Wednesday, July 31, 2019

Lord of the Flies: The best leader “Ralph, piggy or jack”

The lord of the flies began by a plane crash near the Pacific Ocean during an unnamed war in which a group of English schoolboys are lonely on an island, under no adult control. They are left on the island to feed themselves and fight their own battles. The boys started to make rules and laws in which everyone had to follow, but they tended to have arguments with each other when deciding rules. They collapse from their friendships because they didn't agree with the decisions or rules they made. The story starts off with a young character called Ralph. Ralph is a very organised person, making the reader becomes inclined to think that he is also an intelligent individual. He seems certain throughout the book that his father, a commander in the Navy, will come and rescue him and his peers. He was eventually chosen to be a designated leader of the group by the others. This is most likely because he is a polite character and he also carried the advantage of being one of the older members of the group. Piggy was Ralph's best friend; this is largely due to the fact that he listened to what he said and didn't hesitate to follow his rules. Eventually, as time passed by, piggy developed into a father figure towards the younger boys. ‘Lord of the flies' has become a widely known story over the years, due to the unusual idea of the famous ‘conch.' The boys took to the idea of using this conch to grant one another the power to speak-out without being interrupted in the many assemblies they had. With Ralph as the leader, it was inevitable to the reader that a device of this kind would be thought up, as Ralph, being a sensible youth, seemed to appreciate the great importance of being able to sustain order within the temporary community. This is why he came up with the idea of using a conch. In doing this, the element of fairness in Ralph's character is also demonstrated to the reader. Ralph began to find rules and limits in which they could remain safe on the island. Ralph, Jack and Simon explored the island and began plans for shelters from the weather. Simon was a young lad, although he was still granted respect from the elders, and likewise he respected them. Ralph also made the decision that a fire should be lit permanently on the mountains as a constant smoke signal. This was a very pragmatic idea, again demonstrating to the reader the great leadership skills that Ralph possessed. Ralph then decides to have a meeting about lighting a fire on the mountains and Jack also decides to make a hunting party to hunt for pigs. A small boy claims to have seen a serpent-like beast, but the idea is quickly discarded after Ralph and Jack convince the group to collect wood. The group hurriedly rushes to the mountain and collect wood for a fire. At first they didn't have anything to light the fire with. Then jack uses Piggy's glasses as a magnifying glass to make sunrays as heat. Although there was only a little amount of fire created, the rest of the boys put some green branches on the fire, so they could have more fire. When the next meeting happened Ralph decided to make more regulations or commands to set people on specific tasks like building shelters and putting the fire on. From now Ralph and Jack start to make different decisions and start to ignore Ralph's rules. Jack got more into hunting and started to forget his to goal of being rescued. Everyone started doing there own kind of activities, while Ralph and Simon were the only ones who were building shelters. The younger children started to help less and got more into playing games on the beach. Later on, a ship sails past the island but unluckily fails to notice the boys because Jack's choir had let the fire out completely. Jack and his boys had lost attention in the fire and had gone off hunting. Jack and his boys caught a pig and told Ralph about all the things that had happened during his absence. However, he wasn't interested as he was much more concerned over the fact that they'd failed to keep the fire going. â€Å"There was a ship out there, they might have seen us and we could have gone home. Your stupid ideas about hunting let everything down.† Jack lights the fire again by using Piggy's glasses and prepares pigs meat for a little feast. By reading this phrase proves that Ralph cared about him self and others to be rescued. Later on in the story situation had changed from fire into beast situation because the young children's were scared at night and told Ralph and jack that there is a beast on the island. Jack didn't bother about Ralph rules and started to protect little children's from beast. One night when piggy and Ralph were sleeping, the twins rushed to them and told them that they saw a beast with huge claws and teeth's. Ralph then made a little assembly in the morning and told the rest of the children's about what Sam and Eric saw last night. Jack and Ralph went to explore the island with some other children's but they didn't find anything. Ralph told the group to keep the fire going as well, while we are searching for the beast. The group started to ignore Ralph rules and joined Jack to hunt for the beast. Ralph still hanged around with jack for a little while. Jack told some of the children to come along with him so they can check if there is a beast living on the top of the mountain. Ralph volunteered to come along as well. They claim to see something which they were influenced as if it was the beast. They ran away from the living thing and came down the mountain to protect their self. Ralph had planned a feast at night. They invited everyone to come and eat with them. They all were chanting and started to become louder and louder. Roger pretended if he was a beast and everyone slowly tried to attack him. Piggy stood in one place looking at them. While they were enjoying the festival, â€Å"Simon† went up to the mountain to see if there was really a beast living up there. He walked through the woods and ended up on the mountain. When he saw the beast he stepped back and got scared. Then he went to take a closer look at the beast and he found out that it was only a person made out of parachute which always got blown by the wind and makes it move. It pretended that if it was a real beast. Simon went running down the mountain and ran through the forest to tell everyone that there is no beast. While he is returning the boys saw that there was figure coming down. Someone shouted out that it's a beast. Everyone rushed towards him and stabbed him several times until he can't move. Then they stopped stabbing it and found out that the dead body was Simon. Ralph was in tears about Simon death. Now there were only piggy and Eric left on his side. Ralph told piggy that this was a murder. Piggy replied that it was too dark to see, it was also raining with thunders. It was accident said piggy. We couldn't see who it was. It could have been anyone. Jack had stolen piggy glasses and their fire place. They had fort near the cliffs. Ralph and piggy went to the castle to collect piggy specs from jack, because they needed the specs to light the fire so they can be rescued of from the island. Piggy told jack that he has got the conch and he has got the right to talk. during his speech, he says â€Å"that you lot are acting like a bunch of kids with your faces painted like Niger's†. Jack wasn't even listening to piggy, than Ralph took the conch of piggy and called jack a thief and they both got into a fight. Everyone started to chant. Then eventually the pair stopped, and Piggy spoke. His long speech was interrupted when one of the savages rolled a huge rock down the cliff which struck Piggy and pushed him forty feet down the mountain and ended up falling on top of the pointy rocks. Jack showing no signs of remorse threw a spear which hit Ralph in the ribs. Ralph ran to the forest to save his self. All of the boys were gone, Ralph thought. Only cruelly children have remained. While Ralph was in the forest, he saw Sam and Eric. They told him that he should run and hide because Jack and Roger were going to hunt him soon. Suddenly Roger came to see if the twins were keeping guard. Ralph hid in a grove. When Roger left, Ralph ran away and thought about the best course of action. The island was on fire. The whole group was looking for Ralph. Jack spotted him and the whole group was soon chasing after him through the forest. Ralph was humiliated and ran out of the forest, and fell into the sand, in front of two shoes. The shoes of a sailor whose ship was waiting to take them home. Ralph told him about the deaths and then broke into tears. The sailor said â€Å"he wasn't suspecting like this kind things from English boys†. Diary based on two characters, â€Å"which I consider may have become the selected leader†. Piggy When i was first crashed on an island, I was so scared, because there was no one to look after me or the rest of the group. I met a boy called Ralph. I told him what they used to call me back at the school time. Ralph started to have a little laugh. We carried on walking by the beach, when both us came across a shell. Ralph picked it up and asked me what you exactly do with this. â€Å"You blow it from underneath the hole and it makes a loud noise†, piggy replied in a gentle voice. â€Å"In olden times people use to take this has a symbol of justice, to speak out in assemblies†. As they we were walking and talking to each other, we saw a group of boys walking towards us; they were singing a song. Jack was one of the boys in that group. He asked our names, and then sat down and starts talking about how did they both met each other. When they were in middle of their conversation Ralph said that â€Å"they should have a leader who will give rules to everyone about how they are going to live, eat and do other things†. Jack and Ralph were both chosen to receive votes. Only a few people voted for jack, but quiet few of them said that Ralph should be the chief. Then at last I slowly raised my hand up voting for Ralph. Everything was going great. The entire group was following Ralph's rules, later on things started to collapse because jack and Ralph didn't agree with each other decisions. I was Ralph's best friend and I didn't like jack because he didn't treated me in the same way like he did to everyone else. He called my names and said that I am too fat to do anything good. They all ways leave me behind with the little children's because I was like their father figure. Jack always has wondered off to hunting and the fire would always go off. Our main advantage of the fire was the smoke, which was their signal of proving that someone or something is on the island and they need their help. Ralph When I was crashed on the island, I felt a bit scared because there was no one on the island to look after me. There were a lot of different sounds coming from the trees, like if something was looking or hunting for something. When I was walking beside the trees the first person I met was piggy. I told him my name and a bit about my self. Piggy was so kind and didn't raise his voice above mine. When we were walking down, we saw a group of boys coming down. They were singing a song. A group of boys from them was called jack, he asked our names and then started talking about what's going to happen on this island. I said, â€Å"That. There should be a leader who is going to tell everyone what to do, what to eat, what's there jobs† e.c.t They both agreed with each other decisions. Then jack said to everyone to put their hands up who want me to be the chief. Only a few people voted for him but when it was my turn nearly everyone said that he should be the chief of us. Slowly, slowly my friend piggy raised his hand up at last. I told them that I am the chief, I will tell you lot what to do and what not to do. I structured everyone some fundamental things and told my group to follow some crucial regulations so we can be rescued of from the island. My main rule was to maintain the fire going so we can be noticed on the island and then can be capable of being rescued. Later on jack stopped listening to my rules because he said that I don't do anything for hunting or I don't feed the little children's. From then jack never listened to me and always wondered off to do hunting or to have fun on the beach. During jack's hunting, he killed a pig and became so excited to tell this news to me. I wasn't bothered if they had killed a pig or not because I told them that there was a ship out there. If you lot didn't have gone off to hunting we could have gone home. Your stupid plans to go for hunting had failed me the group, also let out the fire. I was disappointed of being a leader of my group. My worries are that I wish that everyone had worked in a group and then we can have been rescued off from the island soon as possible. Everyone didn't do as i told them to, except from my best friend piggy.

Tuesday, July 30, 2019

Meaning of Life and Life Essay

Every person has a variety of questions about the meaning of life but how we as humans perceive and search for the answers to life’s ultimate questions will vary depending on what one’s beliefs and traditions may be. One of the most prominent and most publicized ways to search for the answers of life is through a practise of religion. Another way to find meaning which is just as significant as religion is science. Equally as important but under looked is the ultimate questions that are searched for in suffering. These three paths to solving the ultimate questions to life are the most prominent and yet the most common. With reference to Lonergan’s quote people have a variety of questions about life, this essay will analyse how people search for life’s ultimate questions. Some people search for meaning through Religion, the religion that is practised often and is recognised for helping answer some of life’s ultimate questions is Christianity, people who are Christian say that God helps them find their meaning to life. According to the ‘chasing something more’ article Justin Langer went to visit a chaplain and said â€Å"I’ve got a beautiful wife and two gorgeous kids, a great house. I should be happy- but something is missing. † The Chaplain said â€Å"have you read the bible lately? † This gave Justin a new mind set and he started reading the bible on his trips overseas now. According to the writer Michael McVeigh Justin said â€Å"I’ve being brought up catholic, but it’s not just about the teachings, it’s about what happens in real life. † Karl Rahner who was a famous Catholic theologian believed â€Å"For if God really doesn’t exist, the hunger for meaning is absurd. † [Rahner 1990] (Morgan 1996). Rahner never forced people to believe in God but he says that it is realistic to suggest, because he thinks it’s a goal that cannot be completed within ourselves, without God, In the bible it says â€Å"May the God of hope fill you with all joy and peace as you trust in him, so that you may overflow with hope by the power of the Holy Spirit† (Romans 15:13) this quote from the bible backs up with Karl Rahner and what he believes. Paul Davies a contemporary Australian physicist, thinks that although science gives you the answers to some questions but the deeper and more meaningful questions will not be able to be answered by science. Science is the new way of challenging religion and the way we find meaning and answer life’s ultimate questions. According to Peter Morales a Unitarian Universalists he says science and religion share a common wellspring. He believes that through science you learn more about the world and how it works. He says that we can know and face the truth through science and then move on and define our own meaning through religion. Science proposes that we are an accidental outcome of a procedure of evolution, Peter Morales says that all science questions are questions that can be answered and we can compare the answers, and he says that we can choose the answer that best fits our experiences. Sam Harris a neuroscientist says â€Å"science can help us get what we want† (TED 2010) he believes that no matter what our values are religion or anything you are still concerned about conscious and its changes, and when people from a religion say that changes can persist after death, this a fact and factual answers are from science. Paul Davies who is a scientist is so captivated by the universe that he like Lonergan believes that his questions are limitless. Davies is indefinite to whether he believes in God, but what he does believe is the ‘theory of everything. ’ Suffering is an under looked experience that contributes to the search for life’s ultimate questions. According to Friedrich Nietzsche a prominent theorist he believes that ‘God is dead’ he felt that people went to God as an ultimate explanation for everything. Victor Frankl also a prominent theorist says that through suffering and experience, According to Nietzsche he says â€Å"we cannot avoid suffering but we can choose how to cope with it, find meaning in it, and move forward with renewed purpose. † Frankl believed that if there is a meaning in life, then there is essentially meaning in suffering, he says â€Å"suffering is an ineradicable part of life even as fate and death. Without suffering and death human life cannot be complete. † Frankl says that even with a despairing situation, â€Å"the human mind can transform a personal tragedy into triumph† (Ed Batista website 2010) According to Frankl after a tragedy in someone’s life their tragedy turns into an achievement. Ulrich Diehl a philosopher in the making believes that all human beings share the same needs and that we all search for a meaning of life, but although human suffering can be a challenge to the meaning of life, the outcome from the personal affect actually helps people find meaning to life and answer some questions they need to know about their life. Lonergan says that there is no limit to our questions, although finding the answer to these questions will vary depending on what one’s beliefs and traditions may be, through religion, science and suffering this is shown most prominent to help humans to find these answers. All these aspects help humans find meaning to life, and they are all equally as important as each other. These three paths demonstrate that they are most useful to use when searching for meaning and answers to some of life’s ultimate questions.

Monday, July 29, 2019

Case Briefing and Problem Solving

doesn’t owe an ethical duty to remove the product from the market unless the company doesn’t warn its customers of the danger they can meet upon misuse of the product. If the company takes all the measures to warn their customers of the danger of the product once it’s misused, customers have knowledge of the risk and voluntarily assume it. For example, the use of any antibiotics with the alcohol can lead to many harmful processes and activities. Nevertheless, pharmaceutical companies don’t remove these products from the market because of that. It’s a customer’s responsibility to use the product properly. Case problems 8–1 Business Ethics. Jason Trevor owns a commercial bakery in Blakely, Georgia, that produces a variety of goods sold in grocery stores. Trevor is required by law to perform internal tests on food produced at his plant to check for contamination. Three times in 2008, the tests of food products that contained peanut butter were positive for salmonella contamination. Trevor was not required to report the results to U. S. Food and Drug Administration officials, however, so he did not. Instead, Trevor instructed his employees to simply repeat the tests until the outcome was negative. Therefore, the products that had originally tested positive for salmonella were eventually shipped out to retailers. Five people who ate Trevor’s baked goods in 2008 became seriously ill, and one person died from salmonella. Even though Trevor’s conduct was legal, was it unethical for him to sell goods that had once tested positive for salmonella? If Trevor had followed the six basic guidelines for making ethical business decisions, would he still have sold the contaminated goods? Why or why not? The issue in this case problem is whether Trevor’s actions were unethical. In my opinion it was unethical for Jason Trevor to sell goods that had once tested positive for salmonella. Salmonella is a bacterium that can cause many illnesses. Two basic ethical approaches can be applied to this case. Firstly, Trevor should’ve thought about his customers from the religious position. He could’ve foreseen that products positive tested on salmonella would harm people inevitably. Secondly, he had to consider the outcome of this sale. He didn’t think about the consequences that can follow. He acted negligent by letting his employees ship the products to the retailers. If Trevor followed the six basic guidelines for making ethical business decisions he would not have sold the contaminated goods to the public. Having five people seriously ill and one person died because of the contaminated products harms the name of the brand associated with this incident. Thus, company loses its customers and, as a result, part of the revenues. I think Trevor also should feel guilty about what happened to those people meaning that on the Conscience step, which is the 4th guideline, he would’ve reconsidered his actions and probably changed his mind. I guess he would’ve not been happy to be interviewed about the actions he was about to take. And the next step, which is Promises to his customers, would’ve made him doubt his decisions because of the trust of the customers that he held in his hands. And I am sure Trevor’s hero would not have acted the way that can harm people. Thus, Trevor would not have sold the contaminated goods had he followed the basic guidelines for making ethical business decisions. Brody v. Transitional Hospitals Corporation United States Court of Appeals, Ninth Circuit, 280 F. 3d 997 (9th Cir. 2002). http://caselaw. findlaw. com/us-9th-circuit/1019105. html FACTS Jules Brody and Joyce T. Crawford filed a class action complaint against Transitional Hospitals Corporation (THC) and its officers on August 28, 1997 accusing THC of unlawful insider trading after THC bought 800,000 shares of its stock between February 26 and February 28 without first disclosing that Vencor and other parties had expressed interest in THC. In addition, Brody and Crawford claimed that THC, in its March 19 and April 24 press releases, materially misled them about THC’s intention to sell the company. The district court granted the defendant’s motion to dismiss the claims. The plaintiffs appealed to the US Court of Appeal, Ninth Circuit. ISSUE Are Brody and Crawford the proper plaintiffs to sue THC for damages for violation of the statute and rule? regarding the insider trading? DECISION No. US Court of Appeal, Ninth circuit, affirmed the district court’s decision to dismiss Brody and Crawford’s complaint for failure to state a claim upon which relief can be granted. REASON The Court noted that plaintiffs did not meet a contemporaneous trading requirement, a judicially-created standing requirement, which specified in Section 14(e) and Rule 14e-3 that the plaintiffs must have traded in a company’s stock at about the same time as the alleged insider. In addition, the Court decided that the plaintiffs’ complaint must specify the reason or reasons why the statements made by THC in its press releases were misleading. Brody and Crawford argued that in order for statement not to be misleading, â€Å"once disclosure is made, there is a duty to make it complete and accurate†, for which the Court found no support in the case law. The case law? only prohibits misleading and untrue statements, not statements that are incomplete. FOOTNOTES: ? Sections 10(b), 14(e), and 20(a) of the Exchange Act, 15 U. S. C.  §Ã‚ § 78j (b), 78n (e), and 78t (a), and Rules 10b-5 and 14e 3, 17 C. F. R.  §Ã‚ § 240. 10b-5 and 240. 14e-3, promulgated thereunder by the Securities Exchange Commission (â€Å"SEC†) ? Rule 10b-5 and Section 14(e) Full case: BRODY v. TRANSITIONAL HOSPITALS CORPORATION Jules BRODY; Joyce T. Crawford, Plaintiffs-Appellants, v. TRANSITIONAL HOSPITALS CORPORATION; Wendy L. Simpson; Richard L. Conte, Defendants-Appellees. No.? 99-15672. Argued and Submitted July 11, 2001. — February 07, 2002 Before: HALL, WARDLAW and BERZON, Circuit Judges. Jeffrey S. Abraham, New York, NY, for the plaintiffs-appellants. Mark R. McDonald, Morrison Foerster, Los Angeles, CA, for the defendants-appellees. In this case we address several securities fraud issues, centering on whether a plaintiff must have traded at about the same time as the insider it allege violated securities laws. ? Jules Brody and Joyce T. Crawford brought suit against Transitional Hospital Corporation (â€Å"THC† or â€Å"the company†) and its officers claiming violations of the Securities and Exchange Act of 1934 (â€Å"Exchange Act†) and state law because the defendants both traded in reliance on inside information and released misleading public information. ? The district court granted the defendant’s motion to dismiss for failure to state a claim. Brody and Crawford now appeal the district court’s order on several grounds. BACKGROUND In determining whether the complaint states a claim upon which relief could be granted, we assume the facts alleged in the complaint to be true. ?Ronconi v. Larkin, 253 F. 3d 423, 427 (9th Cir. 2001). ? The facts alleged in the complaint are as f ollows: THC was a Nevada corporation that delivered long-term acute care services through hospitals and satellite facilities across the United States. ? In August 1996, the company announced its plan to buy back from time to time on the open market up to $25 million in company stock. Two months later, THC expanded the repurchase plan to $75 million. On February 24, 1997, Vencor, Inc. submitted to THC’s board of directors a written offer to acquire the company for $11. 50 per share. ? THC did not disclose this offer publicly. ? Between February 26 and February 28, THC purchased 800,000 shares of its own stock at an average price of $9. 25 per share. ? This $7. 4 million buy-back was in addition to another $21. 1 million that THC had spent purchasing its stock in the three month period that ended on February 28, 1997. The plaintiffs do not allege that the total repurchase exceeded $75 million. THC issued a press release on March 19, 1997, detailing the progress and extent of it s stock repurchase program. ? The press release did not mention Vencor or any other party’s interest in acquiring THC. The plaintiffs argue that because of this omission, the March press release was misleading. On April 1, 1997, Vencor increased its offer to purchase THC to $13 per share. ? In the next few weeks, THC also received offers from two other competing bidders. ? On April 24, after receiving all hree offers, THC issued another press release, stating that the company had â€Å"received expressions of interest from certain parties who have indicated an interest in acquiring† it. ? The same document also stated that THC had hired â€Å"financial advisers to advise the company in connection with a possible sale. † ? The plaintiffs argue that this press release was also misleading; because it did not state that substantial due diligence had already taken place, that THC had received competing offers exceeding $13 per share, or that a THC board meeting would take place two days later to consider these offers. At the board meeting, the THC board voted to negotiate a merger agreement with Select Medical Corporation (â€Å"Select†). ? On May 4, THC publicly announced that it and Select had entered into a definitive merger agreement and that Select would purchase THC at $14. 55 per share. ? Vencor thereupon threatened a hostile takeover. ? To fend off that maneuver, THC ultimately agreed, on June 12, to a takeover by Vencor rather than Select, at $16 per share. Brody and Crawford sold shares at times that sandwich the April 24 press release. ? Two days before that press release was issued, Crawford sold 500 shares at $8. 75 per share. ? Brody sold 3,000 shares of THC stock at $10. 50 per share on April 24, just after the press release was made public. ? The plaintiffs argue that had they not been misled by THC, they would have held onto their shares, and benefitted from their subsequent increase in value. Brody and Crawford filed a class action complaint against THC and its officers on August 28, 1997. ? In addition to alleging violations of Nevada state law, Brody and Crawford alleged violations of Sections 10(b), 14(e), and 20(a) of the Exchange Act, 15 U. S. C.  §Ã‚ §? 78j(b), 78n(e), and 78t(a), and Rules 10b-5 and 14e 3, 17 C. F. R.  §Ã‚ §? 240. 10b-5 and 240. 14e-3, promulgated thereunder by the Securities Exchange Commission (â€Å"SEC†). ? These claims focus on two aspects of THC’s course of action: Brody and Crawford accuse the company of illegal insider trading because THC repurchased 800,000 shares of its stock between February 26 and February 28 without first disclosing that Vencor and other parties had expressed interest in THC. In addition, Brody and Crawford claim that THC, in its March 19 and April 24 press releases, materially misled them about THC’s progress toward its eventual merger. The district court dismissed all of Brody and Crawford’s claims. ? In so doing, the district court held that Brody and Crawford are not proper parties to assert any insider trading claims, as Brody and Crawford did not trade contemporaneously with THC. In addition, the district court decided that the plaintiffs failed to state a claim under Rule 10b-5 or any other law based on materially misleading information, as the press releases were not misleading under the applicable standards. The plaintiffs appeal these aspects of the district court’s dismissal. We review de novo the district court’s dismissal for failure to state a claim pursuant to Federal Rule of Procedure Rule 12(b)(6). ?Zimmerman v. City of Oakland, 255 F. 3d 734, 737 (9th Cir. 2001). DISCUSSION A.? Insider Trading As they pertain to insider trading, Section 10(b), Rule 10b-5, Section 14(e) and Rule 14e-3 make it illegal in some circumstances for those possessing inside information about a company to trade in that company’s securities unless they first disclose the information. See, e. g. , United States v. Smith, 155 F. 3d 1051, 1063-64 (9th Cir. 998). ? This type of prohibition is known as an â€Å"abstain or disclose† rule, because it requires insiders either to abstain from trading or to disclose the inside information that they possess. The district court dismissed the insider trading claims, holding that the named plaintiffs could not assert them because they did not trade contemporaneously with THC. On appeal, Brody and Crawford argue that nothing in the applicable securities laws requires investors to have traded contemporaneously with insiders in order to maintain a suit for insider trading. In addition, they argue that even if such a requirement exists, they in fact did trade contemporaneously with THC. 1.? Section 10(b) and Rule 10b-5 Neither section 10(b)1 nor Rule 10b-52 contain an express right of action for private parties. ? The Supreme Court has h eld, however, that proper plaintiffs may sue for damages for violation of the statute and rule. ? See Superintendent of Ins. v. Bankers Life and Cas. Co. , 404 U. S. 6, 13 n. 9, 92 S. Ct. 165, 30 L. Ed. 2d 128 (1971). Because neither the statute nor the rule contains an express right of action, they also do not delineate who is a proper plaintiff. ? In the absence of explicit Congressional guidance, courts have developed various â€Å"standing† limitations, primarily on policy bases. 3 For example, in Blue Chip Stamps v. Manor Drug Stores, 421 U. S. 723, 95 S. Ct. 1917, 44 L. Ed. 2d 539 (1975), the Supreme Court held that to bring an insider trading claim under Rule 10b-5, a plaintiff must have traded in the same stock or other securities as the insider trader. The contemporaneous trading requirement, at issue in this case, is another judicially-created standing requirement, specifying that to bring an insider trading claim, the plaintiff must have traded in a company’ s stock at about the same time as the alleged insider. ?In Neubronner v. Milken, 6 F. 3d 666, 669 (9th Cir. 1993), the Ninth Circuit adopted a contemporaneous trading requirement for Section 10(b) and Rule 10b-5 actions. ? See also In re Worlds of Wonder Sec. Litig. , 35 F. 3d 1407, 1427 (9th Cir. 1994). Neubronner explained that two reasons animate this rule: First, â€Å"noncontemporaneous traders do not require the protection of the ‘disclose or abstain’ rule because they do not suffer the disadvantage of trading with someone who has superior access to information. † ? 6 F. 3d at 669-70 (quoting Wilson v. Comtech Telecommunications Corp. , 648 F. 2d 88, 94 95 (2d Cir. 1981)). ? Second, the contemporaneous trading requirement puts reasonable limits on Section 10(b) and Rule 10b-5’s reach; without such a limitation, an insider defendant could be liable to a very large number of parties. Id. at 670. Brody and Crawford offer two reasons why the contemporane ous trading rule adopted in Neubronner should not here apply. ? First, they argue that the rule does not make sense, as a matter of statutory interpretation. ? In other words, they request that we declare that Neubronner’s interpretation of Section 10(b) and Rule 10b-5 was incorrect. ? Although the decision in Neubronner is not beyond debate, we do not consider the question further, as a Ninth Circuit panel may not overrule a prior Ninth Circuit decision. ?Hart v. Massanari, 266 F. 3d 1155, 1171 (9th Cir. 2001). Brody and Crawford attempt to avoid this precedential barrier by claiming that Neubronner’s implementation of the contemporaneous rule was dictum, and therefore not binding on us. ? It was not. ?Neubronner explicitly described its ruling regarding the contemporaneous trading requirement as a â€Å"holding. † ? 6 F. 3d at 670. ? In addition, the determination was a necessary predicate for the case’s ultimate conclusion that contemporaneous trading must be pleaded with particularity. ? Id. at 673. Brody and Crawford’s second submission in avoidance of Neubronner is that United States v. O’Hagan, 521 U. S. 642, 117 S. Ct. 2199, 138 L. Ed. 2d 724 (1997), overruled Neubronner. ? That assertion is simply wrong. ? O’Hagan, which was a criminal case, addressed neither the contemporaneous trading requirement in private actions nor any other standing rule. ? Instead, by approving of an expansive concept of who qualifies as an insider under Section 10(b), the Supreme Court in O’Hagan clarified that more defendants may be liable under Section 10(b) than some courts have previously thought. ? Id. at 650, 117 S. Ct. 2199. ? In so doing, the Supreme Court did not alter pre-existing notions concerning whom insiders harm when they trade based on privileged information. Brody and Crawford next argue that even if the Section 10(b) and Rule 10b-5 contemporaneous trading requirements remain, the court should define contemporaneous trades as trades that take place within six months of one another. ? Under this definition, Brody and Crawford would have standing, as they sold their stock just under two months after they allege THC bought the large block of stock in February. [3]? In Neubronner, this court did not decide the length of the contemporaneous trading period for insider trading violations under Section 10(b) and Rule 10b-5, 6 F. d at 670, nor has this court decided the question since. ? Because the two-month time period presented by the facts of this case exceeds any possible delineation of a contemporaneous trading period, it is not necessary in this case either to define the exact contours of the period. ? We simply note that a contemporaneous trading period of two months would gut the contemporaneous trading rule’s premise-that there is a need to filter out plaintiffs who could not possibly have traded with the insider, given the manner in which public trades are transacted. 2.? Section 14(e) and Rule 14e-3 Brody and Crawford also argue that the district court erred in dismissing their claims under Section 14(e)4 and Rule 14e-35 by holding that insider trading actions brought under Section 14(e) and Rule 14e-3 must also conform to a contemporaneous trading requirement. ? In making this argument, the plaintiffs urge that we hold for them on two matters of first impression: (1) whether a private right of action exists under Rule 14e-3; and (2) if a private right of action does exist, whether it contains a contemporaneous standing requirement. We can assume, without deciding, that a private right of action exists under Rule 14e-3, for we see no reason why the same contemporaneous trading rule that applies under Rule 10b-5 would not apply in such an action. ?As noted, this court has definitively adopted a contemporaneous trading requirement under Rule 10b-5. ? Although Rule 14e-3 differs in some respects from Rule 10b-5, (and was adopted in order to plug some ho les the SEC perceived in Rule 10b-5),6 its core, like the core of Rule 10b-5, is an â€Å"abstain or disclose† requirement. And, as is true of the â€Å"abstain or disclose† requirement of Rule 10b-5, the similar requirement of Rule 14e-3 is designed to prevent the disadvantage that inheres in trading with an insider with superior access to information. ?45 Fed. Reg. 60411-12 (1980). ? So we would have to have some excellent reason to adopt a different standing rule under Rule 14e 3 from the one we use under Rule 10b-5. ? We are convinced that there is no basis for drawing such a distinction. The best candidate appellants have advanced as a basis for differentiating the standing requirement under the two Rules is Plaine v. McCabe, 797 F. d 713 (9th Cir. 1986). ?Plaine held that a plaintiff suing under Section 14(e) need not have traded at all, let alone contemporaneously. ? Id. at 718. The fulcrum of Plaine was a distinction suggested by Piper v. Chris-Craft Indus. , I nc. , 430 U. S. 1, 38-39, 97 S. Ct. 926, 51 L. Ed. 2d 124 (1977), between the types of shareholder protections contained in Sections 10(b) and 14(e): Piper noted that while Section 10(b) was enacted to protect only individuals who actually traded in stocks, Section 14(e) can be understood as protecting not only those who buy or sell stocks but also shareholders who decide not to trade. 430 U. S. at 38-39, 97 S. Ct. 926. ? Because Rule 14e-3 was promulgated under Section 14(e), the argument that a plaintiff who alleges insider trading under Section 14(e) or Rule 14e-3 need not worry about the contemporaneous trading requirement-because he need not have traded at all-has some initial plausibility. On a closer examination, however, Plaine does not speak to the issue at hand. Rather, Plaine focused only on non-insider trading claims brought under Section 14(e), and did not consider the standing requirements for an insider trading claim brought under Rule 14e-3. Section 14(e) broadly pro hibits â€Å"fraudulent, deceptive, or manipulative acts or practices, in connection with any tender offer;† it does not contain any specific reference to insider trading. ? Rule 14e-3, on the other hand, focuses on one type of behavior, insider trading, whose prohibition is thought to prevent fraudulent, deceptive, or manipulative acts. ? See O’Hagan, 521 U. S. at 672-73, 117 S. Ct. 2199. ? In accordance with its specific, prophylactic focus, Rule 14e-3 applies to a different set of behaviors than does Section 14(e): Section 14(e) centers on the actual tender offer, whereas Rule 14e-3 regulates illegal insider trading that takes place while a tender offer is under consideration. ? As appellants’ brief states, â€Å"[a]ll the elements of a Section 14(e)/Rule 14e-3 insider trading violation are supplied by the language of Rule 14e-3. A comparison of the facts in Plaine with the facts in this case illustrates the difference between the Section 14(e) claim conside red in Plaine and the Rule 14e-3 claim considered here. ? Plaine held shares in a company subject to a tender offer. ? She complained that false information in proxy materials had induced other shareholders to tender their shares. ? Because so many other shareholders tendered their shares, the merger went through at a price Plaine viewed as inadequate. Although Plaine did not tender her shares, the court ruled that she alleged injury occurring as a result of fraudulent activity in connection with a tender offer and had standing to assert her claim. ?797 F. 2d at 717. ? Plaine did not, however, allege insider trading, and therefore could not have made out a claim under Rule 14e-3. Brody and Crawford, on the other hand, did allege insider trading but did not allege that THC manipulated the tender offer process through the use of false information or by any other means. ? As such, the facts in the current case present a very different situation than that presented in Plaine. The circum stances do, however, bear a much closer resemblance to those in Neubronner, a Rule 10b-5 case centering around accusations of insider trading in violation of an abstain-or-disclose requirement. ? See Neubronner, 6 F. 3d at 667. Despite the similarities of the issues here and in Neubronner and between Rules 10b-5 and 14e-3, as applied to insider trading allegations, Brody and Crawford emphasize the differences between the Rules. ? Unlike Rule 10b-5, Rule 14e-3 does not require proof that a person traded on information obtained in violation of a duty owed to the source of the inside information. Instead, Rule 14e-3(a) creates a duty for a person with inside information to abstain or disclose â€Å"without regard to whether the trader owes a pre-existing fiduciary duty to respect the confidentiality of the information. † ? O’Hagan, 521 U. S. at 669, 117 S. Ct. 2199 (quoting United States v. Chestman, 947 F. 2d 551, 557 (2d Cir. 1991) (en banc)). ? Although Rule 14e-3 thus expands the notion of who is an insider, it does not follow that the Rule also expands the class of shareholders who may complain when an insider trades without disclosing insider information. As a result, the fact that Rule 10b-5 and Rule 14e-3 are not identical does not lead to the conclusion that one has a contemporaneous trading requirement and the other does not. More importantly, perhaps, in this case, the allegation is that THC traded in its own stock on the basis of inside information. ? Such allegations would state a â€Å"†¦Ã¢â‚¬Ëœtraditional’ or ‘classical’ theory of insider trading liability [under] Rule 10b-5 based on ‘a relationship of trust and confidence between the shareholders of a corporation and those insiders who have obtained information by reason of their position with that corporation. †¦Ã¢â‚¬  ? O’Hagan, 521 U. S. at 651-652, 117 S. Ct. 2199 (quoting Chiarella, 445 U. S. at 228, 100 S. Ct. 1108). ? As such, this case is one that could be-and indeed, was-brought under both Rule 10b-5 and Rule 14e-3, and as to which any differences between the two rules regarding the necessary relationship between the insider and the source of information is not relevant. Brody and Crawford note another reason that, they argue, suggests an expansive reading of Rule 14e-3 is appropriate. In O’Hagan, the Supreme Court ruled that the SEC is permitted to promulgate rules under Section 14(e), such as Rule 14e-3, that prohibit acts not themselves fraudulent under the common law if the rules are reasonably designed to prevent acts that are. ?521 U. S. at 671-73, 117 S. Ct. 2199. ? This authority derives from the prophylactic rule-making power granted to the SEC by Section 14(e), a power that has no parallel in Section 10(b). ?Id. That the SEC had more power to protect investors when it promulgated Rule 14e-3 than it did when it promulgated Rule 10b-5 does not mean, however, that the SEC exercised that power so as to protect noncontemporaneous traders under Rule 14e-3. ? And, in fact, what evidence there is demonstrates that the SEC did not intend to protect investors who could not have possibly traded with the insiders. In O’Hagan, the Supreme Court quoted at length from and afforded deference to the SEC’s explanation of why it promulgated Rule 14e-3. Part of the Federal Register excerpt quoted in O’Hagan stated: The Commission has previously expressed and continues to have serious concerns about trading by persons in possession of material, nonpublic information relating to a tender offer. ? This practice results in unfair disparities in market information and market disruption. ? Security holders who purchase from or sell to such persons are effectively denied the benefits of disclosure and the substantive protections of the [legislation that includes Section 14(e)]. 21 U. S. at 674, 117 S. Ct. 2199 (quoting 45 Fed. Reg. 60412 (1980)). This quotation evinces a particular concern for those who â€Å"purchase from or sell to† insiders, and suggests that these shareholders, and not others who trade later, are the intended beneficiaries of Rule 14e-3. ? The contemporaneous trading requirement, designed to limit the class of potential plaintiffs to only those who could have possibly traded with the insider, is therefore precisely congruent with the SEC’s expressed purpose in promulgating Rule 14e-3. In sum, Rule 10b-5 and Rule 14e-3 contain similar insider trading prohibitions, triggered by similar concerns. ? While Rule 14e-3 focuses on the tender offer context, the background history and language of Rule 14e-3 indicate that the Rule does not alter the premise that a shareholder must have traded with an insider or have traded at about the same time as an insider to be harmed by the insider’s trading. ? We conclude that there is no principled distinction between Rules 10b-5 and 14e-3 as regards the need for a contemporaneous trading allegation. We therefore extend the contemporaneous trading requirement to insider trading actions brought under Section 14(e) and Rule 14e-3 actions. ? Because Brody and Crawford traded nearly two months after they allege THC traded, they did not trade contemporaneously with THC. The district court was correct in dismissing their Rule 14e-3 insider trading claims. B.? Misrepresentation We next consider a different set of concerns addressed by the securities laws: Rule 10b-5 and Section 14(e)’s explicit prohibition against the making of untrue or misleading statements. The plaintiffs do not maintain that either press release issued by THC was untrue. ? They do argue, though, that THC violated the prohibitions against making misleading statements when it issued the two press releases here at issue. ? In order to survive a motion to dismiss under the heightened pleading standards of the Private Securities Litigation Reform Act (â€Å"PSLRA†), the plaintiffs’ complaint must spe cify the reason or reasons why the statements made by THC were misleading. ?15 U. S. C.  §? 78u-4(b) (1); see also Ronconi, 253 F. 3d at 429. As an initial matter, Brody and Crawford correctly assert that a statement that is literally true can be misleading and thus actionable under the securities laws. ? See In re GlenFed Sec. Litig. , 42 F. 3d 1541, 1551 (9th Cir. 1994). ? But they err when they argue that in order for a statement not to be misleading, â€Å"once a disclosure is made, there is a duty to make it complete and accurate. † This proposition has no support in the case law. ?Rule 10b-5 and Section 14(e) in terms prohibit only misleading and untrue statements, not statements that are incomplete. Similarly, the primary case upon which Brody and Crawford rely for their innovative completeness rule supports only a rule requiring that parties not mislead. ? Virginia Bankshares, Inc. v. Sandberg, 501 U. S. 1083, 1098 n. 7, 111 S. Ct. 2749, 115 L. Ed. 2d 929 (1991). ? Often, a statement will not mislead even if it is incomplete or does not include all relevant facts. 8 ? Further, a completeness rule such as Brody and Crawford suggest could implicate nearly all public statements potentially affecting securities sales or tender offers. No matter how detailed and accurate disclosure statements are, there are likely to be additional details that could have been disclosed but were not. ? To be actionable under the securities laws, an omission must be misleading; in other words it must affirmatively create an impression of a state of affairs that differs in a material way from the one that actually exists. ? See McCormick v. The Fund American Cos. , 26 F. 3d 869, 880 (9th Cir. 1994). We conclude that neither Rule 10b-5 nor Section 14(e) contains a freestanding completeness requirement; the requirement is that any public statements companies make that could affect security sales or tender offers not be misleading or untrue. ? Thus, in order to survive a motion to dismiss under the heightened pleading standards of the Private Securities Litigation Reform Act (â€Å"PSLRA†), the plaintiffs’ complaint must specify the reason or reasons why the statements made by THC were misleading or untrue, not simply why the statements were incomplete. 15 U. S. C.  §? 78u-4(b) (1); see also Ronconi, 253 F. 3d at 429. ?Brody and Crawford’s allegations do not comport with this requirement. ? They allege, first, that the press release issued on March 19 was misleading because it provided information about THC’s stock repurchase program but did not contain information regarding THC’s possible takeover. ? Although Brody and Crawford specify what inf ormation THC omitted, they do not indicate why the statement THC made was misleading. ? If the press elease had affirmatively intimated that no merger was imminent, it may well have been misleading. ? The actual press release, however, neither stated nor implied anything regarding a merger. ?Brody and Crawford also claim that THC’s second press release, issued on April 24, was misleading. ? Again, the plaintiffs do not argue that the press release was untrue. ? Instead, they argue that it was misleading because it stated generally that THC had received â€Å"expressions of interest† from potential acquirers, when in fact it had received actual proposals from three different parties. Importantly, the complaint does not provide an explanation as to why this general statement was misleading, nor is it self-evident that it was. A proposal is certainly an â€Å"expression of interest. † ? Moreover, the press release did not simply state that there had been vague â₠¬Å"expressions of interest;† it went on to state that the â€Å"expressions† were â€Å"from certain parties who have indicated an interest in acquiring either the entire company or in acquiring the company, with the company’s shareholders retaining their pro rata interests in Behavioral Healthcare Corporation [a THC subsidiary]. ? This specificity concerning the nature of the parties’ proposals certainly suggests that something more than preliminary inquiries had taken place. Further, the press release additionally stated that the â€Å"Board of Directors has engaged financial advisors to advise the company in connection with a possible sale. † ? This additional information again suggested proposals that were concrete enough to be taken seriously. ? And the reference to multiple parties contained in the press release suggests an ongoing auction for THC was taking place with at least two participants. In short, the press release did not give the impression that THC had not received actual proposals from three parties or otherwise mislead readers about the stage of the negotiations. ? Instead, although the press release did not provide all the information that THC possessed about its possible sale, the information THC did provide-and the reasonable inferences one could draw from that information-were entirely consistent with the more detailed explanation of the merger process that Brody and Crawford argue the press release should have included. Put another way, Brody, if he read the press release, would have been on notice, before he sold his shares, of the distinct possibility that the value of the shares would increase in the near future because of a takeover contest. 9 [11] Because Brody and Crawford have not alleged facts indicating that THC’s April 24 press release was misleading, the district court properly dismissed that aspect of the plaintiffs’ complaint. CON CLUSION Brody and Crawford have not met the contemporaneous trading requirements necessary to have standing in the insider trading claims they assert. Additionally, they have failed properly to allege misrepresentation against THC. As a result, we affirm the district court’s decision to dismiss Brody and Crawford’s complaint for failure to state a claim upon which relief could be granted. AFFIRMED FOOTNOTES 1. ?Section 10, in relevant part, states: It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce or of the mails, or of any facility of any national securities exchange-?..... b)? To use or employ, in connection with the purchase or sale of any security registered on a national securities exchange or any security not so registered, or any securities-based swap agreement (as defined in section 206B of the Gramm-Leach-Bliley Act), any manipulative or deceptive device or contrivance in contraventio n of such rules and regulations as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors. 2. Rule 10b-5 states: It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails or of any facility of any national securities exchange,(a)? To employ any device, scheme, or artifice to defraud,(b)? To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or(c)? To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person, in connection with the purchase or sale of any security. 3. ?These â€Å"standing† limitations are not, of course of the constitutional variety, grounded in Article III of the Constitution, but simply delineate the scope of the implied cause of action. 4. ?Section 14(e) states: It shall be unlawful for any person to make any untrue statement of a material fact or omit to tate any material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or to engage in any fraudulent, deceptive, or manipulative acts or practices, in connection with any tender offer or request or invitation for tenders, or any solicitation of security holders in opposition to or in favor of any such offer, request, or invitation. ? The Commission shall, for the purposes of this subsection, by rules and regulat ions define, and prescribe means reasonably designed to prevent, such acts and practices as are fraudulent, deceptive, or manipulative. . ?Rule 14e-3(a) states:(a)? If any person has taken a substantial step or steps to commence, or has commenced, a tender offer (the â€Å"offering person†), it shall constitute a fraudulent, deceptive or manipulative act or practice within the meaning of section 14(e) of the Act for any other person who is in possession of material information relating to such tender offer which information he knows or has reason to know is nonpublic and which he knows or has reason to know has been acquired directly or indirectly from:(1)? The offering person,(2)? The issuer of the securities sought or to be sought by such tender offer, or(3)? Any officer, director, partner or employee or any other person acting on behalf of the offering person or such issuer, to purchase or sell or cause to be purchased or sold any of such securities or any securities convertible into or exchangeable for any such securities or any option or right to obtain or to dispose of any of the foregoing securities, unless within a reasonable time prior to any purchase or sale such information and its source are publicly disclosed by press release or otherwise. 6. ?Chiarella v. United States, 445 U. S. 222, 100 S. Ct. 1108, 63 L. Ed. d 348 (1980), considered, but did not decide, the viability of a misappropriation theory of liability under Rule 10b-5. ?445 U. S. at 235-37, 100 S. Ct. 1108. ?(A misappropriation theory extends liability to some parties who trade in a company’s securities on the basis of confidential information but who have no special relationship with the company’s shareholders. ) Following Chiarella, the SEC promulgate d Rule 14e-3, which clearly creates liability for insiders who trade in connection with a tender offer and do not disclose the inside information, regardless of their relationship to the shareholders or the source of the information. Then in 1997, the Supreme Court decided O’Hagan, answering the question left open by Chiarella and deciding that Section 10(b) and Rule 10b-5 do create liability under a misappropriation theory. ?521 U. S. at 650, 117 S. Ct. 2199. ? The upshot is that Rules 10b-5 and 14e-3 largely overlap with regard to the scope of insider trader liability, although they differ in some respects not here pertinent. ? See p. 1004, infra. 7. As we discuss below, in O’Hagan the Supreme Court approved Rule 14e-3 as a prophylactic rule designed to prevent core violations of Section 14(e). ? See p. 1004, infra. 8. ?For example, if a company reports that its sales have risen from one year to the next, that statement is not misleading even though it does not inclu de a detailed breakdown of the company’s region by region or month by month sales. 9. ?We note that Crawford sold his shares before the April 24 press release, so he could not have been influenced in his trading by the release. BERZON, Circuit Judge.

Nursing Care for Clients With Acute and Chronic Health Problems Essay

Nursing Care for Clients With Acute and Chronic Health Problems - Essay Example What the doctor would probably order A complete blood count that determines the number, size, volume, and hemoglobin content of red blood cells. Blood iron level and serum ferritin level which is the best indicator of total body iron stores(Killip, Bennett, & Chambers, 2007). Level of vitamin B12and folate, vitamins necessary for red blood cell production. Special blood tests to detect rare causes of anemia, such as an immune attack on your red blood cells, red blood cell fragility, and defects of enzymes, hemoglobin, and clotting(Weiss & Goodnough, 2005). Â   Significant parts of her history The most important part of the history is the fact that she was started on iron due to low HB levels but later stopped taking them due to stomach upset, this means that if she had a hematological problem, then with time it progressed to a greater degree(Bross, Soch, & Smith-Knuppel, 2010).

Sunday, July 28, 2019

Quality of education in post-conflict in Rwanda and post-disasters in Essay

Quality of education in post-conflict in Rwanda and post-disasters in Pakistan - Essay Example Education can spare and support lives, offering physical, cognitive and psychosocial security when conveyed in protected, nonpartisan spaces. Education restores routine and gives individuals trust for the future; it can likewise serve as a channel both for meeting other essential compassionate needs and conveying basic messages that advance security and prosperity. During conflicts and catastrophes, education systems, students and personnel suffer the effects of the conflicts and catastrophes and forced displacement. Some of these effects include, loss of life, loss of property and loved ones, loss of educational opportunities, and mass rape and other sexual violence which is as a result of alteration of the school programs. Conflicts and catastrophes intensify inequality, disrupts the whole society. This can have severe psychological effects particular to the children who are in school (Schweisfurth, 2006). However, not having enough education worsens security and deepens poverty in a country. The presence of unequal education opportunities fuels a sense of injustice and grievances. Education of terrible quality can be exceedingly divisive, especially if choices about educational module content, course books or dialect of guideline prohibit or permit denunciation of some social gatherings, and if education strengthens messages that savagery i s a worthy answer to individual, social or political issues. Education has vast value for its own sake. This means that all young people and children, including those that have been affected by conflict and catastrophes have the right to receive a quality education. Nevertheless, education is needed in emergency setting to prepare the society for ultimate post-disaster and post-conflict reconstruction and social-economic development (Jones, 2006). Balanced development with economic development obliges that young people of all social, ethnic, religious and

Saturday, July 27, 2019

Motivation in Business Assignment Example | Topics and Well Written Essays - 1750 words

Motivation in Business - Assignment Example There are many reasons why it is important to have a highly motivated workforce and all of them have become integral parts of the bottom line, to give something positive for the organization’s performance, especially in a highly competitive environment. In this paper, the author tries to incorporate some reasons why it is important to have a highly motivated workforce in an organization. From the perspective of a business consultant, some important moves in order to increase the motivation of employees and the implementation of these actions are discussed. The importance of motivation Motivation has varying definitions because there are different approaches that could explain it including instinct, drive, arousal, incentive, cognitive, and the hierarchy of needs (Feldman, 2003). At some point, it is more effective to combine all these approaches in order to explain what motivation is all about. For example, an individual’s effort to survive after an accident can be expl ained as an impact of his instinct to survive, then he would seek for medical help from the perspective of drive-reduction, and then his expectation that the doctors could help him can be justified using the cognitive perspective (Feldman, 2003). Applying the concept of motivation at work is important for the organization to tap the maximum potential of its workforce. ...Although, for instance, the lack of creativity may not simply imply a lack of motivation because not all people are creative in nature or has the ability to be creative. Fortunately, employees can be motivated in order to achieve the expected energy, commitment, and creativity. Energy It is important to motivate employees because motivation can actually provide them with the energy they need in order to perform their maximum function. From the point of view of Herzberg’s two-factor theory, employee’s satisfaction at work can significantly provide them with substantially high energy in order to do what they are expected of (French et al., 2008). However, Herzberg just emphasized that employees should have the ability and opportunity prior to motivating them.

Friday, July 26, 2019

Generally Accepted Auditing Standards Paper Essay

Generally Accepted Auditing Standards Paper - Essay Example The audit opinion resulting from verification of financial statements provides a reasonable assurance that the statements give a true and fair value in accordance with the frameworks of financial reporting; therefore, Mobitech Accessories Ltd. does not expect auditors to produce absolute assurance by detecting all aspects of errors and fraud. Types of audits that organizations can perform include statutory, internal, external, and compulsory audits. Various standards, Acts, and boards have been initiated to guide the auditing function. Generally Accepted Auditing Standards provides a basis for performing and judging the quality of audits (Catty, 2012). The general requirements of GAAS include maintenance of independence in audit matters, adequate technical training, and proficiency for audit performance, and exercising professional care during audit performance and report preparation. Mobitech Accessories Ltd enables auditors to obtain sufficient understanding of the enterprise and allows auditors to access sufficient evidence by performing audit procedures in accordance with GAAS. GAAS also require the auditor to express an opinion regarding the financial statements; an opinion can be qualified, unqualified or disclaimer (Huault & Richard, 2012). Mobitech Accessories Ltd auditors usually state reasons in the report where they cannot express an overall opinion. GAAS provide assumptions, principles, and constraints to achieve basic objectives and implement fundamental qualities (Huault & Richard, 2012). The accounting entity assumption assumes that the business entity is a being and separate and distinct from its owners and managers. The going concern assumption assumes that the business will remain in operation indefinitely. The historical cost principle requires companies to report their liabilities and assets based on costs of acquisition rather than fair market value. The principle of revenue

Thursday, July 25, 2019

The Educational System in the United States Research Paper

The Educational System in the United States - Research Paper Example From this discussion it is clear that  everyday conversational skills such as writing, reading and collaboration can truly solidify the foundation of the student’s cognitive and linguistic skills. In the process of learning an additional language, ESL students must keep up with the daily strains that are placed in their program of studies.  ESL students must learn to excel in time management skills. Indisputably, each student has a unique set of literacy development needs. Most ESL students have a strict schedule and must be accommodated with personalized program of activities that is managed by the staff itself. One can only imagine the surreal experience of international students, who at times felt hopeless as a foreign student in a North American School. The point is to acknowledge that internationals students are faced with academic, social, and emotional challenges in every aspect of life, which makes learning English much more difficult.This study highlights that lea rning and applying that knowledge is a fairly non-trivial challenge for the average American. But what of non-natives who are required to learn and master one of the most grammatically complex languages? This is a struggle which is unquantifiable and difficult to overcome.  Many non-native English speakers who often feel confused, frustrated, and pressured to achieve in an environment of native English speakers are in continuous pressure to excel in academics.... Clearly, it is vital that students should ask for help and set goals on how to overcome each issue. Therefore, â€Å"procedure† becomes a necessary element to facilitate student growth as the tutor advises them to set goals and helps them accomplish these goals. In addition, it affords students the opportunity to discuss with the tutor any concerns they have.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚     For majority of the ELL students, grammar is the biggest focal point. ESL students are often very knowledgeable in grammar yet fall into the trap of superfluity. ESL students are constantly struggling to write like their counterparts, yet they traditionally fall short because they approach the problem with a skewed mentality. ESL students aim for a high status instead of learning from experience.   The challenge of writing like a native English student extends beyond writing the ‘right’ word as the language itself contains multiple-word meanings. In addition, the American standard demands effective argumentation and synthesis at higher levels. This standard challenges students not only adapt to different writing styles, but to acknowledge other writing method - a seemingly painless task which is continuously compounded by a lack of familiarity with the language and its intricacies.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   As a tutor, it is important to account for the differences in writing style prevalent between ESL and native English speakers. The lack of context and organization present in ESL students’ writing stems from an overemphasis on grammar. Nevertheless, these differences do not correspond to a deficiency. Most ESL students get so caught up by wanting to get their papers fixed that they fail to understand the objective of the tutoring session, which

Wednesday, July 24, 2019

Effects of National Culture on Accounting Rule Application Essay

Effects of National Culture on Accounting Rule Application - Essay Example The study will randomly select Certified Public Accountants from eight states to measure contingent liabilities and contingent assets recognition and disclosure decisions. The study will use an analysis of variance to compare the group average to determine if there are any statistically significant differences between the variables. The proposed study has both a theoretical and practical implication. The study will attempt to validate Tsakumis’ survey that applied Gray’s accounting theory with respect to conservatism and secrecy. From a practical application, the study may identify variables that influence an accountant’s disclosure decisions that could lead to improving information reporting between manager and other stakeholders. The cross-border dynamics of the global economy has consistently required businesses to conduct trade across international lines in order to remain or become competitive. In each host country, the authorities require multinational firm s to submit financial statements that adhere to the host nation’s Generally Accepted Accounting Principles (GAAP). However, cultural differences have resulted in accountants exercising a degree of caution relative to adopting new accounting GAAP. The International Accounting Standards Board (IASB) has developed International Accounting Standards (IAS) and, in particular, International Financial Reporting Standards (IFRS). These standards are intended to produce uniformity in financial information reports for all multinational firms globally. In the U.S., the Security and Exchange Commission (SEC) has mandated that all publicly traded firms in the U. S. adopt the IAS by 2016.

Tuesday, July 23, 2019

Strategy Book Case Study Example | Topics and Well Written Essays - 750 words

Strategy Book - Case Study Example The sand dunes are the largest in the world, and they cover the largest coastal sand dune area in the USA (50 miles). The Stellar sea lion rookery is the only one in the mainland 48 states (Essentix). Florence has impressive man-made resources, as well, including: a rich history (Siuslaw Indians and loggers), a doll museum and pioneer artifacts museum, a sand dune golf course and an award-winning golf course. The Old Town has been tastefully restored. There is shopping, art, restaurants, river walks, historical buildings, live music and dancing. Peace Harbor Hospital serves Western Lane County. There is an existing tourism industry (Essentix). All towns have weaknesses, however. Florence’s population is weighted unevenly on the side of senior citizens. According to the 2010 census, the median age is 57 (Wikipedia). I suspect this has a negative effect on available tax income, and would shape the town in a conservative direction, where stability is preferable to risky opportunities. An older population is probably not attractive to young people, and there might be insufficient motivation to relocate there. In considering opportunities, what stands out in my mind is healthy, natural living and tourism. Residents are mostly older, so health support is attractive to them. People are living longer and want to feel good. Tourists want active, outdoor activities. That is why they come to Florence. For opportunity, we must build on tourism and natural resources, perhaps targeting a group not currently targeted. Threats may include resistance to abrupt change, due to an older population. Expanding nature-based tourism is dependent on outsider cooperation, as well as insider cooperation. Florence is not as well-known as Newport and Coos Bay, although it is uniquely positioned. Based on my SWOT analysis, it is clear that Florence is all about healthy, natural living and tourism. In googling Florence, this emphasis is quite visible. Although the town experienced

London Transportation Essay Example for Free

London Transportation Essay London, England has long been regarded as a cosmopolitan metropolis with international appeal at the cutting edge of culture and technology, as well as its ancient and innovative transportation options. London’s location next to a major tributary â€Å"in the middle stretch of the Thames valley† , its basin rim terraced with materials formed from sedimentary sand and clay, has played an integral part in its transportation history(a full geographical representation of the city is shown in Appendix A). It was water-borne trade which allowed it to grow and prosper after the Romans, renowned for their road-building systems, built the city they named Londinium. No longer relying just on watercraft as a lifeline to the rest of the world, London today provides a wealth of sophisticated transportation options to its citizens with the vast entirety of its public motor thoroughfares redesigned after World War II. A modern visitor to London can now board a train or bus, descend underground and take a tube (subway), hop on a light rail or take a ride from one of many express terminals. It has taken decades for London to achieve, and then regain, its status as a great city for transportation, however. The second world war nearly devastated the city. During the following two decades, â€Å"London’s status as the hub of the British Empire† declined along with a reduction in public transport options . By 1986, the Greater London Development Council, which had dealt with issues of reconstruction, was abolished and for the first time in 97 years, â€Å"there was no unified representative government† for the city . London was now forced to address its post-war problems including the challenge of providing additional transportation options for the growing populace and creating a federal transport authority. Today, the United Kingdom has a population of 60,776,238, with the majority of this based in London and Great Britain. The country enjoys a strong economy and low unemployment while the government is focusing on â€Å"the improvement of education, transport, and health services, at a cost in higher taxes and a widening public deficit† . The numerous transitions in London’s transportation are examined here in chronological order beginning with its ancient history, its revival post-war, continuing into the 1960’s, a look back at the era of the 1980’s and finally, an overview of mass, affordable transportation options in today’s London society with a forecast for the future. History The Romans were the first recorded populace to recognize the importance of the Thames River. After their invasion of the area in AD 43, the Romans built a permanent bridge over the river as well as a network of roadways . The course of many of these roads is still the basis of modern thoroughfares today. In the 1st century, Londinium’s port was active with commerce. The River Thames was used by invaders as a waterway to storm the city during Viking times and new streets laid out after the takeover by the Saxons, some of which even used lanes much like we would expect today to subdivide them . The famed London Bridge was rebuilt in the late 12th century and during this time many of the streets were named with monikers still in use today. The Great Fire of 1666 prompted the construction of two new streets to intersect city as well as the widening of many of London’s streets and lane. Six new bridges were added to cross the River Thames between 1750 and 1835 and toll roadways were created to pay for repairs to existing thoroughfares. Hansom cabs were first introduced as another form of transportation in 1834 while the first passenger railway appeared just two years later. Deep water basins were added to the river at this time to reduce congestion from shipping. The Thames Tunnel was opened in 1843 to provide another avenue of transport over the river. Victorian London witnessed a revolution in transportation with the arrival of omnibuses, the extension of the railways for passenger trains to completely traverse the city, trams (first horse-drawn, then electrified by the turn of the century) and tube railways. The first underground railroad was opened in London in 1884. It was the very first of its kind and a model for other metropolitan areas in the ensuring decades. Appendix B contains a map of London’s current underground system with its extensive labyrinth of passageways. The growth of the commuting labor force living in the suburbs prompted the construction of new trunk roads and the expansion of the underground system to accommodate them in the years prior to World War II. Subsequent bombings of the city during the war in the 1940’s would escalate redevelopment of its ancient roadways. World War II In the midst of the second World War in September, 1940, Germany instituted the Blitz, a sustained six-month bombardment of London which killed 20,000 residents. After the bombing ended in May, 1941, London became a â€Å"major centre of wartime production† before Hitler renewed his assault on the city in summer of 1944 resulting in 29,890 Londoners killed and 50,507 injured. Underground rail stations were even used as shelters and the tunnels pressed into use for weapons storage. While the negative effects of these bombings included reduction of the population and significant damage caused throughout parts of the city, the end of the war became the impetus for England to start replanning the layout of London and surrounding towns, roadways and public transport and urge relocation from overpopulated areas to the suburbs (see Appendix C for a map of areas affected by bombing). Without a federal transport authority to draw up plans for redevelopment of roadways, much of the work was undertaken by landowners and commercial developers whose interests it would best serve. Construction of an airport began in 1946. In 1947, the legislature passed the Town and Country Planning Act to redevelop the slums of the East End, which had long been largely ignored since the majority of wealthy citizens resided in the West End. Narrow and impassable roads in the area were replaced for a nearly complete revitalization. After years of austerity in the war, it was with great acclaim that Britain crowned their new queen, Elizabeth II, in 1952. Her coronation ceremony, complete with a drive through London in the ancient Gold State Coach, prompted a renewed interest in horse and carriages. The British Driving Society was formed soon thereafter to honor the ancient sport of driving various horse-drawn vehicles . Royalty used the Long Walk at Windsor to display their horsemanship skills while the general public was confined to the pathways of parks in the West End. While Queen Elizabeth began her reign, the last of the famous London trams was officially retired. The decade of the 50’s was one rife with innovation, however. 1953 saw the opening of the newly completed Heathrow Airport in London. The first commercial air service between London and Moscow was launched in 1957 and the city received its first parking meters in 1958. The initial section of the London-Birmingham Motorway opened in 1959, closing out the decade with a loud roar.

Monday, July 22, 2019

A Modest Proposal Essay Example for Free

A Modest Proposal Essay A Modest Proposal is a satiric essay by Jonathan Swift, written in 1729. It is aimed at the rich landowners of Ireland who are keeping the poor of Ireland in poverty and virtual starvation. The narrator is Swift, who seems to be making a strong case for cannibalism as a method for solving the problem of hunger and overpopulation in one ostensibly simple solution. He proposes that the Irish should sell their children under the age of one year as meat for the tables of the wealthy. The problems Swift describes are primarily the number of poor in Ireland who are being forced to work for food in amounts less than that which is needed to feed their families. He hints that because of their religion they over-breed, being catholic and not practicing birth control. The same problems described by Swift in the 18th century are occurring today in many parts of the world. Hunger exists and children are born into families too poor and uneducated to do anything about a pregnancy when they cannot feed or clothe the children they have. The U. N. attempts to ameliorate the hunger but nothing is done about the source of the problem so the food only fuels a new generation who are doomed to be as hungry as the one before it. Swift argues that marriage could be looked upon as a method of producing children as meat for the tables of the rich and that the union of a couple would have great financial benefits. They could produce meat children as a farmer raises pigs for slaughter. Swift speaks ironically of his proposals having the benefit, â€Å"Of teaching landlords to have at least one degree of mercy toward their tenants,† (Swift). Bibliography Swift, J. A Modest Proposal 1729.

Sunday, July 21, 2019

Alternate Forms of Stable Government: Contractual Society

Alternate Forms of Stable Government: Contractual Society Clayton Wheatley A Stable Form of Alternate Government Should another entity choose what is better for another man? Our Current political system seems to think so. Imagine a way of living in which one controls the economy with supply and demand being the base for essentially every aspect in one’s life. This is what a contractual society is, a society based purely on voluntary action, entirely unhampered by violence or threats of violence. Using this idea of a Contractual society, certain aspects of the current political system will be retained, but allow increased individual sovereignty and promote a market free of regulation. Anarcho-capitalists agree that the most profitable society would be one based on the voluntary trade of private property and services as well as respecting the necessity of charity and communal arrangements. What must remain un-interrupted in this ideology is that whatever is acquired is done so without help or hindrance from an external source. Monopolies tend to be corrupt and inefficient, so in this new society the policy on them will remain the same, but will only stay this way if it is the agreement of the people, who as a whole vote with the payment given to a particular corporation or corporations. If the people continue to pay into this monopolistic being it will continue to survive and remain the majority, but this must mean it is in the best interest for the people because they are not influenced to provide payment. Close to anarcho-capitalism are the ideals of individual-ownership and original appropriation. These include but are not limited to being the proper owner of on e’s physical body and allowed to make decisions based on what they see best for their own personal property. This ownership of â€Å"originally appropriated† implies the right to use and manipulate places and goods owned by an individual anyway that seems fit provided that the physical integrity of places and goods claimed by another individual remain unaltered by you, the external source. Once any amount of time or work is invested into a plot of land or on a specific object, it can only be exchanged by a mutual agreement. What makes this form of government stand out is it does not reject the idea of individual or joint ownership; in fact it is actually encouraged. What one needs or does not need is entirely up to the person. Though anarcho-capitalists assert the right to hold and maintain private property, some point out that communal property can exist. Just as property becomes owned by mixing labor with it or making use of the area on a more permanent basis, a whole community can come to own something in common by doing just that, meaning that no individual may appropriate it as his own. Situations in which this could arise are for things like roads, parks, rivers, and portions of oceans. If allowing everyone to take a small role in helping maintain the area and it’s a resource mutually beneficial to the group that is what it becomes a group effort. Nevertheless, when property is owned by multiple persons, the level of accountability each individual holds tends to deteriorate unlike in personal ownership, where the maintenance is only up to the one, original owner. Privatization, decentralization, and individualization are often anarcho-capitalist goals, but in a few select cases they not only a re considered difficult to uphold, but are impossible. Ocean routes for example are a certain property that would be seen as unavailable for private ownership. Individual sovereignty is the idea of property in ones own person, shown as the natural right of a person to have basic freedoms, and have the final say in ones own body and life. According to G. Cohen, the concept of self-ownership is that â€Å"Each person enjoys, over himself and his powers, full and exclusive rights of control and use, and therefore owes no service or product to anyone else that he has not contracted to supply.† One may describe someone with this type of freedom as those which have supreme authority and sovereignty over their own choices. This is a tenant to classical liberalism and essential to any ideologies which encompass one making decisions for themselves and leading their own lives. This is the root of anarcho-capitalist property rights, and where they differ from other forms of anarchism such as anarcho-communism where the means of production are controlled by the community as a whole and the product produced is placed into a collectivized pool and distributed on a system determined by necessity. This particular anarcho-capitalist society stresses the value of individual integrity and living a life based on your own terms; this includes dealing with one’s own mistakes once they are made and no one else being involved unless they are bound by a contract mutually agreed upon by both original parties. The free market further increases individual freedoms within this society because it allows for a person to decide which services are maintained and provided within his personal way of life. Basically if something like defense is considered too much of a goal one has the power to lower payment on it and in some cases, if necessary, en it entirely. This either lowers how much is available because of the lack in demand, or stops a completely unnecessary service because no one is stimulating its personal economy. Supply and demand will be the basis for what does and does not survive within this society. The old west is actually an accurate portrayal of this idea. United states in the time of 1830 to 1900 was similar to this political idea in that private agencies provided the necessary ground to provide a somewhat orderly society but mainly allowed property to be protected and disagreements able to be resolved. The common that is that the Old West was in a state of chaos with little respect for property rights is false. Since squatters had no right to new lands under federal law, third party organizations formed to take the place of the government regulation. The defense companies each created their own written contract laying out the laws that provided the means for defining and protecting property rights in the land. They enforced procedures for registration of land claims, as well as for protection of those claims against others, and for ruling on internal disputes that arose. A pressing matter within the conversations of possible outcomes which could arise is â€Å"whether anarcho-capitalist society is justified on the morality of an action based on the action’s obedience to a rule of one’s conduct are the ultimate basis for any judgments about the rightness of the conduct, or both.† Natural-law anarcho-capitalism claims that a universal system of rights can be derived from natural law. Some do not like the idea of relying on these natural rights, but instead choose to rely on economic justifications for a free-market capitalist society. Kosanke sees such a debate as irrelevant since, â€Å"in the absence of the state, sovereign individuals will make their own decisions about morality, and will be held accountable via contractual law.† Communities of sovereign persons expel negative influences the same way that unbeneficial business practices are taken out because of the mutual want in the marketplace as a whole. For him, the o nly thing that needs to be debated is the nature of the contractual mechanism that abolished the state or prevents it from coming into existence where new communities form. Crime can encompass many different things. It could be something as simple as jaywalking, or littering. These crimes while not really moral, are not really immoral either they are just unfavorable actions. On the other hand you have much more serious problems facing everyone involved in a society. Things like homicide, kidnapping, robbery, etc are much more severe. These crimes involve a victim; some third party who did not wish to be involved was forced to become a part of this. The victim is not in the wrong for they didn’t wish for these things to be done to them, thus you have a stiff punishment. Now, there is a third type of crime, crimes that don’t involve anyone other than an individual making his own decision, yet the punishment for these result in the same penalty as the more serious crimes mentioned earlier. The type of actions that result in this are called victimless crimes, crimes that involve no one else other than he who had the idea to commit this Ã¢â‚¬Ë œcrime’. Richard Frase defines what victimless crimes are, â€Å"The practical arguments against victimless crimes appear to derive from three attributes of these offenses: (1) most involve no complaining parties other than police officers; (2) many involve the exchange of prohibited goods or services that are strongly desired by the participants; and (3) all seek to prevent individual or social harms that are widely believed to be less serious and/or less likely to occur than the harms involved in crimes with victims.† For example drugs, prostitution, gambling, and even something little like not wearing a seatbelt are all victimless crimes. For drugs you have an individual who takes the steps to purchase this substance. He and the participating party make a mutual agreement for an exchange and who is to say that isn’t allowed? Prostitution, again, both of the parties involved have profited in their eyes. Who is the victim if both parties have profited? In an an archo society victimless crimes wouldn’t exist. If no one is wronged and no one is unwillingly involved there is no problem. A contractual society will provide these certain aspects of the current political system but allow increased individual sovereignty and promote a market free of regulation. The positive use of charity and a distrust of monopolies will remain, while individual sovereignty will be upheld and increased in daily life. This ‘individual sovereignty’ is further increased by the idea of a free market and stimulating what you believe is in you best interests. This means if it is in no one’s market and stimulating what you believe is in your best interests. This means if it is in no one’s benefit it will lose funding and thusly cease to exist upholding the idea of making decisions concerning your life. If these ideas are incorporated into current government policies it would prove better for the people and worse for the overall rule the current administration holds as a whole over us. Works cited Hogeye, Bill T. â€Å"Anarcho-capitalist FAQ.† Anarcho-capitalistFAQ. Bill Hogeye, 6 Dec. 2011. Web. 11 Dec. 2013. http://www.ozarkia.net/bill/anarchism/faq.html>. Taylor, Jared M. â€Å"The Property and Freedom Society.† The Property and Freedom Society RSS. WordPress Admin, Jan.-Feb. 2012. Web. 12 Dev. 2013 http://propertyandfreedom.org/>. Vallentyne, Peter. â€Å"Libertarianism.† Standford University. Standford University, 05 Sept. 2002. Web. 12 Dec. 2013. http://plato.standord.edu/entries/libertarianism/>.

Saturday, July 20, 2019

Consequences of Nick Carraway as Narrator of F. Scott Fitzgeralds The

The Importance of Nick Carraway as Narrator of The Great Gatsby    In The Great Gatsby, Fitzgerald critiques the disillusionment of the American Dream by contrasting the corruption of those who adopt a superficial lifestyle with the honesty of Nick Carraway. As Carraway familiarizes himself with the lives of Tom and Daisy Buchanan, Jordan Baker and Jay Gatsby, he realizes the false seductiveness of the New York lifestyle and regains respect for the Midwest he left behind. "Fitzgerald needs an objective narrator to convey and prove this criticism, and uses Carraway not only as the point of view character, but also as a counter example to the immorality and dishonesty Carraway finds in New York" (Bewley 31). Fitzgerald must construct this narrator as reliable. Due to the nature of the novel, the reader would not believe the story if it were told from the perspective of any other character. Fitzgerald cannot expect the reader to believe what the immoral and careless characters have to say, and he spends so much time establishing them as such. Thus, Car raway is deemed narrator and the reader trusts him. As the practical character in the novel, Carraway is not rash; he is not swayed by the greed and alcohol as some other members of East and West Egg society are. He proclaims, "I have been drunk just twice in my life" (Fitzgerald 33). Fitzgerald constructs Carraway as a follower, not a man of action. He observes Gatsby's parties, never fully experiencing them. He observes the moment before the kiss between the starlet and her director, although Fitzgerald never details the physicality of his relationship with Baker. He observes the affair between Tom Buchanan and Myrtle Wilson, but he never confronts Tom Buchanan, nor does he e... ...y to tell the story, but also to critique the mass disillusionment with the American Dream. Carraway's honesty makes him ideal to represent all that the Buchanans lack and legitimizes his admiration of Gatsby. No reader would consider the full impact of Fitzgerald's themes had less attention been given to the creation and execution of the character of Carraway. Works Cited and Consulted: Bewley, Marius. "Scott Fizgerald's Criticism of America." Bloomington: Indiana UP, 1983. Fitzgerald, F. Scott. The Great Gatsby. New York: Macmillan Publishing Company, 1992. Hobsbawm, Eric. The Age of Extremes. New York: Pantheon, 1994. Raleigh, John Henry. "F. Scott Fitzgerald's The Great Gatsby." Trilling 99-103. Trilling, Lionel. "F. Scott Fitzgerald." Critical Essays on Scott Fitzgerald's "Great Gatsby." Ed. Scott Donaldson. Boston: Hall, 1984. 13-20.

Aime Cesaires A Tempest Clarifies Shakespeares The Tempest Essay exam

Cesaire's A Tempest Clarifies Shakespeare's The Tempest      Ã‚  Ã‚   "Negritude, originally a literary and ideological movement of French-speaking black intellectuals, reflects an important and comprehensive reaction to the colonial situation of European colonization" (Carlberg).   This movement, which influenced Africans as well as blacks around the world, specifically rejects the political, social, and moral domination of the West.  Ã‚   Leopold Senghor, Leon Damas, and Aime Cesaire are the three pioneers of the revolution.   The founder who expresses his ideas more broadly, though, is Cesaire, who uses literary works to express his viewpoint on colonization.   An excellent example of such a tactic is his play, A Tempest, which is a revision of William Shakespeare's The Tempest.   Both Shakespeare and Cesaire accentuate the greed of Europeans in their plays.   However, Cesaire is more obvious in his approach to exposing it.   A comparison of the two plays demonstrates that Cesaire's version, written in the late 1960's, is written as a confrontation of Shakespeare's play.   He is attempting to comment on the corruption of Colonialism and the European domination of the New World through such strategies as making seemingly minor changes, switching the main character role, and altering the storyline itself.    Incorporating alterations such as ethical changes, using different language, and the change in title may seem ineffective initially, but close reading proves that Cesaire uses these strategies as his reaction to European colonialism.   Because it was written in the 1600's, a time when European domination of the East was present and blacks were nothing more than servants, William Shakespeare's play does not include, nor mention black... ... Theories of Colonialism & Postcolonialism", Brown Univ. 1993 Available: http://www.scholars.nus.edu.sg/landow/post/poldiscourse/negritude.html   Cesaire, Aime. A Tempest. Trans. Richard Miller. New York: UBU, 1992. Davis, Gregson.   Aime Cesaire.   United Kingdom : Cambridge Univ. Press, 1997. Dayan, Joan. "Playing Caliban; Cesaireà ­s Tempest." Arizona Ouarterly. 48.4 (1942): 125-145. Shakespeare, William. The Tempest. Ed. Frank Kermode. Cambridge: Harvard UP, 1958.    Works Consulted Breitman, George. The Bible. Malcolm X Speaks; Selected Speeches and Statements. New York: Pathfinder, 1989. Neilson, Francis. Shakespeare and The Tempest. New Hampshire: Richard C. Smith Inc., 1956. West, Cornel. Race Matters. New York: Vintage, 1992. Wood, Joe, ed. Malcolm X: In Our Own Image. New York: St. Martins, 1992.         

Friday, July 19, 2019

Automobile Suspension Systems :: essays research papers

  Ã‚  Ã‚  Ã‚  Ã‚  Vehicle suspension is the system of springs and dampers that controls vertical oscillations of the vehicle, determining ride comfort and operating safety. With the technology available today, there are three different functions that can be accomplished with adjustable, electronically controlled suspension.   Ã‚  Ã‚  Ã‚  Ã‚  The simplest suspension adjustment is load-leveling used to control ride height for towing and carrying a heavy load in the trunk. Early versions, such as Packards in the fifties, utilized torsion bar rear springs. Ride height was adjusted by rotating the anchored end of the bar with a starter-type motor, a gearbox and heavy bell crank linkage. Since the weight on the front axle doesn’t change much, the motor solenoid was controlled with a simple mercury switch mounted parallel to the frame rail, acting as the rear height sensor. Simple load-leveling suspensions today use air-adjustable springs or shock absorbers, an onboard air compressor and a real ride height sensor that supplies data to a control unit or an onboard computer.   Ã‚  Ã‚  Ã‚  Ã‚  The next function of an electronic suspension is semi-active suspension. Semi- active suspension works by changing spring and/or dampening rate. The control unit receives information about vehicle behavior, interprets that information as road surface condition and driver intent, then adjusts dampening to a programmed level of firmness. Dampening adjustment is usually accomplished with a shock absorber that has several different orifice valves to control the flow of oil, with a solenoid or stepper motor used to control valve selection.   Ã‚  Ã‚  Ã‚  Ã‚  Finally comes the full-active suspension. A fully active system can counteract body motions by actually forcing the suspension to extend in response to measured and anticipated vehicle motion. In many ways, active suspension is simpler than other systems because it doesn’t need exotic shock absorbers or air spring technology, just four hydraulic rams and the attendant valves and plumbing.