Homosexuality and the Bible

Jason Dulle


What does the Bible teach about homosexuality? The general public appears to be confused on the issue. According to the Barna Research Group 53% of Americans believe the Bible specifically condemns homosexuality, while 27% of Americans do not think the Bible specifically condemns homosexuality, and 20% do not know.1

The traditional understanding that the Bible condemns homosexuality has long been attacked from without, but over the last few years it has been increasingly attacked from within by professing Christians and Christian theologians. In 2003 the Episcopalian church ordained an openly practicing homosexual-Gene Robinson-as a bishop. In 2004 the United Methodist Church court approved the ministry of lesbian minister, Karen Dammann. Fortunately the United Methodist Church approved a measure later that same year reaffirming and strengthening their previous ban on homosexual ministers. In 2004 the Presbyterian Church (USA) narrowly defeated a measure (259-255) that would have been the first step towards ordaining homosexuals to the ministry. In 2005 a special task force of the United Evangelical Lutheran Church has recommended that the Lutheran church allow the ordination of gays. Whether they act on this recommendation waits to be seen later this year. What's important to note is that in each of these instances Christian believers argued that the Scripture either allows for, supports, or is ambiguous on the issue of homosexuality.

This new understanding of the Bible's teaching on homosexuality is interesting in light of the fact that thousands of theologians in the preceding 19 centuries never saw it! How is it that so many Christians and theologians are suddenly receiving the revelation that the Bible is actually accepting of homosexuality? I am persuaded that Biblical hermeneutics has little to do with this new understanding. The shift is motivated by a desire to accommodate Scripture to cultural mores. Historic Christianity represents the greatest obstacle to the normalization of homosexuality. "If homosexual advocates are to succeed, they must either marginalize or neutralize the Bible as an authority."2 While non-Christian homosexual advocates have attempted to do just that for many years, Christian theologians are increasingly singing the same mantra.

So what is the Biblical teaching on homosexuality? Does the Bible teach that the practice is sinful, or does the Bible teach that it is acceptable? I am persuaded that Scripture is clear in its condemnation of the behavior. Let us examine the relevant texts from both the Old and New Testaments.

Genesis 19:4-11

"But before they [Lot and the two angels] lay down, the men of the city, the men of Sodom surrounded the house, both old and young from every quarter: 5 And they called to Lot, and said to him, Where are the men which came in to you this night? Bring them out to us so that we may know them. 6 And Lot went out to them at the doorway, and shut the door after him 7 and said, Please, brethren, do not act wickedly. 8 Behold now, I have two daughters which have not known a man; please let me bring them out to you, and you can do to them what is good in your eyes: only do nothing to these men, for they came under the shadow of my roof. 9 And they said, Stand back. And they said again, This one came in to sojourn, and now he wants to be a judge: now will we deal worse with you than with them. And they pressed sore upon Lot and came near to break the door. 10 But the men put forth their hand, and pulled Lot into the house to them and shut to the door. 11 And they smote the men that were at the door of the house with blindness, both small and great: so that they wearied themselves to find the door."

Pro-homosexual advocates often claim that the sin for which Sodom was destroyed was inhospitality, not homosexuality. There is no question that hospitality was extremely important in ancient near eastern cultures. It was so important to Lot that Lot was willing to give his virgin daughters to the men to spare his visitors. But the inhospitality of the citizens of Sodom is only implied. The only explicit sin in the text is that of homosexuality. Furthermore, God had already determined to destroy the city prior to this episode of "inhospitality," so that could not be the reason they were destroyed. The same goes for other suggestions such as attempted rape.

Sodom is mentioned 27 times in Scripture as a symbol of gross immorality. The destruction of Sodom was the worst destruction in Scripture next to the Flood. Do we really think inhospitality was the reason God was so angry with Sodom? Would God destroy two entire cities for having bad social manners?3

Some suggest that "to know" means "to interrogate." According to this argument the men of the city only wanted to interview the visitors to make sure they were not spies. To their credit the Hebrew word, yada, usually means to know some thing through one's senses, not sexual relations; however, it does mean sexual relations in the following passages: Genesis 4:1, 17, 25; 38:26; Numbers 31:17, 35; Judges 11:39; 19:22, 25; 21:11; I Samuel 1:19; I Kings 1:4. Clearly that is the intended meaning in Genesis 19 as well. If the men of Sodom only wanted to "interrogate" the visitors to make sure they were not spies why did Lot offer his daughters to them? Was he saying "Interrogate my daughters instead"? Clearly not.

Others suggest yada is being used in the sense of "getting acquainted with." But would all the men of the city surround Lot's house and nearly beat down his door merely to "get acquainted" with the visitors? And why would Lot have begged them "Please, my brothers don't act so wickedly!" if they only wanted an interview? Furthermore, why would he offer them his daughters saying, they "have not known a man." Was he saying, "They have never been interviewed before"? That the mob intended to do evil is evident by Lot's statement concerning his daughters, "Do to them whatever you like; only do nothing to these men."

Based on Ezekiel 16:49-50 homosexual advocates argue that Sodom was destroyed for their arrogance and injustice, not the sin of homosexuality:

"Behold, this was the guilt of your sister Sodom: she and her daughters had pride, surfeit of food, and prosperous ease, but did not aid the poor and needy. They were haughty, and did abominable things before me; therefore I removed them, when I saw it." (RSV)

There is no question that Sodom was guilty of many sins other than homosexuality. They were arrogant, unjust, and failed to feed the poor. But the text is clear that they were also destroyed because they did abominable things. The only thing we know they practiced that God identified as an abomination is homosexuality. In fact, the only sin committed by Sodom that God deemed deserving of capital punishment in the Law of Moses was homosexuality (not inhospitality).

Leviticus 18:22 and 20:13

"You shall not lie with a male as one lies with a female; it is an abomination." (NASB)

"If there is a man who lies with a male as those who lie with a woman, both of them have committed a detestable act; they shall surely be put to death. Their bloodguiltiness is upon them." (NASB)

While the meaning of these passages seems clear, pro-homosexual advocates argue that since Leviticus 18:22 appears in the holiness codes for the Levitical priesthood it refers to ritual, not moral impurity; ceremonial, not moral prohibitions.

Others argue that since these passages condemning homosexuality are surrounded by other commands that were purely ceremonial in nature and no longer apply to believers under the New Covenant, the same applies to the command against homosexuality: it is ceremonial in nature, and no longer applicable to NT believers.

These lines of argumentation are flawed for several reasons. First, they ignores the fact that the New Testament condemns homosexuality as well.

Secondly, it is not true that these passages are surrounded by ceremonial commands pertaining to ritual purity. The immediate contexts of both passages are filled with moral commands that apply to all men, not just the Levitical priesthood. Among them are commands forbidding incest and other inter-family sexuality (18:6-17; 20:11-14, 17, 19-21), adultery (18:20; 20:10), child sacrifice (18:20-21; 20:2-5), bestiality (18:23; 20:15-16), and the seeking of diviners (20:6). There are only two non-moral commandments in the immediate context: killing kids for cursing their parents (20:9); forbidding sex with a woman on her period (18; 20:18). While there are many non-moral commands in other parts of Leviticus, that does not detract from the fact that the immediate context in both anti-homosexuality passages consists of a host of moral sins.

Some argue that God's condemnation of homosexuality was limited to homosexual acts associated with idolatrous worship. "Normal" homosexuality apart from this context was acceptable. If such were the case, why does the text not make this explicit? Furthermore, following this line of reasoning one could cheat on their wife, have sex with their daughter, have sex with animals, and kill their children so long as those acts were not in the context of idolatrous worship!

The fact of the matter is that there is no way to get out of the plain reading of these passages without doing serious injustice to the normal methods of interpretation and common sense.

2 Samuel 1:26

"I am distressed for you, my brother Jonathan: very pleasant hast thou been unto me: thy love to me was wonderful, passing the love of women."

Based on this one verse homosexual advocates have suggested that David and Jonathan were homosexual lovers, despite the fact that no sexual acts between them is ever hinted at in Scripture. Craig Blomberg notes that "only modern Westerners unfamiliar with the physical expression of friendship between men in the Middle East would mistake the Bible's references for homosexuality. … David's whole point in this text is that Jonathan was his 'blood brother' with a loyalty that surpassed that which mere eroticism creates."4

Romans 1:26-27

"For this reason God gave them over to dishonorable passions. For their women exchanged the natural sexual relations for unnatural ones, 27 and likewise the men also abandoned natural relations with women and were inflamed in their passions for one another. Men committed shameless acts with men and received in themselves the due penalty for their error." (NET Bible)

Pro-homosexual interpreters argue that Paul is not condemning homosexual behavior in general, but the abuse of homosexuality; i.e. he is promoting temperance, not abstinence. This idea fails to stand up to scrutiny. The Bible condemns sex outside of marriage, but sanctions frequent sex within the marriage bed (I Corinthians 7:3-5; Hebrews 13:4). If homosexual sex was acceptable before God, surely homosexuals could engage in frequent sex so long as they were married. Unfortunately the Bible does not sanction same-sex marriage, and condemns all homosexual acts.

Others argue that Paul only meant to convey that it is sin for one to violate their sexual orientation, exchanging their natural desire for the same sex for an unnatural desire towards the opposite sex. John Boswell, professor of history at Yale, is one such example. Boswell wrote:

The persons Paul condemns are manifestly not homosexual: What he derogates are homosexual acts committed by apparently heterosexual persons. The whole point of Romans 1, in fact, is to stigmatize persons who have rejected their calling, gotten off the true path they were once on. ... It is not clear that Paul distinguished in his thoughts or writings between gay persons (in the sense of permanent sexual preference) and heterosexuals who simply engaged in periodic homosexual behavior. It is in fact unlikely that many Jews of his day recognized such a distinction, but it is quite apparent that-whether or not he was aware of their existence-Paul did not discuss gay persons, but only homosexual acts committed by heterosexual persons. "Nature" in Romans 1:26, then, should be understood as the personal nature of the pagans in question."5 [emphasis in the original]

Virginia Mollenkott agrees, writing, "What Paul seems to be emphasizing here is that persons who are heterosexual by nature have not only exchanged the true God for a false one but have also exchanged their ability to relate to the opposite sex by indulging in homosexual behavior that is not natural to them."6

Janet Fishburn of Drew University Theological School argues: "Yet, some biblical scholars point out that this passage can only refer to the homosexual acts of heterosexual persons. This is because the writers of the Bible did not distinguish between homosexual orientation and same-gender sexual acts. If this distinction is accepted, the condemnation of homosexuality in Romans does not apply to the sexual acts of homosexual persons."

According to this interpretation the truly immoral act would be to suggest that a homosexual become heterosexual, because you would be requiring them to go against their natural desire for the same sex.

There are five reasons that the "violation of one's sexual orientation" argument fails:7

1. The argument assumes homosexuality constitutionality; i.e. homosexuality is not something you do, but something you are. The problem with this assumption is that no genetic link to homosexuality has ever been found. The data still suggests that homosexual desires are caused by environment and nurture, not nature.
2. It commits the genetic fallacy. You cannot get an "ought" from an "is." Just because one naturally feels attracted to someone of the same sex does not mean such an attraction is moral. Pedophiles have a sexual attraction for little children, but that fact ("is") does not make it moral ("ought").
3. It introduces a concept foreign to the text. If Paul was interested in condemning the violation of one's sexual orientation we would have expected Paul to mention those who burn unnaturally for the opposite sex. But there is no verse that says if your natural inclination is toward the same sex, you should not burn in lust toward the opposite sex.
4. If all who have a desire for the same sex do so naturally, then who does this verse apply to? Who gets into bed with someone for whom they have no sexual desire to do so?8
5. It is clear what Paul meant by "natural." The Greek word phusis refers to natural function, not natural desire. What Paul has in mind is the violation of natural sexual functions. Sexuality is not determined by what you want sexually, but by how you are designed to function sexually. Natural desires go with natural functions. The passion that exchanges the natural function of sex for an unnatural function of sex is what Paul calls "a degrading passion."9 While adultery is immoral because it exploits the natural sexual function in an illegitimate way, homosexuality is worse because it is a perversion of our natural sexual functions.

Paul's choice of words gives further indication that Paul was not simply warning against violating one's sexual orientation. Joe Dallas noted that when Paul

refers to "men" and "women" in these verses, he chooses the Greek words that most emphasize biology: arsenes and theleias. Both words are rarely used in the New Testament. When they do appear, they appear in verses meant to emphasize the gender of the subject, as in a male child (arsenes). In this context, Paul is very pointedly saying the homosexual behavior committed by these people was unnatural to them as males and females (arsenes and theleias). He is not considering any such thing as sexual orientation. He is saying, in other words, that homosexuality is biologically unnatural-not just unnatural to heterosexuals, but unnatural to anyone.10

Some claim Paul was only condemning homosexual behavior associated with idolatrous worship. For example, Troy Perry writes, "The homosexual practices cited in Romans 1:24- 27 were believed to result from idolatry and are associated with some very serious offenses as noted in Romans 1. Taken in this larger context, it should be obvious that such acts are significantly different than loving, responsible lesbian and gay relationships seen today."11 This approach to interpreting the text fails for the same reason it failed in Leviticus. Paul's comments on homosexuality appear in a long list of sins, all intended to highlight just how deep-seated man's rebellion against God truly is. Such sins include envy, murder, strife, deceit, hostility, gossip, slander, arrogance, and disobedience to parents. Are we to believe that Paul was only condemning such practices when they are associated with idolatry? Are we to believe that these are morally acceptable so long as they are not associated with idolatrous worship? Of course not. Then there is no reason to single out one of Paul's condemnations-homosexuality-and claim that this and this alone was condemned only when in association with idolatrous worship. This "interpretation" adds to the text what is not there, and violates the obvious sense of the passage in the process. It is clear that Paul was making a blanket condemnation of homosexual behavior. The context makes it impossible to view this passage in any positive light. Pro-homosexual interpreters are forced to add words and footnotes to Paul's teaching to make it conform to their agenda.

1 Corinthians 6:9-10

"Do you not know that the unrighteous will not inherit the kingdom of God? Do not be deceived! The sexually immoral, idolaters, adulterers, passive homosexual partners (malakoi), practicing homosexuals (arsenokoitai), thieves, the greedy, drunkards, the verbally abusive, and swindlers will not inherit the kingdom of God." (NET Bible)

The Greek word malakos appears only here and in 1 Timothy 1:10 in the NT.  In both passages the word appears in a “vice list.”  The lack of a narrative context makes it difficult to accurately define the word.  Malakos appear many times, however, in extra-biblical literature.  It is fairly clear that the basic meaning of the word is “softness,” or “effeminate.”  The word is used in both a positive and negative manner.  Positively, it is used of expensive clothes, gourmet food, and even the wind.  Negatively, it is used as a moral condemnation against laziness, cowardice, luxury, and of men who study too much!  In essence, it refers to all things feminine.  When used of males in a sexual context, it has a broad range of meaning.  It can be used of males who—like females—are penetrated by other men.  It is also used to refer to heterosexual men who pretty themselves up to attract women (i.e. a “pretty boy”), of men who fall in love with women, and of men who have sex with many women.12  Dale Martin writes:

In Greco-Roman culture, it seems generally to have been assumed that both men and women would be attracted to a pretty-boy. And boys who worked to make themselves more attractive, whether they were crying to attract men or women, were called effeminate. An old hag in a play by Aristophanes drags off a young man, saying, “Come along, my little softie” (malakion), although she has perfectly heterosexual things in mind (Ecclesiazusae 1058). The Roman playwright Plautus uses the Latin transliteration malacus to indicate effeminate men. But whereas in one comedy the term is cinaedus malacus, referring to a penetrated man, in another it is moechus malacus, referring to a man who seduces other men's wives (Miles Gloriosus 3.1 [1.668]; Truculentus2.7.49 [1.610]).
In the ancient world, effeminacy was implicated in heterosexual sex as much as homosexual — or more so. … Chariton in his novel Chaereas and Callirhoe provides a typical portrait of an effeminate man (1.4.9): he has a fresh hairdo, scented with perfume; he wears eye makeup, a soft (malakon) mantle, and light, swishy slippers; his fingers glisten with rings. Only a modem audience would find it strange that he is off to seduce not a man but a maiden.  When the author of the Pseudo-Aristotelian Physiognomy wants to portray the "Charitable Type" of man, he makes him typically effeminate-and very hetero-sexual. Such men, he says, are delicate, pale, with shining eyes and wrinkled noses; they cry a lot, are "reminiscent," warmhearted, and with nice dispositions. They are particularly fond of women, with whom they have lots of sex, and they tend to produce female children (808a34).13

Malakos, then, refers to soft, effeminate males.  Whether Paul has in mind men who are penetrated by other men is difficult to say given the lack of context, but it remains a viable option given what we know about Paul’s teaching on the topic elsewhere.

What about arsenokoites?  This word is a hapax legomenon, meaning it only occurs once in the New Testament.  Scholars are divided over its meaning.  Most scholars think the term was coined from the LXX translation of Leviticus 18:22 and 20:13, both of which use the words arsen (male) and koite (bed) to describe male homosex.  Some scholars, however, aren’t so sure.  While they agree that it probably involves the notion of sex, they think it refers to sexual exploitation (whether it be rape, pimping, or prostitution, and whether it be male or female) for economic gain.  One of the lines of evidence used to support this meaning is the extra-biblical contexts in which arsenokoites appears.  Like the New Testament, the word usually appears in vice lists.  Vice lists tended to be grouped into categories.  The author might first condemn a number of sexual vices such as adultery and rape, then move on to economic vices such as theft and extortion, and then vices of violence such as brawling. 

In several non-biblical texts arsenokoites does not appear in the group/context of sexual vices, but in the group/context of economic injustices and exploitation.  It is reasoned that if arsenokoites only referred to homosex, it should appear in lists condemning sexual sin.  The fact that it doesn’t, and that appears in lists of economic vices, suggests that what is being condemned is some kind of sexual exploitation, not homosex among consenting individuals.

Where does arsenokoites appear in Paul’s vice lists?  In 1 Corinthians 6:9 it is preceded by the sexual vices of sexual immorality, idolatry (does not fit the general grouping), adultery, and malakos, and it is followed by the economic vices of stealing, greed, drunkenness (does not fit the general grouping), verbal abusers (does not fit the general grouping), and swindlers.  Since it is immediately preceded and followed by two different groupings of vices, it is not possible to determine whether it should be grouped with the sexual sins that come before it, or the economic sins that follow it.  The situation in 1 Timothy 1:10 is similar.  Arsenokoites is preceded by sexual immorality and followed by kidnappers.  Which type of vice should it be grouped with?  The evidence based on its location in NT vice lists is indeterminate.

There are at least a couple of non-biblical texts, however, in which we are provided with a narrative context.  In these texts arsenokoites appears to refer to homosex without any reference to economic exploitation.  It is very likely, then, that the word had multiple uses depending on the context.  The question is, How was Paul using the term?  It is impossible to provide a definitive answer to this question.  The juxtaposition of arsenokoites and malakos, however,may reveal Paul’s intent to condemn any and all homosexual behavior, tipping the scale in favor of the translation offered above.  If Paul wanted to refer to both active and passive homosex, he could not have chosen better words to do so.

If Paul is referring to homosex by either his use of malakos or arsenokoites, verse 11 is instructive regarding the argument that God made people with a homosexual orientation, and thus they need not (or cannot) change their sexual behavior: “And such were some of you, but you were washed, you were sanctified, you were justified in the name of the Lord Jesus Christ and by the Spirit of our God.”  A homosexual orientation is not from God.  For those who have developed a homosexual orientation, not only are they required to abstain from homosex, but they are given the power to do so in Christ.

1 Timothy 1:9-10

"Realizing the fact that law is not made for a righteous man, but for those who are lawless and rebellious, for the ungodly and sinners, for the unholy and profane, for those who kill their fathers or mothers, for murderers 10 and immoral men and homosexuals (arsenokoitais) and kidnappers and liars and perjurers, and whatever else is contrary to sound teaching" (NASB)

As in 1 Corinthians 6:9, Paul speaks of arsenokoitais.  If Paul is using this word to refer to sex between males, then we have a clear condemnation of homosex as being “contrary to sound teaching.”

Jude 6-7 and 2 Peter 2:6-10

"You also know that the angels who did not keep within their proper domain but abandoned their own place of residence, he has kept in eternal chains in utter darkness, locked up for the judgment of the great Day. Even as Sodom and Gomorrah, and the cities about them in like manner, giving themselves over to fornication, and going after strange flesh, are set forth for an example, suffering the vengeance of eternal fire."

"And if He condemned the cities of Sodom and Gomorrah to destruction by reducing them to ashes, having made them an example to those who would live ungodly thereafter; 7 and if He rescued righteous Lot, oppressed by the sensual conduct of unprincipled men 8 (for by what he saw and heard that righteous man, while living among them, felt his righteous soul tormented day after day with their lawless deeds), 9 then the Lord knows how to rescue the godly from temptation, and to keep the unrighteous under punishment for the day of judgment, 10 and especially those who indulge the flesh in its corrupt desires and despise authority. Daring, self-willed, they do not tremble when they revile angelic majesties."
(NET Bible)

What interpretation can make sense of Jude and Peter's reference to immorality and going after strange flesh? Some have suggested that Jude's reference to "strange flesh" is a reference to sex with angels. According to this view the sin of Sodom was not that they wanted to have sex with someone of the same sex, but that they wanted to have sex with angels. This interpretation will not work because the men of Sodom did not know the two visitors were angels. They knew them as men. Besides, the judgment of Sodom was determined prior to the angels arriving; therefore, their attempt to have sex with the angels could not have been the cause of their destruction.


If the Bible only condemned homosexual behavior one time pro-homosexual advocates might be able to claim that the passage had simply been mistranslated or taken out of context, but when you have at least six clear passages condemning homosexuality between both the Old and New Testaments, and over two millennia of Jewish and Christian interpreters who consistently translated and interpreted the passages as condemning homosexual behavior, the cards are stacked against the pro-homosexual camp. While one may choose to believe homosexuality is normal and morally acceptable they do not have the liberty to alter the clear teaching of the Bible. Dismiss it if you will, or call it outdated, but do not change its message to fit your own beliefs. Let's be clear on what the Bible teaches concerning homosexuality: homosexuality is a sexual perversion that is contrary to the way God designed us to function sexually.


Related Articles:

"I Now Pronounce You Man and Man?": An Argument Against Same-Sex Marriage
What is the Definition of the "Definition" of Marriage?
Marriage by Any Other Name is Still Marriage
Arguing Against Homosexuality: A Response to Challenges From a University of California Professor
Dialogue With a Homosexual
What Single-Parenting Can Tell Us About Same-Sex Parenting
Arguing Against Homosexuality
The Same-Sex Marriage Debate: Who Has the Burden of Proof?


1. Barna Research Group, "Americans Draw Theological Beliefs from Diverse Points of View", poll 10-08-02; available from http://www.barna.org/FlexPage.aspx?Page=BarnaUpdate&BarnaUpdateID=122; Internet; accessed 11 May 2003.
2. Albert Mohler, "Homosexuality and the Bible: Telling the Truth"; available from http://www.crosswalk.com/news/weblogs/mohler/?adate=4/22/2004#1258637; Internet; accessed 19 November 2004.
3. Greg Koukl, Setting the Record Straight: The Bible and Homosexuality, audiotape of lecture from Stand to Reason ministries; date unknown, available from http://www.str.org/cgi-bin/shop.pl/task=search/subject=Homosexuality/SID=PUT_SID_HERE.
4. Craig Blomberg, "What the Bible Really Says About Sex," quoted in Matt Kaufman, "Selling Homosexuality"; available from http://www.leaderu.com/socialsciences/sellinghomosexuality.html; Internet; accessed 29 April 2004.
5. John Boswell, Christianity, Social Tolerance and Homosexuality (Chicago: University of Chicago Press, 1980), 109.
6. Virginia Mollenkott, Is the Homosexual My Neighbor? (San Francisco: Harper Collins, 1978), 65-66.
7. Greg Koukl, "Romans 1 on Homosexuality"; available from http://www.str.org/free/studies/homorom1.htm; Internet; accessed 12 November 2003.
8. Greg Koukl, Setting the Record Straight: The Bible and Homosexuality, audiotape of lecture from Stand to Reason ministries; date unknown, available from http://www.str.org/cgi-bin/shop.pl/task=search/subject=Homosexuality/SID=PUT_SID_HERE.
9. Ibid.
10. Joe Dallas, "Responding to Pro-Gay Theology"; available from http://www.nationalcoalition.org/culture/articles/ga030915.html; Internet; accessed 24 November 2004.
11. Troy Perry, Don't Be Afraid Anymore (New York: St. Martin's Press, 1990), 342.
12. Dale Martin, “Arsenokoités and Malakos: Meanings and Consequences”; available from http://www.clgs.org/arsenokoit%C3%A9s-and-malakos-meanings-and-consequences; Internet; accessed 23 April 2010.
13. Ibid.

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