Free apps are going to be massively, disproportionately affected by Apple’s Core Technology Fee, which is why I don't think it will stand as-is.

If you have just 2M users on a completely free app, you're looking at $45,290 in monthly fees to Apple, or half a million dollars a year.

To make use of any of Apple's other EU terms or fees as a developer, you have to accept this one

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