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It is not known. The Rhind Papyrus describes how the area of a circle is related to pi where pi was estimated as (4/3)4 ≈ 3.1605 (approx).

The Rhind Papyrus dates from around 1700 BCE. So either very ancient people used pi = 3 or else they were later people who were dogmatically required to use pi = 3.

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Q: Who were the first group of people known to calculate the area of a circle using a pi approximation of 3?
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