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The Publisher is not registered as an investment advisor with any federal or state regulatory agency.  Rather, Publisher relies upon the "publisher's exclusion" from the definition of "investment advisor" as provided under Section 202(a)(11) of the Investment Advisers Act of 1940 and corresponding state securities laws.  The Newsletter is a bona fide publication of general and regular circulation offering impersonalized investment-related advise to subscribers and/or prospective subscribers (e.g., not tailored to the specific investment portfolio or needs of current and/or prospective subscribers).