Saturday, August 31, 2019

Dr. Pepper/Seven Up, Inc. Squirt Brand Essay

DR PEPPER SNAPPLE GROUP INCORPORATION Opportunity Analysis, Market Segmentation, and Market Targeting Thinking of energy drinks competitor they have lot of ideas and strategies made to compete they innovate their products to have a new ideal in the eyes of customer. There are 43 million energy drink users in US. they are lack of product promotion because the competitors are more well known while Dr Pepper Snapple Group Inc, before are the major energy drink they need to innovate the product like for example for the health conscious people they can make a sugar free energy drink, or for fitness. They only targeted for males and sport man while they can have an innovation of it to target female like energy diet drink to make them sexy. The important thing is to promote first the product my using social networking like facebook to get the attention of the customer , commercialize the product with the use of well known artist. Served Market Where To Compete What is Marketing Market Sales Potential and Profitability Estimating Market Sales Potential Market Sales Potential is a Quantitativ e Approximation of Effective Demand Maximum Level of Sales that Might Be Available to All Organizations Serving a Defined Market During a Specific Time Period Definition Three Variables That effect Market Sales Potential The Number Of Prospective Buyers Who Are Willing And Able To Purchase and Offering(B) The Quantity Of An Offering Purchased By An Average Buyer In A Specific Time Period (Q) The Price Of An Average Unit Of An Offering (P) B x Q x P = Chain Ratio Method to Create Clear Marketing Plan Chain Ratio Method Provides A Quantitative Estimate of Market Sales Potential Highlights Factors That Are Controllable and Uncontrollable Using the Chain Ratio Method to Influence Market Sales Potential for Carbonated Cola Soft Drink Market in a South American Country Factors That Can Be Manipulated (B) Proportion of population that consumes carbonated soft drinks (Q) Availability and ease of access to carbonated cola soft drinks (P) Pricing of carbonated cola soft drinks Sales and Profit Forecasting Once one has determined a market’s sale potential and identified variables that can be manipulated to increase sales of a particular product, one needs to determine the estimated sales that can be expected from a given marketing  strategy. We do this by creating a â€Å"Sales Forecast† Sales Forecast Level of sales a single organization can expect to achieve based on a chosen marketing strategy and an assumed market environment. Sales Forecast Forecasted Sales Size Of The Target Market The Marketing Mix Chosen For The Target Market Assumed Number Of Competitors In The Target Market Competitive Intesity In The Target Market An Example Total Estimated Prospective Buyers Target Market (25% of Total Buyers) Distribution/ Communication Coverage (75% of Target Market) Annual Purchase Rate (20 Units Per Year) Average Product Price Per Unit ($10.00) 1 Million 0.25 0.75 20 $10.00 37.5 Million A Disclaimer While this is an adequate example of a chain ratio method calculation forecasting sales in a particular target market, this forecast does not take into consideration the number of competitors vying for the same target market or the competitive intensity of the target market and therefore should be adjusted downward to reflect the effect of these added variables on the sales forecast. Finally A Pro Forma income statement should be prepared showing the forecasted sales, budgeted expenses, and estimated net profit. Population

Friday, August 30, 2019

The Hunters: Phantom Chapter 18

Caleb's hand was hot and heavy against her lips, and Elena scrabbled against it with her nails. He gripped her tightly with his other hand, holding her stil , his fingers digging into her shoulder. Elena struggled fiercely, flailing her arms and landing a firm blow in Caleb's stomach. She bit down hard on the hand he had over her mouth. Caleb jerked backward, quickly letting go of her and pul ing his bitten hand to his chest. As soon as her mouth was uncovered, Elena screamed. Caleb stepped away from her, holding his hands up in surrender. â€Å"Elena!† he said. â€Å"Elena, I'm so sorry. I didn't mean to scare you. I just didn't want you to scream.† Elena eyed him warily, breathing hard. â€Å"What are you doing here?† she asked. â€Å"Why were you sneaking up behind me if you didn't want to scare me?† Caleb shrugged and looked a little embarrassed. â€Å"I was worried about you,† he confessed, stuffing his hands in his pockets and hanging his head. â€Å"I was hiking up by Hot Springs earlier and I saw you and your friends. They were pul ing you out of the water, and it looked like you weren't breathing.† He peeked up at her through his long golden lashes. â€Å"You were so worried about me you decided to grab me and cover my mouth to keep me from screaming?† Elena asked. Caleb ducked his head further and scrubbed at the back of his neck in an embarrassed way. â€Å"I wasn't thinking.† Caleb nodded solemnly. â€Å"You looked so pale,† he said. â€Å"But you opened your eyes and sat up. I was going to come down and see if you were okay, but your friend saw me and started running up the path toward me like he was going to jump me, and I guess I just freaked out.† He grinned suddenly. â€Å"I'm not usual y such a wuss,† he said. â€Å"But he looked mad.† Elena found herself feeling unexpectedly disarmed. Her shoulder stil ached where Caleb had grabbed her. But he seemed so sincere, and so apologetic. â€Å"Anyway,† Caleb continued, gazing at her out of candid light blue eyes, â€Å"I was driving back to my aunt and uncle's place, and I recognized your car in the cemetery parking lot. I just came in because I wanted to talk to you and make sure you were okay. And then, when I got close to you, you were sitting down and talking, and I guess I was embarrassed. I didn't want to interrupt you, and I didn't want to barge in on something personal, so I just waited.† He ducked his head sheepishly again. â€Å"And instead I ended up assaulting you and scaring you to death, which sure wasn't the better way to go. I'm real y sorry, Elena.† Elena's heartbeat was returning to normal. Whatever Caleb's intentions, he obviously wasn't going to attack her again now. â€Å"It's al right,† she said. â€Å"I hit my head on an underwater rock. I'm fine now, though. It must have looked pretty weird to see me just sitting here and muttering. Sometimes I come here to talk to my parents, that's al . This is where they're buried.† â€Å"It's not weird,† he said quietly. â€Å"I find myself talking to my parents sometimes, too. When something happens and I wish they were with me, I start tel ing them about it and it makes me feel like they're there.† He swal owed hard. â€Å"It's been a few years, but you never stop missing them, do you?† The last bits of anger and fear drained out of Elena when she saw the sadness in Caleb's face. â€Å"Oh, Caleb,† she said, reaching out to touch his arm. She caught a sudden motion out of the corner of her eye and then, seemingly out of nowhere, Stefan appeared, running incredibly fast, straight toward them. â€Å"Caleb,† he growled, grabbing him by the shirt and throwing him to the ground. Caleb let out a grunt of surprise and pain. â€Å"Stefan, no!† shouted Elena. Stefan spun to look at her. His eyes were hard and his fangs were ful y extended. â€Å"He's not what he says he is, Elena,† he said in an eerily calm voice. â€Å"He's dangerous.† Caleb slowly pul ed himself to his feet, using a gravestone as a support. He was staring at Stefan's fangs. â€Å"What's going on?† he asked. â€Å"What are you?† Stefan turned toward him and, almost casual y, slapped him back down. â€Å"Stefan, stop it!† Elena yel ed, unable to contain the note of hysteria in her voice. She reached out for his arm, but missed. â€Å"You're going to hurt him!† â€Å"He wants you, Elena,† Stefan growled. â€Å"Do you understand that? You can't trust him.† â€Å"Stefan,† Elena pleaded. â€Å"Listen to me. He wasn't doing anything wrong. You know that. He's a human.† She could feel hot tears gathering in her eyes and she blinked them away. Now was not the time to weep and wail. Now was the time to be cool and rational and to keep Stefan from losing control. Caleb staggered to his feet, grimacing with pain, and this time charged clumsily at Stefan, his face flushed. He got one arm around Stefan's neck and yanked him to the side, but then Stefan, with an easy strength, tossed Caleb to the ground once more. Stefan loomed over him threateningly as he stared up at him from the grass. â€Å"You can't fight me,† Stefan growled. â€Å"I'm stronger than you. I can drive you out of this town, or kil you just as easily. And I wil do either if you make me think it's necessary. I won't hesitate.† Elena grabbed Stefan's arm. â€Å"Stop it! Stop it!† she shouted. She pul ed him toward her, trying to turn him so she could look into his eyes, so she could get through to him. Breathe, she thought desperately. She had to calm things down here, and she tried to steady her voice, to sound logical. â€Å"Stefan, I don't know what you think is going on with Caleb, but just stop for a minute and think.† â€Å"Elena, look at me,† Stefan said. His eyes were dark with emotion. â€Å"I know, I'm absolutely sure, that Caleb is evil. He's dangerous to us. We have to get rid of him before he gets a chance to destroy us. We can't give him the opportunity to get the better of us by waiting for him to make his move.† â€Å"Stefan†¦Ã¢â‚¬  Elena said. Her voice was shaking, and an oddly rational, detached part of her noted that this must be what it felt like when the person you loved most lost his mind. She didn't know what she was going to say next, but before she could even open her mouth, Caleb had risen again. There was a long scratch down the side of his face, and his blond hair was tangled and ful of dirt. â€Å"Back off,† Caleb said grimly, coming toward Stefan. He was limping a little bit, and clutched a fist-size rock in his right hand. â€Å"You can't just†¦Ã¢â‚¬  He raised the rock threateningly. â€Å"Stop it, both of you,† Elena yel ed, trying for a fierce general's voice that would command their attention. But Caleb just hoisted the rock and threw it straight at Stefan's face. Stefan dodged the rock, moving almost too quickly for Elena to see, grabbed Caleb by the waist, and, in one graceful motion, flung him into the air. For a moment, Caleb was suspended, seemingly as light and boneless as a scarecrow tossed from the back of a pickup truck, and then he hit the side of the marble Civil War monument with a sickening crunch. With a thud, he fel to the ground at the foot of the statue and was stil . â€Å"Caleb!† Elena screamed in horror. She ran toward him, shoving her way between the bushes and clumps of grass that encircled the monument. His eyes were closed and his face was pale. Elena could see the light blue veins in his eyelids. There was a spreading pool of blood on the ground beneath his head. A streak of dirt ran across his face, and that dirt and the long red scratch on his cheek suddenly seemed like some of the most heartbreaking things she had ever seen. He wasn't moving. She couldn't tel whether he was breathing. Elena dropped to her knees and felt for Caleb's pulse, fumbling at his neck. As she found the steady thrum of a heartbeat beneath her fingers, she gasped in relief. â€Å"Elena.† Stefan had fol owed her to Caleb's side. He put his hand on her shoulder. â€Å"Please, Elena.† Elena shook her head, refusing to look at him, and shrugged his hand away. She felt in her pocket for her phone. â€Å"My god, Stefan,† she said, her words clipped and tight, â€Å"you could have kil ed him. You have to get out of here. I can tel the police I found him like this, but if they see you, they're going to know you two were fighting.† She swal owed hard as she realized the streak of dirt staining Caleb's shirt was Stefan's handprint. â€Å"Elena,† Stefan pleaded. At the anguish in his tone, she final y turned toward him. â€Å"Elena, you don't understand. I had to stop him. He was a threat to you.† Stefan's leaf green eyes beseeched her, and Elena had to steel herself to keep from crying. â€Å"You have to leave,† she said. â€Å"Go home. I'l talk to you later.† Don't hurt anyone else, she thought, and bit her lip. Stefan stared at her for a long moment, then final y backed away. â€Å"I love you, Elena.† He turned and disappeared into the trees, through the older and wilder part of the cemetery. Elena took a steadying breath, wiped her eyes, and dialed 911. â€Å"There's been an accident,† she said, her voice panicky, when the operator picked up. â€Å"I'm in the Fel ‘s Church Cemetery off Route Twenty-three, over by the Civil War monument near the edge of the newer section. I've found someone†¦ It looks like he was knocked unconscious somehow†¦Ã¢â‚¬ 

Thursday, August 29, 2019

Understanding Financial Reporting

Financial reports allow the organization to communicate information about their performance to the â€Å"outside world†. So, financial reports provide summarized information about an organization†s transactions for external decision makers. (e. g. Investors). Financial reports can be used by employees and trade unions, government, creditors and lenders, customers, shareholders and investment analysts. All these users may need different statements of financial accounts but the most important statements which they need is the balance sheet, profit and loss account, cash flow account and the income statement. The two main regulatory bodies of financial reporting are the â€Å"Law† and the â€Å"Accounting Profession† with the Accounting Standards Board usually known as ASB. In UK, most of the legislation related to the publishing of accounts is embodied in the Companies Act 1985 and 1989 which are concerned with the accounts of the limited liability companies only. The Companies Act 1989 is the main frame which the companies and accountants have to follow. All the financial statement drawn up under the act 1989 must present a true and fair view and its function is to protect all the users of the financial reports and statements. The second and the most important regulatory body is the accounting profession. The standard setters should be aware of the information needed by all users of financial reports and should know the impact and the outcome of a different accounting method on the needs of those users. The standard setters should also be able to resolve the conflicts which exist between the needs of different users. So, they have to find an alternative way which best satisfy user needs and this could be achieved by choosing the improvement of the â€Å"social welfare† instead of welfare of individuals. We know that Accounting Standards Board is the main accounting standard setter. Because the ASB is composed of professional accountants, they may be unfamiliar with the user needs. So , when there is a need for a change in accounting standard the ASB prepare and publish a draft standard called the FRED (Financial Reporting Exposure Draft). After the publishing of these drafts the comments from the public is invited and in the light of these comments the FRED is changed (or unchanged). Now the FREDs are issued as FRS (Financial Reporting Standard). The main disadvantage of this system is the ASB members are unfamiliar with the different user needs and the comments from the general public may not be equally represented. There are four things that standards in financial reporting supply people using it. The first one is â€Å"Comparability†; financial statements must allow people to compare one company with another one and evaluate the management†s performance without spending time and money adjusting them to a common format and common accounting treatments. It is essential that users of financial reports or investment decision makers be supplied with relevant and standard financial reports which have been regulated and hence standardized. The second thing that standards and regulations supply is called â€Å"Credibility†. Because all this standards and regulations exist accountants have to treat every company in the same way. If the accountancy profession permitted companies experiencing similar events to produce financial reports that disclosed markedly different results simply because of a freedom to select different accounting policies they would lose all of their credibility. So, the standards should be composed of rigid rules and should not be broken. The third thing is â€Å"Influence† that means, setting up the standards has encouraged a constructive appraisal of the policies being proposed for individual reporting problems and has been a stimulus for the development of a conceptual framework. The last thing that the standards have to supply is â€Å"discipline†. Companies left to their own devises without the need to obey standards will eventually be disciplined by the financial markets. But in the short run investors in such companies may suffer loss. The Financial Reporting Council is aware of the need to impose discipline because most of the company failures in recent years are because of obscure financial reporting. Why should the Accounting Standards set? As we argued before, an important role of the regulations is to increase the comparability of accounts by limiting the choice of alternative accounting methods and to supply standardized accounts. This standardization can be achieved only by uniform accounting practice. If all accounting methods were standardized, two organizations which began the year with same balance sheets and which made the same transactions during the year, they would report the same balance sheets and the same profit and loss account at the end of the year. In addition to these advantages of regulations in financial reporting, there are also some more useful functions. Regulations can help to reduce the influence of personal biases and political pressures on accounting judgments. They can increase the level of user confidence in, and understanding of, financial reporting by clarifying the basis on which all accounts are prepared and presented. Finally, they can provide a frame of reference for resolving accounting problems which are not mentioned in legislation or accounting standards. As we argued earlier although the regulations in financial reports have very advantages it has many disadvantages too: One if these disadvantages is the â€Å"Adverse Allocative Effects†, this could occur if the ASB did not take into account of the economic consequences of the new standard or regulation they have issued. For example, additional costs could be imposed on preparers of accounts and suboptimal managerial decisions might be taken to avoid any reduction in earning or net assets. â€Å"Consensus-seeking† can be another disadvantage and this means the issuing of standards that are over-influenced by those with easiest access to the standard-setters. Most of the time this could happen with complex subjects.

Wednesday, August 28, 2019

EXERCISE MODULE 8 Essay Example | Topics and Well Written Essays - 1250 words

EXERCISE MODULE 8 - Essay Example The company may need to finish the project according to a predefined deadline, it may be done to improve project cash flow, it may be a way of avoiding liquidation damages, it may be a way of recovering early days, it may also be a way of avoiding oncoming danger, for example adverse weather conditions that might affect the project’s progress, and it may also be a way of releasing key resources for an oncoming project (Kohli, 2007). It is also important to recognize that as projects continue, there are several indirect costs incurred that can be eliminated by shortening the duration time. These costs include; cost of equipment, interest on investment, machinery, facilities, personnel, labour, and the cost of time lost when some employees do not come regularly to work (Roy, 2005). Project duration can be reduced depending on the type of work being carried out, and the availability of resources. Projects involving installation or development of new software for a company’ s systems for example, may require a specific skill. This can only be obtained from specific persons. Reducing project duration considering this case will require additional labour time for the specialist. He or she will then be required to work overtime. This however, needs additional resources, for the specialist has to be paid for extra time worked. Project duration time can be reduced by: application of multiple-shifts work, offering incentive payments to increase the productivity, using additional resources when necessary, working extended hours, working on holidays and weekends, and using alternative methods and sequences among others (Roy, 2005). Reducing the time taken to complete a project involves reducing the activities’ duration, or adjusting overlaps between activities. This however, has an effect on the original plan in terms of the cost. Whenever activity duration is reduced, the cost increases. This is because, with reduced time for the activity, it means that additional resources were used to ensure a lot of work is done within a short period. Take an example of construction of a building. For a normal duration, there are seven workers employed to do specific duties. It is expected that their work will be completed in a month. Since the project duration has been reduced to two weeks, the company will have to employ additional workers with the same skills to speed up the work. The workers will have to be paid, therefore, additional resources. The tools and equipment used will also have to be added. A similar understanding can be obtained from overtime work. This requires additional wages, as well as costs used to correct quality problems (Kohli, 2007; Roy, 2005). This shows that there is a relationship between the direct cost, and time of completing an activity. The cheaper the resources, the longer the time they take to complete an activity. If the duration is shortened, there is an increase in direct costs. Direct costs are such as; th e cost of equipment, labour, and materials. This should however, not lead to an assumption that there is an automatic inverse relationship between the project duration and the quantity of resources deployed. This is because, not all activities are similar. There are those that can be done in a short time by deployment of more resources, and there are those that deployment of more resources does not reduce the time needed. For example, it should not be

Tuesday, August 27, 2019

Religion and fanaticism in The Kite Runner Essay

Religion and fanaticism in The Kite Runner - Essay Example n is like the biblical David in his childhood, but he takes on a martyr’s ending perhaps to preserve the sainthood the author assigns him (Hosseini 54). These characteristics then set a base for description of some of the celebrated aspects of the Islamic religion. One of the aspects is adherence to love, forgiveness, redemption, and sacrifice to achieve or show honor for the first three mentioned aspects. All these beliefs derive from Allah’s ability to forgive and love even those who out rightly and knowingly transgress against him. Instances where the actions of a character are as a result of religious grounding include Hassan forgiving Amir for the things he did to him. He later on sacrificed his life protecting Amir’s Property while he was hiding from the Taliban in America a clear sign of forgiveness. Courage is also a vital character â€Å"requirement† in the Islamic religion. Some analysts’ confer that, the Islamic religion places women who stay home to protect their families at the same level as men who do not war for the cause of the religion. Amir, the Main character and narrator, lacks courage , and this puts him in an awkward position even with his father (Hosseini 76). Amir’s lack of courage causes him to do awful things. He betrays Hassan’s honor by failing to help him and then cunningly getting rid of him to avoid the guilt. These circumstances lead to the emergence of yet another theme associated with the Islamic faith, redemption. Amir wallows in feelings of guilt from as early as twelve years. Amir, in addition to his cowardice, has not tried to seek redemption. The author explores this theme by relaying that the narrator attributes unfortunate events to punishment. Amir punishes himself in several ways during the course of this book. For instance, he marries a tainted woman because of his personal guilt for his past actions. When Sohrab attempts suicide Amir cries out to Allah let this not be fate! All the while, Amir subtly commits

Kungfu film Essay Example | Topics and Well Written Essays - 250 words

Kungfu film - Essay Example The anti-imperial themes inherent in the Kung Fu and Wuxia films did hold much socio economic appeal in the Chinese and Western culture. It is a fact that everybody tends to harbor sympathy for the underdog. The anti imperialist and anti elite sentiments inherent in the Kung Fu and Wuxia films did appeal to the sentiments of sympathy and awe of the audiences in the Chinese and the Western culture. Both the Kung Fu and Wuxia films do feature the socially marginalized and sidelined characters that fight against the prevalent socio-economic hegemony and revolt against the dominant elite sections of the society. The audiences in the Western and Chinese culture did empathize a lot with the Kung Fu and Wuxia film heroes fighting against the prevalent prejudice, social marginalization and racial discrimination. By doing so these heroes voiced the concerns of the undergo that primarily contributed to their appeal amidst the Chinese and Western audience. Both the Kung Fu and Wuxia films featu re central characters that raise a voice against the elite segments of the society. Thereby it is readily feasible to understand the grass root appeal of these movies in the Western and Chinese culture. The Kung Fu and Wuxia movies did cater to the sentiments of the working class in the Chinese and the Western cultures. Thereby, they accrue immense appeal and following amongst the working class audience. These films did allow them a chance to catharsis and vent out their repressed grudge and anger against a socio economic system dominated by the rich and the

Monday, August 26, 2019

Identify the key influences on the health and well being of Young Essay

Identify the key influences on the health and well being of Young people 13-19 years in westminster - Essay Example There have been major progresses in the Governments approach to children and young people since that report was published; and systems are currently in place to make certain a further planned and coherent approach to childrens issues throughout the Government. The Quality Protects Program to make better life chances of children in public care led the way for the participation of children and young people in its design. The fresh Connexions personal consultant service for 13 to 19yrs. has been made in full discussion with young people The Department for Education and Skills has discussed with young people on its new White Papers to renovate Secondary Education for 14-19 year olds. The core values go together with the standards for children and young peoples involvement in local democratic system set out in the National Youth Agency. The Children and Young Peoples Unit is taking step to make this sort of excellent practice the standard. The Government has decided to follow clear ideology for engaging well with children and young people and the Sections in charge for strategies and services for children and young people in England will make yearly evaluated action plans to show the progress checked against consistent values (Joint Committee On Human Rights, 2003). The Westminster is a City that makes sure everyone’s health and well being. The agenda for a Healthier Westminster stand for more incorporated approach to setting up local services to support work around enhancing the health of local people. This merges work in the region of both the Health Improvement and Modernization Plan, and the Community Care Plan. As a result of combining these two plans together, the Program attracts all the local ideas which are intended to help improve health. This is a broad vision than looking at precise priorities for rising health and social care services and comprises data about the wider determinants of health in Westminster. to improve access to health and social

Sunday, August 25, 2019

English Essay Example | Topics and Well Written Essays - 250 words - 60

English - Essay Example One of the topics that I will be involved in research about it is microfinance. It involves providing of banking services to the low-income earners. It is evident that microfinance enables the low-income earners to be self-sufficient by providing a means of insurance, saving money and borrowing. My research on the topic will boost my marketing skills in the bank sector and I will be able to add more value. The other topic that I will be involved in research about is psychology. It entails the scientific study of human mind and its functions. It is apparent that the research on psychology will help to improve my marketing skills and I will be able to handle different people. Also, I will be able to know the reasons behind the people’s preferences in the business world. For my essay to be factual, I will refer information from the books of Sarkar and Sundaresan about microfinance. I will refer my research on the topic of psychology from McKenna book of business psychology and organizational

Saturday, August 24, 2019

ICICI Management Essay Example | Topics and Well Written Essays - 1250 words

ICICI Management - Essay Example In this way, the employees feel appreciated by the management of the bank and this is done in a manner which not only encourages them to work harder to achieve the goals of this institution but also towards increasing its competitiveness (Bihari & Charde, 2014). The motivation style of ICICI is in line with Herzberg’s two factor theory which advocated for the removal of some of the control which the bank’s management has over its employees and this ensures that there is an increase in their accountability and responsibility over their work. In this way, the employees become motivated through their being given freedom of action while also having more responsibilities which encourage them to work harder for the greater good of the bank. In addition, also in line with the two factor theory, ICICI also motivates its employees through encouraging them to create natural work units where possible and this is done in a manner where the employees themselves are given the respons ibility of creating whole sections of their teams instead of only a part of it (LaBelle, 2005). Moreover, ICICI also works towards the provision of regular feedback directly to its employees and this makes the latter to feel that their welfare at work is being well considered. The fact that the management does not have to go through supervisors to provide feedback encourages workers to improve their job performance (Hassan, 2005). The expectancy theory also comes to play in the way in which ICICI motivates its workers and this is because its management encourages employees to take on challenging tasks so that they may specialise in these tasks and in this manner, remove the need to bring in outsiders to undertake tasks.

Friday, August 23, 2019

In-Depth Audience Analysis Research Paper Example | Topics and Well Written Essays - 750 words - 1

In-Depth Audience Analysis - Research Paper Example The Chamber has more than 200 companies affiliated with it which are the employers for more than 280,000 people. The Chamber aims to support and mentor its members at a very low cost through its various programs and benefits. The Chamber has contributed to the growth of working women and small business enterprises through their low cost or no cost educational supports systems. The major volume of the members of the Chamber constitutes of small business enterprises and the Chamber aims at tapping in every business decision maker as their potential member. The Chamber pays particular attention to make the most of the investment of the small businesses so that the businesses can utilize the benefits of their membership fully. The Chamber provides different benefits to its member companies including wellness and health solutions, communication solutions and business solutions. The cost saving benefits programs are especially suitable for the small businesses. These programs help to support and develop the businesses in the area and thus improving the economic conditions of the area. The Group Health programs are directed at the employees and their family. The benefits of group term life, Health savings Account, and Discount prescription Drug Cards help to save the money of the employees in the member businesses. This provides facilities for the business as well as the employees. The chamber also supports various business issues through their business solutions like the Fuel Protection Program that helps the businesses to minimize their fuel costs at an affordable fee to the Chamber. The accounts receivables solutions are helpful in improving the cash flows and reduce the collection costs, thereby helping the member businesses to expand (Hampton Roads Chamber of Commerce, 2013). The Chamber offers specific programs for the different types of businesses to help the businesses and their employees

Thursday, August 22, 2019

The Life We’ve Always Wanted Essay Example for Free

The Life We’ve Always Wanted Essay John Ortberg’s (2002) book, The Life You’ve Always Wanted: Spiritual Disciplines for Ordinary People, describes the methods by which all ordinary people may achieve their goals for the present life and beyond. The book is about spiritual transformation, or morphing, which is described by the author as â€Å"the inward and real formation of the essential nature of a person (p. 23). † Ortberg reminds the readers that they could be one with God, the Holy Spirit, and Jesus Christ. To do so, however, readers must be willing to understand their shortcomings on the path of spirituality. They must know whether they are disappointed with themselves and/or life in general. Ortberg describes his own disappointments, too, allowing the reader to relate to an ordinary person who has given serious thought to living a life he had always wanted. The life we have always wanted revolves around our personal relationships with God. The author reminds the reader that God is accessible, and when we pray we must bear in mind that Jesus Christ is right next to us. Moreover, ordinary persons must seek intimacy with God. According to Ortberg, â€Å"Practices such as reading Scripture and praying are important – not because they prove how spiritual we are – but because God can use them to lead us into life (p. 43). † These practices train people to listen to God. Ortberg insists that it is possible for all ordinary people to listen to God. However, the following conditions must be met: (1) Ordinary persons who are ready to successfully spend their lives with the guidance of God must believe in The Life We’ve Always Wanted 3 Him; and (2) They must actually begin following His guidance by loving people and loving Him, and by healing themselves of the sickness of hurry, as the author describes it. The author describes many ways in which ordinary people stop themselves from following the guidance of Jesus Christ. Ordinary people may be selfish or lazy when conditions require them to help their brothers and sisters. They may also stop believing that they are servants of God by being vane, prideful, and stubborn. Ortberg writes, â€Å"We have all, in our own way been trying to take God’s place ever since Eden (p. 99). † However, people who pretend to be their own gods cannot enjoy the guidance of God, who knows everything and is therefore able to guide them best. In order to live the lives they have always wanted, ordinary people are required to confess their sins to God. Being free of guilt and shame before God is necessary for the cultivation of a sound relationship with Him. The book drives home the fact that joyfulness, silence, meditation, and an unhurried way of life would help ordinary people to achieve the best in both worlds. Still, Ortberg concerns himself with the present life when he narrates the stories of ordinary people in relation to the subject of the book. Indeed, the book is mainly about achieving success in the present life by obeying God, e. g. by loving God and His people, and by listening to Him with earnestness and knowing that He would not disappoint us. Concrete Response During the last two years, I have actually tried my best to be Christ like. Jesus Christ had said that if we try to be one with him we may be able to do everything that he could do, and The Life We’ve Always Wanted 4 more. I was very interested in learning to heal myself and others, as well as to enjoy the life I have always wanted. So, I spent a great deal of time in prayer, meditation, and reading the Scripture. For some time I was truly able to listen to God. I knew that He was talking to me, and guiding me. It definitely required me to slow down to be able to listen to Him. As soon as I entered a period of being extremely busy, however, I lost the connection. As a matter of fact, I forgot how God used to talk to me. It still bothers me to think that I do not recognize God’s voice even if I hear it now. Although Ortberg has extensively written about listening to God, I still cannot do it. I have simply forgotten how to listen to God, and there is no way that anybody can remind me about the method I had used to listen to Him. It was and remains a personal experience. Even if Ortberg’s writing eventually manages to remind me about the way I used to listen to God – I believe it would not be possible until and unless God allows me to listen to Him and to know that it is He. Reflection Jesus Christ had clearly stated that we must be one with him. He was a Messiah, and Ortberg reminds us that ordinary people are servants rather than Messiahs. So, if ordinary people do not have the potential of being Messiahs, why did Jesus Christ say that we should be one with him? If Jesus Christ were living on earth today, the suffering of human beings would surely have lessened. Conflicts around the world are on the increase, and so are diseases. Ortberg The Life We’ve Always Wanted 5 quotes William Iverson who had written, â€Å"A pound of meat would surely be affected by a quarter pound of salt;† and adds, â€Å"If this is real Christianity, the ‘salt of the earth’ where is the effect of which Jesus spoke? (p. 33). † It bothers me that Ortberg mentions this because he has not been able to help our world the way Jesus is expected to. Almost everybody can talk. As far as results are concerned, I would not be able to give enough credit to Ortberg for changing our world. Jesus did not write books. Perhaps, therefore, Ortberg should spend more time in prayer, meditation, and reading the Scripture before he is actually able to influence the world in the manner of Jesus. In my opinion, it is enough for ordinary people to read and understand the Scripture on their own. People that are constantly talking about the Gospel instead of practicing it should reflect on their own spiritual disciplining process. It seems to me that all believers ought to practice more and preach less. Action The answers to all human problems can be resolved by understanding the Scripture. To a friend who is experiencing problems, therefore, I would mention the Scripture and the fact that nothing is impossible for the human being who believes and follows revealed knowledge. However, I recognize the fact that most people do not give thought to the Scripture nowadays even as they experience severe diseases. It is for this reason that I would simply mention the Scripture instead of explaining it in great depth, unless, of course, I encounter people who truly believe that God would love to help them. The Life We’ve Always Wanted 6 As mentioned before, I seem to have lost the connection with God that I had experienced at the time I was genuinely motivated to be one with Him. I have experienced success in life since that time. Still, I miss listening to Him and knowing it is He. In the near future, therefore, I would like to spend time in silence and prayer to start listening to Him again. I would pray for Him to talk with me, with the knowledge that He is with me and would answer my prayer right away, provided that I agree to completely rid myself of the sickness of hurry.

Wednesday, August 21, 2019

The Poverty Problem Essay Example for Free

The Poverty Problem Essay In almost every part of the world, the plague that poverty is can be seen. Even in the most prosperous countries and cities, there are gray areas that reek of poverty. However, poverty is not unsolvable. Pogge (2005, p. 2) highlights one aspect of solving global poverty which involves the prosperous countries. To Pogge, the rationalization of economists that poverty is caused by local factors is what is wrong. It is wrong to think that helping poverty-stricken countries is charity and that withholding help does not make them morally irresponsible. In another aspect, poverty is not just the absence of a stable and good income; it is the absence of opportunities that would allow one to live a tolerable life. Many people live in the absence of sufficient food, shelter, education and health care. These are the basic needs of humans yet they are being deprived of this. They are also often exposed or are vulnerable to ill health, economic dislocation, natural disasters, and ill treatment by the state. There is a huge difference between the situation in rich and in poor countries. In rich countries, 1 of 100 children does not reach its fifth birthday while in poor countries one in five children die before reaching 5, often because of hunger or disease. There is also a huge different in terms of nourishment. In rich countries, less than 5 percent of children are malnourished but in poor countries, more than 50 percent are malnourished (Nwaobi, 3). One of the most poverty-stricken places on the planet may be Africa as its economic performance fall short of all other countries. Most Africans live by $0. 65 a day and this number is even growing at an exponential rate. Poverty in Africa could even become â€Å"dynastic’ such that there is no improvement in the situations. The children of the poor remain just as poor. Africa also suffers from inequality in terms of income, assets, control over public resources, access to services, and pervasive insecurity. This only aggravates the situation in Africa. Nigeria may be a rich country but the people there still suffer from poverty. Politics in Nigeria also resulted in a worsening income distribution—the rich getting richer and the poor getting poorer (Nwaobi, 3-4). Children are especially affected in times of poverty. Since children are still dependents on their parents or guardians, they can only enter or avoid poverty by the level of their family’s financial capacity and economic capabilities. Children cannot do anything about their economic condition until they become adults and are able to fend for themselves. While different governments have a variety of programs to ease children’s suffering because of poverty, it can only do so much. Even in the presence of such programs, children still suffer (Gunn Duncan, 1997, 55-56). The well-being of a child is measured in a variety of categories, namely (1) physical health, (2) cognitive ability, (3) school achievements, (4) emotional and behavioral outcomes, and (5) teenage out-of-wedlock childbearing. Children born from poverty often are underweight which makes them vulnerable to sickness if not born with a sickness. They also often suffer from stunted growth and lead poisoning. Poor children are also 1. 3 times as likely to have learning disabilities and development delays. Since these children suffer financially and cannot afford schooling, they only suffer the more. In the absence of education and experience, these children have a lesser chance of getting out of poverty as they grow old. Additionally, poor children have also been found to be more vulnerable to emotional and behavioral problems. Also, several studies have highlighted that a limited family income have led teenage girls to have non-marital childbirths (Gunn Duncan, 1997, 57-64). While the United States can be considered as one of the richest nations, it has its own share of poverty-related problems. In solving poverty in the United States, several assumptions were initially proposed. Capitalism is not the solution to poverty and even as capitalism can create jobs, there is no assurance that all these jobs will provide an income greater than the minimum wage. However, even as capitalism is not the absolute solution, the poverty problem should be solved using a capitalist approach and not with a socialist approach. Even in good economic times, the US does not have enough jobs to support its populace and there is a need for subsidies, social services and collecting adequate taxes. The government also needs to deal with people who are poor not because they cannot work but because they are lazy. Solving poverty does not demand a single solution. It needs a complex solution since there are different levels of poverty. Additionally, the government needs more taxes to help solve poverty and this means higher taxes from people far above the poverty line. It may seem unfair but it is a legitimate solution. Lastly, since solving poverty will solve other social problems, investing on poverty-alleviation is a good way to go and should always be the first problem to address (How Can We Solve, pp. 61-63). While it has been noted that poverty is present even in the most prosperous nations, it is not insurmountable, though it may require much effort to combat. Poverty is the source of all social problems so solving poverty should always be the first step that the government should take. Poverty has a lot of negative implications especially with children since they still do not have an economic liability. No one step can solve poverty since this is a complex problem, what should be done is create a number of assumptions depending on the depth of the poverty problem and come up with solutions based on these assumptions. ? References Pogge, T. (2005). World Poverty and Human Rights. Ethics and International Affairs 19 (1). Nwaobi, G. Solving the Poverty Crisis in Nigeria: An Applied General Equilibrium Approach. Quantitative Economic Research Bureau. Department of Economics: University of Abuja. Gunn, J. Duncan G. (2007). The Effects of Poverty on Children. Children and Poverty, 7 (2). How Can We Solve The Problem of Poverty. Available from: Pine Forge http://www. pineforge. com/upm-data/13691_Chapter4. pdf

Tuesday, August 20, 2019

Characteristics and Properties of Titanium dioxide

Characteristics and Properties of Titanium dioxide MANOJNA EDARA TITANIUM DIOXIDE   Ã‚   History: Titanium dioxide Characterization: Bright unmistakable ideology and the scope of titanium dioxide nanoparticles are as follows. The UV-Visible maintenance scope of titanium dioxide nanoparticles was sifted in the region of 200 and 700nm. The ingestion of this is most extraordinary occurs at 340nm and this is the thing that it exhibits a band opening estimation of 3.6 eV.DRS ultra violet-Visible spectrum. The DRS-UV-Visible supernatural examination of titanium dioxide nanoparticles was done in the region of in the middle of 200 and 700nm.The plot of absorbance verses wave length is can be watched. The range portrays increase in absorbance just underneath 400nm and the reason is of band hole excitation. By taking 350nm as the onset of absorbance the band gap regard was figured to be 3.5eV. The band gap regard is dependable with that of Ultra Violet Visible ingestion scope of titanium dioxide nanoparticles. Sharp absorbance lines underneath 250nm are the reason due to this titanium dioxide nanoparticles and of size gener ously very littler than those fascinating around 350nm. This is the image of amorphous titanium dioxide. Structure and synthesis: For a physical approach, the metallic nanoparticles can be generally fused by evaporation condensation, which could be finished by using a tube warmer at barometrical weight. In any case, by virtue of using a tube warmer at air weight there are a couple burdens, for instance, a gigantic space of tube radiator, unfathomable use imperativeness for raising the regular temperature around the source material and an impressive measure of time for fulfilling warm robustness. In this way, unique techniques for mix of Ag nanoparticles in perspective of the physical approach have been delivered and in the combination of titanium dioxide nanoparticles, Titanium tetra isopropoxide   was utilized as an antecedent and was blended with hcl, ethanol and deionized water mixture, stirred for 60 minutes, which   pH scope of 1.5.Amount of around 10ml of deionized water was added to the above blend and it was mixed for almost 2 hours at room temperature and at last the arrangement was dried at temper ature and the powder was warmed at 120 degree for 60 minutes and the crystalline character of titanium dioxide was checked by electron diffraction. The electron diffraction configuration exhibits that the cases are made out of an a crystalline shape. Because of the example tio2: Ag diffuse rings in diffraction illustration are evident The diffraction case of the crystalline example tio2:Ag0 certifies its anatase outline .Results procured by electron diffraction relate with the Xray diffraction comes to fruition and the x beam diffraction of the shapeless and crystalline titanium dioxide doped with silver (tio2:Ag0 and TiO2a:Ag0) a. All appearance in the diffraction cases of titanium dioxide were recognized as they are having a place with anatase and in the case of the vague titanium dioxide, no reflections are viewed. In any case, practically identical as in, there are no obvious apexes exhibiting the closeness of silver in the xray diffraction of the silver doped titania tests. It probably comes to fruition due to minimal size of silver nanoparticles which are under 5nm and its low substance which is underneath 2 percent and conversely with Chao et al. titanium dioxide powder calcined starting at now at 400 °C is especially cemented. The mass touchy X-beam diffraction examples were made to brought with Philips XPer diffractometer at a room temperature utilizing monochromatic excitation and the estimations were taken under pillar increasing speed conditions and even though the surface delicate X-beam photoelectron spectroscopy estimations were performed under ultra-high vacuum condition and in a frame work that shows a base weight. Keeping in mind the final result to concentrate the synthetic condition of titanium and oxygen in the nanoparticles we utilized a standard non-monochromatized X-beam source and a VG Clam 4 electron spectrometer. The spectra were redressed for X-beam satellites and optional electron foundation preceding examination. Filtering elect ron microscopy pictures of similar examples were recorded with a LED magnifying lens utilizing an electron bar vitality of 15 keV and a shaft current of 2.62 A. This is the x- ray diffraction pattern of titanium dioxide nanoparticles. Properties: The physicochemical properties of nanoparticles decide both their destiny in the earth and their valuable and destructive impacts. Despite the fact that the span of the nanoparticles can be the most recognizing property when contrasted with ordinary particles, other special physical and compound properties start to rise as particles approach the nanoscale extend. Therefore, Auffan propose that under a basic size, it is unrealistic to just scale the properties of mass materials in view of the surface range to anticipate the properties of nanoparticles. Different researchers concur that albeit some material properties, similar to substance creation and gem structure, are the same on the nanoscale as in the mass stage, different properties vary †¦ a nanoparticle holds properties of both materials in the mass stage and sub-atomic forerunners. Undoubtedly a few reviews bolster these affirmations and in any case, different analysts have found that inspite of the way that the physicoch emical properties contrast, the impacts of nano silver can be like those delivered by traditional ionic silver. These varying discoveries drove the Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel to infer that comparison of physicochemical properties of the nano mass materials are required. Exactly which physiochemical properties of designed nanoparticles, including nano Ag, can be helpful for foreseeing their conduct and collaborations in nature is indistinct. A few associations and autonomous scientists have distributed proposals on the physicochemical portrayal information that ought to go with research discoveries on transport, change, and destiny forms and biological and human poisonous quality. These suggestions depend on a combination of distributed, companion surveyed ponders on the conduct and impacts of nanoparticles, however the prescribed properties fluctuate by association and scientist. A portion of the suggestions with respect to portraya l some time recently, amid, and after danger studies are further depicted in Section 6.1.1. All in all, the most endorsed physicochemical properties include:   Ã‚   †¢ Size, including bunching inclinations. †¢ Morphology, including shape and precious stone structure. †¢ Surface range; †¢ Chemical piece; †¢ Surface science and reactivity; †¢ Solubility; and †¢ Conductive, attractive, and optical properties. Advantages: The ability to rot a broad assortment of possible characteristic toxic substances and NOx gasses consolidated with an especially adaptable era handle that engages the control over titanium dioxide nanoparticle pearl structure, atom size and crystallinity which gives   the variable courses of action as tailorà ¢Ã¢â€š ¬Ã‚ made materials for a given issue or application our customers may experience thus far our titanium dioxide photograph impetuses have been adequately striven for the going with applications: these are for various improvement materials like strong, strong tiles, stoneware tiles, housetop tiles, as an additional substance or as a thin layer. The last improvement materials show a high photocatalytic affect, which enables normal toxin departure and NOx gas removal for various responses for the remediation of polluted air made by warm power stations and significant movement for remediation of mechanical waste water defiled by specific common fragments seeks hydrophilic and photo catalytically dynamic thin layers on various substrates like glass easy-to-clean surfaces. Titanium dioxide in arrangement or suspension can be utilized to sever protein that contains the amino corrosive proline at the site where proline is available. Because of the critical ionic and electronic conduction of Titanium dioxide, it is intense to be utilized as the blended conductor. Disadvantages: This can experience a substance response in sunlight and research uncovered that titanium dioxide got from rutile which is a reddish brown colored mineral which had titanium dioxide and was less hurtful than titanium dioxide got from anatase which is used as pigments in paints, the same as covered titanium dioxide. Titanium dioxide is to a great degree viable in reflecting light, making it a breathtaking white color. This is normally extremely helpful on the off chance that you need to make a splendid white toothpaste. Having reflecting properties its great light make it viable as a sun filter. The blend of daylight, water and titanium in nano-frame makes hydroxyl radicals and these assault the covering of the rooftop. This outcomes in quickly maturing rooftops which ought to keep going for a considerable length of time. Uses: The capacity to break down an extensive variety of conceivable natural poisons and NOx gasses combined with an exceedingly adaptable creation which   prepares that empowers the control over Titanium dioxide nanoparticle precious stone structure, molecule size and crystallinity that gives the variable arrangements as tailorà ¢Ã¢â€š ¬Ã‚ made materials for a given issue or application our clients may experience. Titanium dioxide photo catalysts have been effectively tried for the accompanying applications: For different development materials such as solid tiles, earthenware tiles, rooftop tiles in the type of an added substance or as a thin layer. The last development materials display like a high photocatalytic impact, which empowers natural poison expulsion and NOx gas evacuation for different answers for the remediation of dirtied air created by warm power stations and   unexpected overwhelming movement . for treatment of modern waste water which was   contaminated by particular natural segments for hydrophilic and photo catalytically dynamic thin layers on different substrates which were easy to clean like glass. This figure(a) shows the photo catalysts for air remediation by adding titanium dioxide nanoparticles in roof or concrete tiles. Environmental impacts: It was affirmed that the assessed titanium dioxide nanoparticles, utilized at a focus up to 25% as an UV channel in sunscreens, can be viewed as safe for people after application on a solid, in place or sunburnt skin. Marking of the restorative items may not demonstrate this focus on the bundle, but the security appraisal depends on the current logical information, which demonstrates that neither titanium dioxide in Nano frame nor in non-nano shape enters through the skin. While titanium dioxide itself is a valuable, non-poisonous compound, titanium waste is to a great degree acidic and its transfer techniques which lead to a lot of various ecological issues. For example in a case, Most beach front generation plants utilizing the sulfate procedure dump a lot of sulfuric corrosive into the North Sea. Although the soluble ocean water cushions and kills the weaken acidic waste, dumping sulfuric corrosive causes a sudden drop in the pH estimation of the getting water and decreases the ox ygen substance of the water, consequently this process leads in destroying of marine life. References: Ireland, J.C. et. al. Inactivation of Escheria coli  by Titanium Dioxide Photocatalytic Oxidation. Applied and Environmental Microbiology. Ireland, J.C†¦ et. al. Inactivation of Escheria coli by Titanium Dioxide Photocatalytic Oxidation. . Li SQ, Zhu RR, Zhu H..,, Xue M, Sun XY, et al†¦. Nanotoxicity of TiO2 nanoparticles to erythrocyte in vitro. Food Chem Toxicol. 2008;46:3626-3631. Buzea C,†¦. Pacheco II, Robbie K. Nanomaterials and nanoparticles: sources and toxicity. Biointerphases. 2007;2:17-71 Zhao J, Bowman L, Zhang X, Vallyathan V, Young SH, et al†¦.. Titanium dioxide (TiO2). J Toxicol Environ Health A. Panigrahi S, Basak D. Core-she,,.,ll [emailprotected] ZnO nanorods for efficient ultraviolet photodetection. Nanoscale Yoo K-C, Yoon C-H, Kwon D, Hyun K-H, Woo,.,., SJ, et al. Titanium dioxide. Liao D, Badour C, Liao B.,.,. Preparation of nanosized TiO2/ZnO composite catalyst and J photochem photobiol A Chem www.nanopartikel.info/en/nanoinfo/materials/titanium-dioxide/overview copublications.greenfacts.org/en/titanium-dioxide-nanoparticles/ Zhao.. C, Deng H, Li Y, Liu Z. Photodegradation of oxytetracycline in aqueous by 5A and 13X loaded with TiO2 under UV irradiation. ..,J Hazard Mater. Moon J, Yun CY, ..Chung K-W, Kang M-S, Yi J. Photocatalytic activation of TiO2 under visible light using Acid Red 44†¦ Catalysis Today. Zhang J, Wages M, Cox SB, Maul JD, Li Y, et al. Effect of titanium dioxide nanomaterials.

Disaster Management Essay -- Business Management Studies

Disaster Management Introduction All disaster managers must make decisions. Their decision involves a comparison between several alternatives and an evaluation of the outcome. The quality of the decisions managers make is the true measure of their performance. Each operational decision influences future actions, which in turn, require further decisions. Errors in decision-making, therefore, tend to be cumulative. Decision-making is the major responsibility of a disaster manager, regardless of his or her functional area or level in the organization. Some of these decisions may have a strong impact on the organization, while others will be important, but less crucial. The important point, however, is that all decisions will have some sort of effect. Variables in Decision-making In some cases, decisions are made where there are few alternatives and all the parameters of the decision can be clearly identified. However, many decisions require that a choice be made between different courses of action that may be affected by variables or events beyond a manager's control. For example, the field director of a refugee relief operation knows that the accuracy of new arrival forecasts will depend in large measure, upon political events in another country. Similarly, a supply officer of a relief agency is faced with the problem of how much and what types of supplies should be ordered in the immediate aftermath of an earthquake, without knowing the full extent of the disaster. Decision-making is carried out under three different conditions or sets of variables: 1) certainty; 2) risk; and 3) uncertainty. 1) Decision-making Under Conditions of Certainty à ¦ When a manager knows or is certain of all the effec... ...e. Clarify the problem and try to eliminate irrelevant or unnecessary issues. Step 2. Gather and organize all the information about the problem. Put all the information in a logical form and sequence. Step 3. Extract the relevant information. Step 4. Evaluate the information. Assess the quality and accuracy of the information and estimate the unknowns and variables that may influence the outcome of the decision. Step 5. Identify alternatives. Determine the alternatives and identify as many of the pros and cons and the possible outcomes of each. Step 6. Make the decision. Pick the best (most positive) alternative. Once a decision has been made, it should be adhered to. Hesitation or wavering fosters uncertainty and lack of confidence in the decision-maker, and can reduce the effectiveness of the decision.

Monday, August 19, 2019

The Smoke Signals Forgiveness Essay -- Sherman Alexie Films Movies Med

The Smoke Signals Forgiveness Smoke Signals, written by Sherman Alexie and directed by Chris Eyre, begins on July 4, 1976 on the Coeur d’ Alene Reservation. Arnold Joseph (Gary Farmer), drunk while celebrating the "independence", lit off a firework and set the Builds-the-Fire residence on fire, killing the parents of Thomas Builds-the Fire. Many people were already asleep in the house when the fire started, so no one saw Arnold’s mistake, which he kept a secret from the whole reservation. Both Thomas Builds-the-Fire (Evan Adams) and Victor Joseph (Adam Beach), Arnold’s son, were saved from the burning house. Arnold ran to catch Thomas in his arms after Thomas was thrown from a window. Victor and Thomas grew up together. After the fire, Thomas was raised by his grandmother (Monique Mojica). Victor was raised by his father Arnold and his mother Arlene (Tantoo Cardinal) in a family that was falling apart. After the fire, Arnold turned to alcohol to bury the guilt of accidentally killing the Builds-the-Fire parents by burning down their house by accident. Arnold’s drinking was out of hand. Arnold’s alcohol ended up causing him to abuse his family. He hit both Arlene and Victor. Arlene was also a drinker, but she realized that their drinking became a problem and told Arnold to stop drinking. Refusing the order, Arnold chose to leave his wife and son and move to Phoenix, AZ. For the next ten years, no one was to hear from him ever again. Growing up, Victor and Thomas didn’t get a long so well. Thomas was often annoying and Victor just wanted to be left alone. Thomas often talked of Arnold and Victor never wanted to talk about his deserted father. The last thing that Victor wanted to do was talk about the father that bailed on... ...nts. The film moved in chronological order, so it naturally showed the different stages that Victor faced while dealing with his problems caused by his father. Seeing the sequence of events in this film could cause some of us to notice how similar situations in our lives relate to this. It is this issue of forgiveness that is the most valuable from this film. The viewer can benefit from this by being able to notice how Victor got through his problems. If the viewer has problems of his or her own that are similar to this, then maybe the viewer can apply the film’s lessons to his or her life. The issue of forgiveness is the main point, but there are other great lessons and morals such as the importance of friendship, the danger of alcoholism, handling family conflicts, etc. Not to mention, there is a lot to be learned about Native American culture from this film.

Sunday, August 18, 2019

Can Utopia be obtained in a Capitalist Society :: essays research papers

In a capitalist society can utopia really be obtained? I really don’t think so; because if utopia is defined as a place of ideal perfection especially in laws, government, and social conditions, then a place where everything is perfect for everyone is not likely. Perfection, I believe, cannot be obtained in a capitalist society because of competition. Competition can help society in many areas, such as improving technology, forcing individuals to work harder, and making more money for the overall economy. But ideal perfection can’t be realistic with competition.   Ã‚  Ã‚  Ã‚  Ã‚  Because of competition, in my opinion, perfection in laws cannot be attained. One reason I think this is true is because of the many laws that governments of a capitalist society has; such as monopoly be outlawed. Laws are not ideal perfect because they are some people who would want to generate more money and can’t because of some law that would prevent them to do so. There might also be some ethical issues between businesses that might lead to imperfection. There might be some common law within businesses that might be unfair for other business that makes society imperfect. Ideal perfection means that all people in the society are not only happy with their economic status but also have no need to improve on that, and when we have competition playing a major part in our society, there is no chance of improvement not happening.   Ã‚  Ã‚  Ã‚  Ã‚  Government perfection is really hard to attained because it is rare when everyone agrees on something that the government provides. Government has to maintain not only a good economic system, but also a stable society. In an ideally perfect government there cannot be any differentiation in taxes, nor can there be such a great difference between upper class and lower class. In a capitalistic society there is differentiation in taxes and a wide gap between upper and lower class incomes. A good, successful government in my opinion cannot be ideally perfect. I would think that that could only happen if the government controls the people, like a communist country, but then that in the society’s point of view isn’t perfect either.   Ã‚  Ã‚  Ã‚  Ã‚  Can social conditions really be perfect, ideally perfect, for everyone? This is I believe the strongest argument against attaining utopia. What is perfect social conditions, is it everyone having a job, family, and values. Is it following the economic system and trying to reach for the ultimate goal in a capitalist society, which is the bottom line.

Saturday, August 17, 2019

The Mass Media Should Be Highly Responsible

ELTU 1001 Presentation Outline Name: Chan Yu Yan,Fiona SID: 1155032656 I. Topic The mass media should be highly responsible to the problem of childhood obesity in Hong Kong II. Introduction ?Opener – Ask question; ‘what’s childhood obesity in your mindset? ’ ? Background –To provide statistics about the % of population of having childhood obesity in Hong Kong (To show the seriousness of the problem) ? Purpose/Objective – To persuade the government and the public to agree that the mass media is the key determinant that leads to childhood obesity through the means of television especially. Stance – The mass media is the most influential stakeholder in affecting the severity of the problem when compared to family’s influence and primary education in Hong Kong. ?Preview – To compare the effectiveness of the mass media and the primary schools in solving the problem. III. Body 1. The coverage of the receiver ?The public v. s. pr imary students -Advertisements are published through the mass media, such as television and radio, the recipients of the advestisements are the general public; ? Parents are informed ? teach their children about the correct value -Primary school policies (e. g.PE lessons) only influence the primary students, who may not be able to understand the purpose of these policies? not seriously followed 2. Academic studies showing the influences of the mass media on affecting the lifestyle of the obese children. ? A number of studies have confirmed that obesity is directly related to the number of hours spent watching television (Dietz and Gortmaker, 1985, 1993; Gortmaker et al. 1990). ?Attractive commercials advertising food and drink(Bar-Or et al. , 1998; James, 2002) that promote foods that are not recommended for the optimal development of health and fitness of children(Parizkova and Hills, A.P. , 2005) ? IV. Conclusion – Summary / Concluding statement The mass media is one of the most important channel in affecting the childhood obesity problem in Hong Kong. V. References – Books, Websites, etc. 1. Parizkova & Hills, A. P. (2005). Childhood Obesity: Prevention and Treatment. Florida: CRC Press. 2. Non-communicable Diseases Aware,3(9). (2006). Retrieved November 10, 2012 from Centre for Health Promotion, Department of Health Web site: http://www. chp. gov. hk/files/pdf/grp-NCDAware-en-20060915. pdf 3. Bagchi, D. (2011).Global perspectives on childhood obesity : current status, consequences and prevention. Boston: Academic Press/Elsevier. 4. Hui, S. C. (2007). CUHK Sports Science and Physical Education Department Releases Survey Results on Childhood Obesity in Hong Kong. Retrieved November 10, 2012 from The Chinese University of Hong Kong, The Sports Science and Physical Education Department Web site: http://www. cuhk. edu. hk/cpr/pressrelease/070525e. htm 5. Kulkarni, A. (2010). Mass Media Influence. Retrieved November 22, 2012 from http://www. buzzle . com/articles/mass-media-influence. html

Friday, August 16, 2019

Scorch Trials: Unreality

The book had unreality to It because It Is set In what I believe to be a futuristic post-apocalyptic time. It talks about how society got hit by solar flares and are Infected by this disease by the scorch which makes you Into a crazed lunatic who has lost all sense of humanity and wishes to be dead so that pain would stop yet some driving forces makes it attack and kill any living it can possible get a hold of. Also there is a group called the Gladder which is a group of guys and one girl namedTheresa Agnes who can telepathically communicate to one of the boys named Thomas. They also have to fight these one creatures that have these bulb things all over their bodies and have blades for hands which is completely unreal and they Just gruesomely attack the Gladder Just slaughtering some of them. Finally one thing that is totally unrealistic is when they are traveling through this tunnel they come upon these metal spheres. That are extremely hot and they will drop on your head encasing I tself around your head melting away your entire head in Just minutes, butIf you somehow manage to get the meal sphere off your head your head Is badly burned to where It Is barely recognizable. â€Å"Real-World† This book has many real-world ideas integrated into it. For instance this whole â€Å"trial† is overseen by this group called â€Å"WICKED†. It is basically the post-apocalyptic government which consists of all the remaining governments unite into a single totalitarianism one could say where they control absolutely every aspect of the remaining society and especially over the Gladder.This government is much more technologically advanced than ours by far. The city in the book makes me think back to barbaric times and how each â€Å"city† has a Ajar or â€Å"ruler†. Because the city well the section of the city Is controlled by a Hispanic name Jorge. He is at the top of the hierarchy he Is the king, the strongest among that section of â€Å" half-crazies† (not fully taken by the scorch still half human). Jorge commands the half cranes keeping them safe and Glenn the Jobs to do Just basically keeping them organized In a chills manor.WICKED has an army of soldiers that help out the Gladder (well Thomas) from time to time interfering just to the trial afloat by giving Thomas aid when he almost dies and he bring him to Wicker's doctors to fix up Thomas then they placed him back into the city and left again. The second time they help the Gladder is when they fight the bulb creatures near the end when they finish that part of the trial they take them away from the creatures before the creatures could kill off the rest of the Gladder.The final and most important is that in harsh and trouble times people will unite to survive against the terrible odds. People have an Ingrained desire to survive Its instinct really It may be deeply buried In us but somewhere It lays in us all. In the book these boys don't know each other b ut they unite to survive. They create their own family a band of brothers who rely on one another to survive. â€Å"Genre Fiction† I can honestly say this genre is my favorite for multiple reasons. One it is so with all the relatable topics

Thursday, August 15, 2019

Adam Smith and Karl Marx Essay

Adam Smith and Karl Marx Modern political economic theory and philosophy can be greatly attributed to the works of two men who seemingly held polar opposite views on the subject. Adam Smith, a Scottish philosopher, published his most well known work An Inquiry into the Nature and Causes of the Wealth of Nations in 1776 and is most often associated with the ideas and principles of the political economic system known as Capitalism. At the other end of the spectrum is Karl Marx; the German philosopher most often associated with Communism and the author (or co-author) of The Communist Manifesto. This paper seeks to discuss the core differences in their respective political economic philosophies with regards to what economic value is and what the role of government should be in their versions of political economy. This will conclude with the argument that while Smith's work had laid the foundation for modern economic philosophy, it was Marx who would ultimately leave the most significant impression upon the world with his revolutionary ideas. An Inquiry into the Nature and Causes of the Wealth of Nations (commonly abbreviated as The Wealth of Nations) is considered to be the first full treatment on the study of Economics. This work essentially lays the foundation for the economic system known as Capitalism. Interestingly enough, Capitalism was a term first brought into the public debate, somewhat pejoratively, by Karl Marx himself in describing a â€Å"capitalist† as a private owner of capital or the means or production. (â€Å"Capitalism† (Wikipedia), 2008). A consensus definition of this idea is an economic system based on private individual ownership of property in which the distribution of goods is determined freely by competing market forces and investments are made by individuals. (â€Å"Capitalism† (Merriam-Webster), 2008). In a Capitalist society, individuals are free to own property and invest their capital in the pursuit of profit with relatively limited influence or barriers from the government. The Wealth of Nations was organized into five books of several chapters each. The first two books examine the fundamentals of the market system and include explanations relating to the role of labor, the nature of capital and markets, and the motives people have for entering into the market system. The third book is mostly an historical examination of the economics in ancient societies. The fourth book is the core of Smith's argument for the capitalist society and it in these chapters that Smith lays out the core arguments for the limited role of government that is required for long term economic success. The fifth book deals primarily with government spending, revenues and taxation. The Communist Manifesto was much more a call to action than it was a treatise on economics and is a much shorter work than Smith's The Wealth of Nations. Marx also published a very thorough (and denser) economic examination known as Das Kapital in 1867. The conclusions reached in that and other works would underpin the concepts found in The Communist Manifesto. It is not inaccurate to say that Communism is in many ways the opposite of Capitalism. In The Communist Manifesto, Marx and co-author Friedrich Engels listed 10 attributes of an ideal Communist society. The first one lays out the primary condition: â€Å"Abolition of property in land and application of all rents of land to public purposes. † (Marx & Engels, 2006, p. 32) This effectively describes state-ownership and control of all capital and the means of the production made for the benefit of all in a classless society. Communism espouses the idea that the economy should function for the greater good of all society and not merely act as a tool to enrich the ‘bourgeois† or ruling classes. As the title would indicate, The Communist Manifesto lays out the purpose and reasoning for the existence of the Communist party that was developing across Europe in that time. In the prologue, Marx and Engels state the books purpose: It is high time that Communists should openly, in the face of the whole world, publish their views, their aims, their tendencies, and meet this nursery tale of the Specter of Communism with a Manifesto of the party itself. Marx & Engels, 2006, p. 2) The chief disagreement between Capitalists and Communists is who or what is entitled to ownership and the means of production. In chapter one of the second book of The Wealth of Nations, Smith defined capital as the stock (read: assets or money) that a person does not immediately consume for which the owner expects to derive a f uture profit. (Smith, 1909) This of course implies that the individual has possession and ownership of the capital item in the first place. Marx bestows a social aspect upon what capital is in The Communist Manifesto. Marx stated that capital is a â€Å"collective product? nly by the united action of all members of society, can it be set in motion. Capital is therefore not a personal, it is a social power. † (Marx & Engels, 2006, p. 23) In other words, capital belongs to all of the people that are needed to not only produce it, but to provide a reason for its value. One thing that Marx and Smith seems to have agreed upon is something economists call the Labor Theory of Value. While they would ultimately come to different conclusions on the use of the value, the basic assumption is this theory is that value is ultimate derived in an object from the labor necessary to produce it. â€Å"Labor Theory†, 2008) In chapter 5 of book I of The Wealth of Nations, Smith argues tha t â€Å"the real price of everything? is the toil and trouble of acquiring it. † (Smith, 1909, p. 36) Smith distinguishes this from the nominal value of an item that can vary based on market forces; he holds that the real value is constant in relation to the labor that it used in its production. Smith argues in the following chapter that there are three components to the price of an item: the labor needed to produce it, the â€Å"rent of the land† or resources needed to make it, and the â€Å"profit of stock† that compensates the investor for risking his resources. In Das Kapital, Marx also recognizes the labor component of any item in the first chapter. He states that any commodity has a use-value and an exchange value that is derived from the labor needed to produce it. (Marx, 2000) Marx however viewed the â€Å"profit of stock† as the ability of the capitalist to exploit the wage laborers out of the surplus value of the things they create because of their control over the means of production. The role of government in relation to the economic system is a central theme of how ultimately successful the economic system would become. One of Smith's core arguments to the success of capitalism is summarized in his most famous metaphor of the â€Å"invisible hand† found in Chapter 2 of Book IV in The Wealth of Nations: By preferring the support of domestic to that of foreign industry, he intends only his own security; and by directing that industry in such a manner as its produce may be of the greatest value, he intends only his own gain, and he is in this, as in many other cases, led by an invisible hand to promote an end which was no part of his intention. Nor is it always the worse for the society that it was no part of it. By pursuing his own interest he frequently promotes that of the society more effectually than when he really intends to promote it. (Smith, 1909, p. 351-352) Smith argued that in a fair and free market economic system, producers will act in their own self-interest to maximize their profits. As profits increased, competitors would come about seeking to obtain a share of the profits, and would thus drive down prices through this competition. The result was more efficiency and productivity that would lead to the long term benefit of all of society. He was against any government action that would serve to disrupt this natural balance such as trade restrictions, wage laws, and industry regulation. Smith essentially believed that the more the government stayed out of the way, the better off society would be as a whole. In The Communist Manifesto, Marx makes an argument for an entirely stateless society. â€Å"Political power† he states, â€Å"? is merely the organized power of one class for oppressing another. † (Marx & Engels, 2006, p. 3) A common theme of The Communist Manifesto is the struggle between different classes of society, to which Marx simplifies to a clash between the â€Å"bourgeois† and the â€Å"proletariats†. Marx argues that â€Å"The essential condition for the existence, and for the sway of the bourgeois class, is the formation and augmentation of capital; the condition for ca pital is wage-labor. † (Marx & Engels, 2006, p. 19) Marx held the belief that in a pure Communistic society, there would be no classes, and that the government would out of necessity dominate and control the means of production in the economy. The legacy and impact of Adam Smith's Wealth of Nations was felt throughout Europe shortly after its publication. In England in particular, the British prime ministers sought policies that were attributed to what they had learned in Smith's book including a new commercial treaty with France, customs reform, and a change in fiscal policy that resulted in lower debt and government spending. Government's throughout Europe also began to realize the fallacy of the artificial trade barriers erected between the different countries; so much so that they would prefer to trade with their American colonies more often than their own neighbors. West, 1990) Smith's greatest impact is perhaps the academic contribution to the study of economics. Before The Wealth of Nations, there really was nothing of the sort that so thoroughly examined the fundamentals of economics. Nearly every economist after Smith, including Karl Marx, would use The Wealth of Nations as a primary source and base their argument s off of Smith's suppositions. Marx's influence on the world however was far from an academic exercise. The violent revolution that Marx predicted would need to occur in order for the proletariats to overthrow the bourgeois did indeed occur in Russia during the â€Å"Red October† of 1917. The ruling aristocracy of Russia's Czarists came to an end at the hands of Vladimir Lenin's Bolsheviks. This would lead to the formation of the communist Soviet Union. During the revolution, the Bolsheviks seized all the private property around the country, gave control of all the factories to the government, nationalized all the banks, seized all of the Church's properties, and declared that they would not honor any foreign debts. Thus the first real attempt at Communism took the form of the Soviet Union; symbolized by the worker's sickle and hammer on the flag. â€Å"October Revolution†, 2008) The actions of the Soviet Union would go on to inspire many other Eastern countries to attempt their own versions of Communism; all consistent with the principles Marx envisioned in The Communist Manifesto. The resulting conflict of economic fundamentals between these Communist entities and the more Capitalist economies of Western Europe and the United States would spark conflict throu ghout much of the 20th century. References capitalism. (2008) In Wikipedia, The Free Encyclopedia Retrieved December 17, 2008, from http://en. wikipedia. org/wiki/Capitalism capitalism. (2008). In Merriam-Webster Online Dictionary. Retrieved December 17, 2008, from http://www. merriam-webster. com/dictionary/capitalism labor theory of value. (2008) In Wikipedia, The Free Encyclopedia Retrieved December 17, 2008 from http://en. wikipedia. org/wiki/Labor_theory Marx, K (2000) Das Kapital Gateway Edition, Washington, DC, Regnery Publishing, Inc Marx, K & Engels, F (2006) The Communist Manifesto, New York, Penguin Books October Revolution. 2008) In Wikipedia, The Free Encyclopedia Retrieved December 17, 2008, from http http://en. wikipedia. org/wiki/October_ Revolution Smith, A (1909) Harvard Classics: An Inquiry into the Nature and Causes of the Wealth of Nations, New York, P F Collier and Son West, E (1990) Adam Smith's Revolution, Past and Present. Adam Smith's Legacy: His thought in our time. Retrieved December 17, 2008 from http://www. adamsmith . org/images/uploads/publications /ADAM_SMITH_Legacy. pdf

Common law Essay

A Tort is the French word for a â€Å"wrong.† A tort is a civil wrong. A civil wrong involves a breach of a duty owed to someone else, as opposed to criminal wrongdoing which involves a breach of a duty owed to society. Torts are civil wrongs other than breaches of contract and certain equitable wrongs. The law of torts law is a remainder category of civil wrongs once other wrongs are excluded. It covers a grab bag of legal cases comprising such disparate topics as auto accidents, false imprisonment, slander and libel, product liability (such as defectively designed consumer products), and environmental pollution (toxic torts). A person who suffers legal damage may be able to use tort law to receive damages (usually monetary compensation) from someone who is responsible or liable for those injuries. Generally speaking, tort law defines what is a legal injury and what is not. A person may be held liable (responsible to pay) for another’s injury caused by them. Torts can be classified in a number of different ways, one is to distinguish according to degree of fault, so that there are intentional torts, negligent torts, and strict liability torts. In much of the Western world, the measure of tort liability is negligence. If the injured party cannot prove that the person believed to have caused the injury acted with negligence (lack of reasonable care), at the very least, tort law will not compensate (pay) the victim. However, tort law also recognizes intentional (purposeful) torts and strict liability torts, which apply when the person accused of committing the tort satisfied certain standards of intent (meaning) and/or performed certain types of conduct. In tort law, injury is defined broadly. Injury does not just mean a physical injury, such as where Brenda was struck by a ball. Injuries in tort law reflect any invasion of any number of individual interests. This includes interests recognized in other areas of law, such as property rights. Actions for nuisance (annoying or hurting) and trespass (unlawful entering) of land can arise from interfering with rights in real property. Conversion law and trespass to chattels (personal property) can protect interference with movable property. Interests in prospective (possible future) economic advantages from signed agreements can also be injured and become the subject of tort actions. A number of situations caused by parties in a contractual (written agreement) relationship may still be tort rather than contract claims, such as breach of duties. Tort law may also be used to compensate (pay) for injuries to a number of other individual interests that are not recognized in property or contract law. This includes an interest in freedom from emotional distress, privacy interests, and reputation. These are protected by a number of torts such as Intentional infliction of emotional distress, privacy torts, and defamation/slander (destruction of a reputation). Defamation and privacy torts may, for example, allow a celebrity to sue a newspaper for publishing an untrue and harmful statement about him. Other protected interests include freedom of movement, protected by the intentional tort of false imprisonment which is when you are arrested without cause. The equivalent of tort in civil law jurisdictions is delict. The law of torts can be categorised as part of the law of obligations (duties), but unlike voluntarily assumed obligations (such as those of contract, or trust), the duties imposed by the law of torts apply to all those subject to the relevant jurisdiction. To behave in tortious manner is to harm another’s rights, body, property or other rights. One who commits a tortious act is called a tortfeasor. Law of torts consists of some general defense, which can be pleaded in the court of law to get justice. Types of general defenses 1) INEVITABLE ACCIDENTS[1]: The plea of inevitable accident is usually spoken of as a defense but is, strictly speaking, not a defense but only a denial of liability. For instance, in an action for bodily harm, the plaintiff has ordinarily to prove intent or negligence of the defendant; and if he fails to do so, his injury may be said to be an inevitable accident. The burden to prove plea of inevitable accident lies on the defendant and to establish the defense, the respondent will have to establish that accident could not have been avoided by exercise of ordinary care and caution. Ex: Ryland’s v Fletcher 2) MISTAKE[2]: Mistake of law is generally no defense to civil or criminal liability. Mistake of fact is a general defense under the IPC, but not to an action in tort. For instance, an officer who executes a warrant of arrest against the wrong man by mistake is not guilty of a crime, but he will be liable in an action for false imprisonment. Mistake would be an excuse only in those exceptional cases where an unlawful intent or motive is an essential ingredient in liability. Ex: Hollins v Fowler 3) EXERCISE OF COMMON RIGHTS[3]: This, like inevitable accident, is really nota defense but a denial of a breach of duty or violation of rights, as where the defendant builds on his land and shuts f the light of a new house of his neighbour or opens a new shop and ruins an older rival. The defense is necessary on the assumption that their is a general rule of liability for intentional harm. 4) VOLENTI NON FIT INJURIA[4]: It is also known as the defense of consent. Volenti non fit injuria[5] It is a Latin word which means â€Å"to a willing person, no injury is done† or â€Å"no injury is done to a person who consents†) is a common law doctrine which means that if someone willingly places themselves in a position where harm might result, knowing that some degree of harm might result, they cannot then sue if harm actually results. Volenti only applies to the risk which a reasonable person would consider them as having assumed by their actions; thus a boxer consents to being hit, and to the injuries that might be expected from being hit, but does not consent to (for example) his opponent striking him with an iron bar, or punching him outside the usual terms of boxing. Volenti is also known as a â€Å"voluntary assumption of risk.† In Law of Torts, Volenti non-fit injuria is an exception to liability in torts. It means: Where the sufferer is willing and has the knowledge , no injury is done. the precept that denotes that a person who knows and comprehends the peril and voluntarily exposes himself or herself to it, although not negligent in doing so, is regarded as engaging in an assumption of the risk and is precluded from a recovery for an injury ensuing there from. Volenti non fit iniuria (or injuria) (Latin: â€Å"to a willing person, injury is not done†) is a common law doctrine which states that if someone willingly places with proper knowledge themselves in a position where harm might result, they are not able to bring a claim against any damages from the other party in tort. Volenti only applies to the risk which a reasonable person would consider them as having assumed by their actions; thus a boxer consents to being hit, and to the injuries that might be expected from being hit, but does not consent to (for example) his opponent striking him with an iron bar, or punching him outside the usual terms of boxing. Or a person watching a cricket match getting hurt by the ball can be consented. No act is actionable as a tort at the suit of a person who has expressly or impliedly assented to it. In order to plead this defence, it is necessary that the plaintiff should have consented to physical risk or damage as well as to legal risk (i.e. he will get no remedy in law). ESSENTIAL CONDITIONS ââ€" ª Consent must be given freely ââ€" ª Consent must not have been given to an illegal act ââ€" ª Knowledge of risk is not the same thing as consent to run the risk OR 1. A voluntary 2. Agreement 3. Made in full knowledge of the nature and extent of the risk. 1.Voluntary The agreement must be voluntary and freely entered for the defence of Volenti non fit injuria to succeed. If the Claimant is not in a position to exercise free choice, the defence will not succeed. This element is most commonly seen in relation to employment relationships, rescuers and suicide. 2.Agreement The second requirement for the defence of Volenti non fit injuria is agreement. The agreement may be express or implied. An example of an express agreement would be where there exists a contractual term or notice. 3.Knowledge The Claimant must have knowledge of the full nature and extent of the risk that they ran. The test for this is subjective and not objective and in the context of an intoxicated Claimant, the question is whether the Claimant was so intoxicated that he was incapable of appreciating the nature of the risk. Volenti is sometimes described as the plaintiff â€Å"consenting to run a risk.† In this context, volenti can be distinguished from legal consent in that the latter can prevent some torts arising in the first place (for example, consent to a medical procedure prevents the procedure from being a trespass to the person, or consenting to a person visiting your land prevents them from being a trespasser). | | | | Volenti in English[6] In English tort law, volenti is a full defence, i.e. it fully exonerates the defendant who succeeds in proving it. The defence has two main elements: The claimant was fully aware of all the risks involved, including both the nature and the extent of the risk; and The claimant expressly (by his statement) or impliedly (by his actions) consented to waive all claims for damages. His knowledge of the risk is not sufficient: sciens non est. volens (â€Å"knowing is not volunteering†). His consent must be free and voluntary, i.e. not brought about by duress. If the relationship between the claimant and defendant is such that there is doubt as to whether the consent was truly voluntary, such as the relationship between workers and employers, the courts are unlikely to find volenti. It is not easy for a defendant to show both elements and therefore contributory negligence usually constitutes a better defence in many cases. Note however that contributory negligence is a partial defence , i.e. it usually leads to a reduction of payable damages rather than a full exclusion of liability. Also, the person consenting to an act may not always be negligent: a bungee jumper may take the greatest possible care not to be injured, and if he is, the defence available to the organiser of the event will be volenti, not contributory negligence. In the first case (decided before the Occupier’s Liability Act was passed), a girl who had trespassed on the railway was hit by a train. The House of Lords ruled that the fencing around the railway was adequate, and the girl had voluntarily accepted the risk by breaking through it. In the second case, a student who had broken into a closed swimming-pool and injured himself by diving into the shallow end was similarly held responsible for his own injuries. The third case involved a man who dived into a shallow lake, despite the presence of â€Å"No Swimming† signs; the signs were held to be an adequate warning. The defence of volenti is now excluded by statute where a passenger was injured as a result of agreeing to take a lift from a drunk car driver. However, in a well-known case of Morris v Murray [7][volenti was held to apply to a drunk passenger, who accepted a lift from a drunk pilot. The pilot died in the resulting crash and the passenger who was injured, sued his estate. Although he drove the pilot to the airfield (which was closed at the time) and helped him start the engine and tune the radio, he argued that he did not freely and voluntarily consent to the risk involved in flying. The Court of Appeal held that there was consent: the passenger was not so drunk as to fail to realise the risks of taking a lift from a drunk pilot, and his actions leading up to the flight demonstrated that he voluntarily accepted those risks. Rescuers For reasons of policy, the courts are reluctant to criticize the behavior of rescuers. A rescuer would not be considered volens if: He was acting to rescue persons or property endangered by the defendant’s negligence; He was acting under a compelling legal, social or moral duty; and His conduct in all circumstances was reasonable and a natural consequence of the defendant’s negligence. An example of such a case is Haynes v. Harwood[8], in which a policeman was able to recover damages after being injured restraining a bolting horse: he had a legal and moral duty to protect life and property and as such was not held to have been acting as a volunteer or giving willing consent to the action – it was his contractual obligation as an employee and police officer and moral necessity as a human being to do so, and not a wish to volunteer, which caused him to act. By contrast, in Cutler v. United Dairies [9]a man who was injured trying to restrain a horse was held to be v olens because in that case no human life was in immediate danger and he was not under any compelling duty to act. Unsuccessful attempts to rely on volenti: Examples of cases where a reliance on volenti was unsuccessful include: Nettleship v. Weston[10] Baker v T E Hopkins & Son Ltd[11]). In the first case, the plaintiff was an instructor who was injured while teaching the defendant to drive. The defence of volenti failed i.e. because the plaintiff specifically inquired if the defendant’s insurance covered him before agreeing to teach. In the second case, a doctor went in to try to rescue workmen who were caught in a well after having succumbed to noxious fumes. He did so despite being warned of the danger and told to wait until the fire brigade arrived. The doctor and the workmen all died. The court held that it would be â€Å"unseemly† to hold the doctor to have consented to the risk simply because he acted promptly and bravely in an attempt to save lives. Hall v. Brooklands Auto-Racing Club [12] The plaintiff paid to enter a motor-car race track to watch races on a track owned and managed by the defendants. On the evening the plaintiff was spectating, two of the race-cars collided near the barrier between the spectators and the track. The cars collided with the barrier and caused severe injury to the plaintiff and others. The defendants were held liable to pay damages by a jury who found that they had not taken reasonable precautions to protect spectators. On appeal by the defendant, it was held that there was no evidence to find the defendants had not taken reasonable precautions and that there was no obligation to ensure safety in all circumstances, just that reasonable precautions were taken. The defendant’s case was upheld. Wooldridge v Sumner [13] Facts The plaintiff, Mr. Wooldridge, who was a photographer at a horse race, was injured by the horse belonging to the defendant, Sumner, which was ridden in a competition by Sumner’s, who was a skilled and experienced horseman. 1 Judgment The Court of Appeal held that Sumner owed no duty of care to Wooldridge in this case. As a spectator, Wooldridge accepted the risks involved in a horserace he came to watch. As a reasonable participant in the race, which is a fast and competitive sport, the horseman was expected to concentrate on the race and not on the spectator. In the course of a fast moving competition such as this one, he could be expected to make errors of judgment. As long as the damage was not caused recklessly or deliberately, the participant in a race could not be held liable for the spectators’ injuries because he was not negligent, i.e. not in breach of his duty. Dann v. Hamilton [14] The Claimant was injured when she was a willing passenger in the car driven by the Mr. Hamilton. He had been drinking and the car was involved in a serious crash which killed him. In a claim for damages the Defendant raised the defence of volenti non fit injuria in that in accepting the lift knowing of his drunken condition she had voluntarily accepted the risk. Held: The defence was unsuccessful. The claimant was entitled to damages. Asquith J: â€Å"There may be cases in which the drunkenness of the driver at the material time is so extreme and so glaring that to accept a lift from him is like engaging in an intrinsically and obviously dangerous occupation, intermeddling with an unexploded bomb or walking on the edge of an unfenced cliff. It is not necessary to decide whether in such a case the maxim volenti non fit injuria would apply, for in the present case I find as a fact that the driver’s degree of intoxication fell short of this degree†. HAYNES v HARWOOD [15] facts The plaintiff, a police constable, was on duty inside a police station in a street in which, at the material time, were a large number of people, including children. Seeing the defendants’ runaway horses with a van attached coming down the street he rushed out and eventually stopped them, sustaining injuries in consequence, in respect of which he claimed damages. HELD 1) That on the evidence the defendants’ servant was guilty of negligence in leaving the horses unattended in a busy street. 2) that as the defendants must or ought to have contemplated that some one might attempt to stop the horses in an endeavour to prevent injury to life and limb, and as the police were under a general duty to intervene to protect life and property, the act of, and injuries to, the plaintiff were the natural and probable consequences of the defendants’ negligence. 3) That the maxim â€Å"volenti non fit injuria† did not apply to prevent the plaintiff recovering. . 1 Imperial Chemical Industries v Shatwell [16] Volenti non fit injuria, [Latin: no wrong is done to one who consents] The defense that the plaintiff consented to the injury or (more usually) to the risk of being injured. Facts The plaintiff and his brother were were certificated and experienced shotfirers employed by ICI Ltd in a quarry owned by the defendant company. Part of the brothers’ works included wiring up detonators and checking the electrical circuits. There was an old practice where a galvanometer was applied directly to each detonator for testing purposes. This practice was known to be dangerous and was outlawed by statutory regulation. The plaintiff claimed his brother was 50 per cent to blame for the explosion and the employer was vicariously liable. The plaintiff was awarded half of the total amount of damages. The defendant appealed. The Decision The plaintiff and his brother were both experts. They freely and voluntarily assumed the risk involved in using the galvanometer. There was no pressure from any other source. To the contrary, they were specifically warned about complying with the new safety regulations. The defence of volenti non-fit injuria will apply when there is true and free consent to the risk. Note (1) the employers not being themselves in breach of duty, any liability of theirs would be vicarious liability for the fault of J, and to such liability (whether for negligence or for breach of statutory duty) the principle volenti non fit injuria afforded a defence, where, as here, the facts showed that G and J knew and accepted the risk (albeit a remote risk) of testing in a way that contravened their employers’ instructions and the statutory regulations. (2) Each of them, G and J, (the brothers) emerged from their joint enterprise as author of his own injury, and neither should be regarded as having contributed a separate wrongful act injuring the other. The defence of volenti non fit injuria should be available where the employer is not himself in breach of statutory duty and is not vicariously in breach of any statutory duty through neglect of some person of superior rank to the plaintiff and whose commands the plaintiff is bound to obey, or who has some special and different duty of care. Nettleship v Weston [17] is an English Court of Appeal judgment dealing with the breach of duty in negligence claims. In this case the court had considered the question of the standard of care that should be applied to a learner driver, and whether it should be the same as is expected of an experienced driver. | | Facts Mr. Nettleship, the plaintiff, agreed to teach Mrs. Weston, the defendant, to drive in her husband’s car, after he had inquired the insurance policy. During one of the lessons, the defendant lost control of the car and caused an accident in which the plaintiff was injured. The defendant argued that the plaintiff was well aware of her lack of skill and that the court should make allowance for her since she could not be expected to drive like an experienced motorist. 3 Judgment The Court of Appeal, consisting of Lord Denning MR, Salmon LJ and Megaw LJ held that applying a lower standard to the learner driver because the instructor was aware of his inexperience would result in complicated shifting standards. It would imply, for example, that an inexperienced doctor owed his patient a lower standard of care if the patient was aware of his lack of experience. The standard of care for a learner driver would be the usual standard applied to drivers: that of an experienced and skilled driver. The policy consideration that played a role in this decision was that the learner driver was covered by insurance. Over the dissent of Megaw LJ, the Court of Appeal held that the instructor was also responsible for the accident as he was partially in control of the car and should only be able to recover half of his damages due to negligence. Able to recover half of his damages due to contributory negligence. Baker v T E Hopkins & Son Ltd[18] 1 Facts Two employees of the defendant company were overcome by carbon monoxide fumes in a well they were attempting to decontaminate. The plaintiff, a doctor, went in to try to rescue them even though he was warned of the fumes and told that the fire brigade was on the way. All the three men died. 2 Judgment The defendant company argued that the (the estate of) the plaintiff doctor should either not be compensated because the doctor knowingly accepted the risk he was taking or his damages would be reduced for contributory negligence. The Court of Appeal considered that such a suggestion was â€Å"ungracious† and that it was unseemly and irrational to say that a rescuer freely takes on the risks inherent in a rescue attempt. The doctor’s contributory negligence could only be recognized if he showed â€Å"a wholly unreasonable disregard for his own safety†. 3 Significance This case is one of the many in which the courts have refused to hold rescuers who have suffered in their rescue attempts to have negligently contributed to their injuries or accepted the risks involved in their rescue attempt. This applies to both amateur and professional rescuers, such as fire fighters (See Ogwo v. Tailor [19]) INDIAN CASES United India Insurance Co. Ltd. vs Guguloth Khana And Ors.[20] Facts:– On 23-5-1991 a lorry bearing No. AP 26-T-364 belonging to M/s. Amruthesh Transport Company started at Warangal with some load of groundnut oil cake to go to Anakapalle in Visakhapatnam. One Ch. Mallikarjun was engaged as driver of the said lorry. There was a comprehensive insurance policy for the lorry with the United India Insurance Company. When the lorry reached near Thorrur village on the way leading to Khammamm P.W.D. Road, several villagers were waiting on the road, due to lack of transport facility because of the assassination of Sri Rajiv Gandhi on the previous day (22-5-1991). Then, about 25 persons, including some children and women boarded the lorry. The lorry, after travelling about five kilometers from Thorrur village and reached near Mattedu village, the driver of the lorry applied sudden brakes whereby the lorry turned turtle, as a result of which twelve persons died on the spot and three more persons also died after they were taken to hospital. Ten persons sustained injuries. The claimants, either the injured or the legal heirs of the persons who died in the accident, have filed the O.Ps against the owner, driver and insurer of the lorry. Before the Motor Accidents Claims Tribunal, the driver of the lorry who was served with notices in the O.Ps remained ex parte. Before the Tribunal, owner of the lorry filed counter, denying the averments in the O.Ps, contending that the driver of the lorry was not responsible for the accident. It was contended that at the time of the accident, another lorry was coming in the opposite direction at high speed in a rash and negligent manner, and to avert accident, the driver of the lorry applied sudden brakes by taking the lorry to the extreme left side of the road. Due to bad condition of the road, the lorry turned turtle resulting in fatal road accident. He also contended that he has given strict instructions to the lorry drivers not to carry passengers on their lorries. Before the Tribunal, the present appellant-Insurance Company also filed counters admitting that the lorry involved in the accident was insured with it as a goods vehicle, in which passengers are not allowed to travel. It was contended that as per the conditions of insurance policy only six persons are authorized to travel in the lorry and that the persons who travelled in the lorry were unauthorized passengers. It was contended that even if for any reason it is considered that the deceased and injured are non-fare paying passengers, the liability of the Insurance Company is limited to Rs. 15,000/- in case of death and lesser amount for injuries. The Insurance Company disputed the quantum of compensation claimed in the O.Ps. by the respective claimants. Issues raised †¢ Whether the accident took place due to rash and/or negligent driving by respondent No. 1? †¢ To what compensation if any, the petitioners are entitled to and if so, against which of the respondents? †¢ To what relief ? Subsequently, the issues were recast as under: âž ¢ Whether the accident took place due to rash and/or negligent driving of the lorry by its driver Ch. Mallikarjun? âž ¢ Whether there were specific instructions issued to the drivers of the Transport Company that they should not carry passengers enroute and if so, on that ground that owner of the crime vehicle is not liable to pay the compensation in the claim petitions? âž ¢ Whether the third respondent Insurance Company is not liable to cover the risk of the deceased and injured involved in the accident under the terms of the Insurance policy, the copy of which is marked as Ex.B-1 along with the terms and conditions of the policy including Indian Motor Tariff marked as Ex. B-2? âž ¢ Whether the petitioners are entitled for compensation, if so, to what amount and from whom? âž ¢ To what relief? . Decision (a) On consideration of the oral and documentary evidence on record, the Tribunal held that the accident has taken place due to rash and negligent driving of the lorry by its driver. The Tribunal negatived the contention of the owner of the lorry that he is not liable to pay compensation. Basing on these two findings and the medical and documentary evidence available on record, different amounts of compensations were granted to the different claimants in the respective O.Ps, who are arrayed as respondents in the appeals. (b) Aggrieved by the same, the present appeals are filed by the Insurance Company. (c) The first contention advanced by the Counsel for the appellant-Insurance Company is that the injured/deceased who travelled in the lorry are unauthorized passengers in a goods vehicle and the insurance policy issued is for the goods vehicle and there is no reason to fasten the liability on the Insurance Company; it is a violation of policy conditions and there is no need to fix the liability against the present appellant-Insurance Company. (d) The second contention advanced by the Counsel for the appellant-Insurance Company is that the owner of the lorry got examined R.W. 1, Manager in the Transport Company, who stated that he was informed by the driver of the lorry that the injured/ deceased unauthorisedly entered the lorry, and the maxim/doctrine â€Å"volenti non fit injuria† applied to this case as they voluntarily entered into the lorry at their own risk and there is no reason to fasten liability on the Insurance Company. (e) In these cases, so far as the first contention of the Counsel for appellant that the claimants/respondents are travelling as a gratuitous passengers in a goods vehicle and not entitled for compensation and the Insurance Company is not liable to pay any such compensation, is concerned, it is contrary to the principle laid down by the Supreme Court in New India Assurance Company v. Shri Satpal Singh and Ors[21]. . In that case, the Supreme Court considering clause (ii) of proviso to Sub-section (1) of Section 95 of the Motor Vehicles Act, 1939 (Old Act) and Section 147 of the Motor Vehicles Act, 1988 (new Act), and noticing the absence of a similar clause in the new Act, held†Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦under the new Act an insurance policy covering third party risk is not required to exclude gratuitous passengers in a vehicle, no matter that the vehicle is of any type or class†. In view of the above ruling of the Supreme Court, there is no merit in the first contention of the appellant, that the injured/legal heirs of the deceased in these cases are not entitled to any compensation on the ground that they are gratuitous passengers, is without substance and the same is hereby rejected. . [i](f) Learned Counsel for the appellant-Insurance Company relied on the decision in V. Gangamma v. New India Assurance Co. wherein a learned Single Judge of this Court held that the Insurance Company is not liable to pay compensation to the dependants of the deceased persons who are travelling in the vehicle at the time of accident as trespassers and not as passengers. The facts of that case are entirely different from that of the facts in these appeals. In the case cited, the claimants were treated as passengers on the basis of evidence of R. W. 1 (the driver of the lorry therein), who categorically stated that the claimants-therein have forcibly entered into the lorry asking him to take them to particular place and threatened to beat him if he does not do so. In the present cases, there is no evidence to show that the claimants/deceased entered into the lorry forcibly with any threat to the driver of the lorry. So, the decision in Gangamma’s case (3 supra) is not applicable to the case on hand. The appeals was dismissed. BIBLIOGRAPHY †¢ Rmaswamy Ayers LAW OF TORTS 10th edn.(by A Lakshminath &M Ssridhar) †¢ Winfield and jodowiez, TORT WVH Jogers,7th edn. †¢ 1990] 3 All ER 801 ( Court of Appeal), †¢ [1935] 1 KB †¢ [1933] 2 KB 297 †¢ [1971] 3 All ER 581 (Court of Appeal †¢ [1959] 3 All ER 225 (Court of Appeal †¢ (1933) 1 KB 205 †¢ [1963] 2 QB 23 †¢ 1959] 3 All ER 225 (Court of Appeal †¢ [1988] AC 431). †¢ II (2001) ACC 392, 2001 (2) ALT 185 [1999] RD-SC 411 ———————– [1] Rmaswamy ayers LAW OF TORTS 10th edn.p.939(by A Lakshminath &M Ssridhar) [2] Rmaswamy ayers LAW OF TORTS 10th edn.p.940(by A Lakshminath &M Ssridhar) [3] Rmaswamy ayers LAW OF TORTS 10th edn.p.940(by A Lakshminath &M Ssridhar) [4] Rmaswamy ayers LAW OF TORTS 10th edn.p.940(by A Lakshminath &M Ssridhar) [5] Winfield and jodowiez,TORT WVH Jogers,7th edn.P.1057 [6] Winfield and jodowiez,TORT WVH Jogers,7th edn.P.1058 [7]1990] 3 All ER 801 ( Court of Appeal), [8] [1935] 1 KB 146 [9] [1933] 2 KB 297 [10] [1971] 3 All ER 581 (Court of Appeal [11] [1959] 3 All ER 225 (Court of Appeal [12] (1933) 1 KB 205 [13] [1963] 2 QB 23 [14] [1939] 1 KB 50 [15] [1935] 1 KB 146 [16] [1964] All ER 999 [17] [1971] 2 QB 691 [18] 1959] 3 All ER 225 (Court of Appeal [19] [1988] AC 431). [20] II (2001) ACC 392, 2001 (2) ALT 185 5 [21] [1999] RD-SC 411 ———————– ———————– |LAW OF TORTS |August 29 | | |2013 | |THIS RESEARCH PAPER BRINGS OUT THE APPLICATION OF VOLENTI NON FIT INJURIA, AS A | VOLENTI NON FIT INJURIA &CASES | |DEFENCE IN TORT LAW. | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |