First, we need to show that $\phi(H)$ is non-empty. Since $H$ is a subgroup of $G$, it contains the identity element $e$ of $G$. Then, $\phi(e)$ is the identity element $e'$ of $G'$, because $\phi$ is a homomorphism. So, $e' \in \phi(H)$, and $\phi(H)$ is
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