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Based on the recent result of Peter Koymans and Adam Morgan, who proved that there are infinitely many nonisomorphic hyperelliptic curves of any genus whose Jacobian has rank 1 over any number field, we prove the same result for rank 2; however, our curves do not have simple Jacobians, instead they factor into two rank 1 Jacobians. We also discuss results about higher rank Jacobians of small genus curves. This is joint work with Sun Woo Park.