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Line a 8" square pan with foil; grease foil.
Mix sugar and cocoa in heavy 3 quart saucepan. Stir in milk and butter. Bring to a boil over medium heat, stirring constantly. Without stirring, boil vigorously 5 min. Remove from heat; add chips and stir until melted and smooth. Spread 1 cup in lined pan, top with cookies, then spread remaining fudge evenly over top. Refrigerate 6 hours until firm. Invert pan, peel off foil, invert fudge and cut in 1" squares.
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