Monday, August 24, 2020
Improve Your Writing Essay
Utilize formal language: Passive voice and participles where conceivable 1.Because they would prefer not to inconvenience their folks a few youngsters attempt to take care of their issues themselves. Not having any desire to inconvenience their folks a few adolescents attempt to take care of their issues themselves. 2. Ãâ¢f we live near our folks it can mean having less protection. Living near our folks it can mean having less protection. 3. In the event that we contemplate everything compelling technique is required to confront the issue. Bringing everything into considerationâ⬠¦ 4.If you fill in as a worker in a built up organization, it has a few positive highlights. Filling in as a representative in a built up organization, has a few positive highlights. à 5.If we furnish detainees with fundamental instructional classes in the utilization of devices or PCs all things considered, detainees will discover work after their discharge. Latent voice: If detainees are furnished with fundamental instructional classes in the utilization of devices or PCs all things considered, detainees will discover work after their discharge. Participle: If furnished with fundamental preparing detainees will be bound to discover work after their discharge. 6. On the off chance that we furnish individuals with PC aptitudes, they will have the option to approach a tremendous measure of data. Latent voice: If individuals are outfitted with PC abilities , they will have the option to approach an immense measure of data. Pariciple: If outfitted with PC aptitudes , individuals will have the option to approach an immense measure of data. 7. On the off chance that it is appropriately overseen such a program will undoubtedly bring great outcomes. On the off chance that appropriately overseen such a programâ⬠¦.. 8. I accept that in the event that we have oneââ¬â¢s opportunity removed is in itself, a genuine enough discipline. I accept that having oneââ¬â¢s opportunity removed is in itself, a genuine enough discipline. 9. At the point when we read we utilize our creative mind When perusing we utilize our creative mind 10. There are extensive contrasts between the old and the youthful when they buy electronic hardware. There are significant contrasts between the old and the youthful when buying electronic hardware. 11.While we need government backing to manage the ecological issues, open mindfulness is additionally essential. While requiring government backing to manage the natural issues, open mindfulness is additionally crucial.
Saturday, August 22, 2020
Is College Worth It? Essay
I figure we as a whole can concur that getting instruction is an imperative procedure that is urgent for being effective in our general public, yet does getting an advanced degree ensure oneââ¬â¢s achievement? I know, with the expense of a higher education rising 1,120% inside the previous 30 years, a large number of us would prefer not to pause and discover ourselves. In spite of the fact that getting an advanced degree may not ensure oneââ¬â¢s achievement in the activity advertise, one thing that accompanies an advanced degree is practically sure; a huge number of dollars paying off debtors. 2 out of each 5 credit borrowers are reprobate sooner or later inside the initial 5 years of reimbursement as indicated by the Institute for Higher Education Policy. This shows practically half of individuals who take out credits are experiencing a type of difficulty reimbursing it. With a collective measure of 1. 2 trillion dollars owing debtors that understudies get themselves into a year, I am not amazed. This raises the inquiry: Is College justified, despite all the trouble? A College training is a venture completely all alone, however will your speculation pay off? ââ¬Å"The question is whether you will get your arrival on the interest in real monetary capital or human capital or passionate capital or social capitalâ⬠, as indicated by Professor Boyce Watkins of Syracuse University (Coleman Korva). Getting an advanced degree doesn't promise you any budgetary accomplishment using any and all means. In the 2011-12 scholastic year, the normal net expense for a full-time understudy at an in state funded college was about $15,000 for educational cost, charges, room, load up, books and coincidental costs, as per the College Board (Clark Kim), and an out of state school is almost three time that sum. Simultaneously, just 27 percent of school graduates have a vocation identified with their significant right out of school (Plumer Brad). Despite the fact that solitary 27 percent of school graduates found a new line of work identified with their significant right out of school, 62 percent of U. S. school graduates had a vocation that necessary a higher education directly out of school (Plumer Brad). That is a superior number, however there is as yet 38 percent that either doesnââ¬â¢t have an occupation, or has a vocation that doesnââ¬â¢t require a degree. I donââ¬â¢t think about you, yet I donââ¬â¢t need to wind up flipping burgers when Iââ¬â¢m finished with school. Some portion of making College a beneficial venture is picking the correct major. The correct major can prompt a ton of accessible employments. I realize that we as a whole have various dreams and need to seek after them, yet we got the opportunity to acknowledge the obvious issues; a few majors arenââ¬â¢t doing so hot right now in the activity showcase. In light of high starting joblessness rates and low beginning middle profit of full-time, entire year laborers, creative majors are ghastly at the present time. Ongoing school alumni of from ages 22 to 26 can expect a joblessness pace of 10. 5 percent, well over the national normal (Goudreau Jenna). The individuals who do figure out how to catch a vocation are met with just a middle pay of just $28,000. Because of a high joblessness rate and low middle pay, most craftsmanship majors won't receive much as an end-result of going to school. That is only one of numerous majors that arenââ¬â¢t doing great as well. Different majors that arenââ¬â¢t worth the venture incorporate Sociology, Psychology and Nutrition. Designing then again is one hot ticket right now in the activity showcase. The top major for accomplishing a significant pay is designing (Still Daniel). Out of all the building majors, oil designing tops out with a pay of $90,000 directly out of school. Aeronautic design, synthetic building, and electrical building are not very a long ways behind either. Building in General is by all accounts the best approach in the event that you need your speculation to pay off. Other beneficial majors incorporate Computers, Mathematics, and Pharmaceutical sciences. These majors are what makes heading off to college a beneficial venture. The present place of employment showcase is searching for occupations identifying with these majors. Despite the fact that a vocation isnââ¬â¢t ensured after school, it would in any case be a wise speculation. Presently we as a whole realize that school is a wise venture in the event that you cause it to be, however is there actually a contrast between somebody who has an advanced degree and somebody who has a secondary school training or lower? ââ¬Å"Itââ¬â¢s an extreme activity advertise for school graduates, yet far more regrettable for those without a school education,â⬠says Anthony P. Carnevale co-creator of the investigation led at Georgetown Universityââ¬â¢s Center of Education and the Work Force. During the Great Recession in 2007, Millions of occupations evaporated from the activity showcase, however understudies with lone rangers degrees who had employments didn't decrease (International Business, Times). Simultaneously, the 55 percent of secondary school graduates who had occupations even before the downturn, tumbled to 47 percent after it (Perez-Pena Richard). As though individuals without an advanced degree didnââ¬â¢t have it hard enough as of now. Presently the measure of occupations that require an advanced degree is on the ascent, while individuals without an advanced degree are in effect left in the residue. All things considered, individuals with an advanced degree make significantly more than somebody with a secondary school certificate as well. The normal salary of a secondary school graduate is around $28,700. Contrasted with the normal pay of somebody with a bachelorââ¬â¢s certificate being $53,800. By and large, would gather $940,000 dollars of pay while somebody with a bachelorââ¬â¢s qualification makes twice that sum at $1. 8 million dollars. This is on the grounds that businesses by and large imagine that individuals with an advanced degree are more brilliant than one with a secondary school instruction. Making the ones with an advanced degree increasingly inclined to learning new abilities a vocation requires. This is the reason you see a great deal of secondary school graduates and individuals who never went to any school working at drive-through joints. The activity advertise is an extremely significant factor while considering if school is justified, despite all the trouble, yet one needs to consider the measure of obligation one will amass a short time later. With almost 20 million Americans going to school every year, (Chronicle of Higher Education) 66% of them wind up graduating with a type of obligation (Denhart Chris). What amount of obligation you may inquire? The measure of obligation that undergrads have gathered when they graduate surpasses the 1. 2 trillion dollar mark (Denhart Chris). This makes understudy credits the second most noteworthy type of customer obligation, behind home loan advances. This can truly debilitate somebody from heading off to college. It can particularly dishearten somebody from returning to school in the wake of dropping out on the grounds that, most probable, the individual would be in a type of obligation as of now. Likewise, one wouldn't like to head off to college just to be under water a short time later with no consistent wellspring of salary. Going to school is turning out to be increasingly more fundamental as time passes. Significantly more employments are starting to search for additional individuals with an advanced degree. The inquiry one needs to pose to themselves however would be, ââ¬Å"Is College justified, despite all the trouble? â⬠Without an uncertainty school is costly. Most of school graduates wind up going into a type of obligation when they graduate. It is up to the understudy that is going to school however to decide whether it is justified, despite all the trouble for them or not. They have to ask themselves, ââ¬Å"Will I be bringing in my cash back. â⬠It is dependent upon them to pick a significant that is doing truly well in the present place of employment showcase. I know we as a whole have various interests and objectives, however on the off chance that one needs a higher possibility of being effective they would pick a significant that is progressing nicely. They additionally need to consider the way that it is getting increasingly hard to find a decent line of work that doesnââ¬â¢t require an advanced degree. Individuals with an advanced degree by and large make significantly more as well. Iââ¬â¢m sure no one needs to be working at their nearby McDonalds after they went through such a lot of cash going to four years of school. So put resources into school, pick a decent major, and get decent instruction in light of the fact that soon an advanced degree will be sought after and you will be on the highest priority on the rundown. Work Cited Clark, Kim. ââ¬Å"How Much Does College Actually Cost? â⬠CNNMoney. Link News Network, n.d. Web. 27 Oct. 2013. Highlights, Forbes Special. ââ¬Å"How The $1. 2 Trillion College Debt Crisis Is Crippling Students, Parents And The Economy. â⬠Forbes. Forbes Magazine, 07 Aug. 2013. Web. 28 Oct. 2013. Goudreau, Jenna. ââ¬Å"The 10 Worst College Majors. â⬠Forbes. Forbes Magazine, 11 Oct. 2012. Web. 27 Oct. 2013. Universal Business, Times. ââ¬Å"6 Charts On Why College Is Worth Its Cost. â⬠International Business Times 17 Aug. 2012: Regional Business News. Web. 20 Oct. 2013. Kittle, Cameron. ââ¬Å"Degrees of obligation: UNH graduate says professional education was justified, despite all the trouble, yet obligation trouble poses a potential threat. â⬠Telegraph, The (Nashua, NH) 14 Aug. 2012: Newspaper Source Plus. Web. 20 Oct. 2013. KORVA, COLEMAN. ââ¬Å"Is A College Education Worth The Debt?. â⬠Tell Me More (NPR) (n. d. ): Newspaper Source Plus. Web. 20 Oct. 2013. PEREZ-PENA, RICHARD. ââ¬Å"Benefits of College Degree in Recession Are Outlined. â⬠NY Times. N. p. , 9 Jan. 2013. Web. Plumer, Brad. ââ¬Å"Only 27 Percent of College Grads Have a Job Related to Their Major. â⬠WonkBlog. N. p. , n. d. Web. Weissman, Jordan. ââ¬Å"How Bad Is the Job Market For College Grads? Your Definitive Guide. â⬠The Atlantic. N. p. , 4 Apr. 2013. Web. 28 Oct. 2013.
Saturday, July 18, 2020
Up Your Geek Stats with an Insider Look at the World of Video Game Development
Up Your Geek Stats with an Insider Look at the World of Video Game Development Im a woman who works in STEM and is involved in the gaming industry, so its entirely possible Im biased when I say this is one of the best books Ive read this year. Women in Game Development: Breaking the Glass Level-Cap, is aimed at a fairly specific demographic: women with a passion for video games who might be wondering how to break into what is, at times, a very hostile industry for women. But if you dont fall into either of those categories, dont worry; you certainly dont have to be a lady or a gamer to give this superb and informative collection a read. The book is edited by veteran game developer Jennifer Brandes Hepler (probably best known for her work as a writer at BioWare on the Dragon Age series of video games), and contains 22 personal essays from a wide range of contributors. Each of these women work in different facets of game development, including writers, engineers, technical artists, designers, producers, CEOs, and everything in between. In the space of a short chapter, each of these women speak about how they first fell in love with video games, how they broke into the industryand how they managed, or didnt manage, to stay there. The chapters are loosely grouped by profession, each section capped with supplementary chapters by Hepler which provide additional information, advice, and resources for both women trying to find their place in the industry and for allies already inside who can help make more diverse teams possible. Even in the books happiest success stories, its clear: none of these women had an easy road to get where they wanted to be, or to keep their place there once they earned it. Even if you dont pay attention to video games at all, youre probably aware that these days, being a woman with opinions about video gamesmuch like being a woman with opinions about comicscan be a pretty dangerous thing to be. This danger has escalated in the past five years or so, with the anonymity of the internet allowing more and more trolls to threaten, stalk, doxx, attack, and even drive women from their homes. Their supposed crimes? Pointing out problematic elements in video games. Working in video games. Daring to be publicly part of a space that they actually make up over half of. Yeah, weve all heard this story before. Were all sick to death of hearing this story. But the story keeps happening, and while Women in Game Development isnt directly about this abusive culture, it is a book that is very much born in a time where this sexism (and racism, and homophobia, and body-shaming, and everything else they can throw at you) is a part of daily life in video games, in ways both subtle and blatant. On the one hand, this book is a victorious declaration. Here are twenty-two women who made it work, in twenty-two different ways. And they are women who will not be silenced, who are out in the thick of the industry doing amazing and empowering things through determination, guts, resilience, talent, and above all, a burning passion for video games. But the collection isnt just a celebration of these isolated successes; its also looking forward, a vow to keep fighting to make things better. This is a book published for everyone, but its a book that is primarily written for, and speaking to, the women who will come next. Many of the contributors emphasize the importance of various mentors in their career paths, and this book is working very consciously to help pay that good support forward. This book is speaking, at times directly, to the women who will come next. The ones who need to know what it takes, how many approaches and destinations there are within the vast field of game development. Who need to know how much of a better place the industry has become, thanks to women like those in this book, but also how much further it still has to go.
Thursday, May 21, 2020
The Stranger Critical Analysis - 1788 Words
Works in Translation Assignment: The Stranger by Albert Camus In society, many people will reach a stage in their life where they encounter an ââ¬Å"existential crisisâ⬠and begin to seek answers by questioning the meaning of their existence, or whether a meaning truly exists. Absurdism is the school of thought which argues that meaning is inherently absent in the universe, but that one must embrace this to live freely. Albert Camus uses this philosophy to masterfully craft The Stranger, a novella in which the main character named Meursault blindly wanders through life because he believes that it possesses no true meaning. He is incapable of remorse when he arbitrarily murders an Arab, and thus his life spirals downhill asâ⬠¦show more contentâ⬠¦In this excerpt, Camus selects violent words and imagery such as ââ¬Å"throbbing,â⬠ââ¬Å"crashing,â⬠and ââ¬Å"spearâ⬠alongside the personification of the sun to demonstrate the cruelty of the irrational world as a prelude to Meursaultââ¬â¢s violent actions which woul d follow (58, 59). Another notable technique utilized in this section is structure, as there is a copious amount of punctuation embedded to create pauses in the phraseology and establish a tense and dangerous atmosphere. The seemingly arbitrary changes in the sun can have unpredictable and drastic effects on the actions of Meursault because the world is absurd and Meursault is helpless in its grasp. A second symbol frequently used by Camus which is closely related to the sun is Sunday; throughout part 1 of the novella, a sequence of unfortunate events which result in human suffering unfolds on multiple Sundays. These events include Raymondââ¬â¢s abuse of his mistress due to her alleged infidelity, leading to her physical suffering (which becomes evident when Meursault hears ââ¬Å"some thudsâ⬠and then her screams), the loss of Salamanoââ¬â¢s dog, resulting in Salamanoââ¬â¢s loneliness and desperation (as seen when ââ¬Å"[Meursault] realized he was cryingâ⬠), and finally, Meursaultââ¬â¢s homicide of the Arab during the beach trip, leading to his suffering in prison, which is foreshadowed when heShow MoreRelatedThe Stranger By Albert Camus Critical Analysis971 Words à |à 4 PagesThe Stranger, by Albert Camus tells the story of a man named Meursault who is consumed with the pleasures that life has to offer. In an unusual ending, Meursaultââ¬â¢s fate is ultimately decided based on his actions he has made throughout his life, in which he blatantly ignores the 1940ââ¬â¢s social norms of the French colony, Algiers. The story is told from an Absurdist point-of-view, which ultimately affects the meaning of the novel. This is present when unknowingly to Meursault, Absurdist philosophy dictatesRead MoreThings Fall Apart, And The Heart Of Darkness1518 Words à |à 7 PagesIntroduction The following essay will contain a critical analysis of two passages from Things Fall Apart, and the Heart of Darkness. I will compare and contrast the narrative structure, the language used and the themes explored. Through this critical analysis, we can gain a better understanding of the two extracts, each one helping to illuminate the other. 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This analysis sets up and evaluates the attachment risk model. The attachment risk model is a single factor main effect model. The unit of analysis of the model is twofold. From the time of the childââ¬â¢s birth until two years of age, the unit of analysis is the mother and after two yearsRead MoreAn Empirical Study On Privacy Concerns Of Young Adults On Social Media Platforms Essay1470 Words à |à 6 Pagessocial relations with friends and strangers as well with whom we have similar shared interests, activities, and real life connections. Todayââ¬â¢s generation is engaged more for building relations with the people through the Social Networking Sites such as Facebook, Twitter, Pinterest and many more. For the youngsters everything happens Online. This impact is especially important for children more than the adults because senior children in their teens are at a very critical juncture in terms of their physicalRead MoreThe Writing Apprehension Test ( Wat )987 Words à |à 4 PagesIf one wishes to develop skill at a particular subject it is critical they are able to asses their abilities. This gives an understanding of their strengths and weaknesses. By knowing what to focus on it makes the process easier and more efficient. The Writing Apprehension Test (WAT), Self Perceived Communication Competence Scale (SPCC), listening type inventory, perspective taking inventory, and communication competence inventory are tools to decipher peopleââ¬â¢s communication strengths and weaknessesRead MoreAttachment : A Deep And Enduring Emotional Bond1313 Words à |à 6 Pages Attachment: An Analysis ââ¬Å"Attachment is a deep and enduring emotional bond that connects one person to another across time and spaceââ¬â¢Ã¢â¬â¢ Mary Ainsworth (1973) In this essay I will explore the meaning and purpose of attachment and discuss research into attachment concentrating on John Bowlbyââ¬â¢s 1944 ââ¬Å"44 thievesâ⬠study conducted to test his maternal deprivation theory and Schaffer Emersonââ¬â¢s 1964 ââ¬Å" Glasgow babiesâ⬠study. There are twoRead More Character Analysis of Estelle in Atwoods Rape Fantasies Essay1219 Words à |à 5 PagesCharacter Analysis of Estelle in Atwoods Rape Fantasiesà à à Estelle is the only thoroughly developed character in Margaret Atwoods Rape Fantasies. Though she is the narrator and quite thoughtful of the ideas and reactions of the storys supporting players, it is her almost obsessive preoccupation with a singular topic that actually prompts her to fully illustrate her own ideas and reactions, drawing a character far more compelling than any of the men or women she will attempt to describeRead MoreStepping Into The Self Study Space Essay868 Words à |à 4 Pagesuniversity. We joined as strangers to the group and to one another. We were transitioning from our work as K-12 educators into the academy as new assistant professors. This self-study group challenged us to textualize a professional critical event communicated as a personal lived experience. Part of the challenge of entering a self-study space is that we viewed the self-study members as professionals, not yet critical friends. They were critical others but not yet critical friends. We began our firstRead MoreResearch Project : Using Relatedness Analyses1642 Words à |à 7 Pagescontribute to disease predilection, disease progression, and/or disease severity. Motivation Variations in the DNA sequences of humans can affect how humans develop diseases and respond to chemicals, drugs, vaccines, and other agents. SNPs are also critical for personalized medicine. (Carlson, 2008) Analyzing SNP data is extremely significant in biomedical research in which one can compare regions of the genome between cases and matched controls to discover genetic regions correlated with disease status
Wednesday, May 6, 2020
Analysis Of Yevgeny Zamyatin s The Motif Of Imagination
Yevgeny Zamyatinââ¬â¢s We depicts a dystopian world ruled by the One State through the eyes and conscience of mathematician and protagonist D-503. We was written in 1921, after Russia saw the Great October Socialist Revolution of 1917, led by the Marxist Bolshevik leader, Vladimir Lenin. (Encyclopedia Britannica, n.d.) Zamyatinââ¬â¢s constructed ideals of the One State parallels that of his own country, under the totalitarian regime imposed by the communist government, in order to convey his satirical political opinions of its worsening and limiting effect. In We, Zamyatin demonstrates the importance of imagination and free thought, developing the audienceââ¬â¢s understanding of the limits of happiness under the rule of a totalitarian society seen through the eyes of D-503. The motif of imagination is seen within the novel through Zamyatinââ¬â¢s manipulation of D-503ââ¬â¢s perception of his world, specifically his auditory perception and his description through mathema tical diction, critiquing the oppressive totalitarian society. Throughout the novel, Zamyatin establishes the limits of the coexistence between true happiness and true freedom through the lack of imagination and creativity perceived by the auditory perception of D-503. The One State promotes ââ¬Å"mathematical [music] compositions,â⬠(Zamyatin, 23) as a form of entertainment through which Zamyatin illustrates the impact of One Stateââ¬â¢s restriction of musical expression, ironically contradictory to the nature of music. One
Case Analysis Study Free Essays
Case Study Analysis Paper Prepare a 1,400 to 1,750-word case study analysis paper based on the University of Phoenix Material, ââ¬Å"Case Study for Student Analysis,â⬠located in Week Two of the COMM/215 [pic] page. Below is a detailed description explaining how to prepare a case study analysis paper. ____________________________________________________________ _________________ Typically written in narrative form, a case sets forth, in a factual manner, the events and organizational circumstances surrounding a particular managerial situation. We will write a custom essay sample on Case Analysis Study or any similar topic only for you Order Now Placing the reader at the scene of the action, the real events presented provide an opportunity to help evaluate alternative courses of action. Case analysis is used in academics to help you demonstrate your ability to evaluate situations critically, to apply concepts you have learned in a class, to solve problems, and to communicate your findings and conclusions. The purpose of this exercise is to introduce you to case studies and the analysis process, and to a proper format for writing the case study analysis report. Try not to worry about trying to find the ââ¬Å"right answerâ⬠to a case. Usually, there is no single right answer. Most cases are intentionally ambiguous and can be viewed from many different perspectives. Several feasible solutions are usually available to any give case. The best solution is the one you can best support with thoughtful analysis, logical arguments, and substantiating evidence from your research or your own experience. Your goal in analyzing a case is to provide an effective solution to the situation outlined and to support that solution with solid and persuasive evidence. Overview Analyzing a case study can take several forms, and you should check with your instructor on the specific approach or point of view that he or she recommends. For example, you might analyze the case from the perspective that you are the central character of the narrative and must provide a report of what you would do in the situation. On the other hand, you might play the role of an outside consultant hired to evaluate the situation for which you provide a report. Make sure you allow enough time for the various tasks you must perform. These tasks are listed below and explained in more detail in the following sections. (Note: When writing a case analysis as an exercise in a writing class, there will be no content-related course concepts (e. g. management or health care theories) that apply directly to the case. The objective of the assignment will be to produce a well-written analysis. You should check with your instructor to determine the expectations of content and the amount of research required. Analyzing the Case 1. Read and study the case thoroughly. 2. Define the problem(s). 3. Select a focus for your analysis by identifying key issu es and their causes. 4. Identify and apply course concepts in order to identify possible solutions. 5. Evaluate alternative solutions and choose the solution you believe is best. Writing the Case Analysis 1. Determine how you want to present your views and structure your paper. 6. Produce a first draft of your case analysis. 7. Revise and edit the draft. 8. Format and proofread the final report. Analyzing the Case 1. Read and study the case thoroughly. Read the case once for familiarity with the overall situation, background, and characters involved, noting issues that you think may be important. Read the case again, and highlight all relevant facts. Make sure you understand the situation and have all the facts. Make notes about issues, symptoms of problems, root problems, unresolved issues, and the roles of key players. Watch for indications of issues beneath the surface. 9. Define the problem(s). Identify the key problems or issues in the case. Case studies often contain an overabundance of information about a particular situation, not all of which may be relevant. Do not try to analyze every fact and issue. Part of the skill of good case analysis is in determining which facts are relevant. 10. Select a focus for your analysis by identifying the key issues and their causes. Determine how to focus your analysis. Narrow the problem(s) you have identified to between two and five key issues. Do not try to examine every possible aspect of the case. Identify the most important issues that relate to the concepts you have been studying in the course (if applicable). Once you have focused on one or two key issues, try to gain a fuller understanding of their causes. Why do these problem(s) exist? What caused them? What is the effect of the problem(s) on the organization or the relationships among individuals in the organization? Who is responsible for or affected by the problem(s)? 11. Identify and apply course concepts in order to identify possible solutions. (See previous note regarding writing a case analysis as an exercise in a writing class. This section is included so that you become familiar with the application of case studies in context of applying content-related course concepts. ) a. Identify and apply one or more concepts discussed in class, covered in your readings, or learned from your own experience that would apply to the case and provide some insight or guidance in solving the problem(s). b. Review your notes from c lass discussions and your texts and other readings in the course, conduct outside research, and use your own knowledge and experience to decide what concepts, theories, or ideas could be relevant. 2. Evaluate alternative solutions and choose the solution you believe best reflects the findings from your analysis. Make certain you can support the solution you choose with solid evidence from your case analysis. Weigh the pros and cons of each alternative. Which solution is the most feasible? Make certain you can defend that solution. Now you are ready to proceed to the next stepââ¬âdetermining how to present your ideas and structure your paper. Writing the Case Analysis Written case analyses are short, structured reports. Usually, the instructor will ask for between two and ten typed pages, depending upon the complexity of the case. Some case studies are assigned as individual efforts; others are group projects. Still others may be a partial group effort, with the group collaborating in the analysis and each individual student being asked to prepare a separate written analysis. Your task, in writing your case analysis, is to combine aspects of the case and key issues with your perceptions and supported opinions. You must then examine alternatives, choose the most viable solution, and provide evidence to support your views. You obtain this evidence from class discussions, your text readings, outside research, and your personal experiences. 1. Determine how you want to present your views and structure your paper. Most case studies follow a prescribed format and structure and can vary depending upon the course in which it is used, such as those discussed next. Check with your instructor regarding his or her preference as to the sections of the case study analysis report. Case study analyses are written as reports with headings, not as essays. The report should clearly identify the relevant sections for the reader. . Title page Use standard APA format to develop a title page. b. Introduction Determine a thesis. Summarize, in one sentence, the principal outcome of your analysis. This is the thesis for your report and should be clearly stated in the first few paragraphs. The introduction identifies the central problem. c. Background Take the central problem, and place it in a context for the reader providing background information about the case. Do not reiterate or rehash the facts stated in the case. Rather, place the case in a research context. The background section demonstrates to the reader that you have conducted research, either academically or in the field, regarding the types of problems that the case study describes. Be sure that your written presentation focuses your diagnosis of the problems on the most important issues. d. Key Problems This is where you identify your thoughts about the problems that exist. It is considered a very important part of the report. Start with the ââ¬Å"who-when-where-what-why-howâ⬠typical questions (Gerson Gerson, 2002). Ask yourself here as you ponder the situation: ââ¬Å"What are the problems at this company? There certainly is usually more than one problem. Identify the ones you see as being instrumental to the success of the company or its project. e. Alternatives Now that you have conducted research and placed the problem(s) into a context, you will have informed choices about the alternative solutions to the problem(s). You are not expected to analyze all possible altern atives. However, you should have considered several alternatives when you formed your opinion about the case. Discuss these alternatives and why you rejected them in determining your solution to the case. Why are these viable alternatives? What are the constraints (e. g. money, time, personnel, resources) imposed and the reason that you do not recommend the alternative at this time? f. Proposed Solution Discuss your proposed solution providing support with solid evidence. Generally, you should only provide one proposed solution. Keep in mind that in the context of the case study, the characters or company can only start on one solution at a time. Which one do you propose and why? Justify why this solution is the best option through a logical argument supported by research. The proposed solution should be specific and realistic. g. Recommendations If appropriate, you may conclude your written analysis with a discussion of the implications of the problems you identified on the functioning of the organization or on the relationship among individuals in the case. You may also want to make recommendations for further action that might be taken to resolve some of these issues. Be specific about what should be done and who should do it. This section discusses specific strategies that the individuals in the case can do to accomplish the proposed solution. Check with your instructor as to whether this section should be included in your case analysis report. 13. Produce a first draft of your case analysis. 14. Revise and edit the draft. 15. Format and proofread the final report. Case study reports are written in a structured format, not as essays. Case study reports usually contain an Executive Summary that contains brief summaries of the Introduction, Background, and Proposed Solution sections of your report. The Executive Summary provides a quick, easy-to-read summary of these three main parts of the case study. Check with your instructor to see if he or she requires an Executive Summary to be included with your report. ) Tips for formatting the final report: a. If an Executive Summary is to be included, it should be single-spaced with relevant headings identifying the sections. The Executive Summary should summarize those sections of the report, and not contain any information not discussed by the report. b. The case study analysis s hould be written as a structured report, with relevant headings. The case study analysis is not an essay. 16. Include any relevant appendices and references in a proper APA format. How to cite Case Analysis Study, Papers
Sunday, April 26, 2020
Miles In Two Hours It Died. Essays - , Term Papers
miles in two hours it died." As a final instance of the force of limitations in the development of concentration, I must mention that beautiful creature, Helen Keller, whom I have known for these many years. I am filled with the wonder of her knowledge, acquired because shut out from all distraction. If I could have been deaf, dumb, and blind I also might have arrived at something. VOTES FOR WOMEN. AT THE ANNUAL MEETING OF THE HEBREW TECHNICAL SCHOOL FOR GIRLS, HELD IN THE TEMPLE EMMANUEL, JANUARY 20, 1901 Mr. Clemens was introduced by President Meyer, who said: "In one of Mr. Clemens's works he expressed his opinion of men, saying he had no choice between Hebrew and Gentile, black men or white; to him all men were alike. But I never could find that he expressed his opinion of women; perhaps that opinion was so exalted that he could not express it. We shall now be called to hear what he thinks of women." LADIES AND GENTLEMEN,- It is a small help that I can afford, but it is just such help that one can give as coming from the heart through the mouth. The report of Mr. Meyer was admirable, and I was as interested in it as you have been. Why, I'm twice as old as he, and I've had so much experience that I would say to him, when he makes his appeal for help: "Don't make it for to-day or to-morrow, but collect the money on the spot." We are all creatures of sudden impulse. We must be worked up by steam, as it were. Get them to write their wills now, or it may be too late by-and-by. Fifteen or twenty years ago I had an experience I shall never forget. I got into a church which was crowded by a sweltering and panting multitude. The city missionary of our town- Hartford- made a telling appeal for help. He t
Wednesday, March 18, 2020
Alpha and Omega of Active Compasion essays
Alpha and Omega of Active Compasion essays Alpha and Omega of Active Compassion Have you ever walked down a crowded city street and looked down to see a homeless man stretching out his soiled hand in hopes of a measly dollar? As human beings, are we obligated to give this man our earning? And just how much do we give him? A dollar? Our VISA card? We have a general responsibility, as residents of civilization, to our fellow man, as long as it doesnt interfere with our own personal progress. The ideals of welfare, charity, and the generous foreign policies are all prime examples of our aid to others, but the world is still uncertain on, how much do we give?. The idea of welfare was founded in the United States around the time of the great depression. It was meant to temporarily help the financially less fortunate. This was intended to get the ball rolling for the economy. The government would play Robin Hood by taking from those who had money, and giving it to help those who didnt. In time, they would put their feet back on the ground and would no longer need the relief of their government. This was a very kind and productive way to help our fellow man in his time of need. Unfortunately somewhere along the line the idea of helping the broke modified, and we were simply giving them money when they had no intention on recovering from the debts of poverty. And so we continued to show everyone else how to get money for free. This is an excellent example on how we exceeded our obligation to others. Instead of a few dollars of generosity to uphold others, we give up to half of our earnings to support those who choose not to help the mselves. By doing this, we have slowed our individual progress in society. Charity is another form of helping the less fortunate persons on earth. That, unlike welfare, is to be executed at our own discretion. There is no forcing hand in charity, although sometimes we still do not know ...
Monday, March 2, 2020
Its a Wonderful Life - Quotes, Values, and a Swim Gym
Its a Wonderful Life - Quotes, Values, and a Swim Gym On December 20, 1946 a post-war, sentimental Christmas film was first shown to a charity gathering. The main character in Frank Capras movie Its a Wonderful Life wants to travel and see the world when hes young - Italy, Greece, the Parthenon, the Colosseum - all traditional places to study architecture. Then he wants to build thingsà - skyscrapers a hundred stories high and bridges a mile long. George Bailey has the mind of an architect.à Although this quotable Hollywood classic is traditional Christmastime fare, Its a Wonderful Life continues to say plenty about American values, the housing sector, and the way we live. The Swim Gym A favorite scene in the movie is the graduation dance at the local high school. During the Charleston competition, the actors Donna Reed and Jimmy Stewart plunge beneath the gym floor into the swimming pool below. What a stunt! Was that just more Hollywood magic? Not at all. The Beverly Hills High School was used in that classic 1946 film scene, and the Swim Gym is still used today. The architecture works just the way it does in the movie - a gym floor covers a swimming pool and can mechanically roll aside with a key and a button. The system was designed by architect Stiles O. Clements and built in 1939 under the Work Projects Administration (WPA). The WPA was one of the top New Deal programs that helped America out of the Great Depression. The federal government paid millions of unemployed Americans to build schools, bridges, beaches, and hundreds of other public works projects. Like the Swim Gym, many of these federal projects from this era are still in use today, including the Levitt Shell in Memphis where Elvis Presley first performed, the art deco structures in Fair Park in Dallas, Texas, and many, many post office buildings throughout the United States. WPA projects often brought new ideas and artistry to everyday buildings and structures. The Beverly Hills High School Swim Gym is a great example of innovative public architecture paid for with government funds. The Film Also Explores Values But this film is much more than showing off the technology of the day. It begins with youthful dreams and fun, but the plot revolves around business values during the post-Depression, midcentury building boom in the United States. The ongoing conflict is between an unrelenting old businessman named Henry F. Potter and his local competition, the family business known as the Bailey Building and Loan. The character of George Bailey, who took over the business after his fathers death, explained the workings of his familys financial institution to anxious patrons who had just made a run on the bank: Youre thinking of this place all wrong. As if I had the money back in a safe. The moneys not here. Your moneys in Joes house...right next to yours. And in the Kennedy house, and Mrs. Macklins house, and a hundred others. Why, youre lending them the money to build, and then, theyre going to pay it back to you as best they can. Now what are you going to do? Foreclose on them? The arch enemy to the savings and loan lending system was the banker, Mr. Potter, who would have foreclosed on any rabble who could not pay. Back in 1946, the Baileys saw a community of people helping each other - to Potter, everything was money and business. Fast Forward to the 21st Century When Its a Wonderful Life is shown every year around Christmastime, we are reminded of the value conflicts between builders and banks. We remember our own 21st century housing crisis. Profit-driven practices in the banking and housing industry contributed to the 2008 financial crisis and economic downturn. Banks loaned money to people who could not pay it back, and lenders did this purely for financial reasons - the liability for those loans was shipped away from the community and sold for a higher investment return. Unlike the Bailey Building and Loan, 21st century banks were not investing in the community - profit was the only goal. The system may have made financial sense to some, but the scheme was unsustainable. Architecture is about building and design, but in most cases the business of architecture is about cost and value. What does this design cost compared to another design? Can One World Trade Center in Lower Manhattan be built for less money if the symbolic height of 1776 feet is made up of a spire instead of full floors? What if we build an office building and cant lease the space? Could we make more money in this housing development if we overlooked accessibility and green design? What will we sacrifice to save money, to make money, or to advance a career? A Couple of Decent Rooms and a Bath In the end, Its a Wonderful Life is a cautionary tale, examining the values of a community and the strengths of its individual members. In our lives, we each have choices to make, and decisions have consequences. The undesirable Pottersville explored in the what if section of the movie has become a metaphor for the Las Vegas-ization of our urban landscape. Is there a Pottersville in your community? In addition to the fun at the swim gym, the other idea that makes this movie so uplifting is that the community of Bedford Falls did not succumb to urban decay and become the metaphoric Pottersville - in large part because George Bailey stood up for the common man. As Bailey tells Potter: Just remember this, Mr. Potter, that this rabble youre talking about...they do most of the working and paying and living and dying in this community. Well, is it too much to have them work and pay and live and die in a couple of decent rooms and a bath? Anyway, my father didnt think so. People were human beings to him, but to you, a warped frustrated old man, theyre cattle. When we think about building our communities, consider that people live in these built environments. The person is part of the architectural world. And, like Laugiers 18th century primitive hut, the architectural requirements are generally modest. Make sure that everyone has a couple of decent rooms and a bath. And a more modern actor like Brad Pitt would add, Make it Right. The power is in the person, and one person can make a difference. Source National Federation of State High School Associations. Beverly Hills Swim Gym combines diverse sports. http://old.nfhs.org/content.aspx?id6251
Friday, February 14, 2020
Operations and IT Management Essay Example | Topics and Well Written Essays - 500 words
Operations and IT Management - Essay Example This will significantly reduce conflicts when we come to implementation or operations of the managers. The information lifecycle approach has strengthened customer relationship management, which is a widely applied strategy for running a companyââ¬â¢s relations with its customers, clients as well as sales prospects. It encompasses the use of technology to organize, computerize, and harmonize business processes-mainly sales activities, but, in addition to those for marketing, client service, along with technical support (Fitzsimmon, 2005). The predominant goals are to find, attract, and convince new clients, nurture and lock in the customers, which the company already had before, entice previous clients back into the fold, and minimize advertising costs and client services. Customer relationship management illustrates a companyââ¬â¢s broad business plan including client interface sections as well as other departments. Computing and valuing customersââ¬â¢ correlation is crucial to implementing this strategy. This has tremendously reduced conflicts between operations managers and information technology managers, due to specialization and division of areas of jurisdiction within the business system. Information privacy and data security; operations managers and information technology managers are now working concurrently to ensure that there is information security. Given the fact that security is an area of concern in the business sector, the two bodies have no choice but, to pull together as a team in considering the desire for information and data privacy, as well as the legislative and cultural standards. Some clients would like their pertinent information to remain their secret, and not to allow any other unauthorized persons, without their permission access to it. Information lifecycle approach enables business firms to keep different business documentation for a different
Sunday, February 2, 2020
A critical assessment of the marketing challenges facing an Essay
A critical assessment of the marketing challenges facing an organisation of your choice and recommendations for the development of Competitive Advantage - Essay Example A close analysis of other companies that have survive during harsh market periods will help point out possible opportunities that Ryanair mas use to escape the looming threat. The research will end with workable recommendations that will provide strategies for Ryanair to survive within the market. In the 21st century business environment, companies have to stay on the alert in terms of aligning their business strategy with the ever-changing business environment. Particularly, the international airlines market has become sensitive with rapid changes in the economic structure, increase in competition and government regulation (Cento, 2009). Ryanair, one of the low-cost international airline operators in Europe, has faced a number of challenges while operating in the dynamic market. The purpose of this essay is to make an analysis of the competitive ability of the company, point out specific problems and develop strategic adaptations for the company. Marketing analysis is concerned with the ability of a company within a specific industry to position itself as a top service provider. Hubbard, Rice, & Beamish (2008, p.69) defined industry as, a group of organizations or business units producing close substitutes. ââ¬Å"Marketâ⬠is a word which use very closely to ââ¬Å"Industry.â⬠Perhaps the most frequent word use as a substitute to ââ¬Å"industry.â⬠However, ââ¬Å"marketâ⬠defined as a group of consumers with similar needs. (Hubbard, Rice, & Beamish, 2008, p. 97). Evidently, each organization has operates within a particular industry and has a specific target market. Within an industry, organizations compete as a way of appealing to their target customer to purchase their service and products. On the other hand, the customers choose organizations that best suit their needs and purchase from organizations that best satisfy their tastes and
Friday, January 24, 2020
Social Reproduction Essay -- Canadian Government, Capitalism
The growth of capitalism and the decline in government help with social reproduction along with cuts to social serves within Canada have lead to many issues within the privet sector. These cut backs leave families struggling, and while the family struggles the main care taker who is majority of the time the women, they are also the ones struggling with more responsibilities in the privet sphere of life. However, the home is not the only place that deteriorates when cut backs take place. When the individual struggles in the privet sector, the public sector along with employment and work take a toll as well. While the women tend to be the care givers of the home they skill contribute to a capitalist society meaning they are now working two jobs. They take care of the home, and still tend to a job in the public aspect of life. Until improvements are made in both privet and public sectors through social reproduction many areas in Canada will continue to suffer. The book Social Reproduct ion focuses on specific issues that are happening in Canada. Chapter four is specific to the topic on social reproduction and the issues that it causes to Canadian individuals, along with how unions are working to change the government to better help the people of Canada. I will focus on how chapter four entitled Bargaining for Collective Responsibility for Social Reproduction by Alice Wolff, deals with the material at hand and also if I believe Wolff presents the material in a well mannered argument. I will start off by looking at what issues Wolff presents in this chapter, and move on to the difficulties it is causing individuals, while finishing off with a critique of the chapter. Social reproduction to Alice Wolff is an important issue that is ... ... would have brought a real life situation at hand for those who are reading about this topic for the first time. I enjoy how the entire chapter focuses specifically within Canada which gives us as Canadians who are reading it a realisation of where Canada stands on this issues and where we possibly need to go. Another area I think she could have spent some more research on would have been how social reproduction differs between the different cultures we have represented in Canada. Canada especially has many different cultures and nationalities represented throughout; it would have been interesting to see how things differed from each culture. Overall I believe Wolff did a great job with the topic and I agree with what she has stated and how it is important to get this message out to others so that possibly soon we can find a way to help relive work-life tensions.
Thursday, January 16, 2020
Nixon’s Checker’s Speech
ââ¬Å"The Checkers Speechâ⬠It was the midst of the 1952 presidential campaign when the New York Postââ¬â¢s newspaper story came out accusing Senator Richard Nixon of having a secret political fund. This accusation caused Nixon to face the reality of virtually being dropped as the presidential candidate of Dwight D. Eisenhowerââ¬â¢s running mate. On September 23, 1952, Nixon sat down to address one of the largest television audiences in political history until Nixonââ¬â¢s 1960 debate with John F. Kennedy.While millions of Americanââ¬â¢s tuned into prime-time television, they sat and watched Senator Richard Nixon defend himself by delivering his influential and famous speech, which is known as his ââ¬Å"Checkers Speech. â⬠From the beginning of time, as seen in all political campaigns, the fight to win over the American public is mainly shown through these persuasive political speeches. In this particular speech, Nixon uses the art of rhetoric to persuade, mani pulate, and gain the trust of his audience. By using the empowerment of the new medium of television, he uses this political tool to manipulate.He bares his heart out through his words, and gives himself credibility by portraying himself as an honest, family man with good character. These key elements of a rhetor such as gaining the audiencesââ¬â¢ approval by their persona, tone, and structure in which they deliver their thesis. All of these are important for a political speaker, so it enables them to overpower the numerous accusations that come along with the campaigning. Richard Nixon was a former Navy marine, which then led him to win a seat in the House of Representatives.Two years later he became a member of the House Committee, and investigated an espionage case, which turned him into a national figure as well as a controversial one. After two terms he was elected into the U. S. Senate. The young Richard Nixon had only six years of a political background when Dwight D. Eise nhower nominated him as his running mate in the 1952 election. With the rise of Nixonââ¬â¢s political career, it came to a halt when the New York Postââ¬â¢s headline stated, ââ¬Å"Secret Rich Menââ¬â¢s Trust Fund Keeps Nixon in Style Far Beyond His Salary. Having relatively no political experience, he showed his virtuous qualities through this speech, knowing that had his future on the line.Richard Nixon was accused of accepting secret funds for his election campaign, but he cleared himself of these accusations and changed his audiencesââ¬â¢ point of view through this speech. He used a brilliant political maneuver to directly address the public via the new medium of television. He began with stating, ââ¬Å"â⬠¦I feel that the people have got to have confidence in the integrity of the men who run for that office and who might obtain it. After this, he structures his speech through persuasion to give explicit reasons examples as to how he is the one that the people sh ould be confident in. Charged with accepting $18,000 from a group of his supporters, he confidently stated that he did not take one cent of it. He went into detail about the lack of funds he used, his earnings throughout the years, and how his wife was a main contributor to his campaign. He brings in the opposition of his opponent, how he puts his wife on the pay roll with his power, which is a gain in income for him and his campaigning.By doing this, Nixon clears the competition by having the He recited the audit that was taken on him through Gibson, Dunn, & Crutcher, one of the biggest law firms in Los Angeles. It concludes that Nixon did not obtain any financial gain from the collection and disbursement of the fund by Dana Smith. He gains his credibility by his hard and honest efforts throughout his life to get him where he is today. By the end of the message he informs the people that he did in fact accept a gift during the electionââ¬âCheckers, their cocker spaniel dog.He e xplains how a Texas man heard his wife on the radio mention how their two children wanted a dog, and the next day he sent them a little cocker spaniel. Nixon explained how it is the one and only gift that he would keep for the sake of his children. Through this, it touched the hearts of Americans, giving him the image of a family man. After all of his truthful evidence, he submits the decision to the Republican National Committee whether his position on the ticket will help or hurt.With this influential speech, he changed the points of views of millions, and saved his name on the ballot, which potentially helped Eisenhower to win. The Checkers Speech is a widely known for its positively argumentative structure against the accusations of the press. He takes into account that being a politician it comes along with the rumors and scandals. He wanted to clearly state that these charges are an honest misunderstanding and he pleads to tell entire truth of his funds.Embedded in an extensiv e and complex listing of his personal finances, he closes by announcing that he did receive a gift and intended on keeping itââ¬âthe dog. This is the point that caught the attention of millions and saved his political career, as well as possibly saving Dwight D. Eisenhowerââ¬â¢s. Having read this speech, I would like to go into further research on why this speech was so persuasive. I would like to research the kind of language Nixon used, and if this speech wasnââ¬â¢t publicly televised, if it would have had a greater impact. Which of the theoretical lenses did he use?
Wednesday, January 8, 2020
Fluid and Electrolyte Management in Diabetic Ketoacidosis...
Fluid and electrolyte management in Diabetic Ketoacidosis and Hyperosmolar Hyperglycaemic state in the emergency department Introduction Diabetes Mellitus is a growing issue for health care providers internationally. The World Health organization estimated in 2013 there were 347 Million diabetics worldwide, predicting that Diabetes will be the 7th leading cause of death by 2030 (WHO, 2013). In both type 1 and type 2 diabetes Mellitus, factors such as poor compliance with diet and medication, infection, acute medical or surgical illness or trauma can lead to poor glycaemic control, precipitating a hyperglycaemic emergency such as Diabetic Ketoacidosis (DKA) (Scobie Samaras, 2009). In Type 2 Diabetes, another equally dangerousâ⬠¦show more contentâ⬠¦ Donelly, R., 2010). As with DKA, at this stage the body attempts to normalize the osmolality through diuresis, which leads to dehydration, loss of electrolytes, and further hyperosmolality. With HHS evolving over days to weeks, (often either through poor medication compliance/inappropriate prescribing, dietary issues, or illness), the effect is insidious, and often by the time a patient presents to the emergency department either directly or via a GP, they are already critical (Kisiel, M. Marsons, L., 2009). Further complicating the diagnosis and treatment can be a mixed picture of both HHS and DKA. This occurs in both type 1 diabetes and Type 2 diabetes. In this case treatment is balanced between correcting the metabolic acidosis and lowering the osmolality of the blood. (Kearney T. Dang, C., 2007) In both conditions (and in a mixed picture of both), the dehydration can be further exacerbated by the resulting Nausea and vomiting, meaning further fluid loss, and critically decreased fluid intake (Lowth, M. 2012). Both conditions require emergency treatment. Correcting the fluid deficit Irrespective of the potential metabolic acidosis, Initial management of both DKA and HHS is focused on rehydration. The aim is to replace fluids in the both the intravascular and extra vascular spaces, while simultaneously diluting glucose levels (and thus lower osmolality) and counter-regulatory hormones (Raghavan, 2014) The Monash Health HHS DKA
Tuesday, December 31, 2019
Chapter 1 A Short Story - 853 Words
Bren nodded to 6D7 after he and the droid agreed to save thr mysterious young woman. Bren shook his head, knowing fill well he would have to improvise and BS most of the way through this. Soon the droid broke their silence on the way with a few beeps. Bren looks over What? You dont think I have a plan for this? the droid gave a low sigh like noise in response. Hey buddy, Bren would stop to comfort his droid You know Ive got one. The droid would give a scoff Dont worry, we got this, 6D7. Bren would quickly reply with a sly smirk on his face, but if 6D7 had eyes, one would certainly have seen them roll at his masters comment. The pair would soon arrive at a small weapons shop run by a Trandoshen, Bren held up a picture of theâ⬠¦show more contentâ⬠¦He would quickly, casually walk over to the stage where she worked and sat down. A beep from his comlink on his gauntlet interrupted the show only for a moment. What is it, 6D7? Bren spoke into his communicator quietly as he could manage. The droid replied with a few beeps and whistles I dont know, check to see if the hanger is open. Do you still have that spike from the job on Rodia, buddy? Bren asks the droid in his still hushed tone to which the droid replied Then use it and tell me when you find something good, this will be a real short trip if you cant find a good ship. The droid beeped again, questioning his master. Do you not think that I know Jedi arent suppose to steal? Just do it, 6D7. The comlink went silent as the communication ended between the pair. After a drink or two, Tatooine sunsets mostly, Bren would get to talking to the young woman, just as she ended her set on the stage, a large Gammorean moving towards the two to stop him from potentially harming her, to which the woman would wave him aside Im Staod Huton, Im here to rescue you and take you back to your father. Bren would introduce himself to the young dancer. The dancer would cock an eyebrow at him, her gaze falling over Bren to size him up Arent you a little short for that, honey? The dancer would reply dismissively towards him Look, do you want out of here or not because I can just leave you here and let your daddy come findShow MoreRelatedShort Story : A Short Chapter : Chapter 1971 Words à |à 4 PagesIse said nothing though she did raise an eyebrow. Naoko coughed nervously and continued, ââ¬Å"Itââ¬â¢s just an idea but Iââ¬â¢d like to at least try it out to see if itââ¬â¢ll even work and since youââ¬â¢re said to be really god with kidÃ
I thought you could help me.â⬠Iseââ¬â¢s face still looked unamused though when she spoke there was a hint of interest in her voice, ââ¬Å"How did you come up with that idea?â⬠The teen shrugged, ââ¬Å"I read about a weapon Quincies have used called Seele Schneider. Itââ¬â¢s like a sword but made ofRead MoreShort Story : A Short Chapter : Chapter 1739 Words à |à 3 Pagesââ¬Å"I guess Yuri was right, which is mildly convenientâ⬠Sabra said. ââ¬Å"The place is almost empty, their numbers are extremely low.â⬠Screaming from a young woman could be heard coming from another room, surprising them. Turning their attention in the direction the scream was coming from. Everyone tried to move towards the screaming, before being halted by Paisley. ââ¬Å"One group can go check that out. We need to go and look for Vittorio, it shouldnââ¬â¢t be an issue to split up for a little.â⬠ââ¬Å"Iââ¬â¢m certainRead MoreShort Story : A Short Chapter : Chapter 11430 Words à |à 6 Pagesher eyes, which were unable to see his in the darkness, then he checked to see Torins hand placed against her small waist more in reassurance than in having to hold her close to the wall. Once they reached the top landing, Duncan pulled the short braided rope attached to an old bronze ships bell. The clang rang off the stone walls which echoed loud enough to surly raise the dead at the very least to alert the household as was the intent. Duncan stepped back to let the door swing outward, whichRead MoreShort Story : A Short Chapter : Chapter 12137 Words à |à 9 Pagesbrothers got in and went back to the motel. ââ¬Å"Fay gets the bed,â⬠Sam was about to protest when Dean quickly shut him up. ââ¬Å"She stabbed a ghost in the eye twice, killed him, made friends with a ghost, and saved both our asses,â⬠Fay just grabbed her black shorts and tank then walked into the bathroom. Stripping down, she turned on the hot water, letting the warmed rinse off the dirt and grime from the asylum. Turning off the water, she grabbed her toothbrush. As she got out the toothpaste there was a knockRead MoreShort Story : A Short Chapter : Chapter 12195 Words à |à 9 Pageshappened to me would be considered within parameters. From there, they let me out of the machine and I faked being Sister long enough to be sent on my way.â⬠Finishing off my water I set it down and nervously licked my lips. ââ¬Å"And thatââ¬â¢s basically my story. After leaving I got a new kit, put myself up in a hotel and over the next few days I wandered around, saw the city, did some research, and experimented a bit with being an Esper... Any questions?â⬠Mikoto and Kuroko stared at each other and at Mikotoââ¬â¢sRead MoreShort Story Chapter 11266 Words à |à 6 Pagesfright. Drakes smirk grew as he noticed this. You dont have a choice. As soon as those words made their way into the dead air he bolted towards the other boy. Shadow pushed Jace behind him and braced for the incoming attack, and not like other stories, this one hit its mark. He winced, and noted the body behind him. Activating the pipes in his calves he dashed towards a clearing only to take a fireball to the back. Come back and fight me coward! Drake was catching up fast. Shadow struggledRead MoreShort Story Chapter 1774 Words à |à 4 PagesThey made it out of Viridian Forest not long after defeating that swarm of Beedrill. It was getting close to evening by the time they made it to the next route, so they stopped to make camp for the night. It would be another two hours before they could make it to Pewter City if they continued. It was safest to just make camp. They sat around the fire Spitfire had made for them. Misty was the only one who didnt release her Pokà ©mon. Rattata snuggled in Gabbys lap and ate from the bag of chips inRead MoreChapter 1 Short Story922 Words à |à 4 Pagesfatherââ¬â¢s council table. He looks to her for advice even in granting justice. Since her motherââ¬â¢s death, the Princess is more the Queen than anything els e. She might offer you some perspective.â⬠Gwen nodded. She glanced toward the sky to see Sol just short of his zenith overhead. ââ¬Å"Perhaps we should ride on then?â⬠ââ¬Å"Weââ¬â¢d make Whitgate in a few hours. Perhaps we might find suitable lodgings afterwards?â⬠Seeing Gwenââ¬â¢s reluctance to put her out further in her eyes, Blancheflor insisted, ââ¬Å"You are my guestRead MoreChapter 1 : A Short Story1136 Words à |à 5 PagesKaterina stepped out of the shadow of the filing cabinet. She pushed her hood down and swung her sniper off of her back before leaning it against the wall. ââ¬Å"Hey Maria.â⬠She said as she placed the suitcase onto agent Hills desk. The brunette glanced at her before she looked back to her computer screen and continued to type. ââ¬Å"Hello, Shadow.â⬠The young woman snorted and quickly appeared next Hill, slinging an arm over her shoulders. ââ¬Å"Oh, donââ¬â¢t be like that. You know calling me ââ¬ËAgent Volkovaââ¬â¢ overRead MoreShort Story : Chapter 11085 Words à |à 5 PagesThe pillow seemed to sink a little, and Johnny died. I looked towards Dally, his face turned ten times younger, his face, his hard, mean, face had tears rolling down it. ââ¬Å"...Johnnyâ⬠¦Ã¢â¬ his voice whispered faintly, but Johnny said nothing. He could not. Dally had a pained expression that only someone who knew him could recognize, his hands were in fists. ââ¬Å"Weââ¬â¢re leaving,â⬠Dally demanded, ââ¬Å"Waitâ⬠the nurse said jogging towards us, ââ¬Å"Johnny wanted you to have this.â⬠she handed me Gone With the Wind. I took
Monday, December 23, 2019
Critical Analysis Of Mills Pig Thesis - 1727 Words
A Critical Analysis of Millââ¬â¢s ââ¬Å"Pig Thesisâ⬠John Stuart Mill published his seminal essay Utilitarianism in 1863. In this essay he builds on the work of his predecessor Jeremy Bentham, who sought to create a scientific approach to ethics, and responds to common criticisms of Benthamââ¬â¢s philosophy. Mill retains the core of Benthamââ¬â¢s Utilitarian philosophy, the Greatest Happiness Principle, but differs from Benthamââ¬â¢s position that pleasure is homogenous and that good actions seek only to produce greater quantities of pleasure, i.e. Quantitative Utilitarianism. Mill asserts that qua our uniquely higher faculties, human beings are capable of, and require, activities which produce qualitatively different pleasures than other animals, i.e.â⬠¦show more contentâ⬠¦However, in his formulation of Utilitarianism Bentham sees pleasure as a homogenous good, varying only in terms of quantity. The pithy formulation of this idea is found in Benthamââ¬â¢ s Rationale of Reward where he contends that ââ¬Å"Prejudice apart, the game of push-pins is of equal value with the arts and sciences of music and poetryâ⬠(Bentham, 206). Benthamââ¬â¢s lack of distinction between pleasures leads to the criticisms of his philosophy as hedonistic and fit only for swine. It is in response to these charges that Mill introduces the concept of qualitatively different pleasures. Keeping the underlying structure of Utilitarianism, with the Greatest Happiness Principle as its prime axiom, Mill diverges significantly from Benthamââ¬â¢s view of pleasure as essentially uniform. Mill introduces the notion that pleasures can differ in terms of quality, saying that ââ¬Å"it would be absurd that while, in estimating all other things, quality is considered as well as quantity, the estimation of pleasures should be supposed to depend on quantity aloneâ⬠. This insight is based primarily on Millââ¬â¢s assertion that ââ¬Å"Human beings have facul ties more elevated than the animal appetitesâ⬠and that due to this fact we require pleasures of a higher quality to attain happiness. It is important to note however, that Mill does not see human beings as fundamentally different in kind from animals, such that his contention is not based on a conception of human
Sunday, December 15, 2019
The Short Stories Of Haruki Murakami English Literature Essay Free Essays
Within The Elephant Vanishes, an anthology of short narratives by Haruki Murakami, and The Outsider, a novel by Albert Camus, civilization is examined and the reader is invited to see civilization as following set regulations and modus operandis. Through the supporters, the reader understands that civilization observes these behaviors without inquiry and in making so are robotic. One of the ways this thought is reinforced through mentions to nutrient. We will write a custom essay sample on The Short Stories Of Haruki Murakami English Literature Essay or any similar topic only for you Order Now Food is shown to fall in people ceremonially and who you portion your nutrient with reveals penetrations about the civilization in which you live. Through the action of the texts and first individual narratives the supporter is established as different to the civilization. In the short narrative, Sleep, the supporter noted, ââ¬ËI went to the life room, switched on the floor lamp beside the couch, and sat there imbibing a full glass of brandy ââ¬Ë ( page 84 ) . Although she enjoys intoxicant, she has to imbibe by stealing. She is restricted in her freedom to bask intoxicant because her hubby does non O.K. of it. Her hubby ââ¬Ës business as a tooth doctor precludes her from eating cocoas until an inadvertent reminder of old cocoa flakes wedged between the pages of the book ââ¬ËI found a few crumpling flakes of cocoa stuck between the pages ââ¬Ë ( page 90 ) . She was so inspired to liberate herself from the bonds of her hubby ââ¬Ës dental fraternity norms. She unashamedly indulged herself on this pleasance impetuously, ââ¬ËI felt a enormous impulse to hold the existent thing ââ¬Ë ( page 90 ) . In Sleep, clocking for tiffin is exactly at 11 40, ââ¬Å" aÃâ à ¦ I looked at my ticker. Eleven Forty. Eleven Forty! â⬠( Page 91, Elephant Vanishes, Sleep ) . The typical type of nutrient was, ââ¬Å" aÃâ à ¦minced scallionsaÃâ à ¦buckwheat noodlesaÃâ à ¦dried seaweedaÃâ à ¦tofu â⬠( page 91 ) . The mention to the exact clip and the type of tiffin indicate modus operandi. ââ¬Å" aÃâ à ¦Cup of coffeeaÃâ à ¦two pieces of staff of life, spread them with butter and mustard, and had a cheese sandwich â⬠( Page 89 ) , something which the supporter wants to get away from. It is merely when she breaks with the conventional regulations that she feels as though she is populating. The hubby sitting on the couch reading the newspaper shows the cultural modus operandi of people in their mundane life, ââ¬ËWhile I cleared the tabular array, my hubby sat on the couch reading the paper ââ¬Ë ( page 92 ) . ââ¬ËI made my hubby his usual java ââ¬Ë ( page 89 ) . The supporter is cognizant of cultural outlooks of which her hubby tenaciously adhere to populating through the same everyday every twenty-four hours. ââ¬ËAnna Karenina lay there beside him, but he did nââ¬â¢t look to notice. He had no involvement in whether I read books ââ¬Ë ( Page 92 ) . The hubby did non pay attending to his married woman ââ¬Ës involvements or in the fact that it was his ain book, which she was reading. It is the everyday and humdrum that he is occupied with the supporter lives through every twenty-four hours making whatever gives her pleasance. This rareness of freedom necessarily leads her to seeking nutrient for pleasance while the hubby, so ingrained in modus operandi, appears robotic. Although nutrient symbolically represents modus operandi in The Outsider, it besides establishes Meursault as an foreigner of the civilization. Both of Mersault ââ¬Ës friends, Masson and Raymond ââ¬Ës immoral behavior has the civilization sort them as foreigners. Due to their unusual behaviors, when these people meet to bask nutrient together, it demonstrates that they encompass similar features of personalities which are deemed unconventional from cultural outlooks. The protagonist drinks wine to attach to nutrient with Raymond and Masson ( page 53 ) . In this context, imbibing intoxicant is an acceptable pattern and civilization, both for work forces and adult females where it was observed by Mersault that Marie, his girlfriend ââ¬Å" aÃâ à ¦she ââ¬Ëd had a spot excessively much to imbibe â⬠( page 53 ) . However, the fact that when Marie, commented, ââ¬Å" Do you cognize what clip it is? It is half past 11 â⬠( page 53 The Foreigner ) , a fact acknowledged by Masson when he responded, ââ¬Å" aÃâ à ¦the clip to hold tiffin is when you are hungry â⬠( page 53 The Foreigner ) , indicates that for Masson, nutrient is an person ââ¬Ës pick non regulated by outlooks of a fixed agenda. At his place, Mersault appears to prefer ââ¬Å" aÃâ à ¦ smoke, and eating chocolatesaÃâ à ¦ â⬠during mealtimes ( page 26 ) The Outsider, while he watched the people below his flat from his gallery. In the text, Meursualt made brooding observations of people that were dressed otherwise within the local community that went passed the street, ââ¬ËHe was have oning a straw chapeau and a bow tie and transporting a walking-stickaÃâ à ¦ I understand why local people said he was distinguished ââ¬Ë ( page 25-26 ) . This reveals the distinguishable behavior of Meursault alongside the normal behavior of the civilization. Similarly, Meursault was besides recognised by the persons that went passed the street, ââ¬ËThe local misss, with their hair down, were walking weaponries in armsaÃâ à ¦ I knew several of the misss and they waved to me. ââ¬Ë ( page 27 ) . Later in the eventide Mersault ââ¬Å" went down to purchase some staff of life and some pasta, did my cookery and I ate standing up â⬠( page 28, The Outsider ) , a position of which is non dictated by conformist pattern. Mersault ââ¬Ës behavior and penetrations uncover how persons within the community stand out by their mere visual aspect that are easy recognizable that identifies them to be ââ¬Ëdifferent ââ¬Ë or ââ¬Ëdistinguishable ââ¬Ë . In add-on, Meursault does repair his eating agenda by a peculiar clip. This farther confirms that he is an unplanned and disorganised individual unlike the ââ¬Ërobot adult female ââ¬Ë ( page 45-46 ) The Outsider. The automaton adult female ââ¬Å" aÃâ à ¦while she was waiting for her hors dââ¬â¢oeuvre she opened her bagaÃâ à ¦took the exact amount plus a tipaÃâ à ¦meticulous undertaking occupied her throughout the repast â⬠( page 46 ) The Outsider. The robot adult female contradicts Meursault ââ¬Ës character, in that he would instead follow his peculiarity with respects to most of his determinations about when, how, where and what to eat. The robot adult females on the other manus, showed the features of order and way when she ordered her repast, ââ¬ËShe called Celeste over and ordered her whole repast at one time, talking exactly but quickly. ââ¬Ë ( page 46 ) of which afterwards she ââ¬Ëdived into her bag once more and took out a bluish pencil and a magazine which gave the wireless programmes for the hebdomad. One by one, she really carefully ticked about every programmeaÃâ à ¦ ââ¬Ë ( page 46 ) . From this rigamarole, the automaton adult female ââ¬Ës actions seem to follow a set of modus operandi. In the narrative, The Second Bakery Attack, the supporters were freshly married and did non pre-empt carrying nutrient in their house, ââ¬ËOur icebox contains non a individual point that could be technically categorized as nutrient ââ¬Ë ( page 37 ) . ââ¬Å" aÃâ à ¦a bottle of Gallic dressing, six tins of beer, two shrivelled onions, a stick of butter, and a box icebox deodorizer â⬠( page 37 ) . This is a symbol of how empty their lives are. Although they work, go to bed at set times, conforming to the modus operandis of work, they are metaphorically, unsated. The twosome ââ¬Ës conformist behavior seems to put them to their ââ¬Ëhunger ââ¬Ë . In order to happen a remedy to interrupt their hungriness, the twosome opposed convention by robbing Mc Donald ââ¬Ës, ââ¬ËAttack another bakeshop. Right off. Now. It ââ¬Ës the lone manner. ââ¬Ë ( page 43 ) . During the robbery, the director of the shop showed typical features of conventionality by the demands o f conformation from the upper authorization stating, ââ¬ËI ca nââ¬â¢t make that. I ââ¬Ëll be held responsible if I close up without permission ââ¬Ë ( Page 46 ) . From this, it shows that the larger bulk of the civilization such as the director and workers are similar to the automaton adult female in that their lives are dictated by order and modus operandi and merely a really little proportion of people operate in a non-conformist manner. Finally, in The Wind-up Bird and Tuesday ââ¬Ës Women, the supporter cooks spaghetti for breakfast. He chooses to populate outside the modus operandi of the civilization and this is reflected by his pick of cookery and eating spaghetti in the forenoon, ââ¬Ë â⬠Spaghetti? ââ¬Å" aÃâ à ¦ ââ¬Ë It ââ¬Ës merely ten-thirty in the forenoon. What are you making cooking spaghetti at ten-thirty in the forenoon? â⬠( page 5, The Wind-Up Bird and Tuesday ââ¬Ës Women ) asked the adult female who telephoned place for 10 proceedingss of his clip. In both The Elephant Vanishes by Haruki Murakami and The Foreigner by Albert Camus, nutrient are focused as a symbol that represents modus operandi or an person ââ¬Ës desire to hold freedom. The function of the characters is reflected in the type of nutrient they chose to eat, where and when the repartee of nutrient takes topographic point. When any of these engagements of nutrient varies, one can spot that these characters may be far-out, bizarre or stand-alone in their relationship to the larger civilization. ( Word Count: 1428 ) How to cite The Short Stories Of Haruki Murakami English Literature Essay, Essay examples
Saturday, December 7, 2019
International Commercial Law Convention Deals
Question: Discuss about the Case Study for International Commercial Law for Convention Deals. Answer: Introduction It is regardless to say that the very nature of future is uncertain. When there exists long term contracts between the parties, there may be situations where prices are suddenly increasing, inflating rising and thereby performance becoming onerous due to changing economic conditions around the globe. However, all such conditions are required to be foreseen by the parties. Contracts can be framed in such a manner by giving provision for the future uncertainties, like by fixing the price and defining performance. Thus, only except of unforeseen situations, the contract shall yield and guarantee performance. One of the paramount features in law of contract is most considerably, the sanctity of contract. The Latin phrase clearly says that the contract must be respected. Parties are mandated to adhere and abide by the terms of the contract agreed between them, as a matter of principle. Thus, this explains the reason as to why international sales remain unaffected by economic hardship as per the Vienna Convention on International Sales[1]. Under international law, it has become a rule for the arbitrators to consider the terms of contract agreed between the parties as supreme. The contract terms are mandated to be respected by the arbitrator as stated under the Arbitration treaty law[2], arbitration rules[3] and arbitration statutes[4]. Further, the sanctity of contract principle has also been confirmed by the arbitrators. This main objective of this paper is to critically evaluate the statement [] the principle of sanctity of contracts (pacta sunt servanda) as the leading maxim of contract law generally has priority over changes in the surrounding economic conditions.[5] For this purpose, the paper has been divided into various sections. The first section deals with the principle of sanctity of contract and seeks to analyze the principle in detail with respect to case laws. The second section deals with a principle, which stands contract to that of sanctity, which is flexibility of contract and also examines the grounds for defending the principle of flexibility. In further sections, the paper seeks to examine the interaction between changed circumstances and sanctity of contract and thus focuses on hardship clause, which is provided as a remedy for any change in circumstances. In the last sections, the main discussion shall be regarding the remedies, which the arbitrators or parties may avail in rega rds to changed circumstances. The principle of sanctity of contract pacta sunt servanda Pacta sunt servanda is a Latin phrase, which in English means that the pact or the agreement must be respected. It is a basic principle of civil and international law, which governs contractual relationship between parties. Article 26 of the Vienna Convention on the Law of Treaties also provides for the principle of pacta sunt servanda and states that every treaty in force is binding upon the parties to it and must be performed by them in good faith. In west, two significant principles, namely, pacta sunt servanda and the contract is the law of the parties protects the fundamental right relating to conclusion of contract between the parties. It is important for the parties to abide by the agreement in all the circumstances. These principles of contract law are not only applicable to contracts governing private persons but also governing state parties. These principles are recognized are eminent rules of private law, which govern the aspects of agreement between the parties and also as rules of law of treaties, which govern the aspects of arbitration among states.[6] Analysis of various commercial arbitration cases show that in addition to the legal issues raised before the arbitral tribunal, the objective of discussion between the parties is to establish the primacy of the principle of sanctity in commercial arbitration contracts over principle of flexibility as followed in the Western culture. The tribunal while giving Sapphire[7] award stated that the principle of sanctity is fundamental principle, which the international courts constantly proclaim by holding that it is pertinent to respect every contractual obligation undertaken by the party. Further, the rule of pacta sunt servanda governs the basis of each and every contractual relationship in the private international law. [8] Earlier award of Aramco[9] and of Sapphire were referred in the Topcos case[10] and it was states that international jurisdiction has never doubted on the existence and implementation of the rule of pacta sunt servanda in international law and thus this maximum must be viewed as a fundamental principle governing the international law. Further, the sole arbitrator in the case of Liamco[11], upheld this principle by stating that international law and practice have widely accepted that unilateral termination of contract is survived by the arbitration clause, which is inserted in the agreement by the parties and this clause continues even after the contract terminates. [12] The principle of sanctity of contract found its application to equal parties but jurists and scholars have extended the applicability of this principle of the contracts governing relations of states as well as private persons. The principle has been integrated and well extended to the international commercial arbitration contracts. Such contracts are now considered binding on the parties and none of the parties have the right to abrogate, modify or nullify the contract unilaterally.[13] The Flexibility Contract Principle It has been observed above that the principle of sanctity is well observed by the international law. However, scholars have countered the aspects of absolute sanctity while stressing on the requirement of brining flexibility in terms of legal implications and performance of international commercial contracts. They have generally pointed out on the very nature of such contracts, which influences the scope of national economic development and governmental functions. Most common arguments raised and their respective defenses and discussions in respect of flexibility of the contract principle of sanctity in international commercial arbitration have been analyzed in the sections below: The argument relating to public interests To defend the flexibility contract principle it has been argued that in reference to international commercial contracts relating to natural resources, these are closely associated with economic development and are underlying instruments of public policy. Thus, in such contracts of natural resources various countries cannot bind themselves in regards to economic welfare of the country since the relationship formed under the contract might derogate with time and affect welfare. Thus, for contracts relating to public interest or welfare, it is pertinent to ensure flexibility principle in application. The argument relating to denial of international status Another argument that defends the principle of flexibility, states that international contracts should not be governed by the public international law rather the law of the host state. Since, individuals were not considered subjects of international law; therefore it was valid to deny the status of international to commercial contracts. This argument was raised in the Anglo-Iranian Oil Company Case by The Permanent Court of International Justice.[14] However, the above argument was countered[15] by stating the view that if state contracts are modified or abrogated, then that shall refer to breach of the international law. It was further stated that the doctrine of flexibility has a fundamental error, which would have been removed if the lawyers of public international law would have give due regard and significance to the teachings, character and role of private international law. In cases where there is no scope for any problem to arise under the customary public international law, it is not possible for any breach of contract to factually occur and thus the principle of pacta sunt servanda goes un-infringed. The private international law of the respective forum governs the contracts. Such law not only has the power to sustain the contract but also modify or abrogate the contractual bond in its entirety. The argument relating to changed circumstances To defend the principle of flexibility, it has been argued that if pacta sunt servanda being the principle of public international law applies to international contract then there are other principles of international law, particular the principles of changed circumstances, which comprise of expectations to the former principle. Principle of changed circumstances as defined under Article 62 of the Vienna Convention on the Law of Treaties as clausal rebus sic stantibus states that in regards to the inter-state agreements, there is not absoluteness in the principle of sanctity of contract. [16] Various international jurists have the view that the principle of changed circumstances can be considered as an exception or reservation to the principle of pacta sunt servanda in international law. This view of jurists has now come to be accepted generally in the international law. Contractual Provisions on Changed Circumstances Parties may agree to implement a hardship clause in their agreement, when there are any chances that future situations may change. Some of the hardship clauses state that the on occurrence of certain specified situation or circumstance, the contract shall be terminated. However, there are other clauses also, namely the price revision clause or the indexation clause, which state that in change of circumstances even the terms of contract shall change. Further, clauses like that of adaptation clause provide that the parties are ordered to adapt to new circumstances as per the contract terms. Various authors have argued that hardship clause in a contract pertaining to long-term relations between the parties must be dealt like a custom. In other words, such a clause of hardship must be implied in long term contracts even when not expressly agreed to between the parties. However, if in contractual terms, parties specifically include a clause of hardship, it shall help in proving that no such general customary principle relating to hardship clause exists.[17] Further, the scope and implication of hardship clause varies in various types of such clauses. The application, scope and remedy of each of hardship clauses are different and thus a customary principle cannot be easily based on such varied and diverse hardship clause. Considering this situation, arbitrators have refused to consider hardship clause as customary in long term contracts rather they have focused on strict interpretation of such clauses as per the facts and circumstance of each case. This means that if there is a clause in the contract that mentions specific changes then such clause must be interpreted in a manner that no other change could be considered or taken into account while dealing with the contract. However, it cannot be said that mere presence of hardship clause shall exclude the entire application of general law relating to changed circumstances. This is so because it is almost impossible for the parties to negotiate and thereafter draft such hardship clause that is capable of covering all possible effects from which performance is likely to be affected. Thus, such changes which cannot be covered under the hardship clause may be applied by integrating the general law on changed circumstances. The arbitrators in the Arbitration Court of the Japan Shipping Exchange[18] stated as follows while recognizing this principle: The relation between this Article (renegotiation clause) and the principle of change in situation is such that the present article does not exclude the said principle, but provides for either one of the parties to request the other for consultation to amend the price, even in the instances where the principle of the change in situation does not need to be applied. Thus, in case of special circumstances, parties may instruct the tribunal to consider such circumstances that have changed post the dispute between the parties. The Iran-US Claims Tribunal [19]also stated that it is the very duty of the tribunal to consider and taking into account any change in circumstances between the contracting parties. Relationship between Pacta Sunt Servanda Rebus Sic Stantibus Most national legal systems have a rule that the binding force of the contract may get affected due to change circumstances. The maximum rebus sic stantibus: when things remain same even the contract remains binding, ensures possibility of such situations. Restricted interpretation of the maxim rebus sic stantibus shall be done to limit the huge scope of its analysis. Such expressed contractual terms are excluded that could not be satisfied, like changes relating to failure to perform as per the contractual conditions. Also, the act of God or Force Majeure, is excluded, since it makes the performance of contract completely impossible[20]. The main of this paper shall be to consider and analyze such changes, which make the performance erroneous rather than impossible. Various legal systems have incorporated the principle of rebus sic stantibus and it is also an important principle of international law. Even the judges of Iran-US Claim Tribunal recognized this principle under the Vienna Convention. Further, the judges stated that with wide implementation of this principle in the national legal systems, it shall not be unreasonable to regard it as a general principle of law.[21] International Law International treaty law defines the principle of Rebus sic stantibus. The Vienna Convention on the law of treaties, 1969 in its Article 62 defines and explains this principle of rebus sic stantibus. The Article 62 states as follows: A fundamental change of circumstances which has occurred with regard to those existing at the time of the conclusion of a treaty, and which was not foreseen by the parties, may not be invoked as a ground for terminating or withdrawing from the treaty unless: (a) the existence of those circumstances constituted an essential basis of the consent of the parties to be bound by the treaty; and (b) the effect of the change is radically to transform the extent of the obligations still to be performed under the treaty. The exception nature of this rebus sic stantibus has been demonstrated by the wording of Article 62. It ensures that this principle is considered subordinate to that of pacta sunt servanda and the same has been clearly stated under Article 26 of the Vienna Convention. It is pertinent for the change in circumstances to be fundamental in nature. The change must be such that the survival of State has been jeopardized entirely. Change cannot be in nature of mere currency reforms or loss in matters of economic interest. In the case of Fisheries Jurisdiction[22], the International Court stated that change must be vital in nature: it should be such that it imperils or prevents the vital development or existence of either of the parties. Further, the change should be such that none of the parties to the contract could reasonable foresee the same. However, it must be noted that even when the principle of rebus sic stantibus is indentified as a rule of international law by arbitrators and invoked by various parties, relief on such ground has not been granted to the parties. Tribunals and even the International Court of Justice have refused to consider the principle of rebus sic stantibus as a treaty.[23] National Law Performance when circumstances of contract change are excused under English Law, as per the doctrine of frustration of purpose. However, the party who demands excuse in performance under this doctrine must prove that the circumstances have changed radically due to which the performance undertaken as per the contract could not be fulfilled. But, the English judges have shown reluctance in implementing this doctrine to state that the contract has been frustrated.[24] Arbitration Practice In regards to international arbitration, implementation and impact of rebus sic stantibus has not been explored. Generally, arbitrators have been strict in implementing this principle to international contracts. Further, arbitrators have concluded that in any case where the mutual convent ants become impossible to perform, the contract shall be rendered impossible. This vitiates the very essence of contract. Thus, in only handful of cases, this doctrine has been actually implemented into the legal scenario relating to change in circumstances. Rather, arbitrators and tribunals have relied on renegotiation between parties in case of change in circumstances as an effective remedy to such problem. Such renegotiation may be included as a part of contract and state that parties may renegotiate in case of any change in circumstances.[25] Also, on successful renegotiations, rearrangement of contractual relationship may be done. However, it is equally important to identify the situation if such renegotiation fails. The clause dealing with renegotiation must be framed in such a manner that it provides solution to all possible situations. Conclusion The above analysis has critically discussed various aspects of the principle of sanctity of contracts. In international contracts, arbitration is the remedy to solve disputes between the parties. Thus, it is important to understand various complexities and rules of international law, which are considered by the arbitrators, tribunals and international courts. The principle of sanctity of contract or pacta sunt servanda states that the parties must serve the agreement or must fulfill the agreement, which leads to contractual relationship. In other words, it can be stated that the parties in no way can derogate from the agreement and ensure every action with the objective to fulfill contractual obligations agreed. It can be analyzed that this principle is a leading maxim under contract of law, which is also agreed by the arbitrators and used while dealing with international law. However, it is needless to say that parties under contract may face change in situations, due to which performance of contract gets affected. From the above discussion, it can be concluded that even when arbitrators have accepted the principle of rebus sic stantibus under international law, it has not been implemented into practical situations dealing with contracts. This principle is also considered as subordinate to pacta sunt servanda. Since, it imposes an obligation on the parties to perform. Further, as a remedy to changed circumstances, arbitrators have opted for the remedy of renegotiation between the parties. This remedy also seeks to fulfill the objective of pacta sunt servanda because it holds that in change of circumstances, parties may renegotiate to new agreement but must fulfill their obligations as per the agreement. Thus, it can be finally concluded that principle of sanctity of contract is the leading principle of contract law and is given priority even in change of circumstances or over the principle of flexibility of contract. References Article 79 of the Vienna Convention deals with force majeure, excludes economic hardship. European Convention on International Commercial Arbitration, 1961, Article VII. C.C. Arbitration Rules, Article 13.5; UNCITRAL Rules, Article 33.3. UNCITRAL Model Law, Article 28(4) already incorporated in many countries. Klaus Peter Berger, Renegotiation and Adaption of International Investment Contracts: The Role of Contract Drafters and Arbitrators, Vanderbilt Journal of Transnational Law, (2003) 36, 1347, 1353. Hamid Reza Nikbakht Fini, State Contract and Abitration, (1990, unpublished thesis, p. 26) Sapphire Intl Petroleums Ltd. v National Iranian Oil Co.,[1967]. George R. Delaume, State Contract and Transnational Arbitration, The American Journal of International Law. (1981) 75, 11. Arabia v Arabian American Oil Company (Aramco), 27 I.L.R. 117, 168 (1958). Texaco Overseas Petroleum Co. v Libya (Topco/Calasiatic Case), 53 I.L.R. 389 (1977). Libyan American Oil Company (LIAMCO) v Government of the Libyan Arab Republic, 17 I.L.M. 3 (1978). Doak Bishop, International arbitration of Petroleum Disputes: the development of a Lex Petrolea, Cepmlp Journal, (2000). Wehberg, Pacta sunt Servanda, American Journal of International Law, 1959, p.775; J. F. Lalive, Contracts Between a State or a State agency and a Foreign company, 13 International and Comparative Law Quarterly, 1964, p.987 Oxford Journal vol. 13 No. 3. Bing B. Tia, The regime of straits in international law, Oxford University Press, (1998). A. Mann, England Rejects Delocalised Contract and Arbitration, International and Comparative Law Quarterly, (1983) vol. 33. p. 194-195. Geiger, The Unilateral Changes of Economic Development Agreements, International and Comparative Law Quarterly, (1974), p. 100. C.C. award No. 5953 (1989), J.D.I., 1990, 1056 at 1059. Arbitration Court of the Japan Shipping Exchange, award September 20, 1975, Yb. Comm. Arb., 153 at 154. Questech decision 9 Iran-US C.T.R., 122-123. Court of Arbitration at the Polish Chamber of Foreign Trade, award February 11, 1958, Comm. Arb., 1981, 147 at 148. Questechdecision, 9Iran - US C.T.R., 122-123. International Court of Justice,Fisheries Jurisdiction case, ICJ Reports, 1973, 4 at 20. Yearbook ILC, 1963, II, 208;Yearbook ILC, 1966, II, 257; R. VAN MEHREN and P. KOURIDES, "International arbitrations between state and foreign private parties: the Libyan nationalisation cases",J.I.L., 1981, 475 at 532. Lauritzen A.S. v. Wijsmuller B.V., "The Super Servant Two",1 Lloyd's Rep., 1990, 1. C.C. award No. 4761 (1987),J.D.I., 1987, 1012. [1] Article 79 of the Vienna Convention deals with force majeure, excludes economic hardship. [2] European Convention on International Commercial Arbitration, 1961, Article VII. [3] Eg: I.C.C. Arbitration Rules, Article 13.5; UNCITRAL Rules, Article 33.3. [4] Eg. UNCITRAL Model Law, Article 28(4) already incorporated in many countries. [5] Klaus Peter Berger, Renegotiation and Adaption of International Investment Contracts: The Role of Contract Drafters and Arbitrators, Vanderbilt Journal of Transnational Law, (2003) 36, 1347, 1353. [6] Hamid Reza Nikbakht Fini, State Contract and Abitration, (1990, unpublished thesis, p. 26) [7] Sapphire Intl Petroleums Ltd. v National Iranian Oil Co.,[1967]. [8] George R. Delaume, State Contract and Transnational Arbitration, The American Journal of International Law. (1981) 75, 11. [9] Arabia v Arabian American Oil Company (Aramco), 27 I.L.R. 117, 168 (1958). [10] Texaco Overseas Petroleum Co. v Libya (Topco/Calasiatic Case), 53 I.L.R. 389 (1977). [11] Libyan American Oil Company (LIAMCO) v Government of the Libyan Arab Republic, 17 I.L.M. 3 (1978). [12] R. Doak Bishop, International arbitration of Petroleum Disputes: the development of a Lex Petrolea, Cepmlp Journal, (2000). [13] H. Wehberg, Pacta sunt Servanda, American Journal of International Law, 1959, p.775; J. F. Lalive, Contracts Between a State or a State agency and a Foreign company, 13 International and Comparative Law Quarterly, 1964, p.987 Oxford Journal vol. 13 No. 3. [14] Bing B. Tia, The regime of straits in international law, Oxford University Press, (1998). [15] F. A. Mann, England Rejects Delocalised Contract and Arbitration, International and Comparative Law Quarterly, (1983) vol. 33. p. 194-195. [16] R. Geiger, The Unilateral Changes of Economic Development Agreements, International and Comparative Law Quarterly, (1974), p. 100. [17] I.C.C. award No. 5953 (1989), J.D.I., 1990, 1056 at 1059. [18] Arbitration Court of the Japan Shipping Exchange, award September 20, 1975, Yb. Comm. Arb., 153 at 154. [19] Questech decision 9 Iran-US C.T.R., 122-123. [20] However arbitrators sometimes bring the former also under the heading of "changed circumstances - rebus sic stantibus".E.g.Court of Arbitration at the Polish Chamber of Foreign Trade, award February 11, 1958,Yb. Comm. Arb., 1981, 147 at 148. [21] Questechdecision, 9Iran - US C.T.R., 122-123. [22] International Court of Justice,Fisheries Jurisdiction case, ICJ Reports, 1973, 4 at 20. [23] Yearbook ILC, 1963, II, 208;Yearbook ILC, 1966, II, 257; R. VAN MEHREN and P. KOURIDES, "International arbitrations between state and foreign private parties: the Libyan nationalisation cases",A.J.I.L., 1981, 475 at 532. [24] J. Lauritzen A.S. v. Wijsmuller B.V., "The Super Servant Two",1 Lloyd's Rep., 1990, 1. [25] I.C.C. award No. 4761 (1987),J.D.I., 1987, 1012.
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