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  <front>
    <journal-meta />
    <article-meta>
      <title-group>
        <article-title>An Ontology Reference Model for Normative Acts</article-title>
      </title-group>
      <contrib-group>
        <contrib contrib-type="author">
          <string-name>Pedro Paulo F. Barcelos</string-name>
          <email>pedropaulofb@gmail.com</email>
          <xref ref-type="aff" rid="aff1">1</xref>
          <xref ref-type="aff" rid="aff2">2</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Renata S. S. Guizzardi</string-name>
          <email>rguizzardi@inf.ufes.br</email>
          <xref ref-type="aff" rid="aff0">0</xref>
          <xref ref-type="aff" rid="aff2">2</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Anilton S. Garcia</string-name>
          <email>anilton@inf.br</email>
          <xref ref-type="aff" rid="aff1">1</xref>
          <xref ref-type="aff" rid="aff2">2</xref>
        </contrib>
        <aff id="aff0">
          <label>0</label>
          <institution>Department of Computer Science - PPGI</institution>
        </aff>
        <aff id="aff1">
          <label>1</label>
          <institution>Electrical Engineering Department - PPGEE</institution>
        </aff>
        <aff id="aff2">
          <label>2</label>
          <institution>Federal University of Espírito Santo - UFES Vitória - ES -</institution>
          <country country="BR">Brazil</country>
        </aff>
      </contrib-group>
      <fpage>35</fpage>
      <lpage>46</lpage>
      <abstract>
        <p>Normative Acts are important legislative and regulatory documents made by different governmental organs. Every year, a huge amount of information is provided in Normative Acts by these organs without control, i.e., there is no effective way to verify redundancies, inconsistencies, crossimpact and ambiguities. In this paper, we propose a domain ontology for Normative Acts based on official documents (the Brazilian Constitution and the Redaction Manual of the Presidency of the Republic) as a reference model that can be used to improve communication, interoperation and automation of Normative Acts. The reference model is built with a highly expressive wellfounded language within a methodology that ensures its quality.</p>
      </abstract>
    </article-meta>
  </front>
  <body>
    <sec id="sec-1">
      <title>1. Introduction</title>
      <p>In order to produce the desired impact to society, the NAs must be carefully
planned in their elaboration stage, involving studies and researches of previous related
NAs. Today, these studies and researches are done manually, without intelligence
provided by computational applications – to research a NA, an editor must use a
nonspecialized research tool, just like any layman would. Moreover, once published, its
content must be easily accessible and researchable by society and other stakeholders. In
fact, in Brazil, a federal law ensures that every public organ or entity must publish, in
detail, the formats used to structure their information. It is widely known that, although
a reference document exists for the NAs writing, this document is not always used by
the legislative houses and regulatory agencies, thus resulting in the above cited
problems.</p>
      <p>The official reference document which deals with the NAs’ writing is the
Presidency Writing Manual (in Portuguese, Manual de Redação da Presidência da
República – available at http://www.planalto.gov.br/ccivil_03/manual/). The Writing
Manual is divided into two parts: the first, among other topics, presents the official
communications and standardizes the layout of expedients. The second part deals with
the elaboration and wording of NAs and presents examples of the Normative Acts and
the legislative procedure.</p>
      <p>
        This second part of the document, in particular, describes the textual elements
that a NA may have and their inter-relationships, making it a valuable reference and a
natural candidate for the development of an Ontology Reference Model for this domain.
Even though the description contained in the Presidency Writing Manual is available
only in natural language (Portuguese), which does not guarantee absence of ambiguities,
the use of an ontologically well-founded language can identify and correct these
possible deficiencies. Such type of language differs from other commonly used
languages to represent data or knowledge in information systems (like databases
schemas) as they are built accordingly to a foundational ontology, i.e., a meta-ontology
that describes a set of real-world categories that can be used to talk about reality
[
        <xref ref-type="bibr" rid="ref12">Guizzardi 2007</xref>
        ]. A framework for ontological evaluation is presented in [
        <xref ref-type="bibr" rid="ref11">Guizzardi
2005</xref>
        ], and an example of an application of this kind of evaluation in a network
language, also described in natural language, can be seen in [
        <xref ref-type="bibr" rid="ref2">Barcelos et al. 2011</xref>
        ].
      </p>
      <p>
        Our objective in this paper is to present a domain ontology developed to be a
reference model for NAs. Reference Models are essential artifacts when dealing with
information of a given domain, as they formalize concepts and their relations in a clear
and unambiguous way, improving communication and information exchange and
interoperation. In fact, the main objective of a reference model is to assist humans in
tasks such as meaning negotiation and consensus establishment. This goal can be
achieved by using highly expressive languages, within a formal ontology engineering
methodology, to create a strongly axiomatized ontology that approximates as well as
possible to the domain conceptualization. The focus on these languages is on
representation adequacy, instead of computational representation [
        <xref ref-type="bibr" rid="ref12">Guizzardi 2007</xref>
        ]. The
Normative Acts ontology reference model is formalized with OntoUML, an
ontologically well-founded profile of the Unified Modeling Language (UML). The
ontology engineering methodology used guarantees the validity and correctness of the
modeled information through syntactical and semantic validations.
      </p>
      <p>In brief, the main contribution of this paper is to provide an ontology reference
model for the NAs domain, formalized with OntoUML within an ontology engineering
methodology. A secondary contribution is the presentation of this ontology`s capabilities
to be used as basis for computational implementation.</p>
      <p>The work described here is placed in the context of the Information and
Knowledge Management Model Project (“Modelo de Gestão da Informação e do
Conhecimento”, MGIC, in Portuguese), a cooperation project between the Federal
Fluminense University and the National Agency of Terrestrial Transportation (ANTT).
The MGIC aims to improve efficiency in ANTT’s decision-making. To achieve this
goal, the information modeling work is performed on four different fronts. The ontology
modeling, one of these fronts, aims to create conceptual reference model ontologies for
structuring the agency’s information.</p>
      <p>This paper is structured as follows: in section 2, we compare this work with
others that are related to NAs; section 3 presents the ontology engineering methodology
used to create and guarantee the quality of the proposed NAs ontology; in section 4, we
describe the ontology reference model for NAs in details; section 5 presents possibilities
of practical use of the NAs ontology as a conceptual model and as basis for
computational implementation; section 6 presents the main conclusions as well as future
works.</p>
    </sec>
    <sec id="sec-2">
      <title>2. Related Works</title>
      <p>
        As the legislative process involves several public entities in various spheres and as it
generates a large amount of information, a huge number of works are published
involving the creation of ontologies used for communication and automation in this
domain. In fact, some of these works are the results of large projects, like the LexML
Project [
        <xref ref-type="bibr" rid="ref14">Lima 2010</xref>
        ], and the International Ontojuris Project [
        <xref ref-type="bibr" rid="ref5">Clara et al. 2010</xref>
        ].
      </p>
      <p>
        Legal ontology projects differentiate from each other in scope, objective and in
which kind of ontology they are based. As an example, the Brazilian LexML project
uses as basis an ontology called FRBROO, an ontology in the domain of cultural
heritage; while the Ontojuris Project uses a lightweight ontology (almost a dictionary),
similarly to other initiatives, such as the LTS (Legal Taxonomy Syllabus) [
        <xref ref-type="bibr" rid="ref1">Ajani et al.
2009</xref>
        ], in Europe.
      </p>
      <p>
        The Power project, in its turn, uses shared conceptual models to facilitate the
legislation process [
        <xref ref-type="bibr" rid="ref8">Engers and Glassée 2001</xref>
        ]. [
        <xref ref-type="bibr" rid="ref19">Visser and Bench-Capon 1996</xref>
        ] also
proposed a Legal Ontology specification, while [
        <xref ref-type="bibr" rid="ref3">Boer et al. 2003</xref>
        ] proposed an ontology
for comparing and harmonizing legislation. Other works aim to provide foundations for
concepts of law, like [
        <xref ref-type="bibr" rid="ref4">Breuker and Hoekstra 2004</xref>
        ]. These works and the ontology
proposed in this paper, however, do not share the same scope, as the foundations are
provided to models representing legislative process concepts, not the internal elements
and relations of Normative Acts.
      </p>
      <p>Even though there is a vast number of works about ontologies in the legislative
area, it appears, however, that no work involves the creation of a well-founded ontology
reference model for the representation of the Normative Acts’ internal structure.</p>
    </sec>
    <sec id="sec-3">
      <title>3. Ontology Engineering Methodology</title>
      <p>
        In order to create an ontology reference model that correctly reflects the intended
domain and that is able to be used by different agents (people, groups of people and
other, like machines) to interoperate, an ontology engineering methodology must be
used. This section presents our methodology, partially based on the Ontological
Approach to Domain Engineering presented in [
        <xref ref-type="bibr" rid="ref9">Falbo et al. 2002</xref>
        ]. In our methodology,
shown in Figure 1, we use the steps of the Ontological Approach to Domain
Engineering with different level of rigor, abstracting non-essential elements to our case.
      </p>
      <p>Scope
Definition</p>
      <p>Information
Acquisition</p>
      <p>Syntatic
Validation
Anti-Pattern
Treatment</p>
      <p>Conceptualization</p>
      <p>Ontology
Formalization
Simulation</p>
      <p>Ontology
Reference</p>
      <p>Model</p>
      <p>Scope definition is the first step of the iterative methodology. Our ontology uses
a reference document, the Presidency Writing Manual, written in natural language
(Portuguese in our case), as the modeling scope.</p>
      <p>
        The second step of the methodology is the ontology capture, were the sub
activities of Information Acquisition and Conceptualization are realized. In order to
acquire information, a domain study is necessary for the modeler to learn about the
subject to be modeled. We used the Presidency Writing Manual and the Brazilian
Constitution as main source of information. Conceptualizations are immaterial entities
that only exist in the mind of the user or a community of users of a language. In order to
be documented, they must be captured in terms of some concrete artifact. This implies
that a language is necessary for representing them in a concise, complete and
unambiguous way [
        <xref ref-type="bibr" rid="ref12">Guizzardi 2007</xref>
        ].
      </p>
      <p>
        The ontology formalization step consists in the formalization, through diagrams,
of the domain model. In order to correctly represent a domain, an expressive language
must be used. This language should be able to represent information despite of
implementation technologies or limitations. In this work, we use OntoUML, an
ontologically well-founded UML profile [
        <xref ref-type="bibr" rid="ref11">Guizzardi 2005</xref>
        ]. As graphical languages are
not always capable of correctly representing the domain, some Object Constraint
Language (OCL) rules are also necessary for restrictions and derivations rules.
      </p>
      <p>As we intend to create a reference model for Normative Acts (NAs), it is
important to ensure that the diagrams allow only instantiation as desired, that is, that the
user can only create instances that are possible in the real world. To do this, we focus on
the validation of information modeled at the diagrams. In this stage, we have two main
types of validation: (1) the syntactic one, which guarantees that the OntoUML models
created are syntactically correct, that is, that the entities created are according to the
languages meta-model; and (2) the semantic validation, where we want to avoid
syntactically correct diagrams that can be instantiated to generate undesired world of
affairs.</p>
      <p>The OntoUML Lightweight Editor (OLED)
(https://code.google.com/p/ontoumllightweight-editor/) provides the syntactical validation. The Semantic Validation does
not ensure that there is no impossible state of affairs allowed by the ontology, it does, in
fact, ensure that its occurrences are reduced. The semantic validation is done in two
steps, within an OLED’s module, called MOVE (OntoUML Model Validation
Environment): the first step is an anti-patterns identification and treatment and the
second step is a simulation using Alloy.</p>
      <p>
        As stated in [
        <xref ref-type="bibr" rid="ref17">Sales et al. 2012</xref>
        ], an anti-pattern is a recurrent decision for a
specific scenario that usually results in more negative consequences than positives ones.
The MOVE tool provides a model verification to check occurrences of anti-patterns.
Simulation can help the modeler to find inconsistencies and unwanted worlds of affairs
allowed by the model. The MOVE tool can translate the model to Alloy [
        <xref ref-type="bibr" rid="ref13">Jackson 2002</xref>
        ].
Alloy is a model-checking language that can be used to simulate possible worlds based
on the formalization provided. This kind of validation guarantees the validity of
modeled information inside an specific context, thus its usage significantly improves
model quality as the user can make assertions and check if these are valid or not.
      </p>
    </sec>
    <sec id="sec-4">
      <title>3.1. The use of OntoUML</title>
      <p>
        OntoUML provides a well-founded UML profile. The classes in OntoUML are based
on some important ontological meta-properties that allow the creation of consistent
ontologies [
        <xref ref-type="bibr" rid="ref11">Guizzardi 2005</xref>
        ].
      </p>
      <p>Examples of meta-properties are identity principle and rigidity. Identity principle
is related to the nature of an object. For example, a Student is a Person, as they have the
same identity principle, but they can never be a Car, as they have different identity
principle. The rigidity principle is the capacity of an entity to be part of a class
maintaining its existence. For example: John is an individual of the class Student but, in
a given world, it can cease to be a Student and still exists as a Person. However, in any
world John cannot cease to be a Person without ceasing to exist. Thus, Student is an
example of an anti-rigid class while Person is an example of a rigid class.</p>
      <p>
        The OntoUML stereotypes present in the Normative Acts Ontology are
summarized in Table 1 above. For an in depth presentation, formal characterization and
empirical evidence for a number of the ontological categories underlying OntoUML, the
reader is referred to [
        <xref ref-type="bibr" rid="ref11">Guizzardi 2005</xref>
        ].
      </p>
    </sec>
    <sec id="sec-5">
      <title>4. The Domain Ontology for Brazilian Normative Acts</title>
      <p>The domain ontology presented here is based on official documents: the Presidency
Writing Manual (hereafter, for short, called PWM) and on the Brazilian Federal
Constitution. Although the Normative Acts (NAs) Ontology created to the National
Agency of Terrestrial Transportation involves three aspects of the Normative Process
Structural Elements, Management Issues and Regulatory Marks – the Reference Model
presented here considers just the Structural Elements of NAs, considering NAs
compositions, aggregations, its internal elements, and all relations between these.</p>
      <p>The ontology reference model presented in detail in this section is divided in
three subdomains and modeled using OntoUML diagrams. For highlight, the first
occurrences of an ontology terms are presented with the Courier New font. It is
important to mention that the ontology reference model is fully available for download
at: http://www.nemo.inf.ufes.br/en/courses/ontologyengineering.</p>
    </sec>
    <sec id="sec-6">
      <title>4.1. Normative Acts and Articles Subdomain</title>
      <p>The model related to this subdomain states the different existing types of Normative
Acts in Brazil and their internal structure.</p>
      <p>Due to space limitations, the diagram that differentiates the NAs is not presented
in image. This diagram’s information was extracted from the 59th Brazilian Federal
Constitution article, where it states that the legislative process involves the creation of:
Constitution Amendments, Complementary Laws, Ordinary Laws,
Delegated Laws, Provisional Measures, Legislative Decrees and
Resolutions. Decree, Ordinance and Handout were extracted from the PWM.
All of these NAs are disjoint from each other, i.e., no NA can be of two different types
at the same time. NAs are defined by its composition by different subkinds of Articles
and by its preliminary elements.</p>
      <p>At the adopted conceptualization, the Article performs the most important
function in NAs as it contains the statements defining the rules and information that the
NA is about. In the ontology reference model every concept has a (direct or indirect)
relation with Articles. It can be seen in Figure 2 that every article has an identifier
number. An OCL rule formalizes that Articles in the same NA have unique natural
numbers.</p>
      <p>
        Preamble, Epigraph and Brief (in Portuguese: Preâmbulo, Epígrafe,
and Ementa, respectively) are obligatory preliminary elements in every NA. These
preliminary elements cannot be modified (vetoed, revoked or altered) – these properties
are stated in the Ontology Reference Model by the composition meta-properties of
essential and inseparable [
        <xref ref-type="bibr" rid="ref11">Guizzardi 2005</xref>
        ].
      </p>
    </sec>
    <sec id="sec-7">
      <title>4.2. Discrimination of Normative Acts’ Elements Subdomain</title>
      <p>Grouping and Discrimination Elements are important part of NAs as they provide to
their author the desired abstraction granularity. The Discrimination Elements
are used to describe in more detail the information being normalized in a NA.</p>
      <p>The different types of Discrimination Elements are: Paragraph, Item,
Letter (in Portuguese: Parágrafo, Inciso, and Alínea, respectively) and Letter
Discriminator. Every Discrimination Element is a part of a Normative Act because
the Articles that are discriminated by these elements are part of the Normative Act.</p>
      <p>Articles can be of two types: Simple Article or Composed Article.
While the former consists only of a text, the latter consists of its introductory text,
named Caput, and of at least one Item or Paragraph. Both types are represented in
Figure 3.</p>
      <p>If there is just one Paragraph composing an Article, its identification string must
be Unique Paragraph. OCL rules ensure these restrictions.</p>
      <p>Articles and Paragraphs can be decomposed in Items (see Figure 3), identified
by roman numbers. Items, represented in Figure 4, can be Simple Items (when
undivided) or composed by Letters. Letters can also be undivided (Simple Letters)
or they can be divided in Letter Discriminators. The PWM states at its section 10.2.2.3
that “Letters can be discriminated with cardinal numbers, followed by periods”. As no
name is given to these discrimination elements, we named them Letter Discriminators.</p>
    </sec>
    <sec id="sec-8">
      <title>4.3 Grouping of Normative Acts’ Elements Subdomain</title>
      <p>The Grouping Elements are used to easily aggregate related information in a NA.
They are the Parts, Books, Charters, Chapters and Sections (in
Portuguese: Parte, Livro, Título, Capítulo, and Seção, respectively). Every Grouping
Element is part of the NA that is composed of the Articles that are grouped by these
Grouping Elements.</p>
      <p>As represented in Figure 5, related Articles can be grouped in Sections or
Chapters. Sections can be of two types: Simple Sections, i.e., Sections that are not
composed by other Sections, and Composed Sections, that are Sections composed
by other Sections or Subsections: a specific type of Section that just occurs
composing a Composed Section.</p>
      <p>The grouping of Chapters by Charters, of Charters by Books, and of Books by
Parts can be seen in Figure 6.</p>
      <p>Parts can be of types Double Part or Multiple Part. OCL rules were
created to state that every NA that is composed by a Multiple Part always have at least
three of these and to state that if the NA is composed of a Double Part it must have
exactly only one instance of a General Part and a Special Part.</p>
    </sec>
    <sec id="sec-9">
      <title>5. Practical Applications</title>
      <p>
        As stated by [
        <xref ref-type="bibr" rid="ref12">Guizzardi 2007</xref>
        ], there is a clear distinction between (a) Conceptual
Modeling, (b) Design and (c) Implementation. The ontology reference model presented
here is a result of the Conceptual Modeling stage, as it aims to make a clear and precise
description of the Normative Acts (NA) domain elements for the purposes of
communication, learning and problem solving, independent of implementation platform
or technology. Considering a Model Driven Architecture approach [
        <xref ref-type="bibr" rid="ref15">Miller and Mukerji
2003</xref>
        ], the Reference Model can be seen as the Computational Independent Model
(CIM), its design products as Platform Independent Models (PIMs) and its
implementation products as Platform Specific Models (PSMs). In the Design and
Implementation phase, this conceptual specification is transformed by taking into
consideration a number of issues ranging from architectural styles, non-functional
quality criteria to be maximized, target implementation environment, etc. The same
conceptual specification can potentially be used to produce a number of different
artifacts in different implementation languages – ranging from relational databases to
semantic web languages, like the Web Ontology Language (OWL).
      </p>
      <p>In Brazil, according to the Federal Information Access Law (Brazilian Federal
Law number 12,527, from November 18th 2011. Available just in Portuguese at
http://www.planalto.gov.br/ccivil_03/_ato2011-2014/2011/lei/l12527.htm), every public
organ or entity must use the Internet to publish, in detail, the formats used to structure
their information. The ontology presented here, as a well-founded formalization of a
domain conceptualization, is the best option to accomplish this requirement. This same
law also states that the public organ or entity must enable automated access by external
systems to the information in open, structured and machine-readable formats. Thus, an
ontology implementation in the Resource Description Framework (RDF) or OWL can
entirely satisfy the law. In fact, the federal government with the World Wide Web
Consortium (W3C), cite OWL as a desirable practice for Open Data [Comitê Gestor da
Internet no Brasil 2011].</p>
      <p>A computational implementation of the proposed ontology reference model can
also be used in applications to assist different stages of the regulatory and legislative
process, like the NA edition. The usage of automation software can significantly
improve the time spent with the huge amount of NAs that are created daily in a public
entity. This automation can make processes more effective as it reduces the domain
specialists’ writing and research time and it gives them more time to think and reason
about the subject of the documents.</p>
      <p>In the edition phase, ontology-based software can eliminate from the writer the
need to know each concepts from the PWM, as the software can automatically create
these concepts for him. Another great improvement is the restriction to create
documents that are not in accordance with the PWM. As an example, every time a writer
creates an Article, if he wants to create a subtopic of this Article, he can just press the
TAB key and two options appears to him: an Item or a Paragraph. So, it is not possible
to create, for example, a Letter discriminating directly an Article. Another possible
usage of this software would be to evaluate Normative Acts already created.</p>
      <p>The ontology-based software for the NA process can be significantly improved
by using other Ontology Models. The usage of an ontology model about NAs’
revocation or modifications can add the ability to control the impact of a newly
published NA in others already published. That is, there will be no need to manually
state that an NA is repealed; it can be done automatically by software – thus, eliminating
human errors.</p>
      <p>
        Also, adding ontology reference models to the domain that the NAs are about,
we can create a semantic annotation feature [
        <xref ref-type="bibr" rid="ref16">Oren et al. 2006</xref>
        ], where the writer can
mark (tag) the concepts improving their semantics in accordance with the conceptual
model. Please consider a reference model about highways, where a highway is
composed by lanes and where it has a relation with other highways (for example
“crosses”). If the NA editor is writing, for example, about BR-101 (a Brazilian
highway), it can mark it as an instance of highway so, even if it is not explicit in the text
that the BR-101 has lanes and that it can cross other highways, this information can be
inferred. Semantic annotation is widely studied and used, even for large-scale scenarios
[
        <xref ref-type="bibr" rid="ref7">Dill et al. 2003</xref>
        ].
      </p>
      <p>With the usage of semantic annotation, the search on documents is improved, as
there is no need to lexically match all search terms. A search using the word “highway”
can return documents that use the term highway, and documents that deal with highways
but do no explicitly use this concept, for example, a document that contains information
about the BR-101. An improved search is vital to guarantee that new NAs do not
conflicts with older NAs.</p>
      <p>
        Already existent ontology-based tools for the legislative process can be found in
[
        <xref ref-type="bibr" rid="ref18">Valente and Breuker 1995</xref>
        ] and [
        <xref ref-type="bibr" rid="ref10">Gangemi et al. 2003</xref>
        ]. The base ontologies used in
these works, however, do not share the same scope of the ontology here presented and
some of them are not formalized using a well-founded ontology language such as
OntoUML.
      </p>
    </sec>
    <sec id="sec-10">
      <title>6. Conclusions</title>
      <p>This work presented an Ontology Reference Model for the domain of Normative Acts,
built over information extracted from the Brazilian Constitution and the Presidency
Writing Manual. The proposed ontology is formalized using an ontologically
wellfounded highly expressive language and it was developed following the ontology
engineering methodology presented here. This ontology can be used as basis for
automation and interoperation of information about this domain.</p>
      <p>The Ontology Reference Model is presented considering three subdomains:
(a) Normative Acts and Articles, where different existing types of Brazilian Normative
Acts are presented as well as their internal structure, representing their composition by
articles and preliminary elements;
(b) Discrimination of Normative Acts’ Elements, related to elements that are used to
describe in detail the information being normalized in a Normative Act;
(c) Grouping of Normative Acts’ Elements, that formalizes elements that are used to
easily aggregate related information.</p>
      <p>As a reference model, this ontology aims to make a clear and precise description
of the domain elements for the purposes of communication, learning and problem
solving. As an implementation, the model is able to solve problems related to the
redaction and edition of Normative Acts, like reference finding, and cross-impact
analysis. The ontology, in its conceptual or computational form, can be used to adequate
public organs to the Federal Information Access Law, as every public organ or entity
must use the Internet to publish, in detail, the formats used to structure their
information.</p>
      <p>Future work involves the expansion of the ontology to represent other aspects of
Normative Acts, like temporal ones (e.g. an NA is valid from a beginning date and can
have an end date). Another important future work is the creation of the computational
ontology in semantic web languages, like OWL.</p>
      <p>Acknowledgements. This research has been funded by the MGIC Project. We thank
the ANTT employees and all project members who have somehow contributed to the
development of this work. This research has also been funded by FAPES/CNPq
(PRONEX 52272362/11).</p>
    </sec>
  </body>
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