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Missing Cert Range

As we all know, early on there were different cert ranges used for different reasons. These included ranges like 30-,31-,40-,50-,60-,81-, and 90-.

They eventually switched over to the pure numerical sequence, and in 2018 or so, when the 29s were just about exhausted, PSA decided to jump to (I think) 41-. After that, they seem to have filled in around ranges that had already been used.

My question is: am I correct in thinking that there are still about 8 million unused cert numbers from 32000000 - 40000000?

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