Tuesday, August 25, 2020

Healthy Lifestyle

Solid Lifestyle ideally we would all beâ eating the privilege food,â exercising, resting wellâ and just for the most part getting a charge out of life. In reality a large portion of us deal with a level of theâ healthy lifestyleâ and wade through decently well with its remainder. Some portion of the issue is we are urged to think, for the most part by the media, that we ought to do everything conceivable towards a sound way of life, constantly. For a large portion of us this is simply unrealistic. Consistent worry about what we ought to or shouldn't do causes our feelings of anxiety to go up and that nullifies any great work that we've done. Truly, we ought to absolutely go after a solid way of life, yet the two watchwords are â€Å"moderation† and â€Å"balance†. By applying these measures to accomplishing a sound way of life we won't beat ourselves in the mood for bombing another eating routine or dropping out of the most recent exercise system. A typical slip-up that numerous individuals make when they choose to embrace a sound way of life is to attempt to do a lot of too early. They at that point give themselves a blame complex when everything self-destructs. It is likewise simple to be impacted by others, when we should just receive a sound way of life intend to suit ourselves. Ok! Did I say way of life plan? Do you have one, or do you simply attempt the following thing that is in your magazine or Sunday supplement? By all methods read these articles and consider as youâ plan how you need your sound way of life to come to fruition. Driving a sound way of life doesn't mean you must run a mile before breakfast, eat seeds and think unadulterated musings. Incredible if that is the thing that you need, yet for the vast majority of us â€Å"healthy† implies being fit as a fiddle, eating our foods grown from the ground and for the most part having a sentiment of imperativeness. Settle on your meaning of a solid way of life, and afterward plan a procedure that works for you. As a major aspect of my wellbeing plan I chose I needed to stroll in the mornings before breakfast, however there was no chance I needed to get up at the beginning of the day to do it. So I arranged a brief circuit that incorporates a short trip of steps and a not very steep slope. I power strolled that course each day and felt great. Sure l wouldn’t make the City to Surf long distance race, however I traded off and made it work for me. Today, much is made of natural nourishments, yet actually natural food is commonly increasingly costly and well out of the range for most spending plans. Indeed natural is presumably the best alternative, however it doesn't imply that in case you're not eating all natural you are not eating right. In case you're worried about general produce, be somewhat perceiving when you shop. Search for products of the soil that are new and unsullied. You ought to likewise purchase item marks that you can trust. In the event that you shop shrewdly, you can have an even solid eating regimen that won't use up every last cent. Fundamentally carrying on with a solid life implies taking a gander at your way of life in general, it isn't just about eating regimen and exercise. It isn't generally important to roll out significant improvements. The vast majority know their shaky areas, and are cheerful on the off chance that they can roll out a couple of improvements that show results. A companion of mine was drinking a few jars of soda daily. She was feeling tired and for the most part sickly. At the point when I read an article about the wellbeing danger of soda I duplicated it and offered it to her, whereupon she chose to surrender the soda there and afterward. After seven days she hit me up and said she was unable to accept the distinction, her vitality levels were up and she was feeling incredible. Simply that one change had the option to have any kind of effect and she likes the sound decision. Rest and recreation time have a major impact in a solid way of life,  and generally individuals think little of the estimation of good rest. Our bodies aren’t intended to work at top execution twenty four hours per day. Anybody in industry realizes that machines that need to work consistently require a great deal of upkeep. At the point when we are dozing our body is mending and recovering itself and we should wake up feeling revived and renewed. We can abandon rest for expanded periods, yet we can't do it inconclusively. The measure of rest an individual needs shifts a lot, and there is nothing of the sort as the correct opportunity to rest. Clearly a great many people rest around evening time, yet in the event that you are one of those society that wakes up in the little hours, you may need to find your rest during the day. A major piece of sound living is being OK with yourself. Try not to be forced into attempting to achieve a specific look, or propel yourself down a profession way you are not fit to. Steady stress over what you are doing will just have the contrary impact on your wellbeing. Try not to get distrustful about yourâ diet,â about what toothpaste you should utilize or about costly gym equipment you have to purchase. Permit a presence of mind way to deal with direct when you are settling on way of life decisions, and recollect, there is nothing amiss with bargain on the off chance that it implies your solid way of life plan will work for you. Article source : http://www. prosperity data. com/article-sound way of life. html Sound Lifestyle Sound Lifestyle ideally we would all beâ eating the privilege food,â exercising, dozing wellâ and just for the most part getting a charge out of life. In reality a large portion of us deal with a level of theâ healthy lifestyleâ and wade through as well as can be expected with its remainder. Some portion of the issue is we are urged to think, generally by the media, that we ought to do everything conceivable towards a solid way of life, constantly. For the majority of us this is simply impractical. Consistent worry about what we ought to or shouldn't do causes our feelings of anxiety to go up and that nullifies any great work that we've done. Truly, we ought to positively pursue a sound way of life, yet the two watchwords are â€Å"moderation† and â€Å"balance†. By applying these standards to accomplishing a sound way of life we won't beat ourselves ready for bombing another eating regimen or dropping out of the most recent exercise system. A typical misstep that numerous individuals make when they choose to embrace a sound way of life is to attempt to do an excessive amount of too early. They at that point give themselves a blame complex when everything self-destructs. It is likewise simple to be impacted by others, when we should just receive a sound way of life intend to suit ourselves. Ok! Did I say way of life plan? Do you have one, or do you simply attempt the following thing that is in your magazine or Sunday supplement? By all methods read these articles and consider as youâ plan how you need your solid way of life to come to fruition. Driving a sound way of life doesn't mean you must run a mile before breakfast, eat seeds and think unadulterated considerations. Incredible if that is the thing that you need, however for the majority of us â€Å"healthy† implies being fit as a fiddle, eating our leafy foods and for the most part having a sentiment of imperativeness. Choose your meaning of a sound way of life, and afterward plan a technique that works for you. As a major aspect of my wellbeing plan I chose I needed to stroll in the mornings before breakfast, yet there was no chance I needed to get up at the beginning of the day to do it. So I arranged a brief circuit that incorporates a short trip of steps and a not very steep grade. I power strolled that course each day and felt great. Sure l wouldn’t make the City to Surf long distance race, however I bargained and made it work for me. Today, much is made of natural nourishments, yet actually natural food is commonly increasingly costly and well out of the range for most financial plans. Truly natural is presumably the best alternative, yet it doesn't imply that in case you're not eating all natural you are not eating right. In case you're worried about general produce, be somewhat observing when you shop. Search for foods grown from the ground that are new and immaculate. You ought to likewise purchase item marks that you can trust. On the off chance that you shop admirably, you can have an even solid eating regimen that won't burn up all available resources. Essentially carrying on with a sound life implies taking a gander at your way of life in general, it isn't just about eating routine and exercise. It isn't generally important to roll out significant improvements. The vast majority know their shaky areas, and are glad on the off chance that they can roll out a couple of improvements that show results. A companion of mine was drinking a few jars of soda pop a day. She was feeling tired and for the most part sickly. At the point when I read an article about the wellbeing danger of soda pop I replicated it and offered it to her, whereupon she chose to surrender the soda there and afterward. After seven days she hit me up and said she was unable to accept the distinction, her vitality levels were up and she was feeling incredible. Simply that one change had the option to have any kind of effect and she likes the solid decision. Rest and recreation time have a major influence in a solid way of life,  and generally individuals think little of the estimation of good rest. Our bodies aren’t intended to work at top execution twenty four hours per day. Anybody in industry realizes that machines that need to work consistently require a great deal of support. At the point when we are dozing our body is mending and recovering itself and we should wake up feeling revived and rejuvenated. We can abandon rest for broadened periods, however we can't do it inconclusively. The measure of rest an individual needs shifts a lot, and there is nothing of the sort as the ideal chance to rest. Clearly the vast majority rest around evening time, yet on the off chance that you are one of those society that wakes up in the little hours, you may need to find your rest during the day. A major piece of sound living is being alright with yourself. Try not to be forced into attempting to achieve a specific look, or propel yourself down a vocation way you are not fit to. Steady stress over what you are doing will just have the contrary impact on your wellbeing. Try not to get suspicious about yourâ diet,â about what toothpaste you should utilize or about costly gym equipment you have to purchase. Permit a presence of mind application

Saturday, August 22, 2020

Analysis Of The Three Financial Models

IntroductionBankruptcy alludes to the condition of a person who can't pay their obligations and against whom a liquidation request has been made by a court. Such requests deny bankrupts of their property, which is then used to pay their obligations. Liquidation procedures are begun by a request, which might be introduced to the court by (1) a leaser or banks; (2) an individual influenced by a deliberate course of action to pay obligations set up by the account holder under the Insolvency Act 1986; (3) the Director of Public Prosecutions; or (4) the indebted person. (Smullen and Hand, 2003).If we accept that a partnership is a different lawful element hence qualifying as a legitimate individual, we can receive the above definition to characterize chapter 11 with regards to the company or corporate insolvency as the condition of an organization that can't pay its obligations and against which liquidation request has been made by a court. (Smullen and Hand, 2003).Analysis of the models for anticipating bankruptcy.There are three fundamental ways to deal with foreseeing liquidation which include: bookkeeping expository methodology, alternative hypothetical methodology and the factual methodology. Becchetti and Sierra (2002: p. 2100).â Under the factual methodology corporate disappointment hazard is investigated through four generally known strategies which utilize asset report proportions: straight or quadratic segregate examination, calculated relapse examination, probit relapse investigation and neural system analysis.For the reasons for this paper we will restrict our investigation to three essential budgetary models, which incorporate the Z-Score model, the discriminant model and the Black-Scholes-Merton Probability. We additionally portray the use of these models in corporations.1. The Z-Score Bankruptcy Prediction ModelThe Z-score expectation model was created by Altman in 1968. (Grice and Ingram, 2001: p. 53). The Z-score model applies multivariate discrim inant examination (MDA) and utilizes money related proportions as information factors to foresee budgetary misery. (Tzeng et al, 2007: p. 297). As indicated by Grice and Ingram (2001: p. 53), Altman (1968) utilized an example of 33 non-bankrupt assembling firms from 1946-1965. Grice and Ingram (2001) affirm that regardless of the way that the z-score model display high precision rates utilizing both estimation and hold-out examples, (95% and 84%), its generalizability to enterprises and periods outside of those in the first example has gotten little attention.This model has be broadly utilized in an assortment of ventures to assess budgetary states of firms and it is consistently being utilized in numerous business circumstances including liquidation forecast and other money related pressure conditions. Grice and Ingram (2001) did a test on the z-score model based three essential tests which incorporate the model’s capacity to foresee liquidation today instead of periods in w hich it was created, the handiness of the model in anticipating insolvency in non-producing just as assembling firms and its capacity to foresee chapter 11 in money related pressure conditions other than bankruptcy.Their discoveries show that in spite of the fact that the model is valuable in anticipating liquidation just as other budgetary conditions, the models exactness is altogether lower in ongoing periods than that detailed in the first work by Altman (1968).Grice and Ingram (2001) additionally find noteworthy contrasts in the model’s coefficients from those revealed by Altman. In view of these discoveries, Grice and Ingram (2001) recommend that better precision can be accomplished by re-assessing the model coefficients utilizing estimation from periods near trials. What's more Grice and Altman (2001) find that the incorporating non-fabricating firms in the example, further debilitates the precision of the model.1.1 Application of the Z-Score modelCommercial banks utili ze the model as a major aspect of the intermittent credit audit process; venture brokers utilize the model in security and portfolio examination. It has been utilized as an administration choice apparatus and as an investigation instrument by inspectors to survey their clients’ capacities to proceed as going concerns (Grice and Ingram, 2001: p. 53).2. The Black-Scholes-Merton Model.According to Reisz and Perlich (2007) after from Black and Scholes (1973) and Merton (1974), the normal supply of a firm can be viewed as a standard call choice on the fundamental resources of the firm. It is accepted that investors have offered the company to loan bosses, and hold the choice of repurchasing it by paying assumed worth (in addition to enthusiasm) of their obligation commitments. (Reisz and Perlich, 2007: p. 2). Then again, utilizing put/call equality, we can consider investors to be holding the firm’s resources (purchased subsequent to obtaining cash from loan bosses) just as a put choice with practice value equivalent to the presumptive worth equivalent to estimation of debt.(Reisz and Perlich, 2007: p. 2). In the occasion where the where the firm worth is underneath the activity value, that is, the place the cost of the firm is beneath the assumed worth of the obligation at development, investors can openly work leave without reimbursing their obligation commitments. (Reisz and Perlich, 2007: p. 2). This is like offering the firm to the bondholers at the assumed worth of the obligation. (Reisz and Perlich, 2007: p. 2). Reisz and Perlich, (2007: p. 2) affirms that such a value based valuation model can prompt better insolvency predictions.In an investigation by Hillegeist et al. (2004), it was discovered that the probabilities of insolvency pulled out from the a Black-Scholes-Merton auxiliary model are up to multiple times increasingly useful that ones surmised from bookkeeping based measurements, for example, the Altman (1968) Z-score. (Reisz and Perl ich, 2007: p. 2). Anyway regardless of the benefits of this Black-Scholes-Merton model, it doesn't give any justification to watched administrative (limited) hazard decisions. (Reisz and Perlich, 2007: p. 3). Furthermore, probabilities of default (PDs) originating from this structure are miscalibrated. (Reisz and Perlich, 2007: p. 3).3. The Mutiple Discriminant ModelMultiple discriminant examination (MDA) is a factual strategy utilized in the arrangement of a perception into one of a few from the earlier groupings, subordinate upon the observation’s singular qualities. It is principally helpful in the arrangement or potentially forecast in issues where the needy variable shows up in subjective structure for instance, male or female, bankrupt or non-bankrupt. Thusly the initial step is to set up unequivocal gathering orders. The quantity of unique groupings might be two or more.The MDA model is invaluable in that it considers the whole profile of qualities regular to the impor tant firms, just as the cooperation of these properties. Alternately, a univariate study can just consider the estimation utilized for gathering assignments each in turn. Another significant preferred position of the MDA model is the decrease of the analyst’s space dimensionality.â When examining a complete rundown of money related proportions in evaluating a firm’s liquidation potential, there is motivation to accept that a portion of the estimations will have a high level of collinearity or relationship with one another. (Altman, 1968).3.1 Application of Multiple Discriminant ModelFollowing its first application during the 1930s, the MDA model has been utilized in numerous examinations and controls. In its previous days it was utilized uniquely in Biology and conduct sciences. Today, the model has been applied effectively in money related issues, for example, credit assessment and venture grouping. For instance, Walter utilized the model to arrange high and low val ue profit proportion firms, and Smith applied the model in the grouping of firms into standard speculation categories.BIBLIOGRAPHYA showcase based structure for liquidation expectation. Alexander S. Reisz and Claudia Perlich. Diary of Financial Stability, 2007, Pages 1-47. A genuine esteemed hereditary calculation to upgrade the parameters of help vector machine for anticipating liquidation. Chih-Hung Wu Gwo-Hshiung Tzeng Yeong-Jia Goo  Wen-Chang Fang. Master Systems with Applications Volume 32, 2007 Pages 397â€408 â€Å"Bankruptcy†Ã‚  A Dictionary of Finance and Banking. John Smullen and Nicholas Hand. Oxford University Press 2005. Oxford Reference Online. Oxford University Press.  â http://www.oxfordreference.com/sees/ENTRY.html?subview=Main&entry=t20.e278Bankruptcy hazard and beneficial proficiency in assembling firms. Leonardo Becchetti and Jaime Sierra Journal of Banking and Finance, Volume 27, Issue 11, November 2003, Pages 2099-2120Tests of the generalizability of Altman’s chapter 11 expectation model. John Stephen Grice and Robert W. Ingram. Diary of Business Research Volume 54, 2001 Pages 53-61.Financial Ratios, Discriminant Analysis and the Prediction of Corporate Bankruptcy. Edward I Altman. Diary of Finance, Volume 27, Issue 4, September 1968, Pages 589-689.

Patients with Idiopathic Nephrotic Syndrome Essay -- Health, Treatment

Presentation It is realized that glucocorticoids (GCs) treatment is the treatment of decision for patients with idiopathic nephrotic condition (INS); anyway a few patients neglect to react to the treatment in any event, when given high-portion GCs. For those patients, the treatment ought to be reinforced by synergising GCs with other immunosuppressant [1]. Albeit biochemical changes and clinical indications in most nephrotic patients appear to be very comparative, significant contrasts are experienced with respect to the course of sickness. Backslides of proteinuria are knowledgeable about around 60% to 80% of steroid-delicate nephrotic disorder patients and in spite of introductory complete reduction some remain steroid subordinate or become steroid-safe [2]. The absence of reaction to corticosteroids has been clarified by a few components. This might be attributed to overpowering sickness seriousness, poor consistence, anomalies in glucocorticoid digestion or poor assimilation, particularly in patients with NS, who regularly grow overwhelming proteinuria and Hypoalbuminaemia, and, at long last, by GCs obstruction because of a GCR or postreceptor irregularity. GCR was implicated in exacerbating the reaction to steroids prior [3,4], however deficient reaction to these specialists, either because of acquired objective tissue blemished reaction or gained impeded responsiveness is frequently detailed by the clinicians in various patients [5]. On the off chance that clinical reaction was anticipated before treatment, synergised treatment may be performed toward the start of the treatment to evade symptoms of ceaseless high-portion hormone treatment, which could improve the individual reaction to GC treatment and advantage more patients. Glucocorticoid receptor (GCR) is by all accounts identified with the pathogenesis of steroid... ...ic marker for patients with idiopathic nephrotic disorder. During line up patients with non-backsliding and inconsistent backsliding nephrotic disorder made some middle memories to accomplish abatement 7 days [5]. In this way taken together each one of those information we can theorize that assessment of the statement of intracellular glucocorticoid receptors appeared as the level of lymphocytes (CD3/GCR) can legitimately foresee early and late responders to steroid treatment, and subsequently the result of nephrotic disorder patients with respect to future backslides assuming any. Nonetheless, there has been no investigation on the connection between the outflow of lymphocytes GCR and an opportunity to accomplish total abatement in pediatric age bunch patients with steroid delicate nephrotic condition up until this point.

Friday, August 21, 2020

How to Encourage More People to Donate Their Organs Free Essays

1) Many of the individuals who get organs have self-harmed their own organs, for example, by sedate utilize or other unreliable practices (eating designs, sexual movement designs, and so on ). There are measures taken by the clinical network to guarantee that they’re not occupied with these practices while they’re sitting tight for an organ yet that doesn’t change the historical backdrop of the practices or how the harm was finished. We will compose a custom exposition test on Step by step instructions to Encourage More People to Donate Their Organs or then again any comparative point just for you Request Now 2) Most of the individuals will have abbreviated life expectancies at any rate regardless of whether they get the organ. ) Most of the individuals who get organs will encounter a variety of inconveniences which will diminish their personal satisfaction and force progressing, regularly deep rooted, budgetary expenses. 4) The prompt and progressing expenses of transplanting organs is extremely high and that cost can frequently be spent better in different manners, for example, by improving wellbeing training and avoidance, chronic drug use treatment, neonatal consideration, sustenance, hereditary research, counterfeit tissue look into, and so on 5) Because of the significant expenses included, organ transplants are in some cases got by means of a bootleg market in which you have the exceptionally rich profiting and the extremely poor selling their organs. This disparity in access would, somewhat, stay regardless of whether everybody were an organ giver. 6) Some individuals are worried about the possibility that that not exactly full endeavors may be made to revive them on the off chance that they are a known organ contributor. For instance, they’re associated with a mishap and afterward after brief endeavors are made to revive them they are left beyond words their organs collected despite the fact that in the event that somebody had invested somewhat more energy they’d be alive. In spite of the fact that this dread is fundamentally unwarranted at any rate in most of the created world, it isn't completely a preposterous dread and it would have some authenticity in certain pieces of the world. ) Many individuals view the body as holy so that we can never be ethically committed to leave behind any piece of it or to get any piece of anothers. Truth be told a few people fortify this view from â€Å"not obligated† to â €Å"obligated to not†, and there are a scope of perspectives in the middle. This feeling of the â€Å"sacredness† of the body need not show in an explicitly strict manner however essentially as an instinctive offensiveness at the idea of upsetting ones conventional substantial association much in the afterlife. Anyway it might show in strict manners also and is the reason such a large number of societies have occupied with custom internment, preservation and treating, and disapprove of things like grave-looting, incineration, and so on. The instinct is, pretty much, that when you abuse the body, even in death, you show a lack of respect both for the life of the individual whose body it was and for life as a rule by making all of us simply potential wares for each other. This connects to point 5. The opposite of this comes toward the start instead of the finish of life and includes not the activity of selling organs but rather of selling youngsters and of imagining kids explicitly to reap their organs. These things really do and have occurred and, sensibly, they repel numerous individuals. 8) The donater is normally unfit to practice any carefulness with respect to who gets the organ or judge their legitimacy to get it. 9) The donater is generally absolutely ignorant of the beneficiary and feels no commitment to them. This absence of felt commitment is, obviously, responded. 0) Although, similarly likewise with immunization programs, the expenses of gift could be brought down by making it compulsory, this is probably not going to occur (see 7) and, on the off chance that it happened, would probably be mishandled (see 5). Together these all give imposing motivations to not give. In spite of the fact that there may stay a few cases to which a portion of the contentions don’t similarly apply, for example, cornea transplants and skin unites and transplants for the youthful and in any case solid and gifts to those you know, the contentions against numerous types of gift and numerous cases thereof are still weightier than you may might suspect. Instructions to refer to How to Encourage More People to Donate Their Organs, Essays

Saturday, August 8, 2020

Reminders Deadlines and Office Closures COLUMBIA UNIVERSITY - SIPA Admissions Blog

Reminders Deadlines and Office Closures COLUMBIA UNIVERSITY - SIPA Admissions Blog I have two announcements for today: (1.) This is a just a friendly reminder that the Fall 2016 Early-Action Deadline is today, November 2, 2015 at 11:59 p.m. EST.  So get that application in before its too late. Youll not only be eligible for SIPAs merit-based aid, but youll have the added benefit of  knowing your admission decision two months sooner than anybody else! So finish your application while youve still got time. (2.) The Office of Admissions Financial Aid will be closed for Election Day, on Tuesday, November 3, 2015. We will reopen during normal business hours on Wednesday, November 4, 2015. [Photo courtesy of  April Sikorski  | CC BY-SA 2.0]

Monday, June 29, 2020

A Problem Question in Intellectual Property Law - Free Essay Example

It is 1st essentially to know who should own the copyrightà ¢Ã¢â€š ¬Ã¢â€ž ¢s title of the manifesto with 4 persons Al (A), Bill (B), Cal (C) and Dina (D). But before discussing about the owner, we must first established the category of such manifesto by s 1(1) of Copyright, Designs and Patents Act (CDPA) 1988[1] as a literary work since it was in written form. It is also note to know that the originality requirement has to be assessed that the work must not be copied and originates from the authors with minimum investment by the author of skill, judgment and labour. The issue hence relies how substantial the effort the authors made to attract their copyright protection and each group members will be discussed individually.[2] AL (A) A came with the notion and the title. However, the notion could not being protected by copyright since it was being an idea not an expression. This means A cannot own the ideaà ¢Ã¢â€š ¬Ã¢â€ž ¢s copyright since it is not original nor form a substantial part of the work.[3] Hence, A can only go after the copyright for the title but not the notion itself. For the title, one will have to look at originality issue whether A has invest a sufficient skill, labour and judgment or not. However a title could be hardly seen as copyright protection since it does not contain substantial enough of works which could be a à ¢Ã¢â€š ¬Ã…“hackneyed expressionà ¢Ã¢â€š ¬Ã‚ .[4] It was suggested that a title would be too short and does not involve literary composition.[5] But, in the case of Newspaper Licensing Agency Ltd v Mel twater Holding BV (or Meltwater)[6], A would be suggested to rely the exception test laid out by European Union (EU) case of Infopaq International A/S v Danske Dagblades Forening (Infopaq case)[7] to focus more on originality than substantiality of effort that the 12 words on the facts (OTF) (which is more than 11 words in Infopaq case) title contain expression of the intellectual creation of the author himself through choice, sequence and combination of words.[8] It does not matter that the title and the rules written is a different person (being A for title with B and C for the rules) which could amount to independent literary work[9] but it must reflects the à ¢Ã¢â€š ¬Ã‹Å"attitude, position or meaning taken by the writer of the articleà ¢Ã¢â€š ¬Ã¢â€ž ¢ in his own way.[10] OTF, the 15 core rules has not been shown so it is hard to determine the issue whether has the headline relate to the manifestoà ¢Ã¢â€š ¬Ã¢â€ž ¢s content or not. However it is submitted Aà ¢Ã¢â€š ¬Ã¢â€ž ¢s t itle could be protected by copyright in the light of Infopaq[11] test as long as the title à ¢Ã¢â€š ¬Ã‹Å"Manifesto of the Desperate: Finding the good life in a Ruthless Worldà ¢Ã¢â€š ¬Ã¢â€ž ¢ could introduce the tone of the manifesto that attract readers with his own intellectual creation without extracting texts from the rules.[12] Although the manifesto is unpublished, it could be still capable of attracting copyright.[13] .The fact that it is well-known, court must also assessed that there is also policy consideration that such title would be easy to infringe the right of freedom to refer the title if offered copyright protection.[14] Bill(B) Cal(C) Since B and C are involved with the same corresponding matter, it is possible then they are joint author of the work itself according CDPA 1988 s 10(1). However, each of them need to establish the requirement of significant contribution which is not distinct from the other authors.[15] For B and C, it is up to whether the contribution is significant enough for cover up the rules as the sole author or both could be joint author. 1st, the 9 rules were written by B some of Bà ¢Ã¢â€š ¬Ã¢â€ž ¢s rules majorly amended by C. Generally, B could be deemed as the author of the rules since B is the creator[16]. In terms of labour, the de minimis principle applies. Nonetheless, there can be no joint authorship here with B and C for the 9 rules since a à ¢Ã¢â€š ¬Ã‹Å"subsequent independent alteration of a finished work will not give rise to work of joint authorshipà ¢Ã¢â€š ¬Ã¢â€ž ¢[17] and must contribute within the production of the work. The question then lies whether C could attract a new copyright to the amended rules or it is infringe Bà ¢Ã¢â€š ¬Ã¢â€ž ¢s copyright by copying. With the amendment by C, applying case of Interlego v Tyco it could be said C could not attract copyright if it is only a minor alterations .[18] In order to attract copyright, C must show that there must be addition of some qu ality or material alteration to make totality of the work an original work [19] or to say element which distinguish raw material (Bà ¢Ã¢â€š ¬Ã¢â€ž ¢s rules) which do not possess[20]. Although the case concerned on artistic work, it referred from case of Black v Murray[21] (a case of literary copyright) where it was held there must be an extensive and substantial alterations rather than a few emendations and addition of few unimportant notes.[22] D would try to argue even so with major investment, C could be just copy of an existing work no matter how much skill or labour devoted cannot give rise to original work of copyright since there might be no originality conferred of the expression.[23] In the case of Hyperion Records Limited v Dr. Lionel Sawkins (or Hyperion case),[24] Lord Justice Jacob also held that à ¢Ã¢â€š ¬Ã…“copyistà ¢Ã¢â€š ¬Ã‚  is a mere copyist only when they are merely performing an easy mechanical function and it is less likely to be original.[25] This is consistent with the current approach of new test of originality laid down in case of Infopaq that author must stamping the work with his à ¢Ã¢â€š ¬Ã‹Å"personal touchà ¢Ã¢â€š ¬Ã¢â€ž ¢[26] regardless of the substantiality of effort. OTF give, it is suggested there should be no limit on how major must amendment be as long as it does not preserve Dà ¢Ã¢â€š ¬Ã¢â€ž ¢s original rule. Hence OTF using this case, it is likely that Cà ¢Ã¢â€š ¬Ã¢â€ž ¢s works of the major amended rules that can attract a new copyright and no infringing issue occurred if intellectual creation is found within the amendment. On the other hand, for the 6 rules created by C, this work would deem C as the author[27] enable to attract copyright as an original literary work as long as standard skill labour applied. Hence, the issue lies within with the help of drafting rule from B, will B be able to obtain authorship as a joint author for Cà ¢Ã¢â€š ¬Ã¢â€ž ¢s work. B will then have to satisfy the requiremen t of joint authorship which there must be a significant contribution[28], collaboration[29], and the inablility to identify distinct contributions[30]. This fact could be draw the analogy with case of Brown v Mcasso Music[31] that joint authorship was held where a person is in charge of draft and then amended by 2nd person[32] it is not possible to separate their contribution in the final work[33] such as that it will lose meaning if were to separate[34]. Applying to the facts, it is unknown whether Bà ¢Ã¢â€š ¬Ã¢â€ž ¢s contribution is significant provided there is absence of fact but it does not have to be equal but an act of drafting in an ordinary meaning could be say that inevitably consist of own intellectual creation hence satisfied. On the other hands, the contribution of B has lead to the creation of Cà ¢Ã¢â€š ¬Ã¢â€ž ¢s work[35]. There is a collaboration between C D as It is not of mere addition to the complete piece since there has been sharing the labour of working i n a à ¢Ã¢â€š ¬Ã‹Å"common designà ¢Ã¢â€š ¬Ã¢â€ž ¢ (the 6 rule)[36] with Bà ¢Ã¢â€š ¬Ã¢â€ž ¢s help of drafting and Cà ¢Ã¢â€š ¬Ã¢â€ž ¢s skill and labour that is practically impossible to separate. In summary, it is likely that B will be able to obtain joint authorship right and share the copyright with C for the 6 rules. Dina (D) For D, since the major role of her is to edit the final text, corrected spelling grammatical errors, D could rely on the principle on the case of Walter v Lane[37] that a correction of spelling and revision of a report could attract copyright. However, it is submitted that this case could not be apply since it was decided before the introduction of originality requirement. The current approach test of originality require a person to have intellectual creation of à ¢Ã¢â€š ¬Ã‹Å"free and creative choicesà ¢Ã¢â€š ¬Ã¢â€ž ¢, with author stamping the work with personal touch. In other words, an element of creativity is required from the author. Followi ng the current test, D could not be an author since the volume of her work since it is lack of originality or intellectual creation. Therefore, D will have no rights over it can only be acting as an agent of the work.[38] ED (E)Fran (F) Here, there are 2 artistic work that can attracting copyright, namely the plan created by E under graphic work category[39] it is no doubt that E will be the planà ¢Ã¢â€š ¬Ã¢â€ž ¢s author since E is the creator[40]. On the other hand, model created by E F could be categorize under work of sculpture[41] or artistic craftsmanship[42] or both. It could not be a model for building where it include a fixed structure[43] which is contrast from Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s model that has interlocking parts for easy assembly disassembly, therefore not fixed. The main difference between a sculpture artistic craftsmanship is that sculpture were created primary aim for aesthetic feature (to attract attention using their visual aspect) rather than utilitaria n function although both feature could be co-exist together.[44] Applying to the fact, this suggest the model can be fall under sculptureà ¢Ã¢â€š ¬Ã¢â€ž ¢s definition where the tree has shown visual aspect via psychedelic fruits hanging from its branches, intended to be focus of attention as an evidence of artistic merit. As for artistic craftsmanship, the work requires both aesthetic functional feature.[45] The approach is unclear clear in defining artistic craftsmanship because there are no consistency as to determining the standard of artistic quality required or any proper comprehensive test is available[46]. This could be seen from several opinion regarding issue about artistic craftsmanship where there is no decisive factors in deciding whether a work is artistic, only certain consideration.[47] However, there are 2 common factors discussed by majority of Lords can be derived from case of George Hensher Ltd v Restawile Upholstery (Lancs) Ltd (George case) : one should lo ok at the intention of the creator or reply on expert witnesses (person who specialize themselves in the field of artist-craftsmen). [48] According to the facts, E Fà ¢Ã¢â€š ¬Ã¢â€ž ¢s intention could be comprehend as creating work of art since the main purpose of centrepiece is for displaying aesthetic appeal. On the other hand, Lord Simon stated that it is work of artistic craftsmanship rather than artistic work of craftsmanship that will be protected.[49] This means it is not required that every individual work produced in artistic craftsmanship must be artistic work but activities of artistic craftsmanship produced is assessed as whole as long as the activity considered is within the range of relevant circles.[50] This could be even further elaborated that there can be 2 authors that the role of craftsman the artist can separate to 2 different persons with one à ¢Ã¢â€š ¬Ã‹Å"makes something in a skilful wayà ¢Ã¢â€š ¬Ã¢â€ž ¢ while the other à ¢Ã¢â€š ¬Ã‹Å"produces something wh ich has aesthetic appealà ¢Ã¢â€š ¬Ã¢â€ž ¢.[51] Although craftsman has not been defined widely, it is suggested work of craftsmanship should be a durable, useful, handmade object.[52] However, It is submitted that Fà ¢Ã¢â€š ¬Ã¢â€ž ¢s effort may be considered in artistic craftsmanship by adapting the role of a craftsman while E as an artist.[53] In spite the plan does not contain aesthetic appeal, it is the model that build according to the plan where aesthetic appeal could be derived from via Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s creative ability. In addition, it is justifiable that there is utilitarian function of the tree model in the sense that it has interlocking parts easy for assembly disassembly. Still in determining whether a craftsmanship could be identified as à ¢Ã¢â€š ¬Ã‹Å"artisticà ¢Ã¢â€š ¬Ã¢â€ž ¢, it has to rely on expert evidence. Whether Fà ¢Ã¢â€š ¬Ã¢â€ž ¢s craftsmanship of building the tree could be recognized as à ¢Ã¢â€š ¬Ã‹Å"artisticà ¢Ã¢â€š ¬Ã¢â€ž ¢, it will be up for ex pertise to decide. In summary, it is likely that the model created can be fall under 2 different category under artistic work of CDPA 1988 s.4 (1)(a) (c) provided Fà ¢Ã¢â€š ¬Ã¢â€ž ¢s work of craftsmanship is considered as à ¢Ã¢â€š ¬Ã‹Å"artisticà ¢Ã¢â€š ¬Ã¢â€ž ¢. Nonetheless, if the work fall under sculpture category under CDPA 1988 then both E F will have to establish themselves as author for the work. There are 2 ways of possible explanation since both E F could be author in their own reason. In Stuart v Barrett and Others it is stated that à ¢Ã¢â€š ¬Ã‹Å"a person with an original idea was not the author of any work unless the person with the idea contributed to the form of the workà ¢Ã¢â€š ¬Ã¢â€ž ¢[54]. One must take note the plan created by E is not only idea but an expression of the idea. So for E, he can be an author since he has contributed of expression of idea (the originality) by drawing up plans for the tree model intellectual creation came from. In additio n, it could be also said that F is author of the work since F is the one who creates it.[55] Hence, the next issue is to consider whether are the artistic workà ¢Ã¢â€š ¬Ã¢â€ž ¢s copyright of the tree model enjoyed by sole author or joint authorship hence it is required to assess the requirement below. For E F to satisfy as joint authorship, there must be work produced by the collaboration of authors where the contribution of each author is not distinct from that of the other author.[56] This principle could be derived from the following relevant case. In Brighton v Jones[57] where Park J has extracted 3 propositions, the propositions as stated was not itself decisive.[58] Firstly, although the contribution must significant led to creation of the work, it does not have to be equal in magnitude compare with other author[59]. Secondly, the contribution of person alleged joint author must be led towards creation of work. It must be a à ¢Ã¢â€š ¬Ã‹Å"right kind of skill and labou rà ¢Ã¢â€š ¬Ã¢â€ž ¢.[60] Thirdly, a person can be joint author where he have a direct responsibility even though other person has effectively adopting what the person has created.[61] Applying first propositions, it could be say Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s contribution is significant in the sense that it is Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s plan who F was following accordingly. F do have contribution too of spent months to build the model. Regarding to 2nd point, Although F is the one who build it, it does not lead to the creation of the work. The current originality test require an author to have his own intellectual creation. It is also arguable that the skill and labour is not of right kind[62]. Referring from Cala Homes (South) Ltd v Alfred McAlpine Homes East Ltd[63] where Lightman J in Robin Ray v Classic FM Plc[64] (or Robin case) review the decision where there can be no author or co-author of a work if thereà ¢Ã¢â€š ¬Ã¢â€ž ¢s no any creative contribution when someone acting as mere scribe, producing the copyright expression in accordance with instructions. Applying it, hence when F build the tree following according to the plan under Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s supervision, it is unlikely that the contribution is to the à ¢Ã¢â€š ¬Ã‹Å"authoringà ¢Ã¢â€š ¬Ã¢â€ž ¢ of the work. It is suggested that there must be some creative input. On the contrary for E, there is an intellectual creation from Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s plan, which originality suffice for creation of the work. In third proposition, F could not rely on it because it was E who prepared the plan instead of F and F adopted the plan. This proposition further reinforce Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s position as the author of the model. The 2nd requirement of joint authorship require collaboration between 2 or more persons. The statute does not define collaboration, instead Jonathan Parker LJ stated it does not mean intention of joint authorship but rather à ¢Ã¢â€š ¬Ã‹Å"joint labouring in furtherance of a common designà ¢Ã¢â €š ¬Ã¢â€ž ¢[65].Although the statement was not elaborated, it is submitted that mere suggestions or ideas may not be enough in terms of contribution[66]. In Robin case, it was held that a suggestion however significantly, reflecting a personà ¢Ã¢â€š ¬Ã¢â€ž ¢s input may insufficient to become a joint author[67], suggesting creative input is required. This statement accord with the principle that copyright protects expression not idea or suggestion. Thus, F could not rely on the ground that the contribution of making suggestion of suitable materials and colour schemes for collaboration requirement. Finally, the contribution must not be distinct from one author to another which mean the contribution of the co-authors are inseparable heavily dependent to each other such as a book of different chapters wrote by different authors is not joint authorship, neither do a song where one person written a song and another one written the words.[68] Apply to the facts, it is shown that E Fà ƒ ¢Ã¢â€š ¬Ã¢â€ž ¢s contribution is separable. With the contribution to the finished product, it consist of 2 distinct work, with Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s plan Fà ¢Ã¢â€š ¬Ã¢â€ž ¢s labour. Nonetheless, the model was build according to Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s plan, it is suggested that Eà ¢Ã¢â€š ¬Ã¢â€ž ¢s plan is not dependant on Fà ¢Ã¢â€š ¬Ã¢â€ž ¢s labour but not in a vice versa form. In short, although F has built the model, it is submitted F is not an author in terms of joint authorship and E may become a sole author of. This is of course if court held the artistic work as a sculpture rather than artistic craftsmanship. Gil (G) Gà ¢Ã¢â€š ¬Ã¢â€ž ¢s song are reinterpretation of Tudor English folk songs, but played faster and on acoustic guitar instead of the traditional lute. The issue is whether Gà ¢Ã¢â€š ¬Ã¢â€ž ¢s act of changing instrument and music pace is capable to be attracting copyright and protected under CDPA 1988 s 3(1) as a musical work. This issue has been conside red in the case of Hyperion[69] and the case will be discussed in depth in terms of musical issue. Mummery LJ held that in determining copyright, it involves a whole assessment of work in whether copyright subsists following the approach of long standing case of Ladbroke.[70] Furthermore, the fixation of a musical score is not the only way copyright could subsists. It involves à ¢Ã¢â€š ¬Ã‹Å"listening to and comparing the sounds of the copyright workà ¢Ã¢â€š ¬Ã¢â€ž ¢ and whether does it sound the same. Example such as improvisations of sounds by a group of people with or without musical instruments could be protected as musical work for copyright purpose too.[71] Conclusively, following the principle G is likely to attract copyright of his musical work even though there are no modification of notes in musicà ¢Ã¢â€š ¬Ã¢â€ž ¢s score as long a minimum standard of originality requirement satisfied. Since Tudor English folk songs could be regarded as no owner, there will be no infringe ment issue even if Gà ¢Ã¢â€š ¬Ã¢â€ž ¢s work does not attract copyright and would not amount to copying. CONCLUSION In summary for literary work of manifesto, A will be likely to gain a copyright of the title if intellectual creation is shown within the title. B will become owner for copyright of the original 9 rules while C will then attract a new copyright for the amended rules provided C could prove intellectual creation within the amendment. As for the 6 written rules created by C, B will most likely to become a joint authorship and share copyright with B. On the other hand, D will not have any copyright of his own since there is a lack of intellectual creation of his own. For the manifesto, since A, B and C own each copyright individually within the work, they could assign it individually. The publisher will have to obtain consent of A, B and C if to publish manifestoà ¢Ã¢â€š ¬Ã¢â€ž ¢s special edition. For artistic work, E will gain copyright over his plan while E and F will gain joint authorship for the tree model if the court decide the model is categorize under à ¢Ã¢â€š ¬Ã‹Å"artistic craftsmanshipà ¢Ã¢â€š ¬Ã¢â€ž ¢ or E may become sole author for the model if it is a à ¢Ã¢â€š ¬Ã‹Å"sculptureà ¢Ã¢â€š ¬Ã¢â€ž ¢. For musical work, it is likely G could create a new copyright of his own for the improvisation. The terms for protection for every copyright work of literary, artistic and musical here will be calculated according to 70 years after the death of the author.[72] [1] Copyright, Designs and Patents Act 1988 s 1(1)(b) [2] Ladbroke (Football) Ltd v William Hill (Football) Ltd (Ladbroke case) [1964] 1 All ER 465, [1964] 1 WLR 273, [291] (Lord Pearce) [3] Designer Guild Limited v Russell Williams (Textiles) Limited (Trading as Washington DC) [2000] 1 WLR 2416 [4] Francis Day Hunter Ltd v Twentieth Century Fox Corp Ltd [1940] AC 112, p [5] Ibid [123]-[124] (Lord Wright) [6] [2010] EWHC 3099 (Ch) [7] [2009] ECDR 16 [8] Ibid 261 [9] Meltwater (n 6) [71] [10] ibid [78] (Justice Proudman) [11] ibid [12] Ibid [85] [13] Meltwater (n 5) [71] [14] Ibid [62] [15] CDPA 1988 s 10(1) [16] CDPA 1988 s 9(1) [17] Beckingham v Hodgens [2002] EWHC 2143 (Ch) at 44 [18] [1989] AC 217 [19] Interlego (n 14) 263 [20] Macmillan Co. Ltd. v. Cooper (1924) 40 TLR 186 [188] (Lord Atkinson) [21] Blacks v. Murray (1870) 8 SLR 261 [22] Hyperion Records Limited v Dr. Lionel Sawkins [2005] EWCA Civ 565 [23] I nterlego (n 14) 371 [24] [2005] EWCA Civ 565 [25] Ibid [82] [26] Painer v Standard Verlags GmbH c-145/10 [2012] ECDR 6 (Painer case) [27] CDPA 1988 s 9(1) [28] Brighton v Jones [2004] EMLR 26 [29] Beckingham v Hodgens [2003] EMLR 18 (CA) [30] Beckingham v Hodgens [2003] ECDR 6 [31] [2005] FSR 40 [32] Paul Torremans, Holyoak Torremans Intellectual Property Law (7th edn, OUP 2013) 248 [33] Brown (n 31) [34] Beckingham v Hodgens [2003] ECDR 6 59 [35] Brighton v Jones [2004] EMLR 26 522 [36] Beckingham (n 29) 51 [37] [1900] AC 539 [38] Paul Torremans, Holyoak Torremans Intellectual Property Law (7th edn, OUP 2013) 249 [39] CDPA 1988 s 4 (1)(a) 4(2) [40] CDPA 1988 s 9 (1) [41] CDPA 1988 s 4 (1)(b) [42] CDPA 1988 s 4 (1)(c) [43] CDPA 1988 s 4 (1)(b) [44] Lucasfilm Limited and others v Ainsworth and another [2011] UKSC 39 [45] Paul Torremans, Holyoak Torremans Intellectual Property Law (7th edn, OUP 2013) 226 [46] Ibi d 224 [47] George Hensher Ltd v Restawile Upholstery (Lancs) Ltd [1976] AC 64 [48] Ibid [94] Lord Simon [49] Ibid. [94] (Lord Simon) [50] Paul Torremans, Holyoak Torremans Intellectual Property Law (7th edn, OUP 2013) 235 [51] Bonz Group (pty) Ltd v Cooke [1994] 3 NZLR 216. (Bonz) This approach was adopted by Mann J in Lucasfilm Limited and others v Ainsworth and another [2011] UKSC 39 [52] à ¢Ã¢â€š ¬Ã‹Å"Work of Artistic Craftsmanshipà ¢Ã¢â€š ¬Ã¢â€ž ¢ https://www.dacs.org.uk/knowledge-base/factsheets/works-of-artistic-craftsmanship#craftsmanship accessed 4 January 2015 [53] Bonz (n 18) [54] [1994] EWHC 448 (Ch) 450 [55] CDPA 1988 s 9 (1) [56] CDPA 1988 s 10 (1) [57] [2004] EMLR 26 [58] Ibid 529 [59] Ibid [34] Park J [60] Flyde Microsystems Ltd v Key Radio Systems Ltd (Flyde) [1998] FSR 449 [61] Cala Homes (South) Ltd v Alfred McAlpine Homes East Ltd (Cala) [1995] FSR 818 [62] Brighton (n 57) 522 [63] Cala (n 61) [64] [1989] FS R 622 [65] Beckingham v Hodgens [2002] EWHC 6 (CH) [66] Hadley v Kemp [1999] EMLR 589 [67] Robin (n 61) 637 [68] David Bainbridge, Intellectual property (9th edn, Pitman Publishing 2012) [69] Hyperion (n 22) [70] Ibid [49] (Lord Mummery) [71] Ibid 53 [72] CDPA 1988 s 12(2)

Saturday, May 23, 2020

Womens Rights in Great Britain - 815 Words

Introduction +thesis Women’s Rights was one of the major social changes that began to gain attention in the media and to peak in active activity during the twentieth century. Women’s rights had been in the making since the eighteenth century. Some of the earliest documented words for Women’s rights appeared in a letter to John Adams by his wife Abigail Adams. During the making of the United States constitution (from the eighteenth to nineteenth century), she wrote to her husband and asked him to â€Å"remember the ladies†. The first state to permit women to vote in the United States (before the nineteenth amendment was drafted) was New Jersey. However, there were restrictions upon who was eligible to vote. Some of these restrictions included†¦show more content†¦They were restricted to occupations that dealt with childcare and minor education positions. Some of the few jobs that women could hold without other is batting an eyelash were governess, schoolteacher, compa nions, a lady’s maid and as stated before an authoress. It was not until 1839 that mothers were permitted to have custody of their children after a divorce but with one catch. The children had to be younger than seven to remain with their mothers were. In 1857, women were permitted to get a divorce from their husbands on the basis that the husband was abusing her. In 1870, women were granted the right to keep their wages earned from their jobs. In 1891, women were granted the right to live separately from their husbands while they were a married couple. Besides the limitations of women’s rights when dealing with domestic issues, there were societal restrictions as well. A woman in the eighteenth and the nineteenth century depending upon her status in life was expected to run the household and to be involved in certain social settings. Some of the things that women would do in their daily lives would be to manage a household budget, make sure that the staff kept up the house and to educate herself in â€Å"womanly† pursuits. According to Sullivan, she was expected to learn languages such as French and Italian butShow MoreRelatedWomens Suffrage in Britain1401 Words   |  6 Pages Women’s Suffrage in Britain Social change in Britain has been achieved primarily through the hard work of organized political groups. These groups created events to recruit and educate supporters of social equality to join them in fighting for progress. The Women’s Suffrage Movement between 1866 and 1928 in Britain is no exception to this trend. The reason for the great efficacy of these political groups, including the National Union of Women’s Suffrage Societies and the Women’s Social and PoliticalRead More The First World War and Womens Suffrage in Britain Essay1743 Words   |  7 Pagesimportant phase for feminism in Britain. The suffrage movement began as a struggle to achieve equal rights for women in 1872. Women then became active in their quest for political recognition, which they finally obtained in 1928. This investigation assesses the question: To what extent did the First World War lead to the accomplishment of the women’s suffrage movement of Britain in 1928? Two of the sources used in the essay, The Women’s Suffrage: a short history of a great Movement by Millicent GarrettRead MoreWomen s Rights During The 19th Century1507 Words   |  7 PagesWomen’s Rights In The 19th Century The 19th century was an important period for women especially in Europe and North America. It was a crucial time for demand for change and women were at the forefront of it all. Viewed only as a homemaker, women found it difficult during this time to show society what they were capable of. Limitations on their capabilities created by gender stereotypes called for change. To understand the significance of the 19th century for women, one must consider the conditionsRead MoreEssay on The Women770 Words   |  4 Pages The womens suffrage party fought for years on the right to vote. They werent going to stop until they got their right. For instance, Alice Paul organized a parade through Washington D.C. on inauguration day, which supported womens suffrage and also picketed the White House for 18 months. Paul was put in jail for that and started a hunger strike. Susan B Anthony and Elizabeth Cady Shanton supported the womens suffrage for fifty years later. Neither of them lived to see the 19th amendment ratifiedRead MoreWomen During The 20th Century1548 Words   |  7 PagesWomen are a large part of our society. They always have been. Without women none of us would be here right now. In the 18th, 19th, and early 20th centuries women did not really get to work much. A woman s job was typically to have and take care of the children. Mother was the main title that a woman could have. Then WWI started, and all of the men went off to fight in the war. With all of the men off fighting, there was no one le ft to to work in the factories. All of the wives and mothers, and womenRead MoreWomen s Rights And The Reform Movement905 Words   |  4 PagesThe year 1776 ignited the colonial rebellion from Great Britain, with colonists from the newly formed United States demanding their individual and colony’s rights. They advocated for representation, their individual rights, and the issue of sovereignty. With the ratification of the Bill of Rights in 1791, individual rights overall were thought to be â€Å"protected† in the newly liberated Unites States. Yet the continued limiting of women’s rights, treatment of the mentally handicapped and emancipatedRead MoreWorld War One: Canadas Efforts1606 Words   |  6 PagesWorld War One: Canada’s Efforts While The Great War may seem like a global effort it can largely still be considered as a forced war upon certain countries participation. A war that reinforces the idea of group efforts and strength in numbers highlights contribution of certain countries, focused on Canada’s encouraged aid. The Great War efforts of Canada may leave room for assumptions and questioning. A prominent theme through out the First World War chapter found in each of the readings, primaryRead MoreThe Women s Suffrage Movement1343 Words   |  6 PagesSuffrage Movement in Britain The Women’s suffrage movement in Britain came to the forefront in 1867 with the formation of the National Society for Women’s Suffrage. The movement grew into the early 20th century by the works of the National Union of Women’s Suffrage Societies (NUWSS), known as the Suffragists, along with the Women’s Social and Political Union (WSPU), known as the Suffragettes. The violence of the WSPU is often the only aspect of the cause remembered, however, for every suffragetteRead MoreEmployment Opportunities of Women in Britain at the Outbreak of War937 Words   |  4 PagesWomen in Britain at the Outbreak of War The First World War brought many changes both to the position of women in society and in the ways that women thought about themselves. Pre-war, women were regarded as second class citizens. They were not even allowed to vote for their Member of Parliament or, become an MP themselves. Pre-war, most women in the working class worked in the sweated trade such as hat and dress making at home. In the industrial areas of Britain e.g. theRead More Mary Wollstonecraft Her Legacy Essay examples1520 Words   |  7 PagesMary Wollstonecraft Her Legacy Following the Enlightenment, Mary Wollstonecraft wrote the feminist novel The Vindication of the Rights of Woman. In this novel she applied rights to females that had formerly been reserved to males, such as unalienable rights. Her novel impacted different areas of society. Wollstonecraft called for the advancement of women’s rights in areas such as education, work, and politics. She also proposes that women are just as capable as men and have a far greater purpose

Tuesday, May 19, 2020

Manual on Forensic Accounting - 2114 Words

FORENSIC ACCOUNTING Introduction Necessity is the mother of all inventions. Yes, it is the growing arena of business and surging number of white-collar crimes that have paved the way for the development of Forensic Accounting. According to AICPA, â€Å"Forensic Accounting is the application of accounting principles, theories and discipline to facts or hypothesis at issues in a legal dispute and encompasses every branch of accounting knowledge.† According to The Accountant’s Handbook on Fraud and Commercial Crime, Forensic Accounting is the application of financial skills and an investigative mentality to unresolved issues, conducted within the context of the rules of evidence. Forensic Accounting borrows knowledge from Accounting,†¦show more content†¦It is a relative thing, that is where fraud and forensic crossed each other’s path. Fraud doesn’t necessarily end up in court, but forensic accountant has to make evidence suitable for admission in court. It is a stereotype thing, as long as auditors are concerned, audit report is supposed to be a mere true and fair view of an account, but when if you are to prove or disprove an allegation of fraud, there must be a forensic accounting investigation and report. It might have been tampered with, ours is not to determine whether the suspect is guilty or not, but to give a better interpretation to the evidences. It impacts on the financial sector of the economy. There are lots of procedures in forensic that you cannot violate like that chain of command, you have to know how the evidences were taken and preserved to avoid cases of tampering with evidence in our court. One major weapon accountants have is the use of questions or the interview technique in conducting auditing jobs; there is no way you can start working without questioning, that is the most critical thing, but not many accountants know its utmost usage, in forensic, we call this embedded incompetence. What actually determines the success of the forensic report is the interview technique. Forensic Accounting ensures: (a) Assessment of the damages causedShow MoreRelatedEssay on Computer Forensics Case Projects Chapter 2786 Words   |  4 Pagescompany information on form and secure the evidence * Request statements from officers on the condition of the computer on time of raid * Request a list of keywords to search * Transport Gateway computer to our secured forensics lab * Prepare a forensics workstation specifically for this case * Make two images of hard drive using two different tools * Examine drives for evidence by running keyword searches and checking URL’s for Internet searches. * Search registry forRead MoreThe Development Of South Africa Essay878 Words   |  4 Pagesthe Gautrain Project, valued at US$3.1 billion (ZAR23 billion), which is one of the largest high-speed rail projects on the African continent. The National Treasury, the key government body that approves deals in South Africa, has developed a PPP Manual and Standardised PPP Provisions to guide PPP projects (Farlam, 2005). However, Nyagwachi (2008) observes that South Africa has a low level of PPP awareness and also lacks project management capacity required to facilitate deal flow, especially atRead MoreHow The Impact On Accounting? Manual Tasks Are Being Automated At A Fast Pace?1045 Words   |  5 PagesAccess to vast amounts of data is creating paradigm shifts in business. What is the impact on accounting? Manual tasks are being automated at a fast pace. Technological advancements, along with the transformation of buying habits to more web-based purchasing is creating opportunities to observe elements of human behavior not previously tracked. Enhanced data tracking creates a sea of data elements available for harvesting. Companies are forming strategies using correlation analysis of behavioralRead MoreComputer Forensics Tools And Resources For Hjc Corporation1515 Words   |  7 Pages Computer Forensic Tools Michael J. Hudgins Strayer University Professor Jessica Chisholm SEC405 Computer Crime Investigation March 3, 2016 Computer Forensic Tools We are now in the process of purchasing computer forensics tools and resources for HJC Corporation. There are many programs, utilities, etc. available on the market that provide computer forensic data retrieval capabilities, however, we are only required to provide information on just two of these tools in our research. TheRead MorePublic Accounting Vs Private Accounting1059 Words   |  5 PagesMichael Lopez Prof. Lapari 8 March 2017 Accounting 201 Public Accounting vs Private Accounting There are two types of accounting practices are public and private these two types are very distinct. I’m going to explain how these both practices work, the different jobs that both practices offer and finally the differences between the two. First I’m going to give the definition of both practices. Public Accounting is viewed as firms that serve clients such as businesses manufacturers, service companiesRead MoreBaap 500 Week 2 Assignment 11474 Words   |  6 Pagescorrectly write off stolen or obsolete products. Both misclassification asset methods result in a higher result on assets and on earnings. (Crumbley, Heitger and Smith, 2013). Financial Accounting Standards Board (FASB) number 2011-11 topic 330 provides information required by generally accepted accounting principles (GAAP) related to inventory. Retail stores operate products on a seasonal basis so the use of Last in First out (LIFO) or retail inventory method is assumed. FASB requires thatRead MoreQuestions On Strategic Information Systems1677 Words   |  7 PagesTRIMESTER 3 Table of Content Introduction: 3 History of the accounting software in Australia: 3 Market size of the accounting software: 4 Information about the Myob: 4 Value of Total size of accounting software: 4 Advantages of this accounting software used in Australia: 5 Service Gap at user forum: 5 Recommendations: 5 Conclusion: 6 References and Bibliography: 7 Appendices: 8 Introduction: According to Curtis (2015), accounting software is useful for every organisation to manage financial calculationsRead MoreManaging All Trade Breaks Raised And Identify Resolution961 Words   |  4 Pagesday’s escrows deposits and advised them on outstanding put letters to be submitted by the clients in support of their short positions. †¢ Intellectual Curiosity: Provided input from a technical perspective on products and developed macros to automate manual processing which reduced errors as well as increase efficiency in process flows. †¢ Team Player: Initiated and assisted in IT troubleshooting for issue resolution on in-house systems and processes to improve efficiency, risk control and ensure thereRead MoreA Report On Hair Specialist And More, A Manufacturing Company Essay1617 Words   |  7 Pagesorganization is currently weighing their options to implement a new Human Resources Information System (also known as HRIS). A HRIS is a software platform used by small to mid-size businesses to help automate and manage HR, payroll management and accounting activities (Dresserassociates, 2016). The objectives the company would like the new system to handle is a self-service approach to record management; which should keep confidential and proprietary data secure. The system should also include an electronicRead MoreDescribe and critique Moffitt1801 Words   |  6 PagesHirshi (1990) who argue that stability is the result of persistent heterogeneity and that people carry such situations with them at any one time and throughout their life courses, and there is evidence that individual differences play a role in accounting for continuity in offending (Nagin and Farrington, 1992). Also, Gottfredson and Hirschi agree that change in offender s can occur over time and this is down to establishing self control early on, as individual differences in self-control are durable

Tuesday, May 12, 2020

Searching for Answers to a Serial Killer, Ted Bundy Essay

What makes a person want to kill or harm another individual? What can make someone reach their breaking point, and want to harm another person? The following report your about to read will take you on a journey. You will learn who â€Å"Ted Bundy† is and why he chose to live a double life. Ted was a special individual who only killed women he had a soft spot for them. Ted Bundy was like a tiger in the wild and women was his prey. When he went out he always went for vulnerable women. Ted would sweet talk them until they trusted him then he would wait until their alone and he would kill them. In the following paragraphs you will learn about Ted Bundy’s past where he came from, what type of parents he had, and the way he was raised. Why did Ted†¦show more content†¦Ted was feeling resentment towards his mother for lying about who his parents was, and for finding out by his cousin instead of her. Ted Bundy told interviewers that his grandfather was aggressive and abusive. He through his younger daughter down the stairs because she overslept. He abused thee family dog and tortured their neighbor’s cats. When it was time for to talk about the paternity for Ted he was very aggressive because he didn’t want to discuss it. Whenever he talked about his grandmother he always said nice things about her. He said that she was a very timid woman but she was also going to treatments because she was depressed. He was afraid to leave her alone because he didn’t know what might happen. When Ted was younger he showed signs of deadly behaviors. When his aunty was asleep he put knives all around her bed and she felt someone standing over her. As she woke up she saw Ted standing over her holding a Knife and smiling ever since that day she was afraid of him. In 1950 Ted and his mother Eleanor left Philadelphia and she changed her name she didn’t want any more connections with her family. While living in Tacoma, Washington Ted mother met and married Johnny Culpepper Bundy. Johnny adopted Ted because he wanted Ted to know that he wanted them to be close. Ted felt that Johnny wasn’t his father and never will be. Eleanor and Johnny had four children together, and Johnny tried to include Ted in everything thatShow MoreRelatedThe Forensic Science of Criminal Profiling Essay1436 Words   |  6 PagesThe Forensic Science of Criminal Profiling Profiling: an invaluable tool for catching criminals and killers. Profiling is a relatively new approach to crime solving, put in place by forensic psychiatrists. Criminal profiling is the process by which a practitioner analyses information from a crime scene in order to create physical and psychological profile of the perpetrator. All information from a crime scene is a reflection of the criminals behavior. And this behavior can create a surprisinglyRead MoreThe Serial Killers : Ted Bundy1438 Words   |  6 PagesTed Bundy, also known as the campus killer, is one of the United States top known serial killers. This twisted man assaulted and murdered many young girls during the 1970s. Bundy captured his victims by his charismatic and handsome and would win their trust by traits he had. He would act injured or as an authority figure before he murdered and assaulted his victims. After the girls died, Bundy would visit the bodies’ hours later and do sexual things to the corp se until animals would finish the girlRead MoreSerial Killer And Its Effects On Society s Most Dangerous Individuals1880 Words   |  8 Pages The word â€Å"psychopath† may call to mind the sadistic Hollywood cannibal Hannibal Lector or the infamous serial killer from the 1970s Ted Bundy. This perception of psychopathy is accurate but incomplete. Psychopaths are significantly more likely to make contact with the criminal justice system and their crimes also tend to be more violent than those of other criminals (Carrà © et al., 2013). Psychopaths are found to be responsible for approximately 50% of serious crimes and make up about 20% of North

Wednesday, May 6, 2020

Goal Setting and Motivation Essay - 972 Words

Goal Setting and Motivation As I type this in my office at Henley beach in South Australia the Winter month are just around the corner and for a lot of people this can lead to a drop of Motivation.Then again you may live in the Northern Emisphere and are getting excited about be able to exercise in the warmer weather. Either way it’s it beneficial to set goals to help you achieve the outcomes you want and to help with your motivation. There is a principle called the S.M.A.R.T.E.R. principle where each letter is an acronym of the principle. Firstly I think writing down your dreams is a very good thing to do. It gets out what you want to achieve. It is important to look further than just writing it down though. We need steps for how†¦show more content†¦Build a positive expectation of success by regularly thinking about your goals and wondering what it would be like to achieve them. I think it can be useful to write down your goals and place them somewhere you will see them regularly. This could be on a wall in the toilet, or on a small post it note near your workspace. Even on a post it note on the dashboard of your car. My husband and I sit down to review our big goals every 6 month. This means we can see how we are going in achieving these bigger goals. This keeps us on track and accountable. It also provides an opportunity to alter something in our plans if we decide to do so. Another great thing about looking at these long term goals together is that we are on the same page, which helps create unity. It is important to be flexible with your goals Jeffrey Hodges T - Timed T stands for setting a specific target date for your goals. If you dont set times for your goals it is easy to say I will do it later. Goals are dreams with a deadline!. Remember to allow a reasonable amount of time for your goals. Insufficient time will lead to stress and possibly compromising on the quality of the job done and too much time will lead to lack of activity or progress. E - Ecology of your whole self Ive seen a few descriptions of this step so I have included theShow MoreRelatedGoal-Setting Theory of Motivation2104 Words   |  9 PagesJOURNAL OF MANAGEMENT, BUSINESS, AND ADMINISTRATION VOLUME 15, NUMBER 1, 2011 Goal-Setting Theory of Motivation Fred C. Lunenburg Sam Houston State University ABSTRACT Locke and Latham provide a well-developed goal-setting theory of motivation. The theory emphasizes the important relationship between goals and performance. Research supports predictions that the most effective performance seems to result when goals are specific and challenging, when they are used to evaluate performance and linkedRead MoreGoal Setting Theory Of Motivation Essay877 Words   |  4 PagesEssay question: It is often claimed that goal-setting is a theory of motivation which works. Critically evaluate the evidence and discuss the extent to which it supports this claim. Introduction As element that drives the person to strive for the best within his or her own capacity, Guay et al. (2010) defined motivation as reasons that underlie behaviour. It is also interpreted by Huitt, W. (2011) cited Kleinginna and Kleinginna (1981) as an internal state or condition (sometimes described as aRead MoreThe Goal Setting Theory Of Motivation1818 Words   |  8 PagesIn the 1960’s, Edwin Locke put forth the Goal-setting theory of motivation. This theory states that goal setting is fundamentally linked to task performance. It standardizes the idea that specific and challenging goals along with constructive feedback, contribute to enhanced task performance. Locke, one of the most notable contributors in goal setting theory, alongside Gary Latham have contributed to the history and evolution of goal setting while highlighting strengths and weaknesses of the theoryRead MoreMotivation Theory And The Goal Setting Theory1159 Words   |  5 Pages Essay 1 Content theories of motivation focus on the importance of work itself, challenges, growth opportunities and responsibilities that the work provides employees. Process theories of motivation focus on the cognitive processes that are part of employee’s decision making. It also deals with our thoughts and perceptions about our jobs. The decisions are made based on calculations of gains versus loses. Also, when it comes to process theories of motivation, how the work situation is perceivedRead MoreThe Goal Setting Theory for Employee Motivation1302 Words   |  6 PagesGoal setting theory can help motivate employees to do their job as managers can relate to Professor Edwin Locke goal theory. 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The setting of goalsRead MoreMotivation Causes Goal Setting and Action to Achieve Our Dreams902 Words   |  4 Pages1. Title Motivation Goal Setting 2. Introduction Motivation is defined as the process that initiates, guides and maintains goal-oriented behaviours. Motivation is what causes us to act, whether it is getting a glass of water to reduce thirst or reading a book to gain knowledge. (http://psychology.about.com/od/mindex/g/motivation-definition.htm). Goal Setting is where we set specific targets / aims that we wish to achieve, they need to be S.M.A.R.T or else they become dreams rather than believableRead MoreCompare and Contrast Expectancy and Goal Setting Theories of Work Motivation. Which Do You Find the More Useful and Why?1384 Words   |  6 Pagescontrast expectancy and goal setting theories of work motivation. Which do you find the more useful and why? Two of the best known approaches to work motivation are the expectancy theory introduced by Victor Vroom (1964) and the goal-setting theory introduced by Edwin A. Locke (1968). Both of these theories have garnered support from subsequent empirical research and have proved influential in how companies motivate their workers through incentive schemes and objective-setting exercises. As theirRead MoreThe Motivation And Self Efficacy Of Struggling Learners1067 Words   |  5 Pagesthan their peers, due to the negative consequences they experience from underachieving (Hojati Abbasi, 2013). In order to build the motivation and self-efficacy of struggling learners, these individuals need to set short-term goals that are specific and achievable (Margolis McCabe, 2004). In this study, the effects of short-term goal setting among the motivation, self-efficacy, academics, and behaviors of special education middle school students were measured. 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The Twilight Saga 3 Eclipse Chapter 14. DECLARATION Free Essays

string(50) " up the phone and dialed Ren\?\?e’s number\." â€Å"YOU CAN’T BE SERIOUS,† I SAID WEDNESDAY AFTERnoon. â€Å"You’ve completely lost your mind!† â€Å"Say whatever you like about me,† Alice answered. â€Å"The party is still on. We will write a custom essay sample on The Twilight Saga 3: Eclipse Chapter 14. DECLARATION or any similar topic only for you Order Now † I stared at her, my eyes so wide with disbelief it felt like they might fall out and land on my lunch tray. â€Å"Oh, calm down, Bella! There’s no reason not to go through with it. Besides, the invitations are already sent.† â€Å"But . . . the . . . you . . . I . . . insane!† I spluttered. â€Å"You’ve already bought my present,† she reminded me. â€Å"You don’t have to do anything but show up.† I made an effort to calm myself. â€Å"With everything that is going on right now, a party is hardly appropriate.† â€Å"Graduation is what’s going on right now, and a party is so appropriate it’s almost pass.† â€Å"Alice!† She sighed, and tried to be serious. â€Å"There are a few things we need to get in order now, and that’s going to take a little time. As long as we’re sitting here waiting, we might as well commemorate the good stuff. You’re only going to graduate from high school – for the first time – once. You don’t get to be human again, Bella. This is a once-in-a-lifetime shot.† Edward, silent through our little argument, flashed her a warning look. She stuck out her tongue at him. She was right – her soft voice would never carry over the babble of the cafeteria. And no one would understand the meaning behind her words in any case. â€Å"What few things do we need to get in order?† I asked, refusing to be sidetracked. Edward answered in a low voice. â€Å"Jasper thinks we could use some help. Tanya’s family isn’t the only choice we have. Carlisle’s trying to track down a few old friends, and Jasper is looking up Peter and Charlotte. He’s considering talking to Maria . . . but no one really wants to involve the southerners.† Alice shuddered delicately. â€Å"It shouldn’t be too hard to convince them to help,† he continued. â€Å"Nobody wants a visit from Italy.† â€Å"But these friends – they’re not going to be . . . vegetarians, right?† I protested, using the Cullens’ tongue-in-cheek nickname for themselves. â€Å"No,† Edward answered, suddenly expressionless. â€Å"Here? In Forks?† â€Å"They’re friends,† Alice reassured me. â€Å"Everything’s going to be fine. Don’t worry. And then, Jasper has to teach us a few courses on newborn elimination. . . .† Edward’s eyes brightened at that, and a brief smile flashed across his face. My stomach suddenly felt like it was full of sharp little splinters of ice. â€Å"When are you going?† I asked in a hollow voice. I couldn’t stand this – the idea that someone might not come back. What if it was Emmett, so brave and thoughtless that he was never the least bit cautious? Or Esme, so sweet and motherly that I couldn’t even imagine her in a fight? Or Alice, so tiny, so fragile-looking? Or . . . but I couldn’t even think the name, consider the possibility. â€Å"A week,† Edward said casually. â€Å"That ought to give us enough time.† The icy splinters twisted uncomfortably in my stomach. I was suddenly nauseated. â€Å"You look kind of green, Bella,† Alice commented. Edward put his arm around me and pulled me tightly against his side. â€Å"It’s going to be fine, Bella. Trust me.† Sure, I thought to myself. Trust him. He wasn’t the one who was going to have to sit behind and wonder whether or not the core of his existence was going to come home. And then it occurred to me. Maybe I didn’t need to sit behind. A week was more than enough time. â€Å"You’re looking for help,† I said slowly. â€Å"Yes.† Alice’s head cocked to the side as she processed the change in my tone. I looked only at her as I answered. My voice was just slightly louder than a whisper. â€Å"I could help.† Edward’s body was suddenly rigid, his arm too tight around me. He exhaled, and the sound was a hiss. But it was Alice, still calm, who answered. â€Å"That really wouldn’t be helpful.† â€Å"Why not?† I argued; I could hear the desperation in my voice. â€Å"Eight is better than seven. There’s more than enough time.† â€Å"There’s not enough time to make you helpful, Bella,† she disagreed coolly. â€Å"Do you remember how Jasper described the young ones? You’d be no good in a fight. You wouldn’t be able to control your instincts, and that would make you an easy target. And then Edward would get hurt trying to protect you.† She folded her arms across her chest, pleased with her unassailable logic. And I knew she was right, when she put it like that. I slumped in my seat, my sudden hope defeated. Beside me, Edward relaxed. He whispered the reminder in my ear. â€Å"Not because you’re afraid.† â€Å"Oh,† Alice said, and a blank look crossed her face. Then her expression became surly. â€Å"I hate last- minute cancellations. So that puts the party attendance list down to sixty-five. . . .† â€Å"Sixty-five!† My eyes bulged again. I didn’t have that many friends. Did I even know that many people? â€Å"Who canceled?† Edward wondered, ignoring me. â€Å"Rene.† â€Å"What?† I gasped. â€Å"She was going to surprise you for your graduation, but something went wrong. You’ll have a message when you get home.† For a moment, I just let myself enjoy the relief. Whatever it was that went wrong for my mother, I was eternally grateful to it. If she had come to Forks now . . . I didn’t want to think about it. My head would explode. The message light was flashing when I got home. My feeling of relief flared again as I listened to my mother describe Phil’s accident on the ball field – while demonstrating a slide, he’d tangled up with the catcher and broken his thigh bone; he was entirely dependent on her, and there was no way she could leave him. My mom was still apologizing when the message cut off. â€Å"Well, that’s one,† I sighed. â€Å"One what?† Edward asked. â€Å"One person I don’t have to worry about getting killed this week.† He rolled his eyes. â€Å"Why won’t you and Alice take this seriously?† I demanded. â€Å"This is serious.† He smiled. â€Å"Confidence.† â€Å"Wonderful,† I grumbled. I picked up the phone and dialed Rene’s number. You read "The Twilight Saga 3: Eclipse Chapter 14. DECLARATION" in category "Essay examples" I knew it would be a long conversation, but I also knew that I wouldn’t have to contribute much. I just listened, and reassured her every time I could get a word in: I wasn’t disappointed, I wasn’t mad, I wasn’t hurt. She should concentrate on helping Phil get better. I passed on my â€Å"get well soon† to Phil, and promised to call her with every single detail from Forks High’s generic graduation. Finally, I had to use my desperate need to study for finals to get off the phone. Edward’s patience was endless. He waited politely through the whole conversation, just playing with my hair and smiling whenever I looked up. It was probably superficial to notice such things while I had so many more important things to think about, but his smile still knocked the breath out of me. He was so beautiful that it made it hard sometimes to think about anything else, hard to concentrate on Phil’s troubles or Rene’s apologies or hostile vampire armies. I was only human. As soon as I hung up, I stretched onto my tiptoes to kiss him. He put his hands around my waist and lifted me onto the kitchen counter, so I wouldn’t have to reach as far. That worked for me. I locked my arms around his neck and melted against his cold chest. Too soon, as usual, he pulled away. I felt my face slip into a pout. He laughed at my expression as he extricated himself from my arms and legs. He leaned against the counter next to me and put one arm lightly around my shoulders. â€Å"I know you think that I have some kind of perfect, unyielding self-control, but that’s not actually the case.† â€Å"I wish,† I sighed. And he sighed, too. â€Å"After school tomorrow,† he said, changing the subject, â€Å"I’m going hunting with Carlisle, Esme, and Rosalie. Just for a few hours – we’ll stay close. Alice, Jasper, and Emmett should be able to keep you safe.† â€Å"Ugh,† I grumbled. Tomorrow was the first day of finals, and it was only a half-day. I had Calculus and History – the only two challenges in my line-up – so I’d have almost the whole day without him, and nothing to do but worry. â€Å"I hate being babysat.† â€Å"It’s temporary,† he promised. â€Å"Jasper will be bored. Emmett will make fun of me.† â€Å"They’ll be on their best behavior.† â€Å"Right,† I grumbled. And then it occurred to me that I did have one option besides babysitters. â€Å"You know . . . I haven’t been to La Push since the bonfire.† I watched his face carefully for any change in expression. His eyes tightened the tiniest bit. â€Å"I’d be safe enough there,† I reminded him. He thought about it for a few seconds. â€Å"You’re probably right.† His face was calm, but just a little too smooth. I almost asked if he’d rather I stayed here, but then I thought of the ribbing Emmett would no doubt dish out, and I changed the subject. â€Å"Are you thirsty already?† I asked, reaching up to stroke the light shadow beneath his eye. His irises were still a deep gold. â€Å"Not really.† He seemed reluctant to answer, and that surprised me. I waited for an explanation. â€Å"We want to be as strong as possible,† he explained, still reluctant. â€Å"We’ll probably hunt again on the way, looking for big game.† â€Å"That makes you stronger?† He searched my face for something, but there was nothing to find but curiosity. â€Å"Yes,† he finally said. â€Å"Human blood makes us the strongest, though only fractionally. Jasper’s been thinking about cheating – adverse as he is to the idea, he’s nothing if not practical – but he won’t suggest it. He knows what Carlisle will say.† â€Å"Would that help?† I asked quietly. â€Å"It doesn’t matter. We aren’t going to change who we are.† I frowned. If something helped even the odds . . . and then I shuddered, realizing I was willing to have a stranger die to protect him. I was horrified at myself, but not entirely able to deny it, either. He changed the subject again. â€Å"That’s why they’re so strong, of course. The newborns are full of human blood – their own blood, reacting to the change. It lingers in the tissues and strengthens them. Their bodies use it up slowly, like Jasper said, the strength starting to wane after about a year.† â€Å"How strong will I be?† He grinned. â€Å"Stronger than I am.† â€Å"Stronger than Emmett?† The grin got bigger. â€Å"Yes. Do me a favor and challenge him to an arm-wrestling match. It would be a good experience for him.† I laughed. It sounded so ridiculous. Then I sighed and hopped down from the counter, because I really couldn’t put it off any longer. I had to cram, and cram hard. Luckily I had Edward’s help, and Edward was an excellent tutor – since he knew absolutely everything. I figured my biggest problem would be just focusing on the tests. If I didn’t watch myself, I might end up writing my History essay on the vampire wars of the South. I took a break to call Jacob, and Edward seemed just as comfortable as he had when I was on the phone with Rene. He played with my hair again. Though it was the middle of the afternoon, my call woke Jacob up, and he was grouchy at first. He cheered right up when I asked if I could visit the next day. The Quileute school was already out for the summer, so he told me to come over as early as I could. I was pleased to have an option besides being babysat. There was a tiny bit more dignity in spending the day with Jacob. Some of that dignity was lost when Edward insisted again on delivering me to the border line like a child being exchanged by custodial guardians. â€Å"So how do you feel you did on your exams?† Edward asked on the way, making small talk. â€Å"History was easy, but I don’t know about the Calculus. It seemed like it was making sense, so that probably means I failed.† He laughed. â€Å"I’m sure you did fine. Or, if you’re really worried, I could bribe Mr. Varner to give you an A.† â€Å"Er, thanks, but no thanks.† He laughed again, but suddenly stopped when we turned the last bend and saw the red car waiting. He frowned in concentration, and then, as he parked the car, he sighed. â€Å"What’s wrong?† I asked, my hand on the door. He shook his head. â€Å"Nothing.† His eyes were narrowed as he stared through the windshield toward the other car. I’d seen that look before. â€Å"You’re not listening to Jacob, are you?† I accused. â€Å"It’s not easy to ignore someone when he’s shouting.† â€Å"Oh.† I thought about that for a second. â€Å"What’s he shouting?† I whispered. â€Å"I’m absolutely certain he’ll mention it himself,† Edward said in a wry tone. I would have pressed the issue, but then Jacob honked his horn – two quick impatient honks. â€Å"That’s impolite,† Edward growled. â€Å"That’s Jacob,† I sighed, and I hurried out before Jacob did something to really set Edward’s teeth on edge. I waved to Edward before I got into the Rabbit and, from that distance, it looked like he was truly upset about the honking thing . . . or whatever Jacob was thinking about. But my eyes were weak and made mistakes all the time. I wanted Edward to come to me. I wanted to make both of them get out of their cars and shake hands and be friends – be Edward and Jacob rather than vampire and werewolf. It was as if I had those two stubborn magnets in my hands again, and I was holding them together, trying to force nature to reverse herself. . . . I sighed, and climbed in Jacob’s car. â€Å"Hey, Bells.† Jake’s tone was cheerful, but his voice dragged. I examined his face as he started down the road, driving a little faster than I did, but slower than Edward, on his way back to La Push. Jacob looked different, maybe even sick. His eyelids drooped and his face was drawn. His shaggy hair stuck out in random directions; it was almost to his chin in some places. â€Å"Are you all right, Jake?† â€Å"Just tired,† he managed to get out before he was overcome by a massive yawn. When he finished, he asked, â€Å"What do you want to do today?† I eyed him for a moment. â€Å"Let’s just hang out at your place for now,† I suggested. He didn’t look like he was up for much more than that. â€Å"We can ride our bikes later.† â€Å"Sure, sure,† he said, yawning again. Jacob’s house was vacant, and that felt strange. I realized I thought of Billy as a nearly permanent fixture there. â€Å"Where’s your dad?† â€Å"Over at the Clearwaters’. He’s been hanging out there a lot since Harry died. Sue gets lonely.† Jacob sat down on the old couch that was no bigger than a loveseat and squished himself to the side to make room for me. â€Å"Oh. That’s nice. Poor Sue.† â€Å"Yeah . . . she’s having some trouble. . . .† He hesitated. â€Å"With her kids.† â€Å"Sure, it’s got to be hard on Seth and Leah, losing their dad. . . .† â€Å"Uh-huh,† he agreed, lost in thought. He picked up the remote and flipped on the TV without seeming to think about it. He yawned. â€Å"What’s with you, Jake? You’re like a zombie.† â€Å"I got about two hours of sleep last night, and four the night before,† he told me. He stretched his long arms slowly, and I could hear the joints crack as he flexed. He settled his left arm along the back of the sofa behind me, and slumped back to rest his head against the wall. â€Å"I’m exhausted.† â€Å"Why aren’t you sleeping?† I asked. He made a face. â€Å"Sam’s being difficult. He doesn’t trust your bloodsuckers. I’ve been running double shifts for two weeks and nobody’s touched me yet, but he still doesn’t buy it. So I’m on my own for now.† â€Å"Double shifts? Is this because you’re trying to watch out for me? Jake, that’s wrong! You need to sleep. I’ll be fine.† â€Å"It’s no big deal.† His eyes were abruptly more alert. â€Å"Hey, did you ever find out who was in your room? Is there anything new?† I ignored the second question. â€Å"No, we didn’t find anything out about my, um, visitor.† â€Å"Then I’ll be around,† he said as his eyes slid closed. â€Å"Jake . . . ,† I started to whine. â€Å"Hey, it’s the least I can do – I offered eternal servitude, remember. I’m your slave for life.† â€Å"I don’t want a slave!† His eyes didn’t open. â€Å"What do you want, Bella?† â€Å"I want my friend Jacob – and I don’t want him half-dead, hurting himself in some misguided attempt -â€Å" He cut me off. â€Å"Look at it this way – I’m hoping I can track down a vampire I’m allowed to kill, okay?† I didn’t answer. He looked at me then, peeking at my reaction. â€Å"Kidding, Bella.† I stared at the TV. â€Å"So, any special plans next week? You’re graduating. Wow. That’s big.† His voice turned flat, and his face, already drawn, looked downright haggard as his eyes closed again – not in exhaustion this time, but in denial. I realized that graduation still had a horrible significance for him, though my intentions were now disrupted. â€Å"No special plans,† I said carefully, hoping he would hear the reassurance in my words without a more detailed explanation. I didn’t want to get into it now. For one thing, he didn’t look up for any difficult conversations. For another, I knew he would read too much into my qualms. â€Å"Well, I do have to go to a graduation party. Mine.† I made a disgusted sound. â€Å"Alice loves parties, and she’s invited the whole town to her place the night of. It’s going to be horrible.† His eyes opened as I spoke, and a relieved smile made his face look less worn. â€Å"I didn’t get an invitation. I’m hurt,† he teased. â€Å"Consider yourself invited. It’s supposedly my party, so I should be able to ask who I want.† â€Å"Thanks,† he said sarcastically, his eyes slipping closed once more. â€Å"I wish you would come,† I said without any hope. â€Å"It would be more fun. For me, I mean.† â€Å"Sure, sure,† he mumbled. â€Å"That would be very . . . wise . . .† His voice trailed off. A few seconds later, he was snoring. Poor Jacob. I studied his dreaming face, and liked what I saw. While he slept, every trace of defensiveness and bitterness disappeared and suddenly he was the boy who had been my very best friend before all the werewolf nonsense had gotten in the way. He looked so much younger. He looked like my Jacob. I nestled into the couch to wait out his nap, hoping he would sleep for a while and make up some of what he’d lost. I flipped through channels, but there wasn’t much on. I settled for a cooking show, knowing, as I watched, that I’d never put that much effort into Charlie’s dinner. Jacob continued to snore, getting louder. I turned up the TV. I was strangely relaxed, almost sleepy, too. This house felt safer than my own, probably because no one had ever come looking for me here. I curled up on the sofa and thought about taking a nap myself. Maybe I would have, but Jacob’s snoring was impossible to tune out. So, instead of sleeping, I let my mind wander. Finals were done, and most of them had been a cakewalk. Calculus, the one exception, was behind me, pass or fail. My high school education was over. And I didn’t really know how I felt about that. I couldn’t look at it objectively, tied up as it was with my human life being over. I wondered how long Edward planned to use this â€Å"not because you’re scared† excuse. I was going to have to put my foot down sometime. If I were thinking practically, I knew it made more sense to ask Carlisle to change me the second I made it through the graduation line. Forks was becoming nearly as dangerous as a war zone. No, Forks was a war zone. Not to mention . . . it would be a good excuse to miss the graduation party. I smiled to myself as I thought of that most trivial of reasons for changing. Silly . . . yet still compelling. But Edward was right – I wasn’t quite ready yet. And I didn’t want to be practical. I wanted Edward to be the one. It wasn’t a rational desire. I was sure that – about two seconds after someone actually bit me and the venom started burning through my veins – I really wouldn’t care anymore who had done it. So it shouldn’t make a difference. It was hard to define, even to myself, why it mattered. There was just something about him being the one to make the choice – to want to keep me enough that he wouldn’t just allow me to be changed, he would act to keep me. It was childish, but I liked the idea that his lips would be the last good thing I would feel. Even more embarrassingly, something I would never say aloud, I wanted his venom to poison my system. It would make me belong to him in a tangible, quantifiable way. But I knew he was going to stick to his marriage scheme like glue – because a delay was what he was clearly after and it was working so far. I tried to imagine telling my parents that I was getting married this summer. Telling Angela and Ben and Mike. I couldn’t. I couldn’t think of the words to say. It would be easier to tell them I was becoming a vampire. And I was sure that at least my mother – were I to tell her every detail of the truth – would be more strenuously opposed to me getting married than to me a becoming vampire. I grimaced to myself as I imagined her horrified expression. Then, for just a second, I saw that same odd vision of Edward and me on a porch swing, wearing clothes from another kind of world. A world where it would surprise no one if I wore his ring on my finger. A simpler place, where love was defined in simpler ways. One plus one equals two. . . . Jacob snorted and rolled to his side. His arm swung off the back of the couch and pinned me against his body. Holy crow, but he was heavy! And hot. It was sweltering after just a few seconds. I tried to slide out from under his arm without waking him, but I had to shove a little bit, and when his arm fell off me, his eyes snapped open. He jumped to his feet, looking around anxiously. â€Å"What? What?† he asked, disoriented. â€Å"It’s just me, Jake. Sorry I woke you.† He turned to look at me, blinking and confused. â€Å"Bella?† â€Å"Hey, sleepy.† â€Å"Oh, man! Did I fall asleep? I’m sorry! How long was I out?† â€Å"A few Emerils. I lost count.† He flopped back on the couch next to me. â€Å"Wow. Sorry about that, really.† I patted his hair, trying to smooth the wild disarray. â€Å"Don’t feel bad. I’m glad you got some sleep.† He yawned and stretched. â€Å"I’m useless these days. No wonder Billy’s always gone. I’m so boring.† â€Å"You’re fine,† I assured him. â€Å"Ugh, let’s go outside. I need to walk around or I’ll pass out again.† â€Å"Jake, go back to sleep. I’m good. I’ll call Edward to come pick me up.† I patted my pockets as I spoke, and realized they were empty. â€Å"Shoot, I’ll have to borrow your phone. I think I must have left his in the car.† I started to unfold myself. â€Å"No!† Jacob insisted, grabbing my hand. â€Å"No, stay. You hardly ever make it down. I can’t believe I wasted all this time.† He pulled me off the couch as he spoke, and then led the way outside, ducking his head as he passed under the doorframe. It had gotten much cooler while Jacob slept; the air was unseasonably cold – there must be a storm on the way. It felt like February, not May. The wintry air seemed to make Jacob more alert. He paced back and forth in front of the house for a minute, dragging me along with him. â€Å"I’m an idiot,† he muttered to himself. â€Å"What’s the matter, Jake? So you fell asleep.† I shrugged. â€Å"I wanted to talk to you. I can’t believe this.† â€Å"Talk to me now,† I said. Jacob met my eyes for a second, and then looked away quickly toward the trees. It almost looked like he was blushing, but it was hard to tell with his dark skin. I suddenly remembered what Edward had said when he dropped me off – that Jacob would tell me whatever he was shouting in his head. I started gnawing on my lip. â€Å"Look,† Jacob said. â€Å"I was planning to do this a little bit differently.† He laughed, and it sounded like he was laughing at himself. â€Å"Smoother,† he added. â€Å"I was going to work up to it, but† – and he looked at the clouds, dimmer as the afternoon progressed – â€Å"I’m out of time to work.† He laughed again, nervous. We were still pacing slowly. â€Å"What are you talking about?† I demanded. He took a deep breath. â€Å"I want to tell you something. And you already know it . . . but I think I should say it out loud anyway. Just so there’s never any confusion on the subject.† I planted my feet, and he came to a stop. I took my hand away and folded my arms across my chest. I was suddenly sure that I didn’t want to know what he was building up to. Jacob’s eyebrows pulled down, throwing his deep-set eyes into shadow. They were pitch black as they bored into mine. â€Å"I’m in love with you, Bella,† Jacob said in a strong, sure voice. â€Å"Bella, I love you. And I want you to pick me instead of him. I know you don’t feel that way, but I need the truth out there so that you know your options. I wouldn’t want a miscommunication to stand in our way.† How to cite The Twilight Saga 3: Eclipse Chapter 14. DECLARATION, Essay examples