IMPLEN NanoPhotometer CFR21 Software User Manual
- June 6, 2024
- IMPLEN
Table of Contents
IMPLEN NanoPhotometer CFR21 Software User Manual
OVERVIEW
The CFR21 software complies with FDA 21 CFR part 11 requirements and is an
optional software tool ideal for GxP laboratories, which require proper
electronic record keeping. It includes user management, access control,
electronic signatures, data integrity, security, and audit trail
functionality.
Note: This CFR21 Software user manual does not describe the general
functionality of the NanoPhotometer®.
The CFR21 software user manual is to be used in conjunction with the NanoPhotometer® user manual.
User Management
Individual Role Based Access Control (RBAC) provides password protected access
and control of the NanoPhotometer®.
Create multiple user accounts with different access rights which are handled
in a hierarchic structure. User role options are Administrator, Power User,
and User. Organize users into working groups to facilitate access of shared
data and stored
methods within a lab. There is also an option for increased transparency with
Four Eye Authentication. Various password settings are available within the
CFR21 Software – for example secure password and password expiration options.
Effectively improve data security and fulfill audit requirements easily with
flexible and appropriate RBAC user management solutions. All features can be
enabled or disabled on demand to meet your laboratory needs.
Electronic Signature
Measurement data can only be saved when confirmed with user ID and password by
the logged in user. All saved files include the user name/author, date and
time of saving for proper electronic records. IDS and PDF files cannot be
altered and ensure data integrity.
Audit Trail
The audit trail automatically records all actions and preference changes in an
audit log. The audit log contains a log ID, time stamp, user ID, and category
for each action. Audit trails can be printed or exported by an Administrator
for documentation purposes. Power User can read the audit trail, but are not
allowed to print or save it.
Important Compliance Information
The NPOS Software, containing the activated CFR21 Software, in conjunction with your company’s SOPs can assist you in complying with FDA 21 Part 11 requirements. Your company must ensure that all aspects of the FDA regulations are maintained. Compliance may include (but is not necessarily limited to):
- Validating your NanoPhotometer®
- Access control and proper documentation.
- Determining that the system users have the knowledge, training, and experience required to perform their assigned tasks.
- Verifying the identity of each user.
- Restricting user accounts appropriately.
- Requiring a periodic change of account passwords.
- Certifying the use of electronic records and electronic signatures to the FDA.
- Configuring the CFR21 software consistently with your intended use.
- Establishing and following conforming SOPs.
Note: For more information on complying with the FDA 21 CFR Part 11 requirements, refer to the FDA website: http://www.fda.gov.
CFR21 SOFTWARE ACTIVATION
The CFR21 software is part of the installed NPOS Software. No further
installation is necessary. Activation of the CFR21 Software is only possible
with a serial number related license file (NPOS.lic).
Note: The purchased license file for the CFR21 software is stored on the
Implen USB flash drive included in the NanoPhotometer delivery.
The CFR21 Software is available for NanoPhotometer® N120/NP80/N60/C40.
Note: The CFR21 Software is not available for NanoPhotometer® N50 and
control devices like tablets and smartphones.
ENABLING CFR21 SOFTWARE
Activation Steps:
-
Save the NPOS.lic (license file) into the root folder of a USB flash drive
-
Insert the USB flash drive into the NanoPhotometer®
-
Select Preferences / CFR21
-
Activate CFR21 toggle
Note : All existing network folder and server access entries will be deleted by this step. -
Add an Administrator account (see page 8 Add Account)
Note : It is necessary to add at least one Administrator account otherwise the CFR21 Software is not activated.
Note : Please keep a copy of your Admin password for your records. For security purposes, Admin passwords cannot be recovered. Should you lose your Admin login details, you will need to contact the Implen Support team (support@implen.de) for assistance with password reset.
DEACTIVATION CFR21 SOFTWARE
For deactivation of the CFR21 Software deactivate the CFR21 toggle switch in Preferences/CFR21. This step will perform a factory reset of the Nano Photometer® Save all data before deactivation of the CFR21 Software and perform a factory reset.
Note : Deactivating the CFR21 Software requires a factory reset of the Nano Photometer® Alldata, user accounts, permissions and settings will be lost. Save all necessary data in advance.
SETTINGS
The CFR21 settings menu includes: Four Eye Administrator, Secure Password and Password Expiry
FOUR EYE AUTHENTICATION
Four Eye Authentication requires confirmation from a second Administrator
account when implementing critical software changes. To enable the Four Eye
Administrator setting, activate the Four Eye Administrator toggle switch. It
is necessary to create at least two Administrator accounts for this setting.
The following features, settings and actions require confirmation from a second Administrator account if four eye authentication is active: Factory reset, change of date and time, deactivation of CFR21 software, deactivation of Four Eye Administrator, secure password, password expiry, rename, delete, move folder, and delete result file.
SECURE PASSWORD
Secure password is set by default and can be switched off. Secure password ON:
At least 8 characters with a minimum of 1 special character, 1 capital letter,
1 lowercase letter and 1 number. Secure password OFF:
At least 4 characters/numbers and no further restrictions.
PASSWORD EXPIRY
Password expiry offers the possibility to have each user prompted to change
the account password on a regular basis. When password expiry is active it is
possible to enter a timeframe between 1 and 365 days. Default setting is 90
days.
Note: If the amount of days before passwords expire is reduced, it is possible that all passwords expire immediately and must be changed with the next login.
SETTING UP USER ACCOUNTS
There are three types of user accounts: Administrator, Power User and User.
An Administrator has full access rights and can create Groups, Administrator,
Power User, User accounts. Power Users and Users need to be assigned to a
group. A Power User can create User accounts in their defined group.
To add an Administrator, Group, Power User or User select the desired
account/group category and push the + icon
Note: If account/group category or + icon is not available, the logged in user does not have access rights to create the account or group.
ADD ACCOUNT
It is possible to add several Admin, Power User and User accounts. Power User
and User accounts need to be assigned to a group.
Note: Please keep a copy of your Admin password for your records. For
security purposes, Admin passwords cannot be recovered. Should you lose your
Admin login details, you will need to contact the Implen Support team
(support@implen.de) for assistance with password
reset. Power User and User passwords can be recovered by an administrator
- Select category: Admin, Power User or User
Note: In order to add a Power User or User create at least one Group.
-
For Power User / User account select a Group
-
Enter user’s first and last name
-
Enter Login Name
Note: Allowed characters are: letters, digits, underscores and dashes. Login name needs to start with a letter. Do not use blank character.
Note: Login names must be unique. It is not possible to use identical login names and/or group names. -
Set Login Password and confirm the password. This password is a temporary password which the user will be prompted to change after the first login.
Note: Secure passwords need to have at least 4 characters/numbers, but if secure password is enabled at least 8 characters are required with a minimum of 1 special character, 1 capital letter, 1 lowercase letter and 1 number.
- Save User account by pushing the icon
Note: It is not possible to delete or change user accounts.
ADD NETWORK FOLDER
Network folders can only be created by the logged in user for the own user
account. To create a network folder select Network Folder in the user account
preferences.
Enter the Network Path of the network folder using either //IP/share/path or
//server/share/path. If the local network requires authentication enter the
user name and password for Windows or MacOS logon and the domain if necessary.
Save the settings by pushing the icon. The network state changes to
“connected” if the network folder is created successfully.
Note: The NanoPhotometer® needs to be connected via LAN or WLAN to the local network.
Network folders can be deleted by pushing the icon.
The folder nickname is created automatically (Network_login name) and is shown
in all directories.
USER RIGHTS
The following table describes the different user rights of Administrator,
Power User or User.
Note: If “Yes/4 Eye” is displayed in the administrator rights column, a
confirmation by a second administrator is required when Four Eye
authentication is active (see page 6 Four Eye Authentication).
Action | Administrator | Power User | User |
---|---|---|---|
Report Problem | Yes | No | No |
Reset | Yes/4 Eye | No | No |
Update | Yes | No | No |
Date and Time | Yes/4 Eye | No | No |
Language | Yes | No | No |
Enable NanoVolume (C40) | Yes | No | No |
Add Dyes | Yes | Yes | No |
Dyes show toggle switch | Yes | No | No |
Delete Dyes/Change Dyes | No | No | No |
Change Warning Messages | Yes | No | No |
Change Network (Settings, WLAN) | Yes | No | No |
Change Printer (Network printer, Report Configuration) | Yes | No | No |
CFR21 Off | Yes/4 Eye | No | No |
Add Admin/Power User Account | Yes | No | No |
Add Group | Yes | No | No |
Add User Account | Yes | Yes | No |
Set temporary password for lost password or misentry of password | Yes | No | No |
4 Eye Administrator | Yes/4 Eye | No | No |
Secure Password | Yes/4 Eye | No | No |
Password Expiry | Yes/4 Eye | No | No |
Audit Trail | Yes | Yes read only | No |
Save parameter as Stored Method | Yes | Yes | No |
Change parameter in opened Stored Method | Yes | Yes | No |
Delete Stored Methods | Yes/4 Eye | No | No |
Rename Folder | Yes/4 Eye | No | No |
Delete Folder | No | No | No |
Move Folder | No | No | No |
Delete Result File | Yes/4 Eye | No | No |
Rename Result File | Yes | Yes | No |
Move Result File | No | No | No |
Delete Results | Yes | No | No |
Note: User rights cannot be changed.
LOGIN TO THE NPOS SOFTWARE
LOGIN
If the CFR21 software is enabled a login is necessary for any action.
To login enter the Login Name and password and confirm with OK.
Note: If another user is logged in e.g. with a control device (computer)
it is not possible to login to the NanoPhotometer® directly unless the logged
in user logs off or a forced log off is requested with an Administrator
account.
AUTOMATIC LOG OFF
There is an automatic screen lock if the NanoPhotometer® is inactive for 10
minutes. The screen can only be unlocked by the logged in user or with a
forced log off by an administrator.
SCREEN LOCK
The screen can be locked in all method by pushing the icon in the navigation
bar.
Note: A locked screen can only be unlocked by the logged in user or with
a forced log off by an Administrator.
LOG OFF
Log off is only possible on the home screen by pushing the icon
ELECTRONIC SIGNATURE
The electronic signature is set by default and cannot be disabled. Saving
measurement data needs to be confirmed by the logged in user (Electronic
Signature: Login Name and Password).
All saved file reports include the author, User ID, User Name, and date and time of the electronic signature. IDS and PDF files cannot be altered.
A second signature is shown as Read/Save/Print if an IDS file is opened and data are printed or exported as an Excel/PDF file. The second signature is the electronic signature of the logged-in user at the time of printing or data export.
Implen NanoPhotometer®
Instrument Type| NP80
Version| NPOS 4.2 build 14756
Serial Number| M80945
Set’test passed| 2019-08-23; 13:17
Autosave| No
File Name| Grippe A/bjones/Header.ids
Reason| Author| Read/Save/Print
User ID| bjones| msmith
User Name| Becky Jones| Mark Smith
eSign Date| 2019-08-23| 2019-08-23
eSign Time| 13:25:16| 13:27:35
AUDIT TRAIL
The audit trail function is automatically activated with CFR21 software activation. The audit trail records all actions and preference changes in an audit log. There is no delete or reset option for the audit trail available.
Analyzing and viewing the audit trail is possible as a logged-in Administrator or Power User by opening the CFR21 preferences using the NPOS computer software:
The audit trail opens a table including the following information for each
recorded action and preference change: ID, Date/Time, User ID, Category,
Action and Details. The audit trail can be printed or saved as a PDF
(Administrator only).
Saved audit trail files are located in the Audit Trail folder. The folder can only be accessed by Administrators via file server access.
PASSWORD LOSS/MISENTRY
If a Power User or User has lost the login password or entered it three times wrong, an Administrator can change the password of the Power User/User in the account settings (Preferences) to a temporary password. The Power User or User will be prompted to change the temporary password after the first login.
Administrator passwords cannot be recovered, if an administrator has lost the password please contact the Implen support team (support@implen.de).
VERSION HISTORY
Version | Date | Changes |
---|---|---|
1.0 | August 2019 | Initial Release |
1.1 | May 2020 | Change of firmware version number in CFR21 Software Statement |
1.2 | March 2021 |
- Change of firmware version number in CFR21 Software Statement
- Power User can read audit trails
- Note / warning message added that administrator passwords cannot be recovered. Implen support is necessary.
A PPENDIX
CFR21 S OFTWARE S TATEMENT
Paragraph | Summary | Features |
---|
11.10 Controls for closed systems
11.10 Persons who use closed systems to create, modify, maintain, or transmit
electronic records shall employ procedures and controls designed to ensure the
authenticity, integrity, and, when appropriate, the confidentiality of
electronic records, and to ensure that the signer cannot readily repudiate the
signed record as not genuine. Such procedures and controls shall include the
following| Controls for closed systems| The NanoPhotometer® Software NPOS
4.2.14756 and higher contains the optional CFR21 feature. Once this CFR21
feature is activated all these requirements are fulfilled.
(a) Validation of systems to ensure accuracy, reliability, consistent intended
performance, and the ability to discern invalid or altered records.| System
validation| The complete NanoPhotometer® Software NPOS 4.2.14756 and higher is
validated by Implen to ensure accurate, reliable and intended performance of
all the components of the NanoPhotometer® system. IQ/OQ procedures for proper
function of the NanoPhotometer® instrument can be put in place. The
proprietary file format IDS is protected by hash codes and encryption to allow
identification of altered files.
(b) The ability to generate accurate and complete copies of records in both
human readable and electronic form suitable for inspection, review, and
copying by the agency. Persons should contact the agency if there are any
questions regarding the ability of the agency to perform such review and
copying of the electronic records.| Record generation and copying| In addition
to the protected IDS files, all relevant measurement parameters and results
can be exported to PDF using the PDF/A standard as well as Excel file format.
(c) Protection of records to enable their accurate and ready retrieval
throughout the records retention| Record protection| Every export is
accompanied with an IDS file, which is protected by hash codes and encryption
to allow detection of tampering.
period.| | At any time, PDF and Excel reports can be regenerated from these
IDS files. Security measures for storage of these reports lie within the
responsibility of the operating company.
(d) Limiting system access to authorized individuals.| Access limitation|
Before any use of the system, every user is required to login for system
access.
Each user has a defined role, including access privileges.
(e) Use of secure, computer- generated, time-stamped audit trails to
independently record the date and time of operator entries and actions that
create, modify, or delete electronic records. Record changes shall not obscure
previously recorded information. Such audit trail documentation shall be
retained for a period at least as long as that required for the subject
electronic records and shall be available for agency review and copying.|
Audit trails| Time-stamped audit trails are recorded for actions performed on
the instrument by the user such as file storage, transfer activities and
preference changes. The audit trails can be exported in PDF format. The
creation and signature of the report files also creates an audit trail report
entry. Reports cannot be overwritten.
(f) Use of operational system checks to enforce permitted
sequencing of steps and events, as appropriate.
| Operational system checks| Not applicable.
(g) Use of authority checks to ensure that only authorized individuals can use
the system, electronically sign a record, access the operation or computer
system input or output device, alter a record, or perform the operation at
hand.| Authority checks| It is ensured that users have the proper authority to
carry out particular functions based on their roles and access privileges. It
is the responsibility of the operating company to ensure that each user name
can be traced to a real individual and to ensure correct assignment of roles.
(h) Use of device (e.g. terminal) checks to determine, as appropriate, the
validity of the source of data input or operational instruction.| Device/
terminal checks| Checks are applied to allow only valid information input in
respective files. All CSV and JSON input files are checked to ensure valid
content.
(i) Determination that persons who develop, maintain, or use electronic
record/electronic signature systems have the education, training, and
experience to perform their assigned tasks.| Training and user accountability|
Implen Software Development team is fully and continuously trained. Implen
provides NanoPhotometer® Software user trainings. The operating company is
responsible for training on their SOPs in regard to electronic records and
electronic signatures. Implen supports the installation of these SOPs in
relation to NanoPhotometer® Software.
(j) The establishment of, and adherence to, written policies that hold
individuals accountable and responsible for actions initiated under their
electronic signatures, in order to deter record and signature falsification.|
Policies| Responsibility of the operating company.
(k) Use of appropriate controls over systems documentation including:
(1) Adequate controls over the distribution of, access to, and use of documentation for system operation and maintenance.
(2) Revision and change control procedures to maintain an audit trail that documents time-sequenced development and modification of systems documentation.
| System Document Control| A release-specific software manual is distributed together with the NanoPhotometer® Software.
NanoPhotometer® Software development is governed by a design and change control process that ensures the creation and tracking of relevant documents.
11.30 Controls for open systems.
Persons who use open systems to create, modify, maintain, or transmit
electronic records shall employ procedures and controls designed to ensure the
authenticity, integrity, and, as appropriate, the confidentiality of
electronic records from the point of their creation to the point of their
receipt. Such procedures and controls shall include those identified in 11.10,
as appropriate, and additional measures such as document encryption and use of
appropriate digital signature standards to ensure, as necessary under the
circumstances, record authenticity, integrity, and confidentiality.| | Not
applicable. The NanoPhotometer® operates as a closed system.
11.50 Signature manifestations.
(a) Signed electronic records shall contain information associated with the
signing that clearly indicates all of the following:
(1) The printed name of the signer;
(2) The date and time when the signature was executed; and
(3) The meaning (such as review, approval, responsibility, or authorship) associated with the signature.
| Signature manifestations| The user management ensures that all user IDs are unique.
- The system verifies the user credentials before creating any report (the user is required to re-enter his/her user ID and password). The protected IDS file as well as PDF and Excel files contain the user ID and the full name of the user.
- The date & time when the signature was executed is associated with the signature.
- The signature for creating the initial reports including the protected IDS file is indicated as “Author” as reason for signature. The signature for (re-)creating reports in PDF and Excel format are indicated as “Read/Save/Print” as reason for signature.
(b) The items identified in paragraphs (a)(1), (a)(2), and (a)(3) of this
section shall be subject to the same controls as for electronic records and
shall be included as part of any human readable form of the electronic record|
Signature in electronic records and in human readable form| User’s full name,
date and time are included within the IDS file, which is protected by hash
codes and encryption. When generating the human readable PDF and Excel files,
the electronic signature is displayed with user ID, user’s
(such as electronic display or printout).| | full name, date & time, and
reason.
11.70 Signature/record linking.
Electronic signatures and handwritten signatures executed to electronic
records shall be linked to their respective electronic records to ensure that
the signatures cannot be excised, copied, or otherwise transferred to falsify
an electronic record by ordinary means.| Signature/ record linking| The
signature is integrated in the IDS file and can therefore not be excised,
transferred or copied.
11.100 General requirements.
(a) Each electronic signature shall be unique to one individual and shall not
be reused by, or reassigned to, anyone else.| Uniqueness of electronic
signatures| The user management system ensures that all user IDs are unique.
Therefore, all electronic signatures are unique.
(b) Before an organization establishes, assigns, certifies, or otherwise
sanctions an individual’s electronic signature, or any element of such
electronic signature, the organization shall verify the identity of the
individual.| Verification of identity| It is the responsibility of the
operating company to ensure the identity of the individual at the time of
creating the individual’s user account.
(c) Persons using electronic signatures shall, prior to or at the time of
such use, certify to the agency that the electronic signatures in their
system, used on or after August 20, 1997, are intended to be the legally
binding equivalent of traditional handwritten signatures.
(1) The certification shall be submitted in paper form and signed with a traditional handwritten signature, to the Office of Regional Operations (HFC-100), 5600 Fishers Lane, Rockville, MD 20857.
(2) Persons using electronic signatures shall, upon agency request, provide additional certification or testimony that a specific electronic signature is the legally binding equivalent of the signer’s handwritten signature.
| Certification| Responsibility of the operating company.
11.200 Electronic signature components and controls.
(a) Electronic signatures that are not based upon biometrics shall:
(1) Employ at least two distinct identification components such as an identification code and password.
| Controls for electronic signatures| Users are requested to enter user ID and
password for every signature action. In order to have access to a signature
action, the user must have a user ID in the user management system and must be
logged in with user ID and password.
(i) When an individual executes a series of signings during a single,| |
continuous period of controlled system access, the first signing shall be
executed using all electronic signature components; subsequent signings shall
be executed using at least one electronic signature component that is only
executable by, and designed to be used only by, the individual.| |
(ii) When an individual executes one or more signings not performed during a
single, continuous period of controlled system access, each signing shall be
executed using all of the electronic signature components.
(2) Be used only by their genuine owners; and
(3) Be administered and executed to ensure that attempted use of an individual’s electronic signature by anyone other than its genuine owner requires collaboration of two or more individuals.
| |
(b) Electronic signatures based upon biometrics shall be designed to ensure
that they cannot be used by anyone other than their genuine owners.| | Not
applicable.
11.300 Controls for identification codes/passwords.
Persons who use electronic signatures based upon use of identification codes
in combination with passwords shall employ controls to ensure their security
and integrity. Such controls shall include:| |
(a) Maintaining the uniqueness of each combined identification code and
password, such that no two individuals have the same combination of
identification code and password.| Uniqueness of ID/ password| The user
management system ensures unique user IDs.
(b) Ensuring that identification code and password issuances are periodically
checked, recalled, or revised (e.g., to cover such events as password aging).|
Password aging| The user management system provides password expiration and
account locking after several authentication failures.
Criteria can be set individually by the operating company.
(c) Following loss management procedures to electronically deauthorize lost,
stolen, missing, or otherwise potentially compromised tokens, cards, and other
devices that bear or generate identification code or password information, and
to issue temporary or permanent replacements using suitable, rigorous
controls.| Lost ID/ password management| The user management system allows an
administrator to assign a new temporary password in case of lost, stolen or
missing passwords. Proper loss management procedures are the responsibility of
the operating company.
(d) Use of transaction safeguards to| Controls to prevent| NPOS with activated
CFR21 feature will
prevent unauthorized use of passwords and/or identification codes, and to
detect and report in an immediate and urgent manner any attempts at their
unauthorized use to the system security unit, and, as appropriate, to
organizational management.| unauthorized credential use| lock the screen after
an inactive period of time to prevent unauthorized attempted use. Other
transaction safeguards such as supervision of blocked accounts etc. lies
within the responsibility of the operating company.
(e) Initial and periodic testing of devices, such as tokens or cards, that
bear or generate identification code or password information to ensure that
they function properly and have not been altered in an unauthorized manner.|
Periodic testing of ID/ password generation| Responsibility of the operating
company.
Important Notice: In accordance with FDA regulation, a vendor cannot claim that its software products are certified 21 CFR Part 11 compliant. A vendor, instead, can provide all Technical Controls for 21 CFR Part 11 compliance built into their product. As such Implen does not, at any time, imply that the use of any Implen CFR21 product will automatically give the customer protection to and therefore compliance with 21 CFR Part 11. It is the responsibility of the user to implement the Procedural and Administrative Controls (both correctly and consistently) along with using products with the correct Technical Controls for overall Part 11 compliance. All CFR21 systems must therefore be independently audited.
DISCLAIMER
THE WARRANTIES SET FORTH IN THE NANOPHOTOMETER MANUAL, ABOVE, ARE IN LIEU OF, AND THIS AGREEMENT EXPRESSLY EXCLUDES, ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, ORAL OR WRITTEN, INCLUDING, WITHOUT LIMITATION,
(a) ANY WARRANTY THAT THE SOFTWARE IS ERROR FREE, WILL OPERATE WITHOUT
INTERRUPTION, OR IS COMPATIBLE WITH ALL EQUIPMENT AND SOFTWARE CONFIGURATIONS;
(b) ANY AND ALL IMPLIED WARRANTIES OF MERCHANTABILITY; AND
(c) ANY AND ALL WARRANTIES OF FITNESS FOR A PARTICULAR PURPOSE.
LIMITATION OF LIABILITY
IN NO EVENT SHALL LICENSOR OR ITS OWN LICENSORS AND SUPPLIERS BE LIABLE FOR ANY INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES, INCLUDING, WITHOUT LIMITATION, LOST PROFITS, ARISING OUT OF OR IN ANY WAY CONNECTED WITH YOUR USE OF THE SOFTWARE OR ANY INFORMATION OR MATERIALS AVAILABLE THROUGH THE SOFTWARE, WHETHER BASED IN CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF LICENSOR HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. IN ADDITION, LICENSOR ASSUMES NO RESPONSIBILITY OR LIABILITY FOR ANY CLAIMS THAT MAY RESULT DIRECTLY OR INDIRECTLY FROM THE RESULTS YOU ACHIEVE USING THE SOFTWARE OR WHICH RELATE TO THE STORAGE OF ANY DATA OR FOR THE DELIVERY, SECURITY, OR AVAILABILITY OF ANY DATA. WITHOUT LIMITATION OF THE FOREGOING, TOTAL LIABILITY OF LICENSOR FOR ANY REASON WHATSOEVER RELATED TO THE SOFTWARE, THE USE OR INABILITY TO USE THE SOFTWARE, OR FOR ANY CLAIMS RELATING TO THIS EULA SHALL NOT EXCEED IN THE AGGREGATE US$5,000.
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