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In my opinion, yes, because they could think and have emotions. They moved and functioned, just like living things (besides plants) do.
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The rider was robed all in black, and black was his lofty helm; yet this was no Ringwraith but a living man. The Lieutenant of the Tower of Barad-dûr he was, and his name is remembered in no tale; for he himself had forgotten it...
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