|On-line resources from the
American Studies Resources Centre at LJMU
Who Wants to Be a Millionaire:
by Matthew Warshauer
Traditionally, Americans have sought to realise the American dream of success, fame and wealth through thrift and hard work. However, the industrialisation of the 19th and 20th centuries began to erode the dream, replacing it with a philosophy of "get rich quick". A variety of seductive but elusive strategies have evolved, and today the three leading ways to instant wealth are large-prize television game shows, big-jackpot state lotteries and compensation lawsuits. In this article, Matthew Warshauer, Professor of History at Central Connecticut State University, examines why so many Americans are persuaded to seek these easy ways to their dream.
to riches the traditional way: through thrift and hard work
Who wants to be a millionaire?
How does one achieve the American Dream? The answer undoubtedly depends upon one’s definition of the Dream, and there are many from which to choose. John Winthrop envisioned a religious paradise in a "City upon a Hill." Martin Luther King, Jr. dreamed of racial equality.  Both men yearned for what they perceived as perfection. Scholars have recognized widely varying conceptions of these quests for American excellence. One component of the American Dream seems, however, to be fairly consistent: the quest for money. Few will deny that Americans are intently focused on the “almighty dollar.” In a society dedicated to capitalism and the maxim that, “the one who dies with the most toys wins,” the ability to purchase a big house and a nice car separates those who are considered successful from those who are not. Yet the question remains, how does one achieve this success? How is the Dream realized? For many Americans the formula is one of instant, albeit elusive, gratification. Rather than adhering to a traditional work ethic, far too many Americans are pinning their hopes on what they perceive as “easy” money. This article focuses on three phenomena in contemporary American society that have successfully captured the quest for the American Dream. Savvy marketers have convinced their audiences that a new wave of television game shows, lottery luck, and lucrative lawsuits are the way to wealth.
|Rags to riches the traditional way: through thrift and hard work||
Instant wealth has not always been a major component of the Dream. Americans have traditionally centered their efforts on thrift and hard work. During the Colonial Period, Benjamin Franklin counseled people on the "The Way to Wealth." Poor Richard's Almanac advised that "Early to Bed, and early to rise, makes a Man healthy, wealthy, and wise." The key to wealth was industry: "Industry pays debts," insisted Poor Richard. Americans of the Early Republic expanded Franklin's notion of industry into a labor ideology. For many the goal was not extravagant wealth, but, rather, economic independence and the opportunity for social advancement through financial gain. Abraham Lincoln insisted that the greatness of the American North was that industry allowed all men to prosper: "The prudent, penniless beginner in the world, labors for wages awhile, saves a surplus with which to buy tools or land, for himself; then labors on his own account another while, and at length hires another new beginner to help him. This…is free labor--the just and generous, and prosperous system, which opens the way for all."
In the midst of industrialization following the Civil War, many Americans experienced profound hardship in the changing economic landscape. They found solace in the tales of Horatio Alger, whose characters overcame adversity through industry, perseverance, self-reliance, and self-discipline. The ubiquitous "rags to riches" legend became a cornerstone of American society; anyone could succeed and achieve wealth if they worked hard. The commitment to industry illustrated by Alger's characters, Lincoln's ideals of free labor, and Franklin's practical maxims were further solidified in the American mind by the addition of a religiously based, Protestant "work ethic." Many believed that hard work allowed one to not only achieve financial success, but, through that success, revealed God's grace.
Numerous scholars note that the shift away from the traditional American work ethic corresponded directly with the rise of industry. Work values changed dramatically when the assembly line production and machine driven atmosphere of industrial America swallowed up skilled workers. The aftermath of World War II exacerbated the ethical shift as a consumer culture blossomed and Americans became preoccupied with material goods. As one critic noted, “consumed by desires for status, material goods, and acceptance, Americans apparently had lost the sense of individuality, thrift, hard work, and craftsmanship that had characterized the nation.”
The result of this shift in work ethic has actually spurred rather than lessened the people’s desire to achieve the American Dream. Yet the real difference is that the Dream has become more of an entitlement than something to work towards. Many Americans no longer entertain a vision for the future that includes time, sweat, and ultimate success. Rather, they covet the shortcut to wealth. Many who are engaged in work view it more as a necessary evil until striking it rich. This idea has been perpetuated by a massive marketing effort that legitimizes the message that wealth can be obtained quickly and easily. Whether through the television entertainment industry, state-based lottery marketing drives, or legal advertisements, Americans are told again and again that the road to the financial success of the American Dream is more a matter of luck than hard work.
|Who wants to be a millionaire?||
Little reveals the shift in the quest for the American Dream more than the insanely popular television game show, "Who Wants To Be A Millionaire," hosted by Regis Philbin. With an average two hundred and forty thousand people per calling in on "Contest Day" attempting to become contestants, and a twenty-nine million per show viewing audience, it is safe to say that Americans are captivated by what many consider to be an easy avenue to achieving financial success. The fact that “Millionaire” was originally a British television show merely emphasizes the extent to which the quest for cash transcends national borders. It is no surprise, however, that the show achieved its greatest success in America. The very title of the show capitalizes on the core of the America Dream: wads of cash. The question, "Who Wants to Be a Millionaire?" is a no-brainer. The American desire to be rich is at the very heart of our nation’s capitalist economy. The show's producers have simply tapped into a value already prevalent in today's society. In doing so, the show has become both a reflection of and a catalyst to greed and materialism.
What sets apart "Who Wants to Be a Millionaire" from game shows of the past is the sheer amount that a contestant can win, combined with what at times seem to be amazingly easy questions. Five players achieved the $1,000,000 mark in 2000, and thus far two more have won the top prize in 2001. Dozens have won upwards of $500,000. In addition to the high rewards, "Who Wants to Be a Millionaire" is successful because the average viewers see themselves as potential winners. One does not need to be a "Jeopardy" brainiac to answer what word was spelled backwards on the mirror in the movie "The Shining." It was "murder" of course. Or, even more simple, what do the rings on the inner part of a tree signify?
The large jackpots and relative ease of "Who Wants to Be a Millionaire" is what places it in the realm of the American Dream. Game shows of the past generally provided new appliances, trips, or cash winnings in the tens of thousands. This new breed of big money game show fits the Dream because it capitalizes both on the psychology and spectacle of being a "millionaire," as well as the idea that anyone can achieve this success. The latter fits directly into the tradition that all individuals who are willing to work hard can achieve financial reward.
The irony of the actual title, "millionaire," is that the show's grand prize is not really enough to achieve the American Dream of total financial independence. After taxes there is still a tidy sum, but it will have to be used wisely and invested to see a person all the way through retirement. Being a millionaire today reminds one of the Austin Powers movie in which the arch villain Dr. Evil holds the world hostage and demands "one million dollars," only to be told that this is a paltry amount in today's economy. He quickly corrects the figure to "one hundred billion dollars."
If the amount won on "Who Wants to Be a Millionaire" does not really meet the perceptions of the American Dream, the means of achieving the money are even more questionable. Where, one might ask, are the work ethic and industry inherent to the traditional conception of the Dream? Some might argue that it takes a degree of intellect and knowledge to win the game, thus some work, that needed to gain knowledge, does exist. Yet such an argument is inherently weak because of the safeguards in the game, as well as the many instances of chance in advancing to the final round. In the course of play, every contestant has three "lifelines" designed as an aid in choosing the correct multiple-choice answer. The player can choose "Fifty-Fifty," in which the computer eliminates two incorrect responses, leaving only two possible answers; "Ask the Audience" allows the player to quiz the studio audience for the most likely correct answer; "Phone a Friend" enables the player to telephone one of five pre-arranged contacts who help to determine the correct response. All of these devices take the weight of knowledge off the contestant, and thus provide a real degree of luck. It certainly does not come close to the level of knowledge one must amass in order to compete in a show like "Jeopardy," on which there are no multiple choice questions and a contestant is on his or her own. Moreover, there exists a great deal of chance to even make it into the final round.
"Who Wants to Be a Millionaire's" success is directly related to the belief that anyone with a little knowledge and lot of luck can be a millionaire. Such a message resonates with the mass of people specifically because it seems to make the American Dream so easily accessible. In the process, the most basic, traditional means of achieving the Dream, industry, has been eradicated. Poor Richard's counsel to engage in "industry" is unnecessary in such a schema. Nowhere in Franklin's writings did it say, "early to bed, early to rise, hope for some luck and you might win a prize."
The success of "Who Wants to Be a Millionaire's" ability to capitalize on the American Dream has spawned a series of copycat shows. "Greed," Twenty-one," and, perhaps most interestingly, "Who Wants to Marry a MultiMillionaire," have utilized the same basic, capitalist American urge for hoards of money. The theme of the latter show is especially amazing. On February 15, 2000, Rick Rockwell, an independent real estate investor, picked from among fifty female contestants who agreed to actually marry a "multimillionaire" if chosen. This Fox Television "epiphany" was the brainchild of executive Mike Darnell who stated that, "the money is a cutesy motivational factor. I think mostly people are looking for a relationship." The show's "winner," an emergency room nurse named Darva Conger, claimed that neither was her goal. She simply wanted a free getaway to Las Vegas, where the show was broadcast, and to "be on TV and wave to my family and friends." "It was just a lark," insisted Conger, I "was just in complete shock" when I won. When Matt Lauer of the Today Show pressed her, insisting that money must have been a major factor in participating on the show, Conger claimed it was not, even though she walked away with a free Caribbean honeymoon, a $35,000 engagement ring, and an Isuzu Trooper. The prizes totaled some $100,000. Even though Conger has vehemently denied charges that money was a key motivation, and had her marriage with Rockwell annulled, she has since posed for Playboy Magazine and earned what some report is upwards of $400,000.
Whatever Conger's motivation, it is abundantly clear that many women jumped at the opportunity to achieve the American Dream through a quickie marriage on a nationally broadcast show. Following the initial airing of "Who Wants to Marry a Multimillionaire," the Fox web site crashed after it was flooded with requests from women to participate on a subsequent episode. Still, the show's rating success of 23 million viewers was greeted with disdain by critics who charged that "the Fox program was dedicated to the proposition that people will do anything for money, that, in fact, money is everything…." Some suggested that the show actually change its name to "People Will Do Anything for Money," or "America's Funniest Prostitutes."
Many viewers surely tuned into "Who Wants to Marry a Multimillionaire" simply because of the novelty. The fact remains, however, that Fox executives consciously capitalized on the quest for the American Dream. They utilized the same strategy as "Who Wants to Be a Millionaire," offering a huge cash prize that had both psychological and spectacle appeal. The contestants also played their part in the Dream quest. Certain prizes were guaranteed, and the possibility of hitting the jackpot was a very alluring 1 in 50. Contestants needed only a pretty face and a voluptuous body. Like Regis Philbin's show, the traditional means of achieving financial success, through industry, was eliminated.
"Who Wants to Be a Millionaire" and similar game shows are only the latest craze in capitalizing on the American Dream. Even more well known, and often more lucrative are state run lotteries. All one needs is "A Buck and a Dream," boasts the New York Lottery. Just as in the game shows, the lottery focuses on the hope of easy money with minimal effort. One does not need to work hard in order to choose a series of numbers. In the lottery scenario, one works for a living only until they hit that big Lotto or Powerball score. The Illinois Lottery's advertisement in a Chicago ghetto encouraged, "This could be your ticket out."
Whereas the payoffs for the big jackpot lotteries are significantly higher than the "Millionaire" games, a May 2000 Powerball game reached 350 million, the odds of winning are equally long. With an average 1 in 12 to 14 million chance of winning, and 1 in 80 million for the big prizes, the degree of luck needed is astronomical. Still, Americans flock to the lottery when the possibility of scoring big is most remote. In 1998, a 300 million dollar jackpot caused thousands of New Yorkers to flood across Connecticut state lines. Greenwich, Connecticut stores had lines 500 people long waiting upwards of 6 hours to purchase tickets. Forced to deal with traffic gridlock and disorderly conduct, the town was forced to spend some $80,000 for police and other emergency services. During the same Powerball drawing, the New Hampshire Lottery executive director held a press conference requesting people not to spend beyond their limits. Notwithstanding such warnings, one man admitted dishing out $3,000 for tickets.
The Powerball and Lotto frenzy is easy to explain: most everyone believes in the American Dream. And though the majority will admit that winning is a long shot, they nevertheless fantasize about the possibility. Having that kernel of hope is part of the
Dream. It is the state lotteries' ability to capitalize on this fantasy that makes them so successful. Operating in 37 states and the District of Columbia, lotteries sales for 1996 totaled 42.9 billion dollars, 38% of which was net revenue, making lotteries by far the most profitable form of gambling. Most gambling venues pay back about 90% of what they take in, whereas lotteries pay out only about 50%.
Yet lotteries have been around for literally hundreds of years. America was created with their help. In 1612, the British crown authorized the Virginia Company of London to hold a lottery to aid the Jamestown colony. During the colonial period and after, Americans held lotteries to raise funds for internal improvements and defense. Thus how are the lotteries today different and why do they influence the traditional meaning of the American Dream?
The simple answer is advertising. State lotteries have learned the importance of effective, comprehensive marketing. Up until 1975 the federal government prohibited states from advertising, but since the ban was lifted lotteries have developed sophisticated, targeted promotions. In 1997 they spent 400 million dollars marketing the various Lotto and instant games, an amount that doubled the percentage spent on advertising by most corporations. Yet it is not merely the sheer scope of the advertising, but, rather, its effectiveness. Many critics argue that lotteries target poor groups who are least economically able to cope with the expense. In doing so, states are capitalizing on those who are perhaps most in need of realizing the American Dream. The Ohio SuperLotto game, for example, suggested in its advertising plan that "promotional 'pushes' be targeted as early as possible in the month. Government benefits, payroll and Social Security payments are released in the first Tuesday of each calendar month. This, in effect, creates millions of additional, non-taxable dollars in the local economies of which the majority is disposable."
The Illinois Lottery engaged in an equally calculated strategy to entice an economically depressed neighborhood in west Chicago. Renting space on 40 billboards, the state promised, "How to get from Washington Boulevard to Easy Street." The advertisement's implicit "rags to riches" message played on the most core aspect of the American Dream. And studies show that such promotions work. The poor spend a larger percentage of their income on lottery tickets than the more affluent.
Just as significant, the lotteries purposely mislead players about their chance of striking it rich. One study found that 70% of television advertisements portrayed people winning. Moreover, the study noted that states purposely disguised the odds and, in fact, gave the impression that there existed a good chance of winning. Even some government officials have grown concerned about such tactics. In 1997, New York Governor George Pataki requested lottery officials to "tone down" their, "Hey, you never know" promotion, and added that lottery marketing should avoid "raising unrealistic expectations." One might ask, is there no law to stop such deceptive commercials? Of course, the Federal Trade Commission has "truth-in-advertising" standards. Yet because lotteries are state entities they are not bound by the same requirements to which private businesses must comply.
Thus lotteries are free to spend hundreds of millions on what is often disingenuous advertising specifically designed to manipulate people's quest for the American Dream. As one author noted, "the lottery, it is said, exploits people's yearnings for a better life, offering them a sucker bet wrapped in promotional hype." Another writer criticized that, "our government shamelessly panders to dreams. They advise people, many of them poor, that the lottery is a good way to get money….If there ever was a get-rich-quick scam, this is it - perpetrated by government."
Similar to the "Millionaire" game shows, one of the key components to realizing the American Dream is luck. Once again, Americans are sent a message that success can be achieved, not through industry, but, rather, via chance. Nor have critics of the lotteries missed this phenomenon. Michael Sandel insisted that lotteries send "a message at odds with the ethic of work, sacrifice and moral responsibility…." Instead, people are told that "with a little luck they can escape the world of work to which misfortune consigns them." Another critic agreed, arguing that, "in short, lotteries may undercut the ethic of work and achievement, replacing it with an ethic of luck."
Yet lotteries, in fact, do even more. They play both on the ethic of luck and attempt to fool one into believing that there is something more than luck -- that skill is a component of winning. The National Gambling Impact Study Commission noted that lottery advertising specifically sought to persuade players that they could "influence their odds through the choices of numbers they pick." Moreover, there are a plethora of books that promise to teach the would-be lottery winner: Found Money: How to Consciously Win the Lottery; The Basics of Winning Lotto-Lottery; How to Win: More Strategies for Increasing a Lottery Win. The implication is that through hard work one can develop the skill necessary to win the lottery, and thus the American Dream.
With such a message one might argue that the American Dream is alive and well, that its integrity has been maintained. Industry, Ben Franklin's traditional ingredient, is realized through calculation and superior planning. Nothing, however, could be further from the truth. The lottery is unquestionably random. One needs only a buck, a dream, and unimaginable luck. Thus, like the "Millionaire" game shows, state lotteries, through carefully targeted advertising, have played upon and drastically altered the customary conception of the American Dream.
If game shows and lotteries have seemingly opened a path to fulfilling the American Dream, so too has the proverbial "million dollar injury." Litigation is as American as apple pie, though it does not leave so sweet a taste in the mouth of most Americans. Indeed, many view the legal profession with disdain, especially personal injury lawyers whose ubiquitous "have you been involved in an accident? You may be entitled to compensation" advertisements encourage the public to believe that easy money can be had. Such "ambulance chasers" have spawned hundreds of lawyer jokes. "What's a million lawyers at the bottom of the Sea? A good start." Such humor, though laughed off in passing, says something about the legal profession in the eyes of the public. Still, Americans file tens of thousands of law suits each year, many in the hopes of cashing in on a personal injury or product liability case. Some scholars have likened such strategies to playing the lottery:
The operation of the tort system is akin to a lottery. Most crucial criteria for payment are largely controlled by chance:(1)whether one is lucky" enough to be injured by someone whose product or conduct can be proved faulty; (2) whether the party's insurance limits or assets are sufficient to promise an award or settlement commensurate with losses and expenses; whether one's own innocence of faulty conduct can be proved; and (4) whether one has the good fortune to retain a lawyer who can exploit all the variables before an impressionable jury, including graphically portraying whatever pain one has suffered.
Equating such a scenario to achieving the American Dream may be viewed as extremely strange at best. Yet the similarity between game shows, lotteries, and tort litigation is not as farfetched as one might think. In all three situations the desired end is a trip to the bank with a fat check. In recent years a number of court cases have resulted in just such an outcome. If a plaintiff wins a lawsuit he will most likely receive not only compensatory damages (those that reimburse for medical expenses, lost wages, etc.), but may also be awarded punitive damages (those that punish the defendant for negligent or dangerous behavior). Moreover, in order to send a message to the offending company jury awards for punitive damages often far exceed compensatory damages.
Heading off such suits with the use of video, however, is hardly the
norm. There are undoubtedly thousands of cases in which plaintiffs fake
injury and symptoms in order to reap financial reward. The difficulty in
assessing this problem is the lack of dependable information on the subject. As
one legal scholar notes, "we know remarkably little about frivolous
litigation. Reliable empirical data is extremely limited, and casual
anecdotal evidence highly unreliable. We have no clear explanation of why
frivolous suits are filed or even common agreement on what constitutes a
When a 46 year old Korean immigrant was electrocuted by the "L" train line in Chicago his family sued and won $3 million in damages. Such an award may not seem outlandish if Mr. Lee had simply stepped onto a faulty rail line or bumped into an exposed wire. Instead, he walked home from a party with a blood alcohol level three times the legal limit, decided to walk past three signs that stated "Danger," "Keep Out," "Electric Current," then proceeded to urinate on a live rail line. He was electrocuted instantly. For contributory negligence the $3 million reward was cut in half.
In Hanover Park, Illinois an unlicensed Thomas Redlin, after having been drinking, borrowed a friend's motorcycle and ultimately crashed into an unmarked median strip. He was paralyzed from the waist down and sued the town for failing to notify drivers of the median. His $6.75 million award was lessened by 10% because of contributory negligence.
In both Illinois cases huge cash settlements provided either the family or the injured party with financial freedom; the goal of the American Dream. Assuredly, the parties in the two cases would most likely prefer to have their health intact rather than the money. Thus we are again faced with the "strange" factor in the litigant's quest for the American Dream. Neither of these gentlemen awoke in the morning and decided that today will be the day that leads me to financial success. In the case of game shows and lotteries, participants are actively pursuing the Dream from the start. For most, the lawsuit "lottery" is a decidedly reactionary strategy. It is also one that often divorces the injured party from taking responsibility for their own actions, something that is a chief complaint among opponents of such lawsuits. Why, they argue, should someone else have to pay when an individual's conduct is clearly negligent and dangerous?
The failure to take responsibility is another element that ties tort litigation to changing conceptions of the American Dream. The accident victim who causes their own injury but expects someone else to pay is very similar to the individual who believes that financial success is owed to them regardless of their lack of work ethic. In both cases, neither party accepts responsibility for their situation. Instead, they maintain a sense of entitlement that justifies their belief.
Connected to the twin problems of failure to take responsibility and harboring a sense of entitlement is the encouragement of others to engage in the same conduct. When an injured party who is clearly responsible for their own predicament, such as both Illinois cases, files a lawsuit and wins, there can be little doubt that it contributes to a litigious environment in which others look to the legal system to get their piece of the financial pie. The end result is a society that is ready to sue on almost any provocation. And the goal is always the same: money. Not all lawsuits result in million dollar awards, but they still provide significant cash incentives for seemingly innocuous incidents. The 1998 American Bar Association Journal reported amounts won in "The Torts of Summer." Slipping on algae in a swimming pool gained one Florida resident $41,000. Getting hit by a softball during warm-ups in the same state provided another individual with $52,000. A collision in a splash pool at a New Jersey water park resulted in a reward of $130,000. Burns from hot coals at a public beach in California granted the victim $435,000.
Equally unbelievable is the Miami, Florida woman who collected $250,000 after binging on cocaine and alcohol, then splashing herself with alcohol, was burned when she attempted to light a barbecue. Or the San Francisco mugger who was awarded $24,595 after being injured when the cab driver he was attempting to rob pinned his leg to a wall until the police arrived. The list goes on and on.
These seemingly "frivolous" lawsuits have initiated a major push for tort reform. State legislatures have responded with a variety of measures: caps on punitive damages, abolishment of punitive damages if a product complied with state or federal regulations, requiring plaintiffs to waive all rights of medical confidentiality in cases involving injury, proposals for the losers in tort cases to pay court costs. The Federal Government has also taken up the tort reform banner. Legislation concerning product liability has been introduced in Congress, and failed, each year since 1983. In 1996, Newt Gingrich made it a staple of the Republican Party's "Contract With America." The reason for such action on the part of the nation's legislators is simple: like many Americans they are tired of what one Illinois lawmaker described as "unfair, ridiculous, frivolous, silly lawsuits."
Opponents of tort reform are equally adamant in their denunciation of reform legislation, arguing that in actuality only a very small percentage of potential tort plaintiffs pursue litigation, that tort claims have not increased over the last decade and, in fact, product liability cases have declined. Moreover, they insist that reform would reduce legal protection for "at-risk" individuals such as the poor, the elderly, and the sick. What lawyer, argues opponents of reform, would take on cases that necessitate significant amounts of time, money, and labor unless they could be certain of victory?
The case that has become the poster child for both pro- and anti-tort reform advocates is the infamous McDonald's hot coffee spill in which an elderly woman was awarded $2.9 million after accidentally pouring hot coffee on to her lap and suffering a serious burn. On the surface the case looked like a quintessential example of tort litigation gone haywire. A woman takes what is known to be a hot beverage, places it between her legs in a car, and proceeds to spill the contents. For this example of utter negligence she is awarded millions. Critics of a legal system run amok had a field day, publishing headlines critical of the verdict: "Big Bucks for Dumb Luck? Coffee is Hot and Life is Full of Risks--Deal With It;" "The Legal Wheel of Fortune is Spinning Out of Control;" "A Great Year for Victims, Some of Whom Could Be Dangerous;" "Enough Already!"
America's popular culture comedians also latched on to the absurdity of the case. David Letterman included as number four on his "Top Ten List of Dr. Kevorkian's Tips for Summer," that one should take a bunch of friends to McDonald's and pour hot coffee on each other. On another show Letterman suggested that the number eight, blizzard safety tip was to clear snow off of the driveway with just one scalding hot cup of McDonald's coffee. Jerry Seinfeld even aired an episode in which Kramer filed a hot coffee lawsuit.
As a result of such commentaries, many Americans increased their distaste for what they considered an already ridiculous legal system that allowed irresponsibility to be rewarded. The flip side of the case, however, and what anti-tort reform advocates continually attempt to point out is that the verdict was in fact justified. Additionally, the verdict was ultimately overturned. Stella Liebeck, the burn victim, received only $640,000. Moreover, the facts in the case were more serious and egregious than most realized. Liebeck suffered second and third degree burns, spent a total of three weeks in the hospital, and underwent surgery for skin grafts. She first contacted McDonald's only to request $10,000 for medical bills, which they refused. Additionally, McDonalds, who served their coffee at a scalding 180 degrees, had received upwards of 700 reports of similar burn incidents, but did nothing to address the problem. Finally, the $2.3 million in punitive damages represented exactly two days of McDonald's coffee sales. The jury was attempting to send a message to the fast food giant.
The reality of the case, especially what seems like McDonald's wanton indifference to complaints that their coffee was too hot, may cause some to rethink the importance of big cash settlements in product liability cases. This is certainly the hope of anti-tort reform advocates. Reality, however, nor tort reform, are the real intent of the present article. Most Americans do not know the specifics of the McDonald's case. They have seen only that a woman was awarded millions for spilling coffee. The fact that Stella Liebeck was not on a litigious quest to fulfill the American Dream makes no difference. Her pyrrhic victory encouraged others who were more than happy to use the hot beverage spill to reap economic reward. Since Liebeck's 1994 incident a host of hot beverage lawsuits have been filed against McDonald's, Burger King, and the like. Thus the moral of the story is that a variety of people viewed the original case as a lesson plan for achieving the American Dream.
Opponents of tort reform insist that the legal system is not overburdened with personal injury and product liability cases. It is, they argue, only a handful of very publicized cases that create such a perception. And those cases are often reported out of context. The McDonald's suit is a case in point. Yet in America it is the perception that counts. One Gallup poll reported that only 41% of the public believes that lawsuits are justified "about half of the time." Other research shows that there is "a widespread impression among jurors that the civil litigation system is overburdened by claimants seeking awards in meritless cases."
The mass of Americans are not familiar with legal articles that may show such assumptions to be faulty. The seeming reality of the situation is that some litigants are getting rich as a result of their own stupidity and negligence. Their failure to take responsibility for their actions, a real sense of entitlement, and a social atmosphere that encourages lawsuits, leads them to the personally injury lawyer's doorstep. In doing so the injured begin their litigious quest for the American Dream. For the plaintiff, there is no industry, no work ethic, and no perseverance or self-reliance involved. As a result, the traditional road to the American Dream has been dashed.
The "rags to riches" legend has and continues to be a cornerstone of the American Dream. The traditional message taught that through hard work, frugality, and self-sacrifice one could achieve financial success and social mobility. Ben Franklin counseled industry, Abraham Lincoln sang the praises of the northern labor system, and Horatio Alger instilled hope in generations of Americans. All three helped to establish basic guidelines for success in a land of infinite possibility.
There are unquestionably many Americans who continue to abide by such tenets and in doing so are rewarded for their efforts. Yet there are also those who have come to believe that the American Dream's promise of riches is just that, a promise, and as such they feel entitled to instant financial success. Nor has the socio-corporate climate in America disappointed such a belief. Savvy television producers and marketing executives have latched on to the core of the American Dream. They understand that Americans are enthralled with striking it rich. Thus millionaire game shows are designed to make winning seem easy. Lotteries are marketed in such a way that one thinks they have a real shot at cashing in. The reality in both instances is that achieving the American Dream through such means is a long shot at best. Too much chance exists. Too much luck is necessary.
What is the end effect on society? Do millionaire game shows and promises of lottery millions help to further erode the ethic of work and self-reliance that once embodied the American Dream, replacing it with an ethic of luck? Or are these sources of instant gratification merely products of an ethic already lost to some Americans? Perhaps the truth lies somewhere in the middle.
The even darker side to this cultural phenomenon is how the sense of entitlement has spilled over into a lack of responsibility. The fact that so many Americans are willing to utilize litigation to cash in on the American Dream is disheartening. Failing to take responsibility for their own mistakes, plaintiffs look to the legal system to make misfortune into fortune. Again, marketing and an avalanche of advertising by personal injury lawyers helps encourage would-be injury victims. Still, the readiness of people to sue is a key social factor.
Ultimately, most Americans would like to achieve the American Dream of financial independence. Yet it is the means to achieving it that are essential to the nation's ethical foundations. It seems that many Americans covet the easy road to the Dream and in the process undercut the core values that established the Dream in the first place. Equally culpable are the big businesses that capitalize on the quest for the Dream. In an ironic sense, such businesses are fulfilling the Dream for themselves while dangling the possibility of the Dream over the heads of the public. There can be little doubt that the producers of the millionaire games shows, the state lotteries, and lawyers are getting rich on other people's yearning for the American Dream.
 Winthrop urged his listeners in a 1630 sermon to follow the Laws of God, and in doing so they would form a proper society and obtain God's grace. "…wee must Consider that wee shall be as a Citty upon a Hill, the eies of all people are upon us." John Winthrop, "A Modell of Christian Charity," in Perry Miller and Thomas H. Johnson, eds., The Puritans: A Sourcebook of Their Writings, (New York: Harper Torchbooks, 1963), 195-199. For King's vision of racial equality, see Martin Luther King, Jr., "The American Dream," Negro History Bulletin 31 (5) (1968): 10-15.
 There are far too many scholarly manifestations of the American Dream to document in one note, but listed are several categories that represent recurring themes. For purposes of space I list, at most, only four works from each category. Economics: Charles R. Geisst, Visionary Capitalism: Financial Markets and the American Dream in the Twentieth Century, (New York: Praeger, 1990); Katherine S. Newman, Declining Fortunes: The Withering of the American Dream, (New York: Basic Books, 1993); Wallace S. Peterson, Silent Depression: The Fate of the American Dream, (New York: Norton, 1994); Alice M. Rivlin, Reviving the American Dream: The Economy, the States & the Federal Government, (Washington: Brookings Institute, 1992. - Education: Larry Cuban, "American Dreams and Public Schools," Social Education 46 (6) (1982): 390-393; Roland L. Guyotte, "Liberal Education and the American Dream: Public Attitudes and the Emergence of Mass of Higher Education," (Ph.D. diss., Northwestern University, 1980); Dale Mann, "Chasing the American Dream: Jobs, Schools, and Employment Training Programs in New York State," Teachers College Record 83 (3) (1982): 341-376. - Ethnicity/Race: Carlos E. Cortes, "Ethnic Groups and the American Dream," Social Education 46 (6) (1982): 400-403; Buell G. Gallagher, "The American Dream: Hypocrisy or Hyperbole?" Crisis 82 (10) (1975): 417-421; Zina T. McGee, "Racial Equality in America: A Dream Deferred," Journal of American Ethnic History 15 (3) (1996): 52-56; Daniel S. Shiffman, "Claiming Membership: Ethnic Narratives and the American Dream," (Ph.D. diss., University of Wisconsin, 1994). - Film/Drama: James C. Curtis and Joseph J. Huthmacher, "The American Dream on Film," Film and History 3 (3) (1973): 17-19; Gerard Jones, Honey, I'm Home! Sitcoms: Selling the American Dream, (New York: Grove Weidenfeld, 1992); Kate Meyers, "John Wayne and the American Dream: The Need for Heroes in a Land With No Exit," Purview Southwest (1988): 190-197; Tom Scanlan, Family, Drama, and American Dreams, (Westport: Greenwood, 1978). - Foreign: Paul Benhamou, "Aspects of the American Dream in the French Enlightenment," Michigan Academician 11 (1) (1978): 33-38; Robert Chodos and Eric Hamovitch, Quebec and the American Dream, (Toronto: Between the Lines, 1991); Ines Murat, Napoleon and the American Dream, (Baton Rouge: Louisiana State University Press, 1981); Richard Madsen, China and the American Dream: A Moral Inquiry, (Berkeley: University of California Press, 1995). - Literature: Sally P. Harvey, Redefining the American Dream: The Novels of Willa Cather, Cranbury: Fairleigh Dickinson University Press, 1995); James B. Klee, "Hemingway and the American Dream," West Georgia College Review 4 (1) (1971): 27-31; Elizabeth Long, The American Dream and the Popular Novel, (Boston: Routledge and Kegan Paul, 1985); William Wasserstrom, The Ironies of Progress: Henry Adams and the American Dream, (Carbondale: Southern Illinois University Press, 1984). - Politics: Ray D. Dearin, "The American Dream as Depicted in Robert J. Dole's 1996 Presidential Nomination Acceptance Speech," Presidential Studies Quarterly 27 (4) (1997): 698-713; Doris Kearns Goodwin, Lyndon Johnson and the American Dream, (New York: St. Martin's, 1991); John W. Sloan, "The Reagan Presidency, Growing Inequality, and the American Dream," Policy Studies Journal 25 (3) (1997): 371-386; Tom Wicker, One of Us: Richard Nixon and the American Dream, (New York: Random House, 1991). - Religion: Robert Benne and Philip Hefner, Defining America: A Christian Critique of the American Dream, (Philadelphia: Fortress, 1974); Malcolm Bull and Kieth Lockhart, Seeking a Sanctuary: Seventh-day Adventism and the American Dream, (New York: Harper & Row, 1989); James Hudnut-Beumler, Looking for God in the Suburbs: The Religion of the American Dream and its Critics, 1945-1965, (New Brunswick: Rutgers University Press, 1994); James C. Juhnke, "One Nation Under God: Religion and the American Dream," Mennonite Life 38 (4) (1983): 23-26. - Sports: Steven A. Reiss, "Sport and the American Dream," Journal of Social History 14 (2) (1980): 295-303; George Grella, "Baseball and the American Dream," Massachusetts Review 16 (3) (1975): 550-567; Gerard A. Brandmeyer, "Baseball and the American Dream: A Conversation with Al Lopez," Tampa Bay History 3 (1) (1981): 48-73.
 Herbert Gans notes that owning a home is at the center of the “middle class dream.” See The Levittowners: Ways of Life and Politics in a New Suburban Community, (New York: Pantheon Books, 1976); Both David Halberstam and Ronald Oakley discuss the importance and proliferation of cars in twentieth century American society. See, Halberstam, The Fifties, (New York: Villard Books, 1993), 486, and Oakley, God’s Country: America in the Fifties, (New York: Debner Books, 1986), 239.
 Larzer Ziff, ed., Benjamin Franklin's Autobiography (New York: Holt, Rinehart and Winston, 1959), 216; Franklin often focused on industry as a way to wealth and success: "Drive thy Business;" "Industry need not wish;" "There are no Gains without Pains;" "At the working Man's House Hunger looks in, but dares not enter;" Diligence is the Mother of Good-luck;" "God gives all Things to Industry;" "Then plough deep, while Sluggards sleep, and you shall have Corn to sell and to keep." Ibid. For commentary on Franklin's conception of economic success and how it relates to contemporary society, see Robert Wuthnow, Poor Richard's Principle: Recovering the American Dream through the Moral Dimension of Work, Business, and Money, (Princeton: Princeton University Press, 1996).
 Abraham Lincoln, "Free Labor…Gives Hope to All," in Mario M Cuomo and Harold Holzer, eds., Lincoln on Democracy, (New York: Harper Collins, 1990), 161. See also Gabor S. Boritt, Lincoln and the Economics of the American Dream, (Memphis: Memphis State University Press, 1978). For more on free labor ideology, see Eric Foner, Free Soil, Free Labor, Free Men: The Ideology of the Republican Party Before the Civil War, (New York: Oxford University Press, 1970).
 For more on the Alger myth, see Ralph D. Gardner, Horatio Alger, or, the American Hero Era, (Mendota: Wayside Press, 1964); John W. Tebbel, From Rags to Riches: Horatio Alger and the American Dream, (New York: Macmillan, 1963); Celeste Macleod, Horatio Alger, Farewell: The End of the American Dream, (New York: Seaview Books, 1980).
 Max Weber, the German political philosopher and sociologist, is most well known for theorizing the connection between the tenets of Calvinism and the rise of capitalism. Like Benjamin Franklin, Weber focused on hard work, thrift, and self-discipline to succeed and ultimately gain wealth. Weber, however, insisted that such a work ethic also helped to quell one's anxieties regarding the Protestant concern over predestination. For many, financial success was one indication that God approved of their hard work and thus they had achieved the coveted state of grace, and subsequently a place in Heaven. See The Protestant Ethic and the Spirit of Capitalism, Talcott Parsons, translator, (London: Unwin Paperbacks, 1985). For an additional development of the Protestant Work Ethic, see R. H. Tawney, Religion and the Rise of Capitalism: A Historical Study, (New York: Harcourt, Brace and Co., 1926).
 Daniel T. Rodgers, The Work Ethic in Industrial America, 1850-1920 (Chicago: University of Chicago Press), 1974; Robert Eisenberger, Blue Monday: The Loss of the Work Ethic in America, (New York: Paragon House), 1989.
 Oakley, God’s Country: America in the Fifties, 239; David Reisman notes that Americans changed their behavior because of social pressures. They became “other-directed,” or “guided by a determination to achieve goals set by colleagues and contemporaries. See The Lonely Crowd, (New Haven: Yale University Press, 1960), 15, 22.
 Millionaire has also had great success in a variety of other countries. See Barry Bearak, “Many, Many in India Want to Be a Millionaire,” New York Times 30 August 2000.
 A player who advances to the final round, the on-air-program, is faced with fifteen multiple-choice questions. With each correct answer the contestant doubles his or her winnings, starting with $100 and ending with the jackpot, $1,000,000. All information on "Who Wants to Be A Millionaire" was taken from the television show's official website. See, "Who Wants to Be A Millionaire," <http://www.abc.go.com/primetime/millionaire/mill_home.html> (29 August 2001).
 In "Jeopardy," players answer a series of questions, in the form of a question, based on a dollar value. Higher dollar values correspond with greater difficulty in the questions. Players choose from various categories. Players receive no hints or help during the game. -- In “Millionaire,” the first step is the "Telephone Qualifying Round" in which three multi-part questions must be answered within ten seconds each. Those players who pass this round "will be in a random drawing" with other players who passed the round on the same day. If a player is chosen to advance to the second stage, he or she must answer an additional five questions on the telephone. Correct answers allow the "semifinalist" to take part in a "computerized random drawing," from which ten contestants will be flown to New York to appear on the television program. In order to actually play the game, the ten "finalists" must answer a multi-part question. The contestant who answers in the shortest amount of time plays the actual game.
 David Brauder, "Who Wants to Marry a Multimillionaire," <http://www.canoe.ca/cnewsheymartha0002/16_millionaire.html> (16 February 2000).
 Lynne Elber, Associated Press, "Multimillionaire Bride: I Made a Big Mistake," <http://www.Phillynews.com/2000.feb/23/marry23.htm> (23 February 2000).
 "Conger to Pose Nude in Playboy," <http://www.sunmedia.ca/televisionshowsw/whowantstomarrymillion.html> (10 May 2000).
 Chris Magyar, "Who Wants to Marry a Multimillionaire?" <http://www.stomptokyo.com/tvdiary/columns00/who-wants-marry-million.htm> (28 February 2000).
 David Walsh, "`Who Wants to Marry a Multimillionaire?': U.S. Television Hits Bottom, for Now," <http://www.wsws.org/articles/2000/feb2000/tele-f25.shtml> (25 February 2000); Carina Chocano, "Who Wants to Marry a Multimillionaire?" <http://www.salon.com/people/feature/2000/02/16/multimillionaire/> (16 February 2000).
 For the purposes of this study, only lotto type lotteries are considered. Instant, scratch off tickets are also a lucrative part of the state lottery business, and though they certainly employ the same easy money, instant gratification mentality, they do not promise windfall million dollar jackpots. For more on instant games, see Karrie Jacobs, "Instant Gratification for the Impulse Gambler, New York Times, (17 September 1998); Suzette Hill, "POP's A Winner for State Lotteries," Point of Purchase Magazine <http://popmag.com/archives/1299/nov99stor2.html> (November 1999).
 Michael J. Sandel, "THE HARD QUESTIONS: BAD BET State Lotteries are Shooting Craps with the Lives of the Poor," The New Republic (10 March 1997): 27.
 "Lotteries," National Gambling Impact Study Commission, <http://www.ngisc.gov/research/lotteries.html> (1999).
 Michael Ring, "The Problems with State Lotteries: Chance for Quick Fix Presents Irresistible yet Dangerous Lure for the Poor," The Tech, at <http://www-tech.mit.edu/v118/n39/ring.39c.html> (3 September 1998).
 "Lotteries," National Gambling Impact Study Commission, <http://www.ngisc.gov/research/lotteries.html> (1999); Lotteries pay out only 40 to 45 cents on every dollar wagered, whereas bookmakers pay 95.5 cents, slot machines pay 75 to 95 cents, and numbers games pay 60 to 70 cents. See Robert G. Blakely, "State Conducted Lotteries: History, Problems, and Promises," Journal of Social Issues 35 (3) (1979): 62-86; Michael J. Sandel, "THE HARD QUESTIONS: BAD BET State Lotteries are Shooting Craps with the Lives of the Poor, 27.
 Robert G. Blakely, "State Conducted Lotteries: History, Problems, and Promises," 63-66; Samuel J. Ezell, Fortune's Merry Wheel: The Lottery in America, (Harvard UP, 1960).
 "Lotteries," National Gambling Impact Study Commission, <http://www.ngisc.gov/research/lotteries.html> (1999).
 Patricia A. McQueen, "Investing in Tomorrow," International Gaming and Wagering Business (January 1998): 48; Charles T. Clotfelter and Philip J. Cook, Selling Hope: State Lotteries in America, (Harvard UP, 1989), 199-201.
 Charles T. Clotfelter and Philip J. Cook, Selling Hope: State Lotteries in America, 203; Ronald A. Reno, <http://www.family.org/cforum/hotissues/a0001276.html> (1 April 1998).
 Charles T. Clotfelter and Philip J. Cook, Selling Hope: State Lotteries in America, 241; for individual state investigations that show disparities between rich and poor purchasing, see Genevieve, Anton, "Money Bet on a Miracle," Colorado Springs Gazette Telegraph, (25 August 1996); Ford Fessenden and John Reilly, "And the Poor Get Poorer," Newsday, (4 December 1995); Carla Crowder, "N.M. Lottery Costs Rank High," Albuquerque Journal, (27 April 1997); "Lottery Claims Bigger Slice of Poor's Income," Chicago Tribune, (26 May 1995); Sheldon Shafer, "Blacks and Poor Spend More Money on Lottery, Study Says," Louisville Courier Journal, (29 June, 1994); Crystal Humphress, "Survey Shows Poor Lose More on Lottery," Dallas Morning News, (10 March 1994). -- Many critics argue that lotteries are actually a "regressive tax" because they take an increasing percentage of income as that income falls. See "Lotteries," National Gambling Impact Study Commission, <http://www.ngisc.gov/research/lotteries.html> (1999).
 Charles T. Clotfelter and Philip J. Cook, "Lotteries in the Real World," Journal of Risk and Uncertainty 4 (1991): 230-231. See also, "Lotteries," National Gambling Impact Study Commission, <http://www.ngisc.gov/research/lotteries.html> (1999).
 Douglas Martin, "Lots of Dollars Chasing a $70 Million State Lottery Dream," New York Times (31 May 1997). See also, Floyd Norris, "It's Time for Honest Ads from State Lotteries," New York Times (28 June 1999).
 Ellen Perlman, "Lotto's Little Luxuries," Governing Magazine (December 1996): 18.
 Charles T. Clotfelter and Philip J. Cook, Selling Hope: State Lotteries in America, 241.
 Julian Simon, "State Lotteries Pander to Dreams," The Cato Institute, <http://www.cato.org/dailys/4-07-97.html> (7 April 1997).
 Michael J. Sandel, "THE HARD QUESTIONS: BAD BET State Lotteries are Shooting Craps with the Lives of the Poor, 27; William H. Willimon, "Lottery Losers," The Christian Century 107 (2) (17 January 1990):48-49; At least one study questions the belief that lottery players believe more in luck than in hard work. See David B. Meinert, James R. Lumpkin, and Robert V. Reich, "Public Opinion toward State Lotteries: A Comparison of Non-Player and Player Views," Journal of Social Behavior and Personality 4 (5) (1989): 481-490.
 "Lotteries," National Gambling Impact Study Commission, <http://www.ngisc.gov/research/lotteries.html> (1999).
 Norbert Henze, How to Win: More Strategies for Increasing a Lottery Win, (A.K. Peters, 1998); Keith Ryan, Found Money: How to Consciously Win the Lottery, (Keith Ryan Publishing, 1998); Jones Staff, The Basics of Winning Lotto-Lottery, (Cardoza Publishing, 1994). See also, Steve Ledoux, How to Win Lotteries, Sweepstakes and Contests in the 21st Century, (Santa Monica Press, 1999); Rob Sanford, Infinite Financial Freedom: What to do Before and After You Win the Lottery, (Titlewaves, 1994).
 Roger Cramton, "What Do Lawyer Jokes Tell us About Lawyers and Lawyering?" Cornell Law Forum 23 (July 1996): 3-9.
 Jeffrey O'Connell, The Law Suit Lottery: Only the Lawyers Win, (Free Press, 1979), 8.
 "TLC: The Secret World of Gambling: Casino Surveillance," The Discovery Channel, see <http://tlc.discover.com/tlcpages/gambling/eyesky.html>
 Robert G. Bone, "Modeling Frivolous Suits," University of Pennsylvania Law Review 145 (January 1997): 519-597.
 Jae Boon Lee v The Chicago Transit Authority, (1992) 152 Ill 2d 432; Mark Lunney, "Letter from America: Tort Reform Illinois Style," The King's College Law Journal 8 (1997-1998): 43-68.
 Mark Lunney, "Letter from America: Tort Reform Illinois Style," 50.
 "The Torts of Summer," American Bar Association Journal 84 (July 1998): 12.
 "Step Right Up, Place Your Bets in Casino-Style Courts," USA Today, 6 March 1995.
 Ibid, 44-47; Mark Thompson, "Letting the Air Out of Tort Reform," American Bar Association Journal 83 (May 1997): 64-72; Robert H. Sand, "Tort Reform: Not Every Judge Welcomes legislative Assistance," Employee Relations Law Journal 24 (1) (Summer 1998): 139-144; 43% of states have enacted legislation limiting punitive damage awards. For a complete listing see, Craig K. Hemphill, "Screens and Mirrors; Don't Be Fooled, Get the Economic Facts Behind Tort Reform and Punitive Damages Limitations," Thurgood Marshall Law Review 23 (Fall 1997): 143-93.
 Andrew F. Popper, "A One-Term Reform Tale: Victimizing the Vulnerable," Harvard Journal on Legislation 35 (Winter 1998): 123-47.
 Grover Norquist, "Spirit of '96," Policy Review 24 (77) (1996): 24-32.
 Mark Lunney, "Letter from America: Tort Reform Illinois Style," 44.
 Mary Davis, "Mass Tort Litigation: Congress's Silent, But Deadly, Reform Effort," Tennessee Law Review 64 (3) (Spring 1997): 913-37; Deborah Rhode, "Too Much Law, Too Little Justice: Too Much Rhetoric, Too Little Reform," The Georgetown Journal of Legal Ethics 11 (4) (Summer 1998): 989-1018; see also, Mark B. Greenlee, "Kramer v. Java World: Images, Issues, and Idols in the Debate Over Tort Reform," Capital University Law Review 26 (4) (1997): 701-38.
 Andrew F. Popper, "A One-Term Reform Tale: Victimizing the Vulnerable," 124;  Mary Davis, "Mass Tort Litigation: Congress's Silent, But Deadly, Reform Effort," 929-930.
 "Big Bucks for Dumb Luck…," San Diego Union-Tribune, 25 August 1994; Rick Van Warner, "The Legal System…," Restaurant News, 12 September 1994; Dave Barry, "A Great Year for Victims…," Dallas Morning News, 1 January 1995; William Porter, "Enough Already!," Phoenix Gazette, 31 December 1994. -- As seen in, Mark B. Greenlee, "Kramer v. Java World: Images, Issues, and Idols in the Debate Over Tort Reform," 701-702, nt. 5.
 "Kevorkian Top Ten List," The Late Show With David Letterman, 29 January 1995; "Blizzard Safety Top Ten List," Ibid, 8 January 1996; "The Maestro," Seinfeld, 5 October 1995. -- As seen in , Mark B. Greenlee, "Kramer v. Java World: Images, Issues, and Idols in the Debate Over Tort Reform," 702, nt. 8, 9.
 Mark B. Greenlee, "Kramer v. Java World: Images, Issues, and Idols in the Debate Over Tort Reform," 718-724; Deborah Rhode,
 "Elderly Woman Severely Burned by Hot-Coffee Spill Sues McDonald's," Miami Herald, 20 September 1997; "McDonald's Hot Tea Suit," Pittsburgh Post-Gazette, 30 August 1997; "BK Faces Lawsuit Over Spilled Tea," Nation's Restaurant News, 19 June 1995; "Copy Cat Coffee Case," National Law Journal, 12 September 1994, A10; "McDonald's Again Sued Over Coffee," San Diego Union-Tribune, 2 May 1995; Michael McCabe, "Woman Sues Starbucks Over Hot Coffee Spill," San Francisco Chronicle, 24 January 1995.
 Robert G. Bone, "Modeling Frivolous Suits," University of Pennsylvania Law Review 145 (January 1997): 519, nt. 1.
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