa, they suffered severe financial losses after "Japan cut its US corn
purchases by more than 50% and South Korea, the second largest U.S. corn export market, banned
the importation of U.S. corn altogether.'' In late-December, Reuters reported that Missouri
Attorney General Jay Nixon demanded that Aventis post a $25 million bond "to ensure the
company had sufficient funds to compensate farmers and grain handlers hit financially by
StarLink." Of the 340,908 acres planted with StarLink corn in the US last year, 134,910 acres
were in Iowa and 18,702 acres in Missouri. StarLink was also planted on a significant scale in
Nebraska, Minnesota, South Dakota, and Kansas. Last October a group of consumers filed a
lawsuit in Chicago, alleging they were poisoned by StarLink-tainted Kraft Taco Bell shells,
while recently 44 people filed complaints with the FDA claiming StarLink products caused them
to suffer rashes, diarrhea, vomiting, itching and life-threatening anaphylactic shock.

* In the wake of the StarLink disaster, Monsanto announced Nov. 27 it would restrict plantings
next year of a new herbicide resistant variety of corn and delay commercialization of another
Bt-spliced corn variety until 2002. On Dec. 17, ConAgra, America's second largest food
processor, announced a recall of 1.5 million pounds of baking ingredients used by restaurants
and institutional food buyers. The same week in a letter mailed to farmers, giant corn
processor A.E. Staley stated, "The only truly safe seed selection [next year] will be seed corn
free of any genetic modification."

* The Wall Street Journal reported on Nov. 20 that Archer-Daniels-Midland Co. "is beginning to
air ads on 24 Iowa and Illinois radio stations warning farmers that ADM mills will buy only
crops 'that have full feed and food approval world-wide.' " "We don't want another StarLink,"
said Larry Cunningham, an ADM spokesman. In a further blow to the industry, Aventis announced
in late-November that it found some of the same Cry9C protein--the key component of StarLink
corn--in another variety of 1998 corn seed produced by Garst Seed Co. of Iowa. USDA officials
admitted that they "didn't understand" how this 1998 contamination could have occurred.

* US activists delivered a blunt warning to the Environmental Protection Agency on Nov. 16 in
San Francisco. Campaigners from Greenpeace, joined by the Organic Consumers Association, Center
for Food Safety, Ruckus Society, the Ecology Center, and Pesticide Action Network, wearing
biohazard suits, dumped two tons of StarLink contaminated corn in front of the EPA
headquarters, demanding that the agency deny approval of the gene-altered corn for human
consumption and take action regarding the environmental damage already being inflicted by
genetically engineered crops. "EPA's own scientific advisors say they don't know if this corn
is safe for people," said Simon Harris of the Organic Consumers Association. "The health of
Americans should not be put at risk simply for the convenience of the biotech industry." On
November 28, the EPA heard from a Scientific Advisory Panel that StarLink may be already
setting off food allergies. For the full testimony of Dr. Michael Hansen from the Consumers
Union on StarLink and Bt corn allergenicity see <>

* On Nov. 14, responding to pressure from Greenpeace and others, McDonald's announced that by
April 2001 all its restaurants in Germany, Denmark and Sweden will serve only chicken raised on
GE-free feed. Five days later McDonald's UK made a similar announcement. According to the
European press, other large food chains are likely to follow suit. The move by McDonald's is
especially significant since almost all US genetically engineered soybeans exported to Europe
are now funneled into animal feeds. McDonald's is the largest buyer of agricultural commodities
in Europe.

* The safety of genetically engineered foods once again came into question Dec. 15 when the
prestigious journal, Science, published an article by two fellows from the American Association
for the Advancement of Science. The article, by Dr. LaReesa Wolfenbarger and Dr. Paul Phifer,
emphasized that there has been almost no peer-reviewed scientific research published which
shows that GE crops are safe for the environment. In their study, Wolfenbarger and Phifer state
that researching environmental risks is likely to be complicated, with risks varying over time
among crops, among strains of a single crop, and between environments. Some risks, they say,
may be all but impossible to assess. In a related story, Dr. Arpad Pusztai, the UK's most
well-know critic of biotech, after surveying the world scientific literature on animal feeding
studies, found a grand total of only four peer-reviewed articles on genetically engineered
foods, despite Monsanto and industry claims that scores of scientific papers have proven their
safety. Pusztai's own safety studies in the late 1990s, conducted at the Rowett Institute in
Scotland, caused a major stir in Europe, when lab rats fed genetically engineered potatoes
spliced with lectin suffered serious damage to their vital organs.

* In other science news, an Expert Panel of the International Cotton Advisory Committee
reported in November that in the Yauggu and Xiuxiang provinces of China, cotton boll worms, a
major pest, are developing resistance to genetically engineered cotton plants spliced with Bt.
Critics of Bt crops have warned for years that "superpests" will inevitably develop,
threatening the livelihood of organic or low-chemical input farmers who use non-genetically
engineered Bt sprays as an emergency pest control tool on cotton, corn, and other crops.
Meanwhile Bt-resistant pests have been reported in Australia and perhaps at a "threateningly
high level" according to scientific experts. For more information see

* Barbara Keeler and Marc Lappe reported in a potentially explosive story in the Los Angeles
Times on Jan. 7 that the FDA apparently ignored troubling data which Monsanto published in the
Journal of Nutrition in March 1996--data which strongly suggests that Roundup Ready soybeans,
the world's most widely cultivated genetically engineered crop, may set off food allergies in
humans. According to the authors, data in Monsanto's study "shows that, relative to
conventional soy meal, raw Roundup Ready soy meal contained 27% more trypsin inhibitor, a
potential allergen that interferes with protein digestion and has been associated with enlarged
cells in rat pancreases." According to Keeler and Lappe "This important measurement was
camouflaged in a table on unrelated information." After toasting the GE soy meal several times,
the levels of another allergen, called lectin, were nearly double those in conventional
soybeans. Scientists have warned for years that conventional soybeans contain low levels of 14
proteins that can potentially set off food allergies in humans and that genetically engineering
soybeans could possibly cause the level of one or more of these 14 proteins to significantly
increase. However, hiding behind the doctrine of "substantial equivalence," the FDA did not
require Monsanto to submit comprehensive data on herbicide resistant Roundup Ready soybeans
before they were brought on the market. In effect this means that RR soybeans may already be
setting off food allergies among large numbers of people, given that 54% of America's soybean
crop is genetically engineered, while 60% of all processed foods contain soy or soy
derivatives. In 1999 the York Nutritional Lab in the UK, commenting on a mysterious 50% rise in
soy allergies among British consumers, attributed the increase in food allergies to the fact
that consumers the previous year had begun ingesting large amount of imported GE soybeans. For
the LA Times article see <>

* On Nov. 11, speaking to a massive crowd at the Vatican, Pope John Paul II urged extreme
caution concerning genetically engineered food, stating that the use of biotechnology in
agriculture, "cannot be evaluated only on the basis of immediate economic interests. It is
necessary to subject it in advance to rigorous scientific and ethical checking to prevent it
ending up in disaster for... the future of the earth." On Nov. 14, the Commission on Social
Action of Reform Judaism passed a resolution on labeling of genetically engineered food. The
Commission called on the government to "monitor the health, ecological and religious liberty
implications of genetic engineering." Among Protestant denominations the United Methodist
Church recently called for mandatory labeling of all GE foods, with pre-market safety testing
required. According to Jaydee Hansen of the UMC, "We call for policies that encourage the
gradual transition to sustainable and organic agriculture."

Antibiotic Bytes: Factory Farm Practices Threaten Public Health

Factory Farm proponents suffered a major blow on Jan. 8 as the Union of Concerned Scientists
(UCS) released an important study in Washington, DC by Charles Benbrook and Margaret Mellon
showing that 70% of all antibiotic drugs in the US are being fed to farm animals as growth
promoters or production aids. The study, which generated significant headlines and TV coverage
across the nation, points out that 25 million pounds of valuable antibiotics--roughly 70
percent of total US antibiotic production--are fed to chickens, pigs, and cows every year for
nontherapeutic purposes like growth promotion. The drug- dependent US meat industry has tried
to downplay its massive use of antibiotics--a practice which is now starting to be banned in
Europe--claiming that it was using "only" 18 million pounds a year of antibiotics in animal
feed each year. Recent research has shown that the overuse of medical prescriptions and the
routine agribusiness practice of adding antibiotics to animal feed are giving rise to virulent
antibiotic-resistant strains of disease in millions of Americans every year, such as
salmonella, campylobacter, pneumonia, meningitis, and ear and blood infections. According to
statistics released by the Centers for Disease Control several years ago approximately 6% of
all hospital
infections are now showing signs of antibiotic resistance. The figure today is probably closer
to 10%.

"The meat industry's share of the antibiotic-resistance problem has been ignored for too long,"
said Dr. Margaret Mellon, of UCS . "Antibiotics are a precious resource and should be used in
animals only when necessary."

"The excessive use of antibiotics by the livestock industry is sobering," said Dr. Charles
Benbrook, an independent economist and co-author of the report. "Feeding antibiotics to animals
from birth to slaughter may modestly improve meat industry profits, but it puts everyone's
health at risk. It is time to rethink how pigs, cattle and poultry are raised in the United

The Factory Farm lobby counterattacked with a series of op-ed pieces and editorials of its own,
claiming that the UCS were exaggerating the problem and that European-type measures to ban the
feeding of antibiotics to animals would cause unnecessary economic hardships to modern
agribusiness. Meanwhile sales of organic meat, eggs, and dairy products, which ban the use of
antibiotics, are booming, not only across the US, but in the entire industrialized world. A
full copy of the UCS report can be found at <>

Mad Cow: Will the Nightmare Spread to the US?

Mad Cow panic has once again swept across the European continent, provoking drastic declines in
beef sales, economic insecurity among farmers, trepidation in the meat, drug, cosmetic, and
plasma industry, and near-hysteria among consumers. Recent revelations of cattle testing
positive for Mad Cow disease (also known as Bovine Spongiform Encephalopathy or BSE) in
Germany, France, Spain, Netherlands, Switzerland, Denmark, Ireland, Portugal, and Italy, and
the expose in the press that thousands of tons of BSE-infected cattle feed were exported from
Britain to other nations over the past decade, have set off the largest food scare in history.

In Germany where 13 cases of Mad Cow have been confirmed since January in the nation's 15
million cattle, government officials have announced plans to slaughter 400,000 at-risk cattle,
while 300,000 bovines are slated to be killed in Ireland. In France consumers have reacted
angrily to reports that the meat from infected cattle has been sold in supermarkets and
restaurants, and that tons of suspect animal feed have been imported from the UK. Effective
Jan. 1, Japan announced a ban on all beef imports from the EU, with other major meat importers
expected to follow suit. Last year Japan imported 642 tons of beef from European Union nations.
A cow from the company that supplies McDonald's in Italy tested positive for BSE on Jan.16,
prompting massive declines in hamburger sales.

Although only 92 Europeans have thus far officially died since 1996 from new variant
Creutzfeldt-Jakob Disease (CJD), the human equivalent of Mad Cow, British scientists admitted
last year that, due to the long latency period of the disease (up to 30-40 years in humans),
and due to the fact that the majority of meat eaters have probably been exposed to Mad Cow,
several hundred thousand Britons (and an indeterminate number of Europeans from other
countries) and perhaps many more may die from the incurable brain-wasting disease over the next
few decades. Trying to keep the situation under control, German officials have proposed
mandatory testing for all cattle over 24 months old for BSE, while EU authorities have placed a
complete ban on the feeding of animal parts (in industry terminology, rendered animal protein)
back to animals, a controversial practice still routine in American agriculture. EU officials
are pleading for calm, telling consumers that the discovery of new cases of BSE outside Britain
are simply the result of the fact that authorities are testing more cattle than ever before.

Commentators have noted for years that the Mad Cow crisis in Europe has been a significant
contributing factor fueling opposition to genetically engineered foods. Seeing how industry and
government scientists have systematically lied to them about the dangers of feeding animals to
animals has made many consumers lose faith in industrial agriculture altogether. Noting that
the same government officials who have repeatedly tried to reassure them that the BSE crisis in
under control are now saying that genetically engineered foods are safe has brought on a
profound skepticism and anger at the grassroots level. Now a similar crisis of confidence may
start to develop in the United States as well.

Bogus FDA Feed Ban

Sandra Blakeslee of the New York Times reported on Jan. 11 that the US Food and Drug
Administration's supposed 1997 ban on feeding rendered animal protein to cows and other
ruminant animals is full of loopholes, and moreover that the so-called ban is not being
enforced among the thousands of companies involved in the $3.2 billion dollar rendering
industry and the $20 billion dollar animal feed industry. As Blakeslee wrote: "Among 180 large
companies that render cattle and another ruminant, sheep, nearly a quarter were not properly
labeling their products and did not have a system to prevent commingling, the FDA said. And
among 347 FDA-licensed feed mills that handle ruminant materials--these tend to be large
operators that mix drugs into their products--20 percent were not using labels with the
required caution statement, and 25 percent did not have a system to prevent commingling. Then
there are some 6,000 to 8,000 feed mills so small they do not require FDA licenses. They are
nonetheless subject to the regulations, and of 1,593 small feed producers that handle ruminant
material and have been inspected, 40 percent were not using approved labels and 25 percent had
no system in place to prevent commingling."

In other words millions of US cows, sheep, game farm deer and elk, and pigs (pigs and cow's
blood were inexplicably exempted in the so-called FDA feed ban of 1997), not to mention
household pets, are still being fed billions of pounds of animal feed or pet food containing
meat and offal from ruminant animals--despite the obvious danger to human and animal health and
despite the fact that the FDA and the USDA for the past three years have been reassuring the
public that this was no longer happening.

But the story gets scarier. In the Times on the front page of the Sunday Jan. 14 edition,
(tucked under a misleading headline "Stringent Steps Taken by US on Cow Illness") Blakeslee
drops the bombshell. Not only has the US Mad Cow feed ban been a joke, but apparently US feed
companies, pet food companies, pharmaceutical firms, and nutritional supplement manufacturers
have been carrying on with business as usual by importing large quantities of possibly
contaminated bovine parts and rendered animal protein--no doubt at bargain basement prices--in
1989 and 1997. It appears that the same thing that has European consumers' blood boiling, that
their government and industry stupidly or greedily imported tons of likely contaminated
rendered animal protein from Britain since 1989 has also been happening in the United States,
and likely other nations as well. After British authorities made it illegal to feed rendered
animal protein to ruminant animals in their own country, the UK feed industry simply sold it

As Blakeslee states, quoting from export records, "British export statistics show that 20 tons
of 'meals of meat or offal' that were 'unfit for human consumption' and probably intended for
animals were sent to the United States in 1989. And 37 tons were exported to the US in 1997,
well after the government banned imports of such risky meat." Blakeslee goes on to point out
what BioDemocracy News and other critics of industrial agriculture have been saying for years,
that even if the US hadn't been importing 57 thousand tons or more of suspect British offal in
the 1990s, there is mounting evidence that US rendered animal protein and bovine, sheep, deer,
and elk parts are themselves likely carriers of BSE and other Mad Cow-like diseases. As
Blakeslee relates, scientists have generally agreed that BSE or BSE-like diseases
"spontaneously" appear in "one out of every million humans, cows, sheep and many other mammals.
"Since 36 million cattle are slaughtered annually in the United States, about 36 cows
spontaneously infected with mad cow disease could be entering the nation's food chain each
year." Thirty-six domestic US Mad Cows a year being ground up and fed back to other animals may
not sound that alarming until you consider the fact that an average cow, pig, chicken, game
farm deer, elk, fish farm fish, or household cat and dog--because of the commingling of many
different animals' body parts at the rendering plant and the feed mill--will be consuming the
body parts of literally thousands of different animals in their feed over their lifetime.

Mad Sheep, Deer, & Elk

And in fact the story gets worse. Scrapie or Mad Sheep Disease has been endemic in US sheep
herds since 1947, and the government has done little or nothing to eradicate it. Significant
numbers of scrapie-infected sheep have undoubtedly been ground up every year and fed back to
other animals. In addition the US currently has a raging epidemic of Mad Deer Disease and Mad
Elk Disease (technically called Chronic Wasting Disease) in parts of Colorado and Wyoming.
There are already several documented cases of young deer hunters in their 20s and 30s dying
from CJD, the human equivalent of Mad Cow. Mad Elk Disease has recently spread into
Saskatchewan, unnerving elk ranchers and the nutritional supplements industry, who sell three
billion dollars worth of supplements each year (mainly to Asia) made from elk antlers. Consider
the fact that at the height of the first Mad Cow crisis in Britain 1-2% of all cows were being
diagnosed with BSE, while the Times reports that up to 18% of mule-tail deer in the Fort
Collins area of Colorado are now carriers of Chronic Wasting Disease. Hunters that kill deer in
Colorado are required to turn in the heads of these animals so that they can be tested for CWD
or Mad Deer Disease. Officials tell hunters not to eat the meat of infected animals, (lab tests
can take as long as six weeks) but have stubbornly refused to ban hunting or eating venison,
despite calls from consumer groups such as the Center for Food Safety and the Organic Consumers
Association to do so. Meanwhile several million people are eating venison and venison sausage
every year in the US, while several million more in the US and overseas are taking "glandular
supplements" or body-building hormones which contain concentrated brain and pituitary material
from US, British, and European cows. For the full Jan. 14 Blakeslee article see

Another FDA Ban?

The FDA warned US drug companies, cosmetic companies, and nutritional supplements firms Dec. 6
to stop using European bovine parts in most of their products as of Jan. 1. It may already be
too late. As Blakeslee points out, even this ban--assuming it actually gets enforced--still has
loopholes. As she writes, nutritional supplements "must have labels listing ingredients like
bovine pituitaries and adrenals, but manufacturers are not required to list the country of
origin. Other beef byproducts that are still allowed in the country include milk, blood, fat,
gelatin, tallow, bone mineral extracts, collagen, semen, amniotic fluid, serum albumin and
other parts of European cattle that are widely used in vaccines and medicines."

For more information on Mad Cow and Mad Cow-like diseases see our website
<> as well as the following sites <> and

The best book on the threat of Mad Cow in the US is the book by John Stauber and Sheldon
Rampton called Mad Cow USA: Could the Nightmare Happen Here? You can order hardback copies of
the book from the Organic Consumers Association for only $10 (this includes shipping). Or you
can access the entire book for free on the internet by going to the excellent website of the
Center for Media and Democracy <>

America and the world's 50-year experiment with chemical-intensive industrial agriculture and
genetic engineering may soon be moving into its final, terminal stage. Mad Cow Disease and the
growing global opposition to factory farming and genetic engineering may turn out to the
harbingers of a new era of sustainable living and organic agriculture. One can only hope that
we make the necessary transition to organic farming and ban the most dangerous practices of
genetic engineering and industrial food production before it is too late. In the meantime, stay
tuned to BioDemocracy News and the Organic Consumers Association website
<> for the latest news and analysis.

By the way you can still get to the OCA website by going to <> We're now using
<> as our primary internet address simply because our adversaries have
set up a counterfeit internet site, filled with lies and industry propaganda, at
<> Take a look at this site if you want to see what we're up against. Keep in
mind, however, that the “Bad Guys” wouldn’t be doing this except for the fact that we're
winning the battle.

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