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The agency says there's still no evidence H7N9 has gained capacity for sustained spread.
So far there's no sign that H7N9 epidemiology is changing for humans, but for poultry, the virus has become more deadly.
Analyses of samples from China and Taiwan hint at resistance to antiviral drugs.
The 111 cases reported in the first half of January have already topped December's total.
In some hard-hit areas, sampling of poultry environments in December showed increased virus levels compared with that time in past waves.
The fast pace of newly reported illnesses during China's 5th wave of illness has already topped last season's total.
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