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Mr Christopher Arnold:
Professional conduct
panel outcome
Panel decision and reasons on behalf of the
Secretary of State for Education
August 2025
2
Contents
Introduction 3
Allegations 4
Summary of evidence 4
Documents 4
Witnesses 4
Decision and reasons 4
Findings of fact 5
Panelâs recommendation to the Secretary of State 8
Decision and reasons on behalf of the Secretary of State 12
3
Professional conduct panel decision and recommendations, and decision on
behalf of the Secretary of State
Teacher: Mr Christopher Arnold
Teacher ref number: 0751124
Teacher date of birth: 27 March 1985
TRA reference: 20783
Date of determination: 1 August 2025
Former employer: Hampton School, Hampton, London
Introduction
A professional conduct panel (âthe panelâ) of the Teaching Regulation Agency (âthe
TRAâ) convened on 1 August 2025 by way of a virtual hearing, to consider the case of
Mr Christopher Arnold.
The panel members were Mr Paul Burton (lay panellist â in the chair), Ms Gill Lyon
(teacher panellist) and Mrs Pamela Thompson (lay panellist).
The legal adviser to the panel was Ms Lara Small of Birketts LLP Solicitors.
The presenting officer for the TRA was Mr Adam Slack of Capsticks LLP Solicitors.
Mr Arnold was present and was not represented.
The hearing took place in public and was recorded. 4
Allegations
The panel considered the allegation set out in the notice of proceedings dated 14 April
2025.
It was alleged that Mr Arnold was guilty of having been convicted of a relevant offence, in
that:
1. On 9 May 2022, he was convicted of the following relevant offence:
a. Observe a person doing a private act on 23 March 2022.
Summary of evidence
Documents
In advance of the hearing, the panel received a bundle of documents which included:
Section 1: Chronology, anonymised pupil list, list of key people and statement of agreed
facts â pages 4 to 10
Section 2: Notice of proceedings and response â pages 11 to 39
Section 3: Teaching Regulation Agency documents â pages 40 to 262
Section 4: Teacher documents â pages 263 to 281
Section 5: Police Documents- pages 285 to 297
In advance of the hearing, the panel also received a service bundle of documents of
18 pages in length.
The panel members confirmed that they had read all of the documents within the
bundles, in advance of the hearing.
In the consideration of this case, the panel had regard to the Procedures .
Witnesses
No witnesses were called by the TRA to attend the hearing.
Decision and reasons
The panel announced its decision and reasons as follows: 5
The panel carefully considered the case before it and reached a decision.
Mr Arnold had been employed at Hampton School (the âSchoolâ) as a Physics and
Computer Science teacher since 1 September 2012.
Mr Arnold was warned by the School in December 2015 when he was suspected of
photographing or recording a [REDACTED] colleague, however no further action was
taken at the time.
On 23 March 2022, [REDACTED] reported to the School that Mr Arnold had held his
mobile phone to the window of the female changing rooms and attempted to take
photographs inside.
Mr Arnold was formally dismissed on 6 May 2022 following a disciplinary hearing.
Mr Arnold was arrested, pleaded guilty and was subsequently convicted with the criminal
offence of âobserving a person doing a private act, knowing that the person did not
consent to being observed for your sexual gratificationâ at Wimbledon Magistrates Court
on 9 May 2022.
On 19 July 2022 Mr Arnold was sentenced to 200 hours of unpaid work, 30 days
rehabilitation and was made subject to notification requirements under the Sexual
Offences Act 2003 (sex offenders register) for 5 years.
The matter was referred to the TRA on 9 May 2022.
Findings of fact
The findings of fact are as follows:
The panel found the following particulars of the allegation against you proved, for these
reasons:
1. You were convicted on 9 May 2022 and sentenced on 19 July 2022 of the
following relevant offence:
a. You were convicted of the relevant offence of, observing a person
doing a private act on 23 March 2022, knowing that the person did not
consent to being observed for your sexual gratification.
The panel considered the Statement of Agreed Facts, signed by Mr Arnold on 10 March
2025. In that statement of agreed facts, Mr Arnold admitted the particulars of allegation
1(a), albeit the panel noted that he had crossed out the words âfor his own sexual
gratificationâ. During the hearing, when asked about this Mr Arnold admitted to the panel
that he accepted the facts of allegation 1(a) in their entirety, in that he accepted that he
had been convicted of the offence of âobserving a person doing a private act on 23 March 6
2022, knowing that the person did not consent to being observed for your sexual
gratificationâ. Notwithstanding this, the panel made a determination based on the facts
available to it.
The panel noted page 8 of the Teacher misconduct: the prohibition of teachers (âthe
Adviceâ) which states that where there has been a conviction at any time, of a criminal
offence, the panel will accept the certificate of conviction as conclusive proof of both the
conviction and the facts necessarily implied by the conviction, unless exceptional
circumstances apply. The panel did not find that any exceptional circumstances applied
in this case.
The panel had been provided with a copy of the certificate of conviction from Wimbledon
Magistratesâ Court, dated 19 July 2022, which detailed that Mr Arnold had been convicted
of:
1. Observing another person doing a private act, knowing that the person did not
consent to being observed for his sexual gratification.
The panel noted that Mr Arnold had pleaded guilty to the offence (albeit the panel
considered Mr Arnoldâs verbal submissions as to the context around the reasons why he
had pleaded guilty).
In respect of the allegation, Mr Arnold was sentenced to 200 hours of unpaid work.
Mr Arnold was also required to register with the police for 5 years on the Sex Offendersâ
register.
The panel therefore found allegation 1(a) proven.
Findings as to conviction of a relevant offence
Having found the allegation proved, the panel went on to consider whether the facts of
that proved allegation amounted to conviction of a relevant offence.
In doing so, the panel had regard to the Advice.
The panel noted that Mr Arnold admitted and accepted in his Statement of Agreed Facts
that he had been convicted of a relevant offence. Notwithstanding this, the panel made a
determination on the evidence available to it.
The panel first considered whether the conduct of Mr Arnold, in relation to the facts found
proved, involved breaches of the Teachersâ Standards.
The panel considered that, by reference to Part 2, Mr Arnold was in breach of the
following standards: 7
ď§ Teachers uphold public trust in the profession and maintain high standards of
ethics and behaviour, within and outside school, by
o building relationships rooted in mutual respect, and at all times observing
proper boundaries appropriate to a teacherâs professional position;
o showing tolerance of and respect for the rights of others; and
o not undermining fundamental British values, including the rule of law.
ď§ Teachers must have proper and professional regard for the ethos, policies and
practices of the school in which they teach.
ď§ Teachers must have an understanding of, and always act within, the statutory
frameworks which set out their professional duties and responsibilities.
The panel noted that Mr Arnoldâs actions were relevant to teaching and working in an
education setting, because he had pleaded guilty to an offence which had been
committed on the Schoolâs grounds.
The panel also took account of the way the teaching profession is viewed by others. The
panel considered that Mr Arnoldâs behaviour in committing the offence could affect public
confidence in the teaching profession, given the influence that teachers may have on
pupils, parents and others in the community.
The panel considered the seriousness, nature and gravity of the offence. The panel
noted that Mr Arnoldâs behaviour did not lead to a sentence of imprisonment, which was
indicative that the offence was at the less serious end of the possible spectrum.
However, the offence type itself (of voyeurism) is a serious offence and the panel noted
that Mr Arnold had been placed on the Sex Offendersâ register for 5 years as a result.
Whilst the panel noted Mr Arnoldâs case is that he did not actually take a photo and/or
see anything in the ladiesâ changing rooms at the School, the panel considered that his
actions in attempting to do so (regardless of the outcome) demonstrated his intent at the
time and is relevant to the seriousness of the offence. The panel also considered that
Mr Arnoldâs actions led to a breach of trust with his colleagues at the School.
The panel also considered the offences listed on pages 12 and 13 of the Advice.
This was a case concerning an offence involving voyeurism, which the Advice states is
likely to be considered a relevant offence. The panel also considered sexual activity to be
relevant in this regard, noting that Mr Arnold admitted that he had been convicted of the
offence of âobserving another person doing a private act, knowing that the person did not
consent to being observed for his sexual gratificationâ.
For the purpose of considering the seriousness of the offence, the panel took into
account evidence of mitigating circumstances raised by Mr Arnold. The panel took into
consideration Mr Arnoldâs account of the [REDACTED]. 8
The panel particularly noted Mr Arnoldâs statement of 22 November 2022.
The panel read Mr Arnoldâs evidence that he committed the offence following at a time
when he was in a [REDACTED] and was not thinking clearly. Mr Arnold submitted in his
statement that he had acted in the way that he did on 23 March 2022 because of his
[REDACTED].
The panel noted that Mr Arnold had immediately owned up to his actions on 23 March
2022, had pleaded guilty at the first available opportunity to do so and had co-operated
with the Schoolâs investigation into the incident. The panel also noted that Mr Arnold had
expressed immediate and continued remorse.
However, although the panel carefully considered Mr Arnoldâs mitigating circumstances
for the purposes of assessing the seriousness of the offence, the panel also found that
the seriousness of the offending behaviour that led to the conviction was relevant to
Mr Arnoldâs ongoing suitability to teach. The panel considered that a finding that this
conviction was for a relevant offence was necessary to reaffirm clear standards of
conduct so as to maintain public confidence in the teaching profession.
The panel therefore found that there has been a conviction of a relevant offence.
Panelâs recommendation to the Secretary of State
Given the panelâs findings in respect of a conviction of a relevant offence, it was
necessary for the panel to go on to consider whether it would be appropriate to
recommend the imposition of a prohibition order by the Secretary of State.
In considering whether to recommend to the Secretary of State that a prohibition order
should be made, the panel had to consider whether it would be an appropriate and
proportionate measure, and whether it would be in the public interest to do so. Prohibition
orders should not be given in order to be punitive, or to show that blame has been
apportioned, although they are likely to have punitive effect.
The panel had regard to the particular public interest considerations set out in the Advice
and, having done so, found a number of them to be relevant in this case, namely:
(i) the protection of other members of the public;
(ii) the maintenance of public confidence in the profession; and
(iii) declaring and upholding proper standards of conduct within the teaching
profession.
In light of the panelâs findings against Mr Arnold, which were conviction of the relevant
offence of observing a private act knowing that the person did not consent to being 9
observed for sexual gratification, the panel considered that public confidence in the
profession could be seriously weakened if conduct such as that found against Mr Arnold
was not treated with the utmost seriousness when regulating the conduct of the
profession.
The panel was of the view that a strong public interest consideration in declaring proper
standards of conduct in the profession was also present as the conduct found against
Mr Arnold was outside that which could reasonably be tolerated.
In addition to the public interest considerations set out above, the panel went on to
consider whether there was a public interest in retaining Mr Arnold in the profession.
The panel noted that there was evidence of Mr Arnold having significant ability and
competence as a teacher. In particular, the panel considered that was evidenced by his
academic career studying at Oxford University, before teaching at the School, a private
school, and successfully obtaining multiple promotions in the ten years he taught there.
The panel also reviewed a number of glowing references about his teaching abilities from
colleagues.
However, whilst there is evidence that Mr Arnold had great ability as an educator, the
panel considered that the adverse public interest considerations above outweigh any
interest in retaining Mr Arnold in the profession, since his behaviour fundamentally
breached the standard of conduct expected of a teacher.
The panel considered carefully the seriousness of the behaviour, noting that the Advice
states that the expectation of both the public and pupils, is that members of the teaching
profession maintain an exemplary level of integrity and ethical standards at all times.
In view of the clear public interest considerations that were present, the panel considered
carefully whether or not it would be proportionate to impose a prohibition order, taking
into account the effect that this would have on Mr Arnold.
The panel took further account of the Advice, which suggests that a prohibition order may
be appropriate if certain behaviours of a teacher have been proved. In the list of such
behaviours, those that were relevant in this case were:
ď§ serious departure from the personal and professional conduct elements of the
Teachersâ Standards;
ď§ the commission of a serious criminal offence, including those that resulted in a
conviction or caution, paying particular attention to offences that are ârelevant
mattersâ for the purposes of the Police Act 1997 and criminal record disclosures;
ď§ abuse of position or trust; and 10
ď§ sexual misconduct, e.g. involving actions that were sexually motivated or of a
sexual nature.
Even though some of the behaviour found proved in this case indicated that a prohibition
order would be appropriate, the panel went on to consider the mitigating factors.
Mitigating factors may indicate that a prohibition order would not be appropriate or
proportionate.
In light of the panelâs findings, there was evidence that Mr Arnoldâs actions were
deliberate. The panel considered Mr Arnoldâs written submission that he acted on
23 March 2022 out of impulse in the belief that it would provide a moment of respite from
feelings of panic and despair during a [REDACTED]. However, the panel also noted that
Mr Arnold had taken deliberate steps to go through the double doors and up the stairs to
reach the ladiesâ changing rooms in the School. The panel further noted that in
Mr Arnoldâs Statement of Agreed Facts he admitted that he had held his phone up to the
window in the ladiesâ changing room with the intent to take photographs of female
members of staff he knew were in the changing room at the time.
There was no evidence to suggest that Mr Arnold was acting under extreme duress, e.g.
a physical threat or significant intimidation.
The panel took into consideration that Mr Arnold did have a previously good academic
history, having demonstrated high standards in both his personal and professional
conduct and having contributed significantly to the education sector during his ten-year
teaching career, this being reflected in his promotions to Assistant Head of Year and
Mental Health and Wellbeing Lead. The panel saw evidence of good character through
references made in support of Mr Arnoldâs applications for these roles. For example, the
panel referred to the reference from Individual A which noted all requested performance
indicators as âoutstandingâ and complimented his âempathy and outstanding
interpersonal skillsâ and experience in pastoral issues. However, the panel noted that no
recent references were provided from any colleagues that could attest to Mr Arnoldâs
abilities as a teacher.
The panel was particularly influenced by the remorse expressed by Mr Arnold in his
statement dated 21 November 2022 and his ongoing and continued regret of the incident.
Mr Arnold stated his actions were âout of character and contrary to my attitudes and
valuesâ, and that he was âkeen to take responsibility for my actionsâ, accepting conviction
and his sentence as an âopportunity to show understanding and acceptance of my
actionsâ.
Mr Arnold described the [REDACTED] he was undertaking to develop strategies to help
him cope with challenges in his personal life and his regret for not getting help sooner
with [REDACTED]. The panel noted in Mr Arnoldâs verbal submissions however that,
whilst he has continued to [REDACTED], the panel had seen no evidence of active steps 11
that he had taken in the last 2.5 years since he wrote his statement on 21 November
2022 to reduce the risk of repetition of a similar event in the future.
The panel was impressed by Mr Arnold attending the hearing in order to give an account
of his actions publicly and express his remorse. The panel was particularly influenced by
the sincerity of the remorse expressed by Mr Arnold in his verbal submissions during the
hearing and the fact that he admitted to the allegations in full. Mr Arnold expressed his
continued remorse, not only for the impact his actions had on his female colleagues on
23 March 2022, but also on the impact his departure has had on the wider profession,
including parents, pupils and colleagues at the School.
The panel first considered whether it would be proportionate to conclude this case with
no recommendation of prohibition, considering whether the publication of the findings
made by the panel would be sufficient.
The panel was of the view that, applying the standard of the ordinary intelligent citizen, it
would not be a proportionate and appropriate response to recommend no prohibition
order. Recommending that the publication of adverse findings would be sufficient would
unacceptably compromise the public interest considerations present in this case, despite
the severity of the consequences for Mr Arnold of prohibition.
The panel was of the view that prohibition was both proportionate and appropriate. The
panel decided that the public interest considerations outweighed the interests of
Mr Arnold. The conviction of a relevant offence, the strong public interest consideration in
declaring proper standards of conduct in the profession and maintaining public
confidence in the profession, and the fact that Mr Arnold remained on the Sex Offenders
Register were significant factors in forming that opinion. Accordingly, the panel made a
recommendation to the Secretary of State that a prohibition order should be imposed with
immediate effect.
The panel went on to consider whether or not it would be appropriate for it to decide to
recommend a review period of the order. The panel was mindful that the Advice states
that a prohibition order applies for life, but there may be circumstances, in any given
case, that may make it appropriate to allow a teacher to apply to have the prohibition
order reviewed after a specified period of time that may not be less than 2 years.
The Advice indicates that there are certain types of case where, if relevant, the public
interest will have greater relevance and weigh in favour of not offering a review period.
One of these includes:
⢠serious sexual misconduct e.g. where the act was sexually motivated and resulted in,
or had the potential to result in, harm to a person or persons. 12
Whilst the panel considered this factor to be relevant, the panel noted that the
circumstances of the commission of the offence were on the lower range of seriousness.
The panel further noted that Mr Arnold has demonstrated insight into his actions and
regret of the incident as outlined in his November 2022 statement and subsequently.
The panel noted Mr Arnoldâs attempts to acknowledge his personal issues and change
his behaviour through undertaking [REDACTED]. The panel noted Mr Arnoldâs comments
that âMy life has changed beyond recognitionâŚand I am wholeheartedly committed to
taking whatever measures necessary to make my future more positive, happy and
fulfillingâ and âmy situation has been truly transformed by opening up and reaching out for
helpâ. The panel also had sight of the letter from the probation service dated 6 October
2022 stating that Mr Arnold had âengaged proactively with all aspects of his orderâ and
that he posed a âlow risk to childrenâ at the time of the letter.
The panel decided that the findings indicated a situation in which a review period would
be appropriate and, as such, decided that it would be proportionate, in all the
circumstances, for the prohibition order to be recommended with provisions for a review
period. The panel considered that, particularly given Mr Arnoldâs continued remorse and
low risk of repetition in future, a review period of two years would be appropriate in this
case.
Decision and reasons on behalf of the Secretary of State
I have given very careful consideration to this case and to the recommendation of the
panel in respect of both sanction and review period.
In considering this case, I have also given very careful attention to the Advice that the
Secretary of State has published concerning the prohibition of teachers.
In this case, the panel has found all of the allegations proven and found that those
proven facts amount to a relevant conviction.
The panel has made a recommendation to the Secretary of State that Mr Christopher
Arnold should be the subject of a prohibition order, with a review period of two years.
In particular, the panel has found that Mr Arnold is in breach of the following standards:
ď§ Teachers uphold public trust in the profession and maintain high standards of
ethics and behaviour, within and outside school, by
o building relationships rooted in mutual respect, and at all times observing
proper boundaries appropriate to a teacherâs professional position;
o showing tolerance of and respect for the rights of others; and 13
o not undermining fundamental British values, including the rule of law.
ď§ Teachers must have proper and professional regard for the ethos, policies and
practices of the school in which they teach.
ď§ Teachers must have an understanding of, and always act within, the statutory
frameworks which set out their professional duties and responsibilities.
The panel finds that the conduct of Mr Arnold fell significantly short of the standards
expected of the profession.
The findings of misconduct are serious as they include a finding of a conviction of the
relevant offence of observing a private act knowing that the person did not consent to
being observed for sexual gratification.
I have to determine whether the imposition of a prohibition order is proportionate and in
the public interest. In considering that for this case, I have considered the overall aim of a
prohibition order which is to protect pupils and to maintain public confidence in the
profession. I have considered the extent to which a prohibition order in this case would
achieve that aim taking into account the impact that it will have on the individual teacher.
I have also asked myself, whether a less intrusive measure, such as the published
finding of a relevant conviction, would itself be sufficient to achieve the overall aim. I have
to consider whether the consequences of such a publication are themselves sufficient. I
have considered therefore whether or not prohibiting Mr Arnold, and the impact that will
have on the teacher, is proportionate and in the public interest.
In this case although the panel did not comment on the extent to which a prohibition
order would protect children/safeguard pupils, however I have observed the following
comment âThe panel noted that Mr Arnoldâs actions were relevant to teaching and
working in an education setting, because he had pleaded guilty to an offence which had
been committed on the Schoolâs grounds.â
I have also taken into account the panelâs comments on insight and remorse, which the
panel sets out as follows, âThe panel was particularly influenced by the remorse
expressed by Mr Arnold in his statement dated 21 November 2022 and his ongoing and
continued regret of the incident. Mr Arnold stated his actions were âout of character and
contrary to my attitudes and valuesâ, and that he was âkeen to take responsibility for my
actionsâ, accepting conviction and his sentence as an âopportunity to show understanding
and acceptance of my actionsâ. I have therefore given this element weight in reaching
my decision.
I have gone on to consider the extent to which a prohibition order would maintain public
confidence in the profession. The panel observe, âIn light of the panelâs findings against
Mr Arnold, which were conviction of the relevant offence of observing a private act
knowing that the person did not consent to being observed for sexual gratification, the 14
panel considered that public confidence in the profession could be seriously weakened if
conduct such as that found against Mr Arnold was not treated with the utmost
seriousness when regulating the conduct of the profession.â I am particularly mindful of
the finding of a relevant offence which had been committed on School grounds in this
case and the impact that such a finding has on the reputation of the profession.
I have had to consider that the public has a high expectation of professional standards of
all teachers and that the public might regard a failure to impose a prohibition order as a
failure to uphold those high standards. In weighing these considerations, I have had to
consider the matter from the point of view of an âordinary intelligent and well-informed
citizen.â
I have considered whether the publication of a finding of a relevant conviction, in the
absence of a prohibition order, can itself be regarded by such a person as being a
proportionate response to the misconduct that has been found proven in this case.
I have also considered the impact of a prohibition order on Mr Arnold himself and the
panel comment âThe panel noted that there was evidence of Mr Arnold having significant
ability and competence as a teacher. In particular, the panel considered that was
evidenced by his academic career studying at Oxford University, before teaching at the
School, a private school, and successfully obtaining multiple promotions in the ten years
he taught there. The panel also reviewed a number of glowing references about his
teaching abilities from colleagues.â
A prohibition order would prevent Mr Arnold from teaching. A prohibition order would also
clearly deprive the public of his contribution to the profession for the period that it is in
force.
In this case, I have placed considerable weight on the panelâs comments concerning the
level of insight or remorse. The panel has said, âMr Arnold described the [REDACTED]
he was undertaking to develop strategies to help him cope with challenges in his
personal life and his regret for not getting help sooner with [REDACTED]. The panel
noted in Mr Arnoldâs verbal submissions however that, whilst he has continued to
[REDACTED], the panel had seen no evidence of active steps that he had taken in the
last 2.5 years since he wrote his statement on 21 November 2022 to reduce the risk of
repetition of a similar event in the future.â
I have also placed considerable weight on the finding of the panel âwhilst there is
evidence that Mr Arnold had great ability as an educator, the panel considered that the
adverse public interest considerations above outweigh any interest in retaining Mr Arnold
in the profession, since his behaviour fundamentally breached the standard of conduct
expected of a teacher.â
I have given less weight in my consideration of sanction therefore, to the contribution that
Mr Arnold has made to the profession. In my view, it is necessary to impose a prohibition 15
order in order to maintain public confidence in the profession. A published decision, in
light of the circumstances in this case, does not in my view satisfy the public interest
requirement concerning public confidence in the profession.
For these reasons, I have concluded that a prohibition order is proportionate and in the
public interest in order to achieve the intended aims of a prohibition order.
I have gone on to consider the matter of a review period. In this case, the panel has
recommended a two-year review period.
I have considered the panelâs comments âThe panel noted Mr Arnoldâs attempts to
acknowledge his personal issues and change his behaviour through undertaking
[REDACTED]. The panel noted Mr Arnoldâs comments that âMy life has changed beyond
recognitionâŚand I am wholeheartedly committed to taking whatever measures
necessary to make my future more positive, happy and fulfillingâ and âmy situation has
been truly transformed by opening up and reaching out for helpâ. The panel also had
sight of the letter from the probation service dated 6 October 2022 stating that Mr Arnold
had âengaged proactively with all aspects of his orderâ and that he posed a âlow risk to
childrenâ at the time of the letter.â The panel has also said that âThe panel considered
that, particularly given Mr Arnoldâs continued remorse and low risk of repetition in future,
a review period of two years would be appropriate in this case.â
I have decided that a two-year review period is proportionate in this case and to achieve
the aim of maintaining public confidence in the profession.
This means that Mr Christopher Arnold is prohibited from teaching indefinitely and
cannot teach in any school, sixth form college, relevant youth accommodation or
childrenâs home in England. He may apply for the prohibition order to be set aside, but
not until 15 August 2027, 2 years from the date of this order at the earliest. This is not an
automatic right to have the prohibition order removed. If he does apply, a panel will meet
to consider whether the prohibition order should be set aside. Without a successful
application, Mr Arnold remains prohibited from teaching indefinitely.
This order takes effect from the date on which it is served on the teacher.
Mr Arnold has a right of appeal to the High Court within 28 days from the date he is given
notice of this order.
Decision maker: Sarah Buxcey
Date: 7 August 2025
This decision is taken by the decision maker named above on behalf of the Secretary of
State.
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