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 Even if Chevron does not apply, interpretations contained in formats such as policy statements, agency manuals, guidelines, and opinion letters are still “entitled to respect” and may “constitute a body of experience and informed judgment to which courts and litigants may properly resort for guidance.” Skidmore v. Swift & Co., 323 U.S. 134, 140 (1944). See also Christensen v. Harris Cty., 529 U.S. 576, 587 (2000). “The weight of [the agency’s] judgment in a particular case will depend upon the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it power to persuade, if lacking power to control.” Skidmore, 323 U.S. at 140. This deference is justified by the “specialized experience and broader investigations and information available to the agency, and given the value of uniformity in its administrative and judicial understandings of what a national law requires.” Mead Corp., 533 U.S. at 234.  

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