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We show that the recently proposed DBI extension of new massive gravity emerges naturally as a counterterm in AdS. The resulting on-shell Euclidean action is independent of the cut-off at zero temperature. We also find that the same choice of counterterm gives the usual area law for the AdS Schwarzschild black hole entropy in a cut-off independent manner. The parameter values of the resulting counterterm action correspond to a theory in the context of AdS/CFT. We rewrite this theory in terms of the gauge field that is used to recast 3D gravity as a Chern-Simons theory.

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