Article Review 5 Reasons For Love Online Bingo - 2099 Words

Article 29 – 5 reasons to love online bingo It is the social online casino game of our time and is one that is played up and down the country by thousands daily. Online bingo is a game that is simple enough in premise, but has enough complexity to keep people engaged. The following looks at why online bingo is such an easy game to fall in love with. Reason 1 – Play anywhere and everywhere you wish Do you remember the days of bingo’s past? The times when you would have to venture out to a smoke filled town hall to play? Well thanks to the introduction of Internet and online bingo, players can now player whenever and wherever they wish. No longer do you even need to take a seat anywhere to play, simply log-on to an online casino via a computer or smartphone, select a bingo game of choice and start playing. It really is just that simple! Reason 2 – Everyone is a winner Unlike slot games, online bingo is a game that pays out a fair amount to players on a regular basis. What this means is that from the huge jackpots to the token prizes, there is plenty up for grabs whenever you sit down to play a ticket or two. It is reported that up to  £4 million is handed out in prizes every single day to online bingo players, that stat in itself stands for a lot. Reason 3- Bingo is brain training Have you ever wondered what makes up those brain-training games that you see advertised everywhere? Well it may come as a surprise, but bingo games actually feature in various titles in suchShow MoreRelatedManagement Course: Mba−10 General Management215330 Words   |  862 PagesHarvard Business Review Finance Articles The Power of Management Capital Feigenbaum−Feigenbaum International Management, Sixth Edition Hodgetts−Luthans−Doh Contemporary Management, Fourth Edition Jones−George Driving Shareholder Value Morin−Jarrell Leadership, Fifth Edition Hughes−Ginnett−Curphy The Art of M A: Merger/Acquisitions/Buyout Guide, Third Edition Reed−Lajoux and others . . . This book was printed on recycled paper. Management http://www.mhhe.com/primis/online/ CopyrightRead MoreMarketing Management 14th Edition Test Bank Kotler Test Bank173911 Words   |  696 Pageskeeping, and growing customers through creating, delivering, and communicating superior customer value. A) Marketing management B) Knowledge management C) Operations management D) Strategic management E) Distribution management Answer: A Page Ref: 5 Objective: 2 Difficulty: Easy 3) Identify the correct statement about marketing management. A) It is primarily concerned with the systematic gathering, recording, and analysis of data about issues related to marketing products and services. Read MoreLogical Reasoning189930 Words   |  760 Pagesinformal logic – keeping an eye on the sorts of arguments found in books on formal logic – forget, or underplay, how much of our daily reasoning is concerned not with arguments leading to truth-valued conclusions but with making choices, assessing reasons, seeking advice, etc. Dowden gets the balance and the emphasis right. Norman Swartz, Simon Fraser University v Acknowledgments For the 1993 edition: The following friends and colleagues deserve thanks for their help and encouragement withRead MoreStrategic Marketing Management337596 Words   |  1351 Pageseconomic, social and technological environments Coming to terms with the industry and market breakpoints Coming to terms with the very different future: the implications for marketing planning Approaches to environmental analysis and scanning Summary 5 Approaches to customer analysis 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 Learning objectives Introduction Coming to terms with buyer behaviour Factors influencing consumer behaviour The buying decision process The rise of the new consumer and the implications

Knowledge Management and Organizational Knowledge - 882 Words

Nowadays, successful organizations adopted the socio-technical systems information and knowledge management has become increasingly importance to businesses. Knowledge Management process continues to enable managers and employees with valuable understanding of their business environment and knowledge to make strategic business decisions. This essay will explain data, information and knowledge as well as the socio-technical system, knowledge management, organizational knowledge and organizational learning. We will also discuss the relationship between organizational knowledge and organizational learning as well as the affect that knowledge management has on each of these concepts. However, in order to understand Knowledge Management, we†¦show more content†¦Organizational Learning - The ability of an organization to adapt accordingly to changes identified in an environment from experience and knowledge (Argote, L. (1999). What is learned by an organization is committed to organizational memory or knowledge, which is continually updated. Socio-technical System- Organizational structure realizing and identifying the interaction between social structures and technological systems. Relationships between Organizational Knowledge and Organizational LearningThe relationship between organizational knowledge and organizational learning is one of interconnectivity. As we have already established, organizational knowledge is the produced knowledge that an organization has accumulated, disseminated and stored as a result of the knowledge management process. Organizational learning is the ability of an organization to learn from experience and knowledge in order to adapt and enable itself to increase efficiency, productivity and better decision making. These two things are very much connected to each other in what can be described as a looping process. As organizational knowledge is created and maintained through the Knowledge Management process employees and managers utilize the organizational knowledge to increase their ability to be more productive, creates innovation and ultimately increase the organizations bottom line. The data or information gleaned in an organization s learning process, onceShow MoreRelatedKnowledge Management and Organizational Learning14946 Words   |  60 PagesLund Institute of Economic Research Working Paper Series Knowledge Management and Organizational Learning: Fundamental Concepts for Theory and Practice 2005/3 Ron Sanchez Ron Sanchez, Professor of Management Copenhagen Business School, Solbjergvej 3 - 3rd floor, DK-2000 Frederiksberg, Denmark, sanchez@cbs.dk Lindà ©n Visiting Professor in Industrial Analysis, Institute of Economic Research, Lund, Sweden Abstract This paper investigates several issues regarding the nature, domain, conceptualRead MoreKnowledge Management as an Organizational Tool Essay949 Words   |  4 PagesKnowledge Management is a tool that uses internet technologies to put large amounts of data online using a company’s intranet. This set up creates a central depository of a company’s information. This gives all employees within a company access to the vast wealth of knowledge a company has created. This knowledge can consist of many different types of information. Some examples are client knowledge, knowledge of process, knowledge in the memory of the firm, knowledge from relationships, and physicalRead MoreOrganizational Learning and Knowledge Management in Mcdonalds3749 Words   |  15 PagesMODULE NUMBER: HRM 4065 ORGANIZATIONAL LEARNING AND DEVELOPMENT REPORT TOPIC: An agreed case study report on organization learning and development analyzing appropriate knowledge management, design, development and learning choices available. MODULE LEADER: PROFESSOR DEREK MILES STUDENT NUMBER: M00373290 SUBMITTED ON: 30TH APRIL 2012 AT MIDDLESEX UNIVERSITY HENDON CAMPUS. CONTENTS: 1. Executive summary 2. Introduction to the report 3. Company Overview 4. TheRead MoreThe Importance Of Knowledge Management Systems And Their Positive Effect On Organizational Performance1926 Words   |  8 Pagesaids and funds. These require a significant importance being put to knowledge management. The research has shown that use of knowledge management can help in understanding the performance in the organizations and (Davenport and Prusak, 1998). Other more recent studies like done by Fugate et al. (2008) and Huang and Chen (2009) also have talked on the importance of knowledge management systems and their positive effect on organizational performance. The aim of this report is to analyze the informationRead MoreThe Role Of Social Media On Organizational Performance And Correct Decision Making992 Words   |  4 PagesKnowledge is power, which has already been regarded as the essential organizational source in organizational strategy (James, 2004) and knowledge can give organizations competitive advantage so as to face the fierce competition in today’s market environment(Erden et al., 2008). At the same time, utilizing the knowledge can contribute to the good organizational performance and correct decision making, which plays a significant role in organizational innovation (Laudon and Laudon, 2006). KnowledgeRead MoreEssay on MBA detail course outline1314 Words   |  6 Pages(Evening): 1.5 years (Quarters, 3, 4, 7, 8 14) General Management 1st Quarter Effective : Spring Quarter 2011 Human Resource Management Finance Accounting Banking Finance †¢ Organizational Communication †¢ Organizational Communication †¢ Organizational Communication †¢ Organizational Communication †¢ Principles of Management †¢ Principles of Management †¢ Principles of Management †¢ Principles of Management †¢ Research Methods †¢ Research Methods †¢ ResearchRead MoreThe Importance Of Knowledge Management And Information969 Words   |  4 Pages Knowledge management and information is the process of capturing, developing, sharing, and effectively using organizational knowledge.It refers to a multi-disciplinary approach to achieving organizational objectives by making the best use of knowledge. It includes the fields of business administration, information systems, management, library, and information sciences. Other fields may contribute to research, including information and media, computer science, public health, and public policy. ManyRead MoreApplying Social Technical Theory in Knowledge Management (Km)1058 Words   |  5 PagesApplying Social Technical Theory in Knowledge Management (KM) The theme of my paper pertains to the application of Social Technical Theory in Knowledge Management. Technology has changed the operation of business organizations around the world. Applying socio-technical theories in knowledge management advances the ability of one organization to rapidly disseminate and share information vital to the fast, sophisticated and highly demanding information technology superhighway. Timely andRead MoreEssay On Knowledge Sharing1479 Words   |  6 Pagesadvantage through knowledge sharing has been constantly overlook and ignored in less developing countries like Pakistan. Under the current study attempt was made to delineate the factors that enhance, facilitates and influence knowledge sharing in developing countries. The current research focuses on banking sector and made contribution in Pakistani scholarly circle within the context of banks. The limited evidences are found that focus on these variable in banking context. Organizational fact ors selectedRead MoreDefinition Of Organizational Management Approach1463 Words   |  6 PagesAssignment Choice #1: Organizational Management Approach Analysis Historical approaches to management have influenced contemporary managerial theories and approaches (Colorado State University - Global Campus, 2015). Current approaches and designs â€Å"can be greatly aided by looking seriously at what clever minds attempted in the past† (Cummings Bridgman, 2011, p. 90); however, historical conventions should not restrict thinking in the future (Cummings Bridgman, 2011). First, a contemporary theory

Demolition Man Essay Example For Students

Demolition Man Essay Demolition ManDemolition Man is an action/science fiction movie staring Sylvester Stallone as a police officer named John Spartan, Wesley Snipes as a criminal named Simon Phoenix, and Sandra Bullock as an SAPD officer named Lenina Huxley. The movie begins in the year 1996 in the out of control city of Los Angeles. The city is out of control. John Spartan arrests Simon Phoenix for a hostage situation, but the hostages are killed and Spartan is charged with their murders. Both men are then sent to a prison where they are to be frozen until their parole. In 2023 when Phoenix is thawed out for his parole hearing he kills some prison officers and then he escapes. Because of Phoenixs actions Spartan is thawed out in order to recapture Phoenix. After Spartan is released he teams up with Lenina Huxley. Spartan and Phoenix have been frozen for 36 years. When they are released the city has changed dramatically, it is now a computerized society called San Angeles. In the city of San Angeles there is no chaos, everything is controlled and in complete harmony. In San Angeles everything that is harmful to people is illegal. Smoking, drinking, salt, caffeine, spicy foods, meat, and contact sports have been banned. This computerized society can keep track of every citizen because they all have a microchip in their bodies and there are cameras on every corner. There are fines for cursing and dirty jokes. The music that the citizens in San Angeles listen to is commercial tunes. Taco Bell is the only restaurant because of the franchise war. San Angeles has a lot of control of its citizens. There is rarely any physical contact, the clothing is bland and it covers up most of the body. Fluid transfer is illegal so women have to go to a clinic and be tested in order to get pregnant. The people who will not obey the strict rules of San Angeles live underground in tunnels and sewers. They are called Scraps or Hooligans. The tunnels and sewers are very dirty, smelly and crowded. The Scraps are against the rules of San Angeles because they feel they take their freedom of choice. The Scraps drink alcohol, eat meat, and curse freely. Because of their behaviors and beliefs the Scraps are seen as outcasts from the rest of society and they are left to fend for themselves. They must steal food from above so they do not starve. Demolition Man can relate to the study of psychology because it deals with the concept of social control. Social control is how society controls how people think and behave. In the movie the city of San Angeles gives us a sense of how people would think and behave if these rules and regulations were placed upon them and some of their freedoms were taken away. In San Angeles the government has complete control over their citizens. There are so many l imitations to what a person can do. The government can monitor everything a person does, there is no privacy. All of the different restrictions cause a lack of social and mental freedoms. In San Angeles every citizen is emotionally balanced, there are no excessive like love, excitement, and anger. The citizens believe and do everything and anything their government asks of them without any questions because it is the only thing they know. The individuals do not decide what is good or bad for them the government does that for them. There is no differentiating between the citizens, everyone thinks, behaves, and views life in the same way. The freedoms and emotions are so important to the Scraps that they are willing to live in underground tunnels rather then succumb to the rules of the government of San Angeles. I do not think that a society like San Angeles could not exist today because you cannot take away the sense of individualism in a person. Besides a government would not be abl e to have total control over its citizens. The effects of living in a civilization like San Angeles would be very bad because people would not think for themselves and they would just agree with what the authority tells them to believe in. Everyone would just be the alike. They would think and behave the same way so you wouldnt be able to learn anything new about a person. No one would have any original ideas and everything would just stay the same.

Tragedy free essay sample

Arthur Millers  The Crucible  illustrates a tragedy due to intense emotional suffering brought on by the accusations of former friends, manipulation, infidelity, and ultimately the death of John Proctor. In Fitzgerald’s The Great Gatsby, Jay, the American romantic hero, devotes his life to proving himself worthy of Daisy. He would have sacrificed his freedom and his life for her, yet she couldn’t spare the time to go to his funeral and pay her condolences. While tragedy consists as a powerful medium in books and short stories, there are many real life cases of tragedy as well.For example, a mother, impaired from drinking vodka and smoking marijuana puts children and other innocent people in harms way while driving home from a weekend camping trip. This trip ends in a tragic disaster when she goes the wrong way on a highway and crashes head on with another vehicle. Eight innocent people are killed including four children. We will write a custom essay sample on Tragedy or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Overall, from a book, or from our society today, we, as humans, use tragedy to teach us to learn from the mistakes and misfortunes of others. â€Å"Tragedy is a form of drama  based on human  suffering that allows the audience to experience catharsis or pleasure from the viewing. The audience, through its viewing of a tragedy, can experience the magnified human emotions brought forth, from a safe distance. Essentially, to see suffering without having to actually suffer is what makes tragedy such a powerful medium. As humans, we may need this so that when faced with suffering of our own we are better prepared. A tragedy is a story in which the main character, usually a hero, is brought to his downfall. In Macbeth, the main character, Macbeth, despite his infallible attitude is brought to ruin by his flaw, which is his â€Å"blind ambition†.Overall, Macbeth is a man with a flaw that the witches were able to see and use for their own amusement. This ambition is exacerbated by the witches and their prophecies, thus making Macbeth a somewhat sympathetic character. In Macbeth, the audience feels throughout the play that Macbeth’s murders are for his own benefit and are cruel and unjustified. Even though Macbeth feels sorry, guilty and has doubts about what he is doing, he still goes through with these acts, which makes us feel that he should be punished and not rewarded the kingship. As a result, the audience feels the need to rid and â€Å"purge† all of these emotions about Macbeth.With the death of Macbeth, the audience finally feels the true meaning of catharsis. The Crucible’s tragedy, in the larger picture, is the downfall of what appeared to be an innocent, pristine community. In addition to this, Proctors hanging and the suffering inflicted upon his wife Elizabeth are also tragic. Although Elizabeth is a good  moral woman who would protect her husband and family with her own life, she is still falsely accused of witchcraft and imprisoned. At the end of the play, she is left without her loving husband who was everything to her.However, as well as the pain and tragedy that Elizabeth experiences; the larger tragedy revolves around all the innocent people accused of witchcraft who are imprisoned or killed, because of un-trustworthy teenage girls. In the story, the reader is easily able to connect with John Proctor due to the fact that adultery is a common culprit in tragedies today. More specifically, the audience is drawn in to experience these extreme human emotions with out the real life suffering and as a result is better prepar ed for the suffering that they may encounter. Jay Gatsby is seen as the tragic American romantic hero because he devoted his life to Daisy, yet in return suffered dire consequences. It excited him, too, that many men had already loved Daisyit increased her value in his eyes. (Fitzgerald 119) He accumulated wealth to impress her, moved from his native land to be near her, held lavish house parties to attract her, battled Tom to win her over, and most importantly took the blame for killing Myrtle, which lead to his death. His biggest flaw is his incorrigible love for Daisy.Jay says, â€Å" your wife doesn’t love you, she’s never loved you, she loves me (Fitzgerald 137) This shows Gatsby’s stubborn attitude towards seeking Daisy’s ultimate love. Although he has achieved great success, his achievements mean little with out Daisy’s returning love. In the end, he dies because of her, which is a direct result of her impact on his life. Throughout the book, the audience feels sympathy for Gatsby because of his devotion to Daisy and her lack luster love back. In the end, though still frustrated, the audience finally feels a release of emotions by seeing Gatsby’s struggle with Daisy end. So we drove on toward death through the cooling twilight. (Fitzgerald, 116) This â€Å"purge† of emotions is the audience’s relief, which ends with the draining of their intense feelings. However, had the story ended without the death of Gatsby, the suffering would have been incomplete, leaving the reader frustrated without any emotional cleansing associated with catharsis. A widely publicized real life tragedy revolved around a New York mom who had at least 10 drinks and smoked marijuana before driving five children the wrong way down a highway and crashing head on into an SUV.She was killed instantly and also took the lives of her 2-year-old daughter and three nieces, also in her van, as well as three men who were in the SUV. Her 5-year-old son was the lone survivor of the crash. â€Å"Schuler had a blood alcohol content of . 19, more than double the legal limit, and was also impaired by marijuana, which just further exacerbated the problem†, according to state attorney Janet Difiore. At one point her 8-year-old niece called her father to say her aunt was behaving strangely. Unfortunately, while the family attempted to monitor Schuler and the children’s location, they were unsuccessful.An event, which results in the untimely death of young children, always evokes tremendous emotion. This event, well popularized and viewed by many, serves as a key reminder in helping us deal with suffering we may experience on our own. By reading about this story, we feel these emotions from a safe distance to better prepare ourselves. This is why a topic/event with tragedy like this draws a large amount of attention. Tragedies in all of these examples are similar due to the effect they have on the audience.In each of these books and real life events, there are common elements causing an emotional effect on the audience. For the most part, these events are the down fall and â€Å"tragic flaws† of the main characters. For example, in The Crucible and The Great Gatsby, Jay Gatsby and John Proctor are driven and flawed by love and romance. In The Great Gatsby, Jay is unable to let his love for Daisy go, thus causing him to go to great lengths to be with her. In The Crucible John Proctor also shows his flaw through love when he commits adultery.Overall, in both of these books, the characters are so indulged in their love they loose sight of what is dangerous and could cause them harm. On the other hand these tragedies also have many differences. For instance, the real life example allows the audience to learn from the tragedy for their own benefit while with Macbeth the audience feels more relieved and cleansed at the result. More specifically, the real life example provides you with less of an emotional roller coaster because you are getting all the information at once.In literature, there is a deliberate design by the author to build you up slowly to a crescendo, culminating in an emotional release. In the real life situation the news media broadcasts the suffering instantaneously, having almost a numbing effect. In conclusion, whether it is a real life example or within a book, tragedy evokes a variety of emotions in the audience. Aristotle describes catharsis as â€Å"the purging of the emotions of pity and fear that are aroused in the viewer of a tragedy† (Aristotle 23).Debate continues about what Aristotle actually means by catharsis, but the concept is â€Å"linked to the positive social function of tragedy†. In Macbeth, Macbeth’s life frustrates the audience with his cruel and unjust ways of becoming king. By the end of the story, when Macbeth dies, this emotion is finally released and the audience is relieved. In The Crucible, John Proctor, by cheating on his wife, causes tragedy to be inflicted upon not only himself but also on his wife. Ultimately, this allows the audience to experience this pain and suffering from a distance, and learn from these mistakes. In the Great Gatsby, at first blush, Jay is seen as a romantic because he did everything for Daisy. However, pursuit of a material life is ultimately his undoing, and in the long run he is faced with dire consequences. Lastly, tragedy is also seen in the death of 8 innocent people in the car crash, a crash that could have been prevented. This also allows the audience to learn from these mistakes and use the emotional experience to better equip themselves. Essentially, to see suffering without having to actually suffer is what makes tragedy such a powerful medium.

Better Use Redneck with Care

Better Use Redneck with Care Better Use Redneck with Care Better Use Redneck with Care By Maeve Maddox A man speaking in a city board meeting in my town this week got into trouble for using the word redneck. He was arguing that shrinking city funds would be better spent on maintaining the local cable access channel than on Christmas lights in the town square. He stirred up a storm of protest when he referred to the city employees putting up the lights as highly-paid rednecks. The uproar got me thinking about this term, one of my least favorite group designators. As far as I can interpret the mans remarks, he wanted to convey the thought that the cable channel, as a means of communicating the workings of the city government, is of more value than mere seasonal display. So why did he choose to call the men putting up the lights rednecks instead of, say, workers? The mind functions in curious ways. Our thoughts reside there in layers upon layers. Sometimes what may seem like an insignificant word choice reveals a layer we may not even be aware of. The speaker came to Arkansas from California. He may not realize it himself, but his choice of the word redneck suggests an attitude of superiority towards the natives. For those readers who may not be familiar with the term, redneck in modern American usage is used chiefly to refer to a perceived type of Southern white person. The term has been used in other contexts with other possible origins, but the term, as popularized by standup comic Jeff Foxworthy, probably derives from the sunburned necks of outdoor laborers. Foxworthy, a native of Georgia, can use the term with impunity, rather as black comics can get away with nigger. Depending upon who is using it, the word redneck can be inoffensive or deeply pejorative. As used in country songs, redneck carries a connotation of pride along with the characteristics of patriotism, belief in God, self-respect, and independence. This kind of redneck probably drives a pickup truck and owns a gun. Hes not afraid of hard work and would rather go hungry than accept charity in any form. He mistrusts overeducated people and prefers the country or small town to the city. As used by outsiders, redneck seems to have replaced hillbilly as a word to stereotype Southerners. As a term of opprobrium, a redneck not only drives a pickup and owns a gun, he is loud, often drunk, ignorant, bigoted, xenophobic, and trashy. He dresses like a slob, speaks with a southern accent, fills his yard with junk, and has no appreciation of the finer things of life. The term has its uses, both in conversation and in writing, but it can be volatile and is best used with care. Youll find further information about redneck and other terms often applied in a pejorative sense to Southerners here (Update: page no longer online). Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Expressions category, check our popular posts, or choose a related post below:Apply to, Apply for, and Apply withEmail EtiquetteNominalized Verbs

The Definition of Deviance Amplification

The Definition of Deviance Amplification Deviance amplification is a process, often performed by the mass media, in which the extent and seriousness of deviant behavior is exaggerated. The effect is to create a greater awareness and interest in deviance which results in more deviance being uncovered, giving the impression that the initial exaggeration was actually a true representation. Leslie T. Wilkins originally reported on the process of deviant amplification in 1964 but it was popularized by Stanely Cohens book  Folk Devils and Moral Panic,  published in 1972. What Is Deviant Behavior? Deviant behavior is a broad term because it covers anything that goes against social norms. This could mean anything from minor crimes like graffiti  to more serious crimes like robbery. Adolescent deviant behavior is often a source of deviance amplification. Local news will sometimes report on a something like a new teen drinking game, implying it is a popular trend instead of the actions of one group. This kind of reporting can sometimes start the trends they were reporting on although each new act will add credence to the initial report.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Deviant Amplification Process Deviant amplification usually starts when one act that is either illegal or against social morals that wouldnt normally be worth of media attention becomes newsworthy. The incident is reported on as being part of a pattern. Once an incident becomes the focus of the media, other similar stories that normally wouldnt make the news fall under this new media focus and become newsworthy. This begins to create the pattern that was initially reported on. The reports can also make the action seem cool or socially acceptable, leading to more people to try it, which reinforces the pattern. It can be hard to prove when deviant amplification is happening because each new event seems to validate the initial claim.   Sometimes citizens will pressure law enforcement and government to take action against the perceived  deviant threat. This can mean anything from the passage of new laws to harsher punishments and sentences on existing laws. This pressure from the citizens often requires  law enforcement to put more resources into an issue that it actually warrants. One of the main problems with deviance amplification is that it makes a problem seem much larger than it is. Which in the process can help create a problem where there was none.  Deviance amplification can be part of a moral panic but they do not always cause them.   This hyper-focus on minor issues can also cause communities to miss larger issues they need to be focusing attention and resources on. It can make social issues harder to solve because all of the focus is going to an event that was artificially created. The deviant amplification process can also cause certain social groups to be discriminated against if the behavior is tied to that group.

Design Patterns Research Paper Example | Topics and Well Written Essays - 1000 words

Design Patterns - Research Paper Example This notification can encompass particular information and facts regarding the topic of the notification. However, the subject can eliminate any of the observers from the list when there is no need for a specific observer to be informed regarding these events or changes with respect to the matter they are registered with the subject. They are used when there is need maintaining constancy and reliability between connected objects while not affecting coupling characteristics of classes. For instance, these patterns can be used when an object needs to be able to inform other objects without having suppositions on the subject of those objects. Moreover, the observer pattern consists of the following elements (Osmani, 2012): Subject: This component is responsible for managing the operation related to observers, such as facilitating, eliminating, or adding observers into the list (Osmani, 2012). Observer: This component is responsible for offering an up to date interface for observers that need to be informed regarding any change (Osmani, 2012). Concrete Subject: This component is responsible for managing transmission and notifications to objects regarding changes to state. It also maintains the state of ConcreteObservers (Osmani, 2012). ConcreteObserver: This component is responsible for establishing and maintaining a reference to the ConcreteSubject. In addition, it also implements a modern interface for the observer to make sure that state is compatible with the subject (Osmani, 2012). Advantages The observer patterns allow software development teams to think effectively about the associations among various elements of software application (Osmani, 2012; Toal, 2012). These patterns also allow software engineers to recognize what application layers have straight associations which could be alternatively replaced with a set of observers and subjects. In this scenario, these patterns can be effectively employed for splitting a software application into a number of sm aller, more freely joined components with the purpose of improving code maintenance as well as competency for re-use (Osmani, 2012; Sud, 2013). These patterns are useful for establishing and maintaining a one-to-many dependency between objects (Marakana Inc., 2013). These patterns provide an excellent communication mechanism for instance, when there is a change in the state all the related objects are notified automatically (Marakana Inc., 2013) Disadvantages As discussed above, these patterns support for decoupling however by decoupling various objects, it can frequently turn out to be hard to get assurance that specific components of a software application are working as they are expected to do (Osmani, 2012; Pierry, 2013). It is believed that in these patterns subscribers are relatively unaware of the subsistence of each other as well as are sightless to the price of switching publishers. Hence, because of this dynamic association between objects, it is difficult to track the upd ate dependence (Osmani, 2012; Sud, 2013). 2. The Factory Pattern The Factory pattern is also one of the most important creational patterns, which is concerned with the concept of developing objects. However, it differentiates with other patterns of the base of a property and that is it doesn't openly require software engineers to make use of use of a constructor. On the other hand, a Factory provides software engineers

Business management Essay Example | Topics and Well Written Essays - 2000 words - 1

Business management - Essay Example Although aspiring to be called an international bank, its home based in France does give Eurobank a somewhat influenced culture and therefore a national expression. Interesting enough, Eurobank has an ill defined corporate culture which is essentially different from a purely national culture, yet its corporate culture is an overt expression of French national values and traits. This may be attributed to presence of the French upper management and corporate policies and dual official languages on one hand while its English locale and the hundreds of local English employees not expatriates on the other hand. Although the General Manager of the bank describes Eurobank as largely transnational, but down the line other managers have taken a rather different outlook. It has been labelled as a national bank but with successful footholds and ventures overseas its international stance cannot be overlooked, perhaps amalgamating through acquisitions as an international bank. Nevertheless in true essence Eurobank in England is not given the recognition of a global organization by some quarters. Though much is being done to remove the traces of national culture and give it an international visage with a high degree of autonomy and hiring of mostly English staff, still we are able to detect the distinct national cultural characteristics influencing their corporate culture. It is the Eurobank policies and functioning style that remain normative to both national and corporate cultures. Preserving its national culture has its merits too, for e.g. as we can see with its broad customer base and customer loyalty agenda. Its national identity does hold importance to its customer groups and that is the reason they seem to have inducted that into their business strategies. The idea behind such a blend is that customers tend to correlate and recognize the culture of the institution that they are entrusting with their assets. Although the increasingly European cultural styles

Jokes and Their Relation to the Unconscious Essay Example for Free

Jokes and Their Relation to the Unconscious Essay As Antonia Peacocke quotes in her essay, â€Å"The show Family Guy is one of the first in history that has been canceled not just once, but twice† (300-301). The show was brought back in August 2000 and again in July 2001 when fans could not get enough of the adult cartoon. As well as being a fan favorite, Family Guy is also a controversial topic for critics all over the world. In the essay, â€Å"Family Guy and Freud: Jokes and Their Relation to the Unconscious†, Antonia Peacocke analyzes the show and gives her reasons why it is not all negative and crude humor. Antonia Peacocke is a student at Harvard University. She is also a National Merit Scholar, and has won awards such as the Catherine Fairfax MacRae prize for Excellence in both English and Mathematics. She was asked to write this essay specifically for the book They Say, I say: with readings. The Peacocke’s main point of her entire essay is that she wants to let readers know why Family Guy is not a bad show, in her and others opinions, but one that has been criticized for solely bringing entertainment. Peacocke does a successful job in portraying this, but it is not completely clear until the end, where her thesis can be found. The very last sentence of the essay is her thesis: â€Å"While I love Family Guy as much as any fan, it’s important not to lose sight of what’s truly unfunny in real life – even as we appreciate what is hilarious in fiction† (Peacocke 308). Peacocke’s thesis could be a little more clear throughout her essay, therefore, I do not feel it is as effective as it could be, but the author clearly states her argument and presents her case. Peacocke starts the essay of by saying, â€Å" Before I was such a devotee, however, I was adamantly opposed to the program for its particular brand of humor† (Peacocke 300). She makes it clear her feelings about the show in the very beginning. Although she is a fan, she at one time disliked the show. She quotes Stephen Dubner, co-author of Freakonomics, as saying â€Å"a cartoon comedy that packs more gags per minute about race, sex, incest, bestiality, etc. than any other show [he] can think of† (Peacocke 300). She backs up her one time opinions by saying â€Å"It will come as no surprise that I was not alone in this view; many still denounce Family Guy as bigoted and crude† (Peacocke 300). Although the show is currently very successful, she says â€Å"It must be one of the few shows in television history that has been canceled not only once, but twice†¦ The show ran until August 2000, but was besieged by so many complaints†¦that Fox shelved it until July 2001† (Peacocke 300). Also, she says, â€Å"I must admit, I can see how parts of the show might seem offensive if taken at face value† (Peacocke 302). At one point Peacocke realized, â€Å" [I found myself] forced to give Family Guy a chance. It was simply everywhere â€Å" (Peacocke 302). One of Peacocke’s main points is that Family Guy has gained much positive attention. On Facebook, as Peacocke explains, â€Å"there are 23 universal separate Family Guy groups with a combined membership of 1,669 people (compared with only 6 groups protesting against Family Guy, with 105 members total). Users of the well-respected Internet Movie Database rate the show 8.8 out of 10† (Peacocke 303). As you can see, â€Å"among the public and within the industry, the show receives fantastic acclaim; it has won eight awards, including three primetime Emmys† (Peacocke 303). Also, when the show was on the brink of cancellation, â€Å" fans provided the brute source necessary to get it back on the air† (Peacocke 303). The more she was around the show, the more positively she viewed it. Peacocke then goes on to say that those who do not often watch the show, â€Å"could easily come to think that the cartoon takes pleasure in controversial humor just for its own s ake† Peacocke 303). The next main point that Peacocke claims is that viewers who â€Å"pay more attention and think about the creators’ intentions can see that Family Guy intelligently satirizes some aspects of American culture† (Peacocke 304). The next paragraph is a segment from an episode in season 4, which shows Stewie reading a book only because it was on the Oprah reading list. Peacocke says â€Å" [Brian and] Stewie demonstrate insightfully and comically how Americans are willing to follow the instructions of a celebrity blindly – and less willing to admit that they are doing so† (Peacocke 304). The jokes that Family Guy is known for, â€Å"attract a different kind of viewer. Such viewers are†¦conscious and critical viewers† (Peacocke 304). In my opinion, the very last sentence is the most powerful in the whole essay. Peacocke states â€Å"They are not – and I cannot stress this enough, self serving as it may seem – immoral or easily manipula ted people† (304). Peacocke says that it sheds light on, and allows viewers â€Å" the ability to analyze what they are watching, the creators of Family Guy point out the weaknesses and defects of U.S. society in a mocking and sometimes intolerant way† (Peacocke 305). A good example of this is the segment from the episode â€Å"I Am Peter, Hear Me Roar.† In this episode, â€Å"the ‘instructional video’ quoted above becomes not only funny but also insightful. In its satire, viewers can recognize the sickly sweet and falsely sensitive sexism of the 1950s in observing just how conveniently self-serving the speaker of the video appears. The message of the clips denounces and ridicules sexism rather than condoning it† (Peacocke 305). The last main point that Peacocke makes is that â€Å"Family Guy does not aim to hurt, and its creators take certain measures to keep it from hitting too hard†¦ Seth MacFarlane plainly states that there are certain jokes too upsetting to certain groups to go on the air† (Peacocke 307). Also, Peacocke states that â€Å"I believe Family Guy has its intelligent points, and some of its seemingly ‘coarse’ scenes often have hidden merit† (Peacocke 308). In the next sentence Peacocke does admit that â€Å"sometimes the creators do seem cross – or, perhaps, eagerly race past – the line of indecency† (Peacocke 308). In her closing paragraph, Peacocke questions the fact that â€Å"while Family Guy can provide a sort of relief by breaking down taboos, we must still wonder whether or not these taboos exist for a reason† (Peacocke 308). All three main points that the author makes are valid, and as seen in quotes, each main topic is backed up by main points. The first main point is that Family Guy is gaining positive attention. Although this is a valid point, as seen by the popularity, and the awards, this isn’t reason enough to call the show ‘good.’ As the author states, at one point she was not a fan of the show but it later turned onto it by exposure. The content of the show did not change for her opinion to change, she just gave the show a chance and realized she liked the humor. The second main point is that the show makes intellectual references to American culture. This is a valid point as to why the show is good. Any show with a little bit of substance makes references to the past and current topics. It tells what is going on in the world, and explains topics everybody should be aware of. The last main point is that Family Guy breaks rules that no other major TV program or network has been able to break. Although many critics believe these are rules that shouldn’t be broken, the creators believe it needs to be done. This makes it a ‘good’ because it crosses boundaries that others are afraid to cross. Conclusion will link back to first comparison to Freud. Work Cited Peacocke, Antonia. â€Å"Family Guy and Freud: Jokes and Their Relation to the Unconscious.† They Say, I Say: with readings. Ed. Cathy Birkenstein, Russel Durst, and Gerald Graff. New York: W.W. Norton, 2012. 300-308. Print.

Metaphor, Sociobiology, and Nature vs. Nurture: The Biological Battle o

Metaphor, Sociobiology, and Nature vs. Nurture: The Biological Battle of the Century Ladies and Gentlemen! I am proud to present one of the biggest and longest-running biological battles of the century! Tonight we recap the surprising nature vs. nurture fight. The following pages will explain the highlights, but if you want to learn about this war in its entirety, you’ll find the blow-by-blow account available to the public in Connie Barlow’s collection, From Gaia to Selfish Genes, in a chapter entitled "Nature, Nurture, and Sociobiology." What began this brawl of the biologists? Was it a woman? No. Was it a war? No. It was a metaphor. And the metaphor states that society is an organism. This metaphor believes that individuals in a society work together in order to function like an organism. But this isn’t the dispute—the real fight lies within the question, How is this organism organized? In other words, do we inherently possess the knowledge to function like an organism or are we taught this skill? Here come the returning champs now! In the Blue Corner—The Returning Champs: The Anti-Sociobiologists Weighing in with a professor from Harvard, a chair of neurobiology from the Open University, and a chair of psychology from Northwestern University, the anti-sociobiologists defend the idea that genes and environment work together, much like a dance, in which the individual is taught social behavior. In an excerpt from their book, Not in Our Genes, theorists Richard Lewontin from Harvard, Steven Rose from the Open University, and Leon Kamin from Northeastern University propose, as the title suggests, that social behavior is not genetic. Rather, it is taught or influenced by an individual’s surrounding environment... ...as hard, scientific evidence, both are lacking. For example, the sociobiologists cannot prove that altruism is a gene, yet the anti-sociobiologists cannot prove otherwise. Thus, the both the sociobiologists and the anti-sociobiologists attempt to answer how an organism is organized with theory—and neither have produced a hypothesis that is agreed upon by a consensus. Yet both positions assume that the metaphor that society is an organism is a commonly accepted idea. Robert Wright reflects my skepticism perfectly when he warns, "this blurring of the line between society and organism is a delicate matter" (150). It appears that, at least for the time being, both sides are going to have to agree to disagree. Work Cited Barlow, Connie, ed. From Gaia to Selfish Genes: Selected Writings in the Life Sciences. Cambridge, Massachusetts: MIT University Press, 1991.

Aging and Disability Worksheet Essay

Identify 2 or 3 issues faced by the aging population. 1 Unequal treatment in employment – Poverty 2 Face prejudice and discrimination – Ageism 3 Face isolation – Elderly Abuse What is ageism? How does ageism influence the presence of diversity in society? Ageism is the practice of prejudice of discrimination to the elderly. The way that ageism influences the presence of diversity in society is by robbing them of their of their choices, independence and treating them with disrespect. Also by treating them as if they are unable to handle things for themselves as if they have reverted back to an infantile stage. It should be noted that the elderly have a lot of knowledge and wisdom to bring to the table and are able to do the same if not more than society gives them credit for. Society also views elderly people as sickly, frail and unable to take care of themselves. What is the Americans with Disabilities Act (ADA)? How does the ADA address issues for the aging population? The ADA is a civil rights law that was enacted in 1990 and that prohibits discrimination against individuals with disabilities. This law addresses the issues for the aging population by protecting anyone that is 40+ from being fired or from employment discrimination. It is designed to protect the aging and/or elderly from being passed over for a promotion or raise, however, it is difficult. This law does in fact protect against being fired, however, it does not do anything for helping obtain employment because of your age. This law was definitely designed to protect the elderly or aging, and in short does help to some degree, however, I personally believe that there is more that can be done to protect the aging or elderly a little more than they are. What is being done to address the issues you identified? There are political organizations that have been established for the elderly. One of those organizations is the Older Women’s League (OWL), which was founded in 1980. Then there is the largest organization is the American Association of Retired Persons (AARP), which was founded in 1958. These organizations were founded for the sole purpose of helping the elderly and aging with finding discounts for health insurance, nursing home reform, pension reform, social security benefits and a muriad of other resourses for the aging and the elderly. The AAPR represents 1 in every 4 registered voters in the Untied States. (AARP 2003) Is the number of aging population expected to rise in numbers or decrease? The number of aging population is expected to rise in numbers. According to the Bureau of Census 2008c, the population of baby boomers What types of legislation may or may not be affected by the aging population? How does poverty affect the aging population? Part II Answer the following questions in 100 to 200 words each. Provide citations for all the sources you use. What does the ADA provide for people with disabilities? How have people with disabilities been treated in the past? How has the attitude toward people with disabilities changed over time? What are some unique circumstances or issues encountered by people with disabilities? What is being done to address those issues? What types of legislation have been introduced to address issues faced by people with disabilities? References: http://www.alfa.org/ Racial and Ethnic Groups, Thirteenth edition, by Richard T. Schaefer. Published by Merrill Prentice Hall. Copyright  © 2012 by Pearson Education, Inc. American Disabilities Act National Nedwork, Information, Guidance, and Training on the American with Disability Act /adata.org/

Report Writing Essay

Eve-teasing is a widespread and most disturbing reality for the girls in Bangladesh. We hardly find reports of eve-teasing in the media until it ends up causing some serious damage to somebody. But we do come across, at times, news and reports telling us how terrifying the consequences of eve-teasing can be. And such news does not usually attract public attention until it grows into a national issue. According to figures released by the Ain-O-Shalish Kendra (ASK) human rights organization, 14 girls and women have taken their own lives over the past four months across the country as a direct result of the insults. It is also a great problem in Sylhet. Young girls, especially school and college girls and female workers top the list as victims of eve-teasing. Given the strict patriarchal social system, it is almost daring for a woman to protest against teasing in public places. In our society, it is usually the girl who is finally held responsible for such incidents. No matter how weak those laws are, most people are unaware of their existence as they are hardly aware of any implementation of those. Considering all these, we can say that laws alone are not enough. What we need most is to change the overall social outlook toward women. We need to raise collective voice and take action against eve-teasing, as we also need to increase the gender-sensitivity of the police force. X,08 Aug 2010: The problems of load-shedding is acute in Sylhet. Bangladesh faces one of the worst power crises of the world. Due to lack of planned investment in the power sector, load shedding has become the flagship phenomenon of the country’s electricity system. Some parts of the city of Sylhet may face black outs for more than 8 hours a day during the very hot summer. The power shortage eventually leads to the failure of water supply. Most citizens have to face a miserable life with little water and no electricity under the scorching tropical heat. There are no significant power station projects in the pipeline and the situation is going to get worse in the coming years. All on a sudden street are covered with darkness with a few lights of cars and buses flashing here and there. Thieves and pick-pockets freely prowl on the street. The suffering of the students due  to load-shedding is beggar’s description. The curse of load-shedding does not spare even the hospital. In fact, words are inadequate to give proper vent to the discomfort and harm caused in our life by this unscrupulous practice of load-shedding. All concerned must join their hands to liberate the people from the curse of load-shedding at a very early date.

Terrorism and Homeland Security Essay Example

Terrorism and Homeland Security Essay Example Terrorism and Homeland Security Essay Terrorism and Homeland Security Essay Essay Topic: Fun Home Terrorism and Homeland Security Name: Course: Institution: Tutor: Date: Terrorism and Homeland Security The terrorism attack threat on Anytown brought to the department of security’s attention is the main drive for the writing of this report. Through research and investigation, it has been confirmed that the renowned terrorist group by the name Abu Nidal Organization (ANO), which conducts most of its operations from Iraq, is behind this threat. It is based in all its main funding countries like Syria, Libya and Iraq. Considering the history of its attacks and the countries it is related to, it can not be underestimated on the places and the extent of damage it is willing to do. A brief attack history of the group is that it has carried out attacks in more than twenty countries worldwide. Some of these countries include modern Palestine, United States, United Kingdom, Israel, PLO and the Arab countries. A total number of nine hundred people have either been killed or injured in all the attacks. As we have encountered them before, their main aim is to kill as many people as they can when undertaking any attack. They especially have a major hatred for the United States because of its efforts to frustrate the group’s operations since 1974. This means that the attack here will be a major one. High Risk areas According to the population data, 88.5% of Caucasians live in the woodland suburbs of Anytown while 75% of the minority resides in the apartments in the urban areas. Due to the group’s aim explained earlier, the group’s main target attacks may be the woodlands suburbs. Another main target for this place may be based on racial grounds. However, the urban areas will not be ignored. The group’s main target will be to get as many casualties as possible, so any part that can accomplish this aim will be targeted. In order to narrow down the vast area, the department has analyzed social places and the most frequented places such as the commercial buildings and social grounds (White, 2011). Malls, restaurants and other eating joints, federal buildings and the churches will be the focus in both the urban areas and the suburbs. Factories with large numbers of employees are also our focus. The large buildings in this area are frequented by approximately three thousand people in a day. The social grounds are attended by approximately a thousand people per day. Since the average income for a person in this city is approximately $48,670, most of the people frequent the stores with average prices. More than 65% of the population is working adults so the most casualties will be the active adults if the attack was to take place. This is the reason why the security department is willing to deploy extra security in the main commercial buildings in the city and the factories with more than 250 employees working in the same area. Evacuation Plans Since we have confirmation that he group has already arrived in the city, the department is doing its best in finding out the areas believed to be their hiding places. The department’s main goal is to stop the attack. However, since we do not have the specific date or dates of the attack(s), our other attention is directed to finding the escape routes. In order to avoid any panic by the public, the evacuation plans are being carried out secretly or in disguise. For example, we have already contacted the major buildings at risk and informed them of having a refresher workshop with the building occupants on how to evacuate a building in case there is any incident. We have told them to carry out this activity as though they were just updating the occupants without raising any panic or suspicion. The department has also encouraged the security in the airports, and train stations to be on alert and to be extremely thorough while doing the checks. This is because we are not sure whether the weapons are already in the country or they will have to be brought in. Extra surveillance has also been placed on the most vulnerable areas mentioned (Nicholson, 2005). Since the ANO is known for hitting where it hurts the most, the schools (especially the kindergarten, elementary and high schools) are under extra surveillance and security. This is not limited to the vulnerable regions. The security has been biffed up in the region to cover all schools. The universities and other learning institutions are under the extra surveillance too. Extra cameras and other security devices have been mounted in the mentioned buildings, schools, federal buildings and the transportation grounds. Although this has been carried out indirectly in order to avoid panic, the people have been asked to avoid staying in large groups or unnecessarily staying in one building for too long. This has been done under the pretence of the attacks taking place in other countries and that it is always good to stay safe. All the attention has been driven to this attack threat and the officials in the department are determined to find the culprits. The whole city is at risk but the areas mentioned as the most vulnerable will be put under high surveillance and the necessary arrangements done in preparation of the attack. Our main priority is preventing the attack. References Carter, D. L. (2004). A Guide for State, Local, and Tribal Law Enforcement Agencies. Law Enforcement Intelligence. Retrieved from intellprogram.msu.edu/Carter_Intelligence_Guide.pdf Nicholson, W. C. (2005). Homeland security law and policy. Springfield, Illinois: Charles C. Thomas. White, J. R. (2011). Terrorism and Homeland Security. Belmont, CA: Wordsworth.

How Fiber Optics Was Invented

How Fiber Optics Was Invented Fiber optics is the contained transmission of light through long fiber rods of either glass or plastics. The light travels by process of internal reflection. The core medium of the rod or cable is more reflective than the material surrounding the core. That causes the light to keep being reflected back into the core where it can continue to travel down the fiber. Fiber optic cables are used for transmitting voice, images, and other data at close to the speed of light. Who Invented Fiber Optics? Corning Glass researchers  Robert Maurer, Donald Keck, and Peter Schultz  invented fiber optic wire or Optical Waveguide Fibers (patent #3,711,262) capable of carrying 65,000 times more information than copper wire, through which information carried by a pattern of light waves could be decoded at a destination even a thousand miles away.   Fiber optic communication methods and materials invented by  them opened the door to the commercialization of fiber optics. From long-distance telephone service to the internet and medical devices such as the endoscope, fiber optics are now a major part of modern life.   Timeline 1854: John Tyndall demonstrated to the Royal Society that light could be conducted through a curved stream of water, proving that a light signal could be bent.1880:  Alexander Graham Bell invented his Photophone, which transmitted a voice signal on a beam of light. Bell focused sunlight with a mirror and then talked into a mechanism that vibrated the mirror. At the receiving end, a detector picked up the vibrating beam and decoded it back into a voice the same way a phone did with electrical signals. However, many things - a cloudy day, for instance - could interfere with the Photophone, causing Bell to stop any further research with this invention.1880: William Wheeler invented a system of light pipes lined with a highly reflective coating that illuminated homes by using light from an electric arc lamp placed in the basement and directing the light around the home with the pipes.1888: The medical team of Roth and Reuss of Vienna used bent glass rods to illuminate body cavities.1 895: French engineer Henry Saint-Rene designed a system of bent glass rods for guiding light images in an attempt at early television. 1898: American David Smith applied for a patent on a bent glass rod device to be used as a surgical lamp.1920s: Englishman John Logie Baird and American Clarence W. Hansell patented the idea of using arrays of transparent rods to transmit images for television and facsimiles respectively.1930: German medical student Heinrich Lamm was the first person to assemble a bundle of optical fibers to carry an image. Lamms goal was to look inside inaccessible parts of the body. During his experiments, he reported transmitting the image of a light bulb. The image was of poor quality, however. His effort to file a patent was denied because of Hansells British patent.1954: Dutch scientist Abraham Van Heel and British scientist Harold H. Hopkins separately wrote papers on imaging bundles. Hopkins reported on imaging bundles of unclad fibers while Van Heel reported on simple bundles of clad fibers. He covered a bare fiber with a transparent cladding of a lower refractive index. This protected the f iber reflection surface from outside distortion and greatly reduced interference between fibers. At the time, the greatest obstacle to a viable use of fiber optics was in achieving the lowest signal (light) loss. 1961: Elias Snitzer of American Optical published a theoretical description of single-mode fibers, a fiber with a core so small it could carry light with only one waveguide mode. Snitzers idea was okay for a medical instrument looking inside the human, but the fiber had a light loss of one decibel per meter. Communications devices needed to operate over much longer distances and required a light loss of no more than ten or 20 decibels (a measurement of light) per kilometer.1964: A critical (and theoretical) specification was identified by Dr. C.K. Kao for long-range communication devices. The specification was ten or 20 decibels of light loss per kilometer, which established the standard. Kao also illustrated the need for a purer form of glass to help reduce light loss.1970: One team of researchers began experimenting with fused silica, a material capable of extreme purity with a high melting point and a low refractive index. Corning Glass researchers Robert Maurer, Donald Keck, and Peter Schultz invented fiber optic wire or Optical Waveguide Fibers (patent #3,711,262) capable of carrying 65,000 times more information than copper wire. This wire allowed for information carried by a pattern of light waves to be decoded at a destination even a thousand miles away. The team had solved the problems presented by Dr. Kao. 1975: The United States government decided to link the computers at the NORAD headquarters at Cheyenne Mountain using fiber optics to reduce interference.1977: The first optical telephone communication system was installed about 1.5 miles under downtown Chicago.  Each optical fiber carried the equivalent of 672 voice channels.By the end of the century, more than 80 percent of the worlds long-distance traffic was carried over optical fiber cables and 25 million kilometers of the cable. Maurer, Keck, and Schultz-designed cables have been installed worldwide. U.S. Army Signal Corp The following information was submitted by Richard Sturzebecher. It was originally published in the Army Corp publication Monmouth Message. In 1958, at the U.S. Army Signal Corps Labs in Fort Monmouth New Jersey, the manager of Copper Cable and Wire hated the signal transmission problems caused by lightning and water. He encouraged Manager of Materials Research Sam DiVita to find a replacement for copper wire. Sam thought glass, fiber, and light signals might work, but the engineers who worked for Sam told him a glass fiber would break. In September 1959, Sam DiVita asked 2nd Lt. Richard Sturzebecher if he knew how to write the formula for a glass fiber capable of transmitting light signals. DiVita had learned that Sturzebecher, who was attending the Signal School, had melted three triaxial glass systems using SiO2 for his 1958 senior thesis at Alfred University. Sturzebecher knew the answer. While using a microscope to measure the index-of-refraction on SiO2 glasses, Richard developed a severe headache. The 60 percent and 70 percent SiO2 glass powders under the microscope allowed higher and higher amounts of brilliant white light to pass through the microscope slide and into his eyes. Remembering the headache and the brilliant white light from high SiO2 glass, Sturzebecher knew that the formula would be ultra pure SiO2. Sturzebecher also knew that Corning made high purity SiO2 powder by oxidizing pure SiCl4 into SiO2. He suggested that DiVita use his power to award a federal contract to Corning to develop the fiber. DiVita had already worked with Corning research people. But he had to make the idea public because all research laboratories had a right to bid on a federal contract. So in 1961 and 1962, the idea of using high purity SiO2 for a glass fiber to transmit light was made public information in a bid solicitation to all research laboratories. As expected, DiVita awarded the contract to Corning Glass Works in Corning, New York in 1962. Federal funding for glass fiber optics at Corning was about $1,000,000 between 1963 and 1970. Signal Corps Federal funding of many research programs on fiber optics continued until 1985, thereby seeding this industry and making todays multibillion-dollar industry that eliminates copper wire in communications a reality. DiVita continued to come to work daily at the U.S. Army Signal Corps in his late 80s and volunteered as a consultant on nanoscience until his death at age 97 in 2010.

Explain the influence of T. S. Eliot on 20th century Arabic poetry, Essay

Explain the influence of T. S. Eliot on 20th century Arabic poetry, giving examples - Essay Example He died in 1965 but his fame did not die with him. Infact he became a model for the future generations in all parts of the world (Nobelprize.org). Eliot’s influence on English writers is well known to everyone. His books â€Å"Prufrock and other Observations†, â€Å"Four Quartets† and in particular â€Å"The Wasteland† has influenced many English writers. However, Eliot’s fame and influence did not confine itself to the borders of Europe and America. Where English poetry under Eliot’s influence moved with a steady pace, the Arabic poetry made a giant leap unleashing itself from the age old Arabic classical poetic model, the qasida, whose form, structure and pattern were laid down in the seventh century and were older than the religion Islam itself (Loya, 1971). The qasida was a couplet which consisted of two symmetrical hemistiches, separated by a caesura followed by a fixed pattern of long and short vowels. Each couplet was independent of the rest of the poem. All the couplets followed a similar rhyme scheme and meter throughout the poem. In Arabic poetry there was also restriction in the selection of themes as well. This pattern was being followed by the Arab poets without any significant changes for the past fourteen hundred centuries. The tribal Arab society gave way to the urbanized society which desperately demanded changes in the poetic form to express its message. The Arab poets became aware of the fact that the traditional qasida form consisting of fixed meter and rhyme was not sufficient to express the harsh realities of life. Despite all this the Arab poets continued to write in the traditional form till the twentieth century. The situation continued till the influence of West, in particular, the influence of T.S. Eliot changed the trend of the Arabic poetry. Many Arabic poets were deeply influenced by T.S. Eliot, whose literary work had touched all parts of the world with admiration (Loya,

The primary focus will be on the comprehensiveness of understanding Essay

The primary focus will be on the comprehensiveness of understanding the many components that are necessary to consider when desi - Essay Example The content of what children are taught in preschool and the method of teaching, or the curriculum is what measures the effectiveness and quality of learning in preschools. Programs focusing on serving 3- and 4-year-olds should decide the content of what children learn, as well as the best way to learn, if they are to improve children’s school success by enhancing their early skills and knowledge. The aim of this paper is to offer a framework that those making decisions can make use of when evaluating curriculums that would be suitable for a preschool program. Definition and scope of a preschool Children’s Health Encyclopedia defines a preschool as ‘an early childhood program in which children combine learning with play in a program run by professionally trained adults.’ Common enrolment years are children aged between ages three and five. Kids as young as two can attend preschools. While a daycare is to enable parents to work, preschool emphasis is on lear ning and development. Before the 1960s, education of young children was primarily the role of families within the home. Nowadays, most young children spend a big part of their time away from their parents. This may partly be attributed to an increase in the number of mothers working away from home. Parents also feel the desire to give their children a head start academically. The qualities of a good preschool, according to the National Institute for Early Education Research are: Helping children to expand their knowledge and build on their vocabulary Focus on literacy and language skills, plus and interactive book reading An emphasis on teaching children basic problem solving skills Learning beginning skills involving the alphabet, numerals and spatial awareness Preschools with the above qualities are only possible when the curriculum designed is good enough. That means the curriculum designer or decision-maker has in mind, the child, the parents and the teacher. For instance, when involving parents, the curricula can help make program-family partnerships or set up continuous meaningful communication with families. Curricular decisions should consider children’s ages, learning needs, cultural and linguistic backgrounds and economic status. Prior experience and training for the teacher is also important. Components of a Preschool Curriculum Given the many types of curriculum models available, there is an uncertainty regarding which models are appropriate for young children overall or more understandable to the population of the three and four year olds. Though the fields of early childhood advocates for programs that utilize what are known as Developmentally Appropriate Practices (Bredekampe & Kopple, 1997), it has not much research to endorse any single curriculum model as the best. Additionally, not a single state government or federal body directs use of just one particular curriculum in the publicly funded preschool programs. When the term curriculum is left undefined it may be very difficult to know what should be learned. It is also hard to sketch â€Å"the set of goals which are the aims of education for children† (as cited in Spodek & Saracho, 2003) in their programs, and what supports the â€Å"children’s physical, social, emotional, and cognitive growth† (as cited in Bowman et al., 2001). The National Association for the Education of Young Children (NAEYC) and the National Associ

Public Policy Analysis Essay Example | Topics and Well Written Essays - 2500 words - 1

Public Policy Analysis - Essay Example It imposes penalties for violation of security laws at higher rates than were applicable earlier. It also increases resources for the Securities and Exchange Commission. The Act is applicable to all the companies whether American or foreign if they are required to file annual and periodical reports with the SEC. This public policy analysis is to have a better appreciation of regulatory relationship between government and corporation (Zameeruddin, 2003). (Lovik, Merkel, & Bowser, 2006) The enactment of the legislation is timely in order to protect the interests of the investor from corporate fraud and to require corporate executives to enhance corporate ethical standards. These are with a view to make the US securities market robust enough to be a safe place for investors to invest and do business. It is argued that SOX is an essential policy tool to realize these objectives. The Act comes into force to address the market failure as a result of scandals such as Enron and others. The Enron scandal alone justifies the legislation to address the market failure characterized by the following consequences. Bankruptcy: 20,000 employees were rendered jobless and deprived of health insurance. Average severance pay was $ 4,500 and top management executives were paid bonuses exceeding $ 55 million. Employees’ retirement funds of $ 1.2 billion were lost. Retirees did not get their $ 2 billion retirement funds. Company’s top executives en-cashed their stocks wor th $ 116 million. Criminal Charges: There were 15 guilty pleas, 6 convictions, 1 acquittal and 11 cases not decided. Three California based stock traders entered their guilty plea for wire fraud. 4 Meryll Lynch executives confessed to fraud in the Nigerian Barge case. Enron’s stock hit a high of $ 90 in 2000 and fell to $ 1 in 2001. 29,000 employees of auditing firm of Arthur Anderson lost their jobs. And Enron’s shareholders sued the company and their banks for $ 20 billion (Jesso, 2009). SOX

Remedial and Institutional Constructive Trusts

Remedial and Institutional Constructive Trusts Title: The remedial constructive trust has taken root in the United States and Canada: it is unlikely to do so in England Millett LJ in Restitution and Constructive Trusts 1998 114 LQR p399. Explain the differences between remedial and institutional constructive trusts and the advantages and disadvantages of each approach. Discuss whether judges in England and Wales are likely to adopt the remedial system. INTRODUCTION A definition of a trust, reflected in case law, suggests that a person with responsibility for property has an obligation in accordance with principles of equity to exhibit beneficence[1] towards any beneficiaries, any of whom might enforce this obligation[2]. The concept of the constructive trust is not overwhelmingly supported, with Hayton categorising it â€Å"â€Å"a fiction which provides a useful remedy when no remedy is available in contract or in tort†[3]. A constructive trust may be either institutional or remedial, although only institutional constructive trusts are acceptable practice in the UK at the present time. According to Halsbury â€Å"the remedial constructive trust†¦is not in reality a trust at all, but merely a remedial mechanism by which equity gives relief for fraud’[4]. The distinction between constructive trusts raise a number of issues that are of particular relevance when considering whether the law in England and Wales is likely to adopt the remedial system. It must be noted, however, that, whilst the importance of both proprietary estoppel[5] and Pallant v Morgan[6] equity are acknowledged as relevant to a discussion on constructive trusts, their applications are specific. Accordingly, due to constraints on space, their inclusion in this particular essay have been omitted[7]. DISCUSSION Whilst law in other jurisdictions needs to resort to such measures as the remedial system, law in the UK currently relies on the Statutes of Limitation[8], within which remedial constructive trusts may be considered to be related to the Limitation Act 1980[9]. The specific distinction between legal and equitable ownership originated through the historical significance of common law and the law of equity, as established through the Courts of Chancery. It is readily acknowledged that a correlation exists between constructive trusts and the doctrine of equity, with effect from the date in which circumstances dictated a need for such intervention, a factor noted in Westdeutsche Bank[10] by Browne-Wilkinson, LJ who observed that â€Å"A remedial constructive trust†¦Ã¢â‚¬ ¦is a judicial remedy giving rise to an enforceable equitable obligation†¦Ã¢â‚¬ [11] Institutional Constructive Trust There have been a number of significant cases heard, where the courts have ruled that institutional constructive trusts will prevail[12]. An institutional constructive trust might be invoked in such cases as domestic disputes involving property, breaches within a fiduciary relationship, contracts relating to sales of land, and certain situations relating to commercial insolvency. Case law established ‘in law and in equity that land could be the subject of ownership’[13], with a further recognition that ‘the person owning either type of estate has a right of property’ according to Lord Browne-Wilkinson[14], established through statute in the Law of Property Act 1925. Freehold land, or land held in fee simple, relates to land held in trust to the Crown, with the owners being beneficiaries, or trustees, or land that is held in cestuis que trust which is revealed as an equitable estate. The requirement for a formal record of equitable entitlement to the transfer of land in accordance with the Law of Property Act 1925 53 (2)[15] reveals a situation inconsistent with the ethos of remedial trusts. Shares in property can be transferred from the owner of a property to bestow the gift of beneficial ownership on another person through the conveyancing procedure of legal transfer by deed according to the Law of Property Act 1925, section 52 (1). Conversely, where full consideration has not been paid when land is transferred an inference of fact would result, as clarified in Subsection 60(3) of the Law of Property Act 1925. Remedial Constructive Trusts Pascoe[16] notes an apparent lack of consensus as to whether remedial constructive trusts are based on an enforcement of proprietary rights or to avoid unconscionable conduct, but suggests it ‘is imposed by equity regardless of actual or presumed agreement or intention’[17] in order for the courts to implement a measure of restitution[18]. Certain situations require a remedy within the law that is particularly suitable for a specific set of circumstances. This is determined at the discretion of the court and is realised in the imposition of a remedial constructive trust, characterised by the particular facet that no trust existed prior to the intervention of the court. An interesting development in the definition attached to constructive trusts was suggested in Barnes v Addy[19] in which Lord Selborne, LC introduced the distinction between a duty owed by directors and duty owed by ‘non-fiduciary strangers’, referring to this concept as ‘the two limbs o f Barnes v Addy’. More recently this referent has been recognised as ‘recipient liability’[20] and ‘accessory liability’[21]. Various jurisdictions around the world acknowledge a distinct emphasis between institutional constructive trusts and remedial constructive trusts, based on the common law precepts of unjust enrichment. The constructive trust would then be recognised as a means of restitution[22], a remedy available for the courts to resort to when other methods of restitution are inappropriate. Often considered synonymous with remedial constructive trusts is the case of Polly Peck International plc (in admin) (No 2)[23]. Referring to additional rights of restitution that might be accorded the plaintiff in respect of legitimate rights to property the Court of Appeal in England made reference to the decision in the Supreme Court in Canada[24]. Different Jurisdictions Amongst the different jurisdictions who habitually utilise the remedial approach, Australia[25] generally adheres to a traditional approach characterised by a link between claimant and the property at dispute, whilst acknowledging the distinction between recipient and accessory[26] liabilities. Accordingly, remedies might be applied ‘in personam’ rather than ‘in rem’. According to Fardell and Fulton[27], the constructive trust has become an important remedy within the courts in New Zealand, fully utilising the concept of remedial constructive trusts in any situation in which a defendant might have prejudiced a plaintiff’s claim to equity as a matter of principle[28]. This particular application of the remedial system has been criticised by the judiciary in Australia as they perceive it represents â€Å"a medium for the indulgence of idiosyncratic notions of justice and fairness†[29]. However, at the New Zealand Court of Appeal Tipping, J concur red with the Australian opinion, although using different reasoning[30]. There have, however, been instances whereby a more controversial approach has been taken, often utilised in the US[31] although, on occasion, in other jurisdictions such as New Zealand in the case of Re Liggett[32] based, as it was, on the decision in the US case of Chase Manhattan Bank. Since then, however, both the Privy Council[33] and the House of Lords[34] have overruled that decision[35]. The law relating to constructive trusts has recently changed in Canada following the Supreme Court’s ruling in the cases of Soulos v. Korkontzilas[36]. Prior to this, such cases as Pettkus v Bekker[37], Sorochan v Sorochan[38] and Rosenfeldt v Olson[39] were the definitive referents in relation to remedies imposed by the courts to prevent the perpetuation of injustices within the specific categories associated with benefiting through unjust enrichment[40]. The Supreme Court focused on the ethos of ‘good conscience’ in their decision when ruling on Soulos v. Korkontzilas[41] . They decided that constructive trusts needed to be imposed to maintain certain standards[42], with four conditions introduced, each of which must present if a constructive trust was to be implemented[43]. Subsequently, these conditions have been applied to all cases relating to constructive trusts heard in Canada’s Supreme Court. CONCLUSION It has been suggested that every resulting trust is realised through the transfer of property in a situation where benefit to the recipient was not the intended option, the consequence of which is a presumption of resulting trust. This significance is recognised in the doctrine of equity in terms of recognition of the terms of endowment. In the UK it is in this particular situation that the inherent importance between constructive and resulting trusts lie. Furthermore, it is this particular situation in which other jurisdictions more often introduce the doctrine of remedial trusts. It appears to be accepted by the majority of commentators that, for a resulting trust to be formed, actual assets must be present in terms of identifiable property, the remedy of which may be found in common law. Despite Millett LJ being of the opinion that the remedial approach is unlikely to take root in England[44], it has been acknowledged in the Court of Appeal[45], the Privy Council[46] and in the House of Lords[47], in obiter dicta, that a possibility might exist for the future incorporation of remedial constructive trusts into UK legislation. This controversy has, by no means been resolved and, at some point will undoubtedly become incorporated into UK legislation, either in its present format, or modified to enable â€Å"†¦an aggrieved party to obtain restitution†[48] through the correlation that exists between constructive trusts and the doctrine of equity which is represented through the concept of morality and obligations, with â€Å"the benefit of an obligation [being] so treated that it has come to look rather like a true proprietary right†[49]. Total Word Count [excluding footnotes and bibliography]: 1,496 words BIBLIOGRAPHY BOOKS: Cope, M (1992): Constructive Trusts. Sweet and Maxwell Maitland, F W (1936): Equity. Cambridge: Cambridge University Press. Page 115 Underhill and Hayton (1995): Law of Trusts and Trustees [15th ed]. London: Butterworth: Page 1 Wilkie, Margaret; Luxton, Peter; and Malcolm, Rosalind (1998): Blackstone’s Land Law. London: Blackstone Press, Page 111 HALSBURY’S LAWS Available Online from: Butterworth’s Direct Search facilities. Access via Athens Gateway: http://www.butterworths.com/butterworths.asp Vol 16 (2000 Reissue) Para 1072 Vol 48 (2000 Reissue) Paras 401 – 403: former Court of Chancery Vol 48 (2000 Reissue) Para 501. Vol 48 (2000 Reissue) Para 592 ARTICLES: Austin, RP (1988): The Melting Down of the Remedial Trust. 11 NSWLJ 66. Available from: Pascoe, Janine: Remedial Constructive Trusts and Corporate Insolvency: an Australian Perspective. Department of Business Law Taxation, Monash University, Australia. Available from: http://www.lbc.com.au/academic/ccl-ezine/pdf/vol8issue1_RemedialTrusts.pdf [Accessed 24th July 2005] Bryan, M (1995): Cleaning up after Breaches of Fiduciary Duty – the Liability of Banks and other Financial Institutions as Constructive Trustees. In 7 Bond Law Review 67. Available in: Pascoe, Janine: Remedial Constructive Trusts and Corporate Insolvency: an Australian Perspective. Department of Business Law Taxation, Monash University, Australia. Available from: http://www.lbc.com.au/academic/ccl-ezine/pdf/vol8issue1_RemedialTrusts.pdf [Accessed 24th July 2005] Dodds, J (1988): The New Constructive Trust: An Analysis of its Nature and Scope. 16 MULR 482. In Pascoe, Janine: Remedial Constructive Trusts and Corporate Insolvency: an Australian Perspective. Department of Business Law Taxation, Monash University, Australia. Available from: http://www.lbc.com.au/academic/ccl-ezine/pdf/vol8issue1_RemedialTrusts.pdf [Accessed 24th July 2005] Fardell, R and Fulton, K (1991): Constructive Trusts-A New Era. NZJL: 90. In Pascoe, Janine: Remedial Constructive Trusts and Corporate Insolvency: an Australian Perspective. Department of Business Law Taxation, Monash University, Australia. Available from: http://www.lbc.com.au/academic/ccl-ezine/pdf/vol8issue1_RemedialTrusts.pdf [Accessed 24th July 2005] Hayton, DJ (1985): Personal Accountability of Strangers as Constructive Trustees. 27 Malaya LR 313,314: Singapore Journal of Legal Studies. Access via ATHENS Gateway McKendrick, E (1994): Unascertained Goods: Ownership and Obligation Distinguished. 110 LQR 509 513 Millett LJ (1998): Restitution and Constructive Trusts 114 LQR p. 399 O’Connor, P (1996): Happy Partners or Strange Bedfellows: the Blending of Remedial and Institutional Features in the Evolving Constructive Trust 30 MULR 735. In Pascoe, Janine: Remedial Constructive Trusts and Corporate Insolvency: an Australian Perspective. Department of Business Law Taxation, Monash University, Australia. Available from: http://www.lbc.com.au/academic/ccl-ezine/pdf/vol8issue1_RemedialTrusts.pdf [Accessed 24th July 2005] ONLINE RESOURCES Pascoe, Janine: Remedial Constructive Trusts and Corporate Insolvency: an Australian Perspective. Department of Business Law Taxation, Monash University, Australia. Available from: http://www.lbc.com.au/academic/ccl-ezine/pdf/vol8issue1_RemedialTrusts.pdf [Accessed 24th July 2005] TABLE OF CASES: Baden Delvaux and Lecuit v Societe Generale [1993] 1 WLR at 509, 575 Bannister v Bannister [1948] 2 All ER 133 Banner Homes Group plc v Luff Developments Ltd [2000] Ch 372, CA Barnes v Addy (1874) LR 9 Ch App 244 Beatty v Guggenheim Exploration Co 225 NY 380 at 386 [1919] Chase Manhattan Bank NA v Israel British Bank (London) Ltd [1981] Ch 105 Cia de Seguros Imperio (a body corporate) v Heath (REBX) Ltd (formerly CE Heath Co (North America) Ltd) [2000] 2 All ER (Comm) 787; [2001] 1 WLR 112, CA Daly v The Sydney Stock Exchange Ltd (1986) 160 CLR 371 Fortex Group Ltd (In Rec and Liq) v MacIntoshes [1994] 3 WLR 199; [1998] 3 NZLR 171. Hussey v Palmer [1972] 3 All ER 70 (CA) Linter Group Ltd v Goldberg (1986) 160 CLR 371 Mabo v Queensland (No 2) [1992] 175 CLR 1, High Court of Australia Metall und Rohstoff AG v Donaldson Lufkin Jenrette Inc [1990] 1 QB 391 and [1989] 3 All ER 14 CA Muschinki v Dodds (1985) 160 CLR 583 at 614 Pallant v Morgan [1953] Ch 43, and [1952] 2 All ER 951 Paragon Finance plc v DB Thakerar Co (a firm) [1999] 1 All ER 400, CA Pettkus v Bekker [1980] 19 RFL (2d) 165 Polly Peck International plc (in admin) (No 2) [1998] 3 All ER 812 at 825-826 Re Goldcorp Exchange Ltd Re Goldcorp Exchange Ltd (in receivership) [1995] 1 AC 74; [1994] 3 WLR 199 and [1994] 2 All ER 606 PC Re Liggett v Kingston [1993] 1 NZLR 257 Re Polly Peck International plc (in administration) (No 2) [1998] 3 All ER 812, and [1998] 2 BCLC 185, CA Re Sharpe [1980] 1 WLR 219 Rosenfeldt v Olson 1 BCLR (2d) 108, [1986] 3 WWR 403, 25 DLR (4th) 472 (CA). Sorochan v Sorochan [1986] 2 SCR 39 Soulos v Korkontzilas [1997] S.C.J. No. 52 Taylor v Davies [1920] AC 636, PC Tinsley v Milligan [1993] 3 WLR 126; [ 1994] 1 A.C. 340, 371 Westdeutsche Landesbank Girozentrale v. Islington London BC [ 1994] 4 All E.R. 890, 962, CA.; varied [ 1996] 2 All E.R. 961, HL; [ 1996] 2 All E.R. 961, 990, H.L; [1996] AC 669 at 714-415 1 Footnotes [1] See Beatty v Guggenheim Exploration Co 225 NY 380 at 386 [1919] [2] This definition is paraphrased from Halsbury’s Laws, Vol. 48 (2000 Reissue) at para 501 who have based this definition on Underhill and Hayton ( ): Law of Trusts and Trustees [15th ed]: Page 1 [3] Hayton, DJ (1985) 27 Mal LR 313,314 [4] Halsbury’s Law, Vol 48 (2000 Reissue) Para 501 [5] Halsbury’s Laws, Vol 16 (Reissue) Para 1072 and Vol 48 at 592 [6] Pallant v Morgan [1953] Ch 43, and [1952] 2 All ER 951. Halsbury’s Laws, Vol 48 at 593 [7] Banner Homes Group plc v Luff Developments Ltd [2000] Ch 372, CA per Chadwick LJ: this case introduced the term Pallant v Morgan equity [8] In accordance with the former Court of Chancery, Halsbury’s Laws, Vol 48, Paras 401 – 403 ante [9] Halsbury’s Laws, Vol 48 (2000 Reissue) Para 501 cites a number of cases relating to this point: Halsbury quotes Taylor v Davies [1920] AC 636, PC; Paragon Finance plc v DB Thakerar Co (a firm) [1999] 1 All ER 400, CA; Cia de Seguros Imperio (a body corporate) v Heath (REBX) Ltd (formerly CE Heath Co (North America) Ltd) [2000] 2 All ER (Comm) 787, and [2001] 1 WLR 112, CA [10] Westdeutsche Bank Landesbank Gironsentrale v Islington London BC [1996] AC 669 at 714-415 per Lord Browne-Wilkinson [11] â€Å"Under an institutional constructive trust, the trust arises by operation of law as from the date of the circumstances which gave rise to it: the function of the court is to declare that such a trust has arisen in the past. The consequences that arise from such a trust having arisen (including the possibly unfair consequences to third parties who, in the interim, have received the trust property) are also determined by rules of law, not under discretion. A remedial constructive trust, as I understand it, is different. It is a judicial remedy giving rise to an enforceable equitable obligation: the extent to which it operates retrospectively to the prejudice of third parties lies in the discretion of the court†. Ibid, Note 9 [12] Bannister v Bannister [1948] 2 All ER 133, Re Sharpe [1980] 1 WLR 219 and Beatty v Guggenheim Exploration Co 225 NY 380 at 386 [1919] [13] Mabo v Queensland (No 2) [1992] per Deane and Gaudron JJ [14] Tinsley v Milligan (1994): â€Å"English law has one single law of property made up of legal and equitable interests† per Lord Browne-Wilkinson [15] Wilkie, Margaret; Luxton, Peter; and Malcolm, Rosalind (1998): Blackstone’s Land Law. London: Blackstone Press, Page 111 [16] Pascoe, Janine ( ): Remedial Constructive Trusts and Corporate Insolvency: An Australian Perspective. Senior Law Lecturer, Department of Business Law Taxation, Monash University, Australia. [17] Muschinki v Dodds (1985) 160 CLR 583 at 614 per Deane J. Also Cope, M (1992): Constructive Trusts [18] Pascoe quotes a number of references from Australian literature: O’Connor, P (1996): Happy Partners or Strange Bedfellows: the Blending of Remedial and Institutional Features in the Evolving Constructive Trust. 30 MULR 735; Also Bryan, M (1995): Cleaning up after Breaches of Fiduciary Duty – the Liability of Banks and other Financial Institutions as Constructive Trustees. 7 Bond Law Review 67; Also Austin, RP (1988): The Melting Down of the Remedial Trust. 11 NSWLJ 66; Also Dodds, J (1988): The New Constructive Trust: An Analysis of its Nature and Scope. 16 MULR 482. [19] Barnes v Addy (1874) LR 9 Ch App 244 [20] See Baden Delvaux and Lecuit v Societe Generale [1993] 1 WLR per Gibson, J at 509; 575 [21] Known as constructive trustees. This relates to a personal liability to an accessory to fraud [22] McKendrick, E (1994): Unascertained Goods: Ownership and Obligation Distinguished 110 LQR 509 [23] Polly Peck International plc (in admin) (No 2) [1998] 3 All ER 812 at 825-826 [24] See Soulos v Korkontzilas [1997] S.C.J. No. 52 [25] Pacoe, Janine: Remedial Constructive Trusts and Corporate Insolvency: an Australian Perspective. Department of Business Law Taxation, Monash University, Australia [26] LinterGroup Ltd v Goldberg (1986) 160 CLR 371: Constructive trustee was Linter Group as plaintiff. Goldberg Furst were directors of Arnsberg Pty Ltd who breached fiduciary duty. Southwell, J granted Linter Group priority over other creditors in terms of equitable claims and Daly v The Sydney Stock Exchange Ltd (1986) 160 CLR 371: this claim was rejected [27] Fardell, R and Fulton, K (1991): Constructive Trusts-A New Era. NZJL: 90 [28] See Fortex Group Ltd (In Rec and Liq) v MacIntoshes [1998] 3 NZLR 171. See also: Re Goldcorp Exchange Ltd [1994] 3 WLR 199 as it represents opposing characteristics [29] Muschinski v Dodds (1985) 160 CLR 583 per Deane J [30] â€Å"the plaintiffs must be able to point to something which can be said to make it unconscionable—contrary to good conscience—for the secured creditors to rely on their rights a law†Fortex Group Ltd (in rec liq) v MacIntosh [1994] 3 WLR 199 per Tipping, J [31] Chase Manhattan Bank NA v Israel British Bank (London) Ltd [1981] Ch 105 [32] Re Liggett v Kingston [1993] 1 NZLR 257 [33] Re Goldcorp Exchange Ltd [1994] 3 WLR 199 [34] Westdeutsche Landesbank Girocentrale v Islington Borough Council [1996] AC 669 [35] Constraints of space preclude a more detailed investigation of any of the cases [36] Soulos v. Korkontzilas [1997] S.C.J. No. 52 [37] [1980] 19 RFL (2d) 165 [38] [1986] 2 SCR 39 [39] 1 BCLR (2d) 108, [1986] 3 WWR 403, 25 DLR (4th) 472 (CA). [40] â€Å"absence of any juristic reason† [41] Soulos v. Korkontzilas [1997] S.C.J. No. 52 [42] â€Å"†¦a constructive trust may be imposed where good conscience so requires. I conclude that in Canada, under the broad umbrella of good conscience, constructive trusts are recognized both for wrongful acts like fraud and breach of duty of loyalty, as well as to remedy unjust enrichment and corresponding deprivation†: Soulos v. Korkontzilas [1997] S.C.J. No. 52, per Justice McLaughlin [43] Breach of an equitable obligation; assets still with defendant; plaintiff to present legitimate reason for recourse to courts; no third parties who might be unjustly penalised through a constructive trust [44] Millett LJ in Restitution and Constructive Trusts 1998 114 LQR p. 399 [45] Metall und Rohstoff AG v Donaldson Lufkin Jenrette Inc [1990] 1 QB 391 and [1989] 3 All ER 14 CA; Also Re Polly Peck International plc (in administration) (No 2) [1998] 3 All ER 812, and [1998] 2 BCLC 185, CA [46] Re Goldcorp Exchange Ltd (in receivership) [1995] 1 AC 74 and [1994] 2 All ER 606 PC [47] Westdeutsche Landesbank Gironzentrale v Islington London Borough Council [1996] AC 669, and [1996] 2 All ER 961, HL [48] Hussey v Palmer [1972] 3 All ER 70 (CA) per Lord Denning [49] Maitland, F W (1936): Equity. Cambridge: Cambridge University Press. Page 115

Free Trade Agreement and Its Affect on Canadian Business Essay

Free Trade Agreement and Its Affect on Canadian Business With the coming of the Free Trade Agreement (FTA) there have been very serious implications for Canadian business and for that matter, Canada as a whole. Many aspects of the previous economic climate have changed such as the reduction or eliminatation of tariffs and the restrictions on subsidies to name only a few. There has been much heated debate on the pros and cons of this deal: whether Canada will prosper or become the 51st. American state. This paper will not take this approach to the issue of whether or not it is a wise agreement, but will look at what business can do to better itself with the existing FTA. If Canadian business is to survive and prosper in this radically changed North American and Global atmosphere of easier trading, then it must adapt. Some of the main areas that will have to be addressed is the need for more productive and efficient operations, a new focus by business on the new trading reality, and a change in policies by Government to enable Canada to function better with the FTA. The FTA stands to alter Canadian business which has grown rather relaxed and inefficient behind walls of tarrifs. While these may have initially spurred industry, they have after time encouraged complacency. With these rapidly disappearing walls, business will have to become "lean and mean" in order to compete in a very competitive global market. Looking at the present state of affairs our status in research and development (R&D), labour costs and expansion, there is much that must be done. Compared to the other industrialized western nations we lag far behind in nearly all areas. Take for example R&D. In 1990 Canada spe... ... Cameron, Duncan. The Free Trade Papers. James Lorimor & Company, Publishers, Toronto, 1986 The Canada and US FTA (Complete Doccument), External affairs Canada, Ottawa Laxer, James. Leap of Faith: Free Rade and the Future of Canada. Hurtig Publishers, Edmonton, 1986 The Case Against the Critics of Free Trade. John Miora. Finanical Post, Feb. 8, 1986 Brave New World. Marc Tait. Maclean's, Jan. 9, 1989 Firms going continental. Jennifer Sachsa. Globe and Mail, June 12, 1990 Roundtable: The Canada-US FTA. Fred Swift. Globe and Mail. August 12, 1988 End Notes 1 Firms going continental. Jennifer Sachsa. Globe and Mail, June 12, 1990 2 Brave New World. Marc Tait. Maclean's, Jan. 9, 1989 3 Firms going continental. Jenniger Sachsa. Globe and Mail, June 12, 1990 4 Roundtable: The Canada-US FTA. Fred Swift. Globe and Mail. August 12, 1988