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UPDATE ROW_COUNT
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Looking at (and testing) it after seeing Dominique's usage, my understanding is that it's a scalar expression, one could achieve the same by saying:

```  (PARTITION BY 'Reindeer' ... ) ```

It simply means the partitioning is based on the exact same value for all rows, much like GROUP BY and as opposed to the ORDER BY clause where a constant integer indicates the column index to order by.