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preliminary theoretical work was carried out prior to the planetary missions of the 1970s. In particular, Lewis showed in 1971 that radioactive decay alone was likely sufficient to produce subsurface oceans in large moons, especially if ammonia ({{chem) were present. Peale and Cassen figured out in 1979 the important role of tidal heating (aka: tidal flexing) on satellite evolution and structure. The first confirmed detection of

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