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Hello Elaina,
It is correct.
It is simply the first two characters (year) of the assembly lot code. It is not an encoded two-digit date code.
Also,
I think what may be causing the confusion is that there is an "or" in the "item" description. There are two possibilities; datecode or lot code.
The field can show the first two digits of the date code, or, part of the lot code.
The example document shows "39" - which obviously is not a valid year (2039?), but it does match the first two digits of the lot code (31T).