Paranormal Activity (2008): the first film in the series, shot just before the housing market crash and released just after.


The demon in Paranormal Activity bites Katie on the hip in one scene, but doesn’t physically harm any other characters until quite late in the film.


Micah Sloat and Katie Featherston play characters with the same names, adding to the aura of the found footage film’s verisimilitude, Paranormal Activity.


Drag Me to Hell (2009) explicitly poses a critique of the banking industry’s callousness in foreclosing on the homes of those most vulnerable.

Katie attends a university where she majors in English and hopes to become a teacher.

Micah admires himself and his video camera when he isn’t pestering Katie with it.

Paranormal Activity 2 (2009): parallel prequel and second film in the series, focusing on Katie’s younger sister Kristi.

Sisters Katie and Kristi, Paranormal Activity 2.

The parallel prequel narrative in Paranormal Activity 2 assumes that we have seen the first film and reminds us of its ending.

Paranormal Activity 2. Demon-possessed Katie kills Dan and Kristi…

…then kidnaps her nephew Hunter.


Micah and his home computer, Paranormal Activity


Micah in his CoinNet tee, Paranormal Activity

Wall Street (1987): Gordon Gecko and the famous tagline, “greed is good,” set a standard for the representation of stockbrokers and investment bankers in Hollywood film.

Margin Call (2011) continues the tradition of portraying employees of high finance corporations as a well-dressed, elite boy’s club.


Demon debt: Paranormal Activity as recessionary post-cinematic allegory

by Julia Leyda

One of the most striking things about watching the horror movie Paranormal Activity nowadays is the way it portrays the U.S. home just before the housing bubble burst, at the height of what President Bush called “the ownership society.” The film is set in September and October of 2006, the same year it was shot on a shoestring budget by writer, director, cinematographer, and editor Oren Peli, but it only gained wide release in 2009 when it was picked up by Paramount-DreamWorks. That year there were 2.8 million foreclosure filings and unemployment reached 10% in the United States (Adler). Made just before the real estate crash and released two years after, at the height of the credit crisis, the movie centers on a young California couple in their large new house. Things begin to go wrong for them when, eerily foreshadowing the housing crisis, a demon begins to toy with them, trying to collect on an ancestor’s Faustian bargain.

U.S. foreclosures climbed steadily during the years bracketing the first two Paranormal Activity movies.

One of the worst-hit states, California saw a record number of foreclosures and increases in the number of people housed in homeless shelters as a result of the housing crash.

The demon-creditor in Paranormal Activity resonates within the movie’s economic milieu, calling in its debt at the expense of all other concerns. The affective experience of this horror movie aptly foreshadows the credit crisis’ “structure of feeling”[1] [open endnotes in new window] of insecurity, helplessness, and dread in the face of enforced compliance with an economic contract. That the demon eschews violence except when severely provoked—preferring intimidation, coercion, and possession—further underscores what it has in common with the consumer finance industry. It doesn’t seem to derive pleasure from causing physical pain—setting these movies apart from recent body horror movie subgenres such as torture porn. In fact, it even exhibits playful behavior which perhaps makes it more comfortable communicating with children in the films.

To be clear, the Paranormal Activity franchise is not explicitly “about” the neoliberal condition of debtor capitalism. There is no indication that the filmmaker consciously constructed his story as an allegory, or, indeed, with any intended message beyond its overt plot about a demon terrorizing a young couple. However, given that the first film was made in the last year of the housing boom, and that its wide release came at the height of the credit crisis, such a cultural interpretation seems unavoidable, despite film critic Dana Stevens’ self-deprecating comment that her reading of the first film, as a “parable about the credit crisis” that is “all about spiritual and ethical debts coming due,” is “possibly crackpot.” I made the same interpretation of the film before reading her review, and I contend that it is decidedly not crackpot. Indeed, while some films explicitly take on the horrors of the housing crisis—such as Sam Raimi’s Drag Me To Hell, which premiered in early 2009—and the subsequent films in this franchise were made during the crisis, the first Paranormal movie’s housing crisis subtext is largely unintended and all the more telling for that reason.

This paper reads the Paranormal Activity franchis eas an ongoing post-cinematic allegory of debtor capitalism, and it raises these issues through three levels of analysis that interpenetrate one another. To begin, I examine the ways in which gender, race, and class coalesce within the domestic space of the twenty-first-century U.S. home. In these movies, the home appears noticeably generic, similar to the way the central female characters are portrayed as nearly interchangeable. Second, a formal analysis of the movies’ post-cinematic aesthetic calls attention to their cinematography and editing, which both portray and employ digital technologies that have become commonplace in most U.S. homes, as well as crucial in the global circulation of information and capital. The final section looks at the incorporation of immaterial labor in the marketing of the first film in particular, through transmedia paratexts and engagement of horror fans’ social media activity in the cultural production of the Paranormal Activity brand.

Demon domestic: 21st-Century horror at home

The first movie centers on Katie, an English major, and her partner Micah, a day trader. They are a young, white, middle-class couple who have just moved into what several reviewers call their “starter home,” implying that it is the first in a series of houses that they will own over the course of their lives. The movie’s action takes place exclusively in this house, captured within the tight frame of a home video camera, producing a claustrophobic effect of isolation and imprisonment—in stark contrast to any idealized notion of the family home as a sign of stability and refuge from the outside world. The movie, seemingly shot entirely on Micah’s home video camera, documents the incidents of daily life and paranormal activity in the house, which culminate in the demon-possessed Katie killing Micah.

Paranormal Activity 2 was released one year later in 2010, when the United States saw 2.9 million foreclosure filings and 9% unemployment. It, too, is set in a family home in southern California in 2006: this movie tells the story of Katie’s sister Kristi in parallel prequel mode, filling in gaps from the first movie and showing more of what happened beforehand. In the course of the second film, the sisters allude to unusual incidents from their childhood, as Katie tells Kristi about the strange things that have started happening in her new house (viewers who have seen the first film already know how the Katie and Micah situation will turn out). Salient facts also emerge as Kristi’s stepdaughter Ali researches demonology online and deduces that one of Kristi’s ancestors must have made a pact with a demon to deliver the family’s next male child: Kristi’s newborn son, Hunter. Like its predecessor, this movie is comprised of allegedly found footage: this time both home video and data from a series of home security cameras. The visuals produce a particularly enervating form of suspense since the viewer must constantly scan the frame in the absence of any seeming guidance from a director or editor or even (it seems) an actual cinematographer. It ends with the demon-possessed Katie killing Micah and fleeing their house (as we know from the first movie); then she kills Kristi and husband Dan and runs away with Hunter. Although I don’t focus on them here, the two subsequent films, Paranormal Activity 3 and Paranormal Activity 4, show the two sisters in their childhood and involve other characters such as their parents and grandmother.

Tim Snelson points out that the last U.S. boom in paranormal movies occurred during a similar moment of national decline, at the end of the recession- and inflation-plagued 1970s. Back then, anxieties about economic and social upheavals, including feminism and the sexual revolution as well as Watergate and the Vietnam War, fueled a cycle of possession and haunted house films such as The Exorcist (1973) and The Amityville Horror (1979). In the haunted house movies, families experienced hauntings that were place-bound to their homes: investigation revealed that ancient burial grounds and past gory crimes committed on the site in the past had caused the paranormal torments those families underwent. These suffering families demonstrate Natasha Zaretsky’s argument that in the crisis-ridden 1970s, “the family served as the symbol for the nation itself” as “both perpetrator and victim, as the site where the origins of national decline could be discovered and where the damages wrought by it could be assessed” (4). Families in 70s haunted house / possession films underwent agonizing paranormal experiences but more often than not survived intact and still together, reinscribing the value of a strong family in times of national crisis. In contrast, unlike in that cycle of films, the demon in the Paranormal movies consistently destroys families through death, kidnapping, and possession. Also unlike the conventional horror movie hauntings, the demon was never human and has no attachment to a particular site or structure—this mobility echoes the increasing mobility of Americans today, a point I develop further in a later section. This supernatural being attends primarily to women and children in its communications and behaviors, and no male characters (so far) have succeeded in defeating it, with or without the help of religious or other experts (as in The Excorcist).

Horror movies in the twenty-first century have shown a marked tendency to appeal to female as well as male spectators, and one remarkable result has been an increase in strong, intelligent horror movie heroines. As Pamela Craig and Martin Fradley point out, a hallmark of recent U.S. horror cinema is an

“overt courting of a female demographic which both refers back to and updates the proto-feminism of the slasher film’s Final Girl from the late 1970s and early 1980s” (87).

Carol Clover identified the trope of the Final Girl as the lone female survivor of the conventional slasher horror film, a girl whom Clover describes as “boyish,” “virginal,” competent and paranoid, usually with an androgynous name (204). Some examples of revised Final Girl characters include television’s Buffy of vampire-slaying fame and Sidney in the Scream franchise, each of whom emerges victorious despite being “feminine” and sexually active. Unlike contemporary descendants of the solitary Final Girl figure, however, Katie and Kristi conform to more stereotypically feminine, retrograde roles: neither has a job, both usually defer to their male partners, and neither takes an aggressive role in eliminating the demon.

The postfeminist traits of Katie and Kristi appear more pronounced when contrasted with earlier and later generations of women in their family. We meet their mother Julie and grandmother Lois in Paranormal Activity 3, which portrays career woman Julie, supporting her boyfriend and daughters Katie and Kristi in the late 80s, much to the disapproval of her domineering mother. Indeed, it was Lois’ aggressive demonic entrepreneurship—in making a deal with a demon—that created the state of indebtedness that dogged her family for generations. In effect, Lois borrowed against a future male descendent, creating a hereditary obligation shouldered unknowingly by her granddaughters when Kristi bears a son.

Young adult viewers, whom the movie’s marketing campaign directly targets (more on this below), might find it difficult to sympathize with passive women like Katie and Kristi whose partners disregard their wishes and advice about the demon, positioning them as postfeminist female horror movie leads rather than as more assertive and independent Final Girls. Interestingly, the teenaged girl characters with similar, androgynous names in the second and fourth films, Kristi’s step-daughter Ali in PA2 and Alex, the adopted sister to Hunter (now named Wyatt) in PA4, take on many of those Final Girl characteristics that Craig and Fradley indicate are having a resurgence: they are independent, intelligent, and active, in contrast with the older and more gender-normative Katie and Kristi.[2] Teenagers Ali and Alex also wield more power in their relationships with their male peers—confiding in them, enlisting their help, sharing and communicating through technological devices more comfortably, and struggling to understand what is happening to their families independently of their parents.

Despite the inclusion of refreshing “new” Final Girl figures Ali and Alex, however, the Paranormal Activity movies are clearly postfeminist, fitting the representational regime of gender relations that coincided with the economic upturn of the 90s and featured a superficial nod to the gender equality for which 70s feminists fought, while at the same time deemphasizing economic equality, often removing women from the workplace, and centering on heterosexual relationships, domesticity, and consumerism (Negra 4). Made in the context of the housing bubble, the first movie is poignant in its prescience, introducing the fairly traditional young couple, Katie and Micah, in their oversized, anonymous-looking house surrounded by consumer goods, yet in the second movie, post-crash, we meet an extremely similar young couple, Kristi and Dan, in an unnervingly similar, yet even more gender-normative, domestic setting. Neither of the women works outside the home, and both are supported by their male partners, who are also portrayed in several scenes making sexist remarks and rolling their eyes at the women.

In their characterizations of Katie and especially Kristi, these movies bear out what Diane Negra and Yvonne Tasker argue: that times of recession are also often times of gender retrenchment—when women’s role in the family home is reinscribed in the face of unemployment and scarcity—as if “equality is a luxury that can no longer be afforded.” In recessionary popular culture, women are more often cast in caregiving roles that emphasize their domestic resourcefulness and protectiveness. Thus Katie and Kristi in the Paranormal Activity movies adopt maternal attitudes toward the men, tolerating the men’s childish and sexist behavior. Indeed, the first three films feature three heterosexual couples in which the women strive in different ways to protect their families within the domestic realm of the home, and in which the men consistently and defiantly behave in ways that endanger them all. Even in the third movie, set in the pre-recession 1980s, Dennis conceals videotaped evidence of the demon from his girlfriend, Katie and Kristi’s mother Julie, because he doesn’t want to frighten her, thus endangering the whole family. In these ways the first two Paranormal movies conform to Tim Snelson’s argument that post-crash domestic horror “expose[s] the inequalities of recession-era households,” while this

“centering of housewives and mothers as the only defense against the (re)possession of the U.S. home might ultimately act to reinforce the ideology of female domesticity.”

Giving their male partners the upper hand in domestic and economic arrangements allows the men to justify disrespecting the postfeminist characters Katie and Kristi in various ways that lead to more danger.

Paranormal Activity 1. Micah and Katie’s furniture is characterless and looks like it belongs in a mid-range hotel. The movie displays the couple’s large, suburban home and its furnishings, including a big rear-projection TV, Paranormal Activity 2. Dan and Kristi’s is more indicative of aspirational middle-class tastes catered to by such companies as Pottery Barn. This flat screen TV is one of several in the home of Dan and Kristi.
Paranormal Activity 2. Exterior of Dan and Kristi’s house, slightly grander than Micah and Katie’s, in a similar new subdivision in southern California. Paranormal Activity 2. Dan Rey hires a home security firm to install multiple surveillance cameras after strange things start happening around the house.
Ali Rey, Kristi’s stepdaughter, researches demons online in Paranormal Activity 2. Paranormal Activity 2. Ali shows her father Dan the surveillance footage of the demon slamming the door and locking her out.

Katie and Kristi manifest the postfeminist tendency toward retreatism, as Diane Negra defines it: women choosing not to work, depending on parents or male partners for economic support, while tending to the family and the running of the household (15). In the 1990s, this retreat to the domestic sphere often figured as a personal choice, as career women opted out of the stressful world of work for the rewards of the home; after the housing crash, women appear more frequently as the stalwart force holding the family together. Accordingly, the first movie is centered around the bedroom, pointing to the centrality of the romantic relationship between Katie and Micah. Echoing Katie's retreat to the domestic and shifting interest from romance to nurturing, much of the paranormal activity in the second movie occurs in Kristi's kitchen and nursery. The demon’s target, stay-at-home mom Kristi, spends most of her time in these two rooms. In the earliest scenes, we see the demon behaving as if it knows it is being recorded, spinning the baby’s play-mobile when Kristi steps out and stopping it abruptly just before she returns. The movie’s low-budget domestic horror works powerfully with minimal special effects: one of the biggest “jumps” in the movie occurs as Kristi sits placidly in the kitchen, when suddenly every cupboard door flies open violently at the same moment. The demon assaults the quiet of these otherwise quotidian moments in the most feminine-coded spaces.

Paranormal Activity 2. Dan’s condescending expression as he mansplains to Ali that it was just the wind, despite her insistence that there was no wind at the time and all the windows and other doors in the house were closed. Paranormal Activity 2. Dan mansplaining to a disbelieving Kristi how the hanging pot rack could have slipped off its apparently stable and intact metal hooks…
…then mocking her in the pool as Micah videotapes him, explaining drily that anything that happens around the house causes Kristi to jump “straight to ghost” for an explanation, revealing that he hasn’t really listened to her explanations of the demon (not ghost). Paranormal Activity 2. Paranormal Activity 3. Dennis, Julie’s boyfriend, lives with her and her daughters, Katie and Kristi.
Paranormal Activity. Micah and Katie’s bedroom, the site of much of the movie’s paranormal activity, shot on their home video camera with tripod, . Paranormal Activity 2. Kristi and Ali in the kitchen, where Kristi spends a lot of time, and where several unexplained incidents take place,

Indeed, the retreat implied by Katie and Kristi’s domesticity is a central part of the demonic capitalist economy, at least in the first two films. Kristi’s maternity means that she performs traditional reproductive labor in bearing and caring for her child, though she has opted out of the formal labor market. Even outside of biological motherhood, Katie and Martine, the domestic worker in PA2, also participate in reproductive labor. Katie, although child-free, expresses her desire to be a teacher and shows genuine affection for her baby nephew; she later becomes a kind of foster-mother of demon-children in Paranormal Activity 4. Martine is condescendingly called a “nanny” at the beginning, when in fact she straddles the public / private divide as she performs physical housework in the form of laundry, cooking, and cleaning, as well as affective labor in her mutual emotional bonding with the children, all figured as simply waged work for Kristi and Dan’s family.

In her study of immigrant women’s domestic labor and its representations in popular culture, Mary Romero demonstrates,

“Purchasing the caretaking and domestic labor of an immigrant woman commodifies reproductive labor and reflects, reinforces, and intensifies social inequalities…. Qualities of intensive mothering, such as sentimental value, nurturing and intense emotional involvement, are not lost when caretaking work is shifted to an employee (Silbaugh 1996).” (Romero 192)

The ironic hierarchies of gender, race, and class in Paranormal Activity 2 crystallize around the figure of Martine, whom Ali sincerely refers to as a part of the family when she learns that her father Dan has fired the housekeeper. Patriarch Dan exercises his power over Martine when he learns that, despite his instructions, she has continued to burn smudges of dried herbs around their house in her efforts to cleanse the space of the evil spirits she believes abide there.

Yet the figure of the Latina domestic worker, although marginalized in her classed and raced position within the domestic economy, also functions similarly to other female figures such as Katie, Kristi, and Alex: as a source of information about the demon. In his desperation, Dan recalls the fired care worker back to his home to ask for her help; Martine obligingly teaches Dan how to shift the demonic attention from Kristi to Katie, expertise that she appears to have acquired in addition to her domestic skills. Ungrudgingly, Martine offers her advice and assistance to the family that had so recently cast her aside, yet neither she nor Dan realizes that the demon’s ultimate goal is to obtain possession of Hunter regardless of which sister it instrumentalizes to get him. Despite successfully switching the demon from Kristi to Katie, the possessed Katie promptly kills Dan in the living room and Kristi in the nursery and absconds with baby Hunter.

Paranormal Activity 2. Hunter’s nursery, another of Kristi’s frequent locations and site of many demonic interventions. Paranormal Activity 2. Martine, the ostensibly Catholic, Latina nanny with expert knowledge of demons, in the kitchen preparing food for the family.
Paranormal Activity 2. Hunter, Kristi, and Martine, share a peaceful moment together as a quasi-family. The costumes in the films are casual and unremarkable, lending no specificity to the characters’ personalities, as if they all shopped from the same J. Crew catalog. Paranormal Activity 2. Dan and Martine frequently argue about the existence of the demon and what should be done about it, causing Dan to fire her and then ask her for help when he finally realizes the demon is real.

Demon day-to-day: ordinary horror

Descended from the Gothic novel, paranormal horror focuses attention on the private home as a domestic site: in which families live, in which power hierarchies co-exist with complex emotional ties, and in which paranormal beings terrorize humans, showing that daily life is both normal and paranormal. Ordinariness gone awry is the mode of many horror movies, and the Paranormal Activity series is no exception. Everything in these movies appears unremarkable, even generic—from the houses themselves, newly built suburban tract homes, to the standard bland furnishings and costumes. Nothing stands out as unique, making it easy to imagine that the movie took place in a real home and that it could take place in any home. These lifestyles as depicted in the films appear to be typical upper-middle-class, white, and suburban, with plenty of square footage as befits the expansionist U.S. dream of home ownership.

The houses of Katie and Kristi are so similar that they appear interchangeable; moreover, the sisters themselves are also ordinary. For many viewers, their ordinariness led to difficulties in distinguishing Katie from Kristi, particularly when viewing the movies one year apart—both have dark hair and are close in age, and they have similar names. When Kristi’s husband Dan succeeds in displacing the demon’s interest from his wife to her sister Katie, thus explaining in the second film why the events of the first befell Katie, it appears that the sisters are as interchangeable as their houses as far as the demon is concerned. Martine performs domestic work as well, thus demonstrating that one mothering figure can replace another. Baby Hunter is revealed as the demon’s rightful property, according to Lois’ decades-old contract: he becomes the currency with which it can be paid off. The films never make clear precisely what was gained from the pact, only that it ensured the family some amount of financial gain. Lois’ home in Paranormal Activity 3 is large and includes outbuildings as well as a garden, so it appears that she continues to live comfortably. But regardless of the details of Lois’ compact with the demon, in the film narrative even the baby—the material result of the women’s reproductive labor—is transformed into an object of exchange that is used to pay a debt.

Paranormal Activity. Katie on the nondescript leather sofa in the unremarkable living room. Paranormal Activity 3. Julie prepares for her daughter Katie’s birthday party in 1988, captured on boyfriend Dennis’s VHS video camera. The homes, the characters, and the costumes in these films are all very ordinary.
Paranormal Activity 2. Kristi holding son Hunter as an infant. Paranormal Activity 2. Katie holding nephew Hunter, now a toddler. Note how similar the two women look.

In many ways, too, Katie's partner Micah’s career as a day trader is predicated on domesticity, ordinariness, and exchange. Many reviewers seem to equate “day trader” with “stockbroker.” However, they are not the same: a day trader buys and sells a high volume of stocks from a home computer connected to the Internet, attuned to minimal market movements. As Randy Martin explains,

“day trading came into existence with the 1990s stock market expansion as a function of that confluence between home access to live data on stock price fluctuations and lowered costs per trade” (46).

Instead of having to telephone in trade orders, suddenly Internet brokerage account holders could transact—and get rich—with a mouse click, almost by magic. This practice is a notable example of the financialization of U.S. life since the 90s, as Martin demonstrates, in that it features the privatization and individualization of a finance-centered livelihood while transposing the risks and anxieties of the market onto the domestic space of the home (46). Careers in finance have received scholarly attention in recent decades, often focusing on stockbrokers working for financial services corporations. In film plots, hypermasculinity accompanies the moral perils of high-risk investing—from the first Wall Street (1987), to the recent Margin Call (2011), a timespan that the Paranormal series bridges in its four movies (see Negra and Tasker “Neoliberal”; Annesley and Scheele).

But distinct from these representations of the high-finance fraternity in their sleek designer suits, popular images of day trading emphasize the solitary, at-home trader. Micah sports casual clothes, including a t-shirt promoting Coin Net (an online precious metals exchange). Instead of competing with colleagues and rivals, day traders are average men who exude “ordinariness” (Martin 49). Micah enjoys spending his money on consumer goods, brandishing a new home video camera that cost him “half of what [he] made” that day. The ordinary-looking lifestyle in the first movie can also be explained in part by the fact that Oren Peli, the filmmaker, used his own new house as its location, including an enormous rear-projection television he bought with the proceeds of his own day trading career in the 90s (Turek).

However, Martin emphasizes the macho albeit solitary egoism of day traders in their compulsion to mask or minimize the (often) massive losses they incur by playing the market so intensively and precariously: “an incessant comparison of success lost” and “hypersensitivity to loss in the eyes of others” characterize the day trader’s persona, whose daily routine is

“repeatable until the money runs out, in which each moment is unique and each day is the same” (46).

Micah’s obsession with recording the demon on time-stamped videos captured in the bedroom where he and Katie sleep, and around the house as they go about their lives, eerily echoes this repetitive day trader lifestyle in digital form. It takes place in the private space of the home, it foregrounds his prowess with digital technology, and it provides him with a chance to be aggressive and successful (although he merely succeeds in provoking the demon which leads to his death).

Indeed, thanks to Micah’s home video camera in PA1 and the home surveillance cameras in PA2, the movies themselves and the seemingly “real” video footage in them are a digitization of the characters and their bodies, as Steven Shaviro has pointed out. Unlike film shot on celluloid, with a digital camera images are converted to strings of numbers, which are then reconstituted algorithmically when the video is played back. In this sense, the “real” people and objects that are filmed digitally are literally reduced to data and digits (Grisham et al.). Shaviro explains how the shift in filmmaking technology also alters the philosophical implications of cinema in the digital age:

“Digital photography is no longer mimetic. The chain of cause and effect is ruptured: no longer does light reflected off an object, and entering a lens, produce analogous chemical changes on a photographic plate. Instead, the stream of light is sampled at precise intervals, and rendered into an abstract binary code (1s and 0s). This abstract code can be easily manipulated and overwritten: which is why it is so simple a task to edit and alter images on a computer…. In digital photography and film, even the most mimetically faithful images are artificial and fictive. There is no longer any ontological distinction between a 'true' image and a 'false' one." (“Emotion” 65)

Digitizing the humans in front of the cameras can be seen as a form of abstraction away from materiality, which can be disconcerting; we are left with what Shaviro calls

“the low-level dread and basic insecurity that forms the incessant background to our consumer-capitalist lives today.”  (Grisham et al.)

In PA1, for example, we see hours of uneventful video showing Katie and Micah sleeping, in fast forward, punctuated by moments of baffling terror that the characters (and often the audience) never fully understand (Grisham et al.). Even the alleged safety and security of the mother-child relation appears somehow flimsy and insubstantial, like the thin walls of the cheaply made suburban houses that offer no real protection to the families inside from “demonic capital” (Shaviro, in Grisham et al.).

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