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I have never had a check for under $100, but I know others has in the past. This is because when Adsense first started up they were paying people at the end of the year where it didn't matter if you had $100 or less, you would still have received your earnings.
They have stopped doing this now. I guess there was alot of work paying so many accounts that just had a few dollars in their adsense account.
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