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Even with Joest getting support from Porsche in '96 and '97, he was officially a privateer team. When Goh and Champion won LM in '04 and '05 they were considered privateer teams by the ACO even though they were semi-factory Audi Sport outfits.
You also have to remember especially from the factory exodus after '99 and until Peugeot came back, most of the LMP900 and LMP1 teams were privateers. It wasn't really until 2011 that the number of private teams vs factory teams broke even and into the hybrid era, almost all the front runners were factory teams and outnumbered the private entries.
Not to mention that the era of private teams running older spec factory cars ended at around that time, and it was mostly Audi R8s in the LMP900 era when that happened. Oreca were basically a second Peugeot factory team, though they were treated as a privateer by Peugeot in 2011.
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