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Only if they hadn't done something similar before. At my work we purposely reuse designs because they don't need to be recertified. If we can show it is the same then we just pay the fee and move on with our lives. Actually getting a design certified is a lot of work though for something new and can take up to  6 months for it to process (longest I've ever seen was 8 months, reusing a certified design knocks it down to a few weeks).