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Simultaneously, the gay liberation movement (post-Stonewall 1969) was fighting for the right to love without persecution. This movement was, in its early days, often trans-exclusionary. Prominent figures like lesbian feminist writer Janice Raymond (author of The Transsexual Empire , 1979) argued that trans women were infiltrators or agents of patriarchy. The famous "Michigan Womyn's Music Festival" banned trans women for decades, a policy known as trans-exclusionary radical feminism (TERF).

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