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The instanton approach to the in-gap fluctuation states is applied to the spectrum of biased bilayer graphene. It is shown that the density of states falls off with energy measured from the band-edge as $\nu(\epsilon)\propto \exp(-|\epsilon/\epsilon_t|^{3/2})\epsilon_tn_in_i^{2/3}$. While the bare energy spectrum is characterized by two energies: the bias-induced gap, , and interlayer tunneling, , the tail, , contains a {\it single} combination . We show that the above expression for in the tail actually applies all the way down to the mid-gap.

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