The Miss Leadings Of William Shakespeare s Romeo And Juliet

The miss leadings of Romeo and Juliet Evelyn McHale is peacefully sleeping. Her ankles are crossed; lines follow down to her shoeless feet. Her gloved hand pulls ever so slightly on her pearl necklace, the other lying limp beside her craned head. Her face is relaxed, red lips parted and white eye lids closed. The stunning Evelyn McHale is seemingly sleeping on the hood of a car. The hood of the Black Cadillac contorts to Miss McHale’s body. The medal crushed under her, following the curvature of her slim figure. Shattered Glass seems to be near her face but does not dare damage her beauty. Four minutes after Evelyn McHale’s suicide, Rover C. Wile snapped a picture of Evelyn; this picture was titled â€Å"The Most Beautiful Suicide†. Evelyn McHale was immortalized by the beauty in her death and the tragedy in her story. (â€Å"Picture of the Week†) Evelyn McHale jumped from the Empire state building on May first 1947. She was the eleventh person to jump from the Empire state building since it had opened on May first 1931. She left a suicide note saying she didn’t want to be remembered. She wanted to be cremated and forgotten. She said her fiancà © deserved someone better and she’d never make a good mother. She was planned to be married in June of 1947. The last person she was with was her fiancà ©, he had no idea that she was anything but happy. When she landed on the car, the sound was reported to be as loud as an explosion. (â€Å"Picture of the Week†) I think use to think about deathShow MoreRelatedEssay on Comparing Romeo and Juliet Films1328 Words   |  6 PagesComparing Romeo and Juliet Films In this essay I intend to compare both the part scenes of Franco Zefferelli and Baz Lurhman movie. Franco’s film was screened in 1970; the actors who play the role of RomeoJuliet are Leonardo Whiting and Olivia Hussey. Baz’s film was screened in 1997. Leonardo Di Caprio played the role of Romeo and Clare Danes had played the role of Juliet. In this essay I will discuss the differences in both these film that tell the sameRead MoreCrm in Supermarkets30832 Words   |  124 PagesEB 2003-02 February 2003 FOOD INDUSTRY MANAGEMENT CORNELL U N I V E R S I T Y Customer Relationship Marketing (CRM) in the U.S. Supermarket Industry: Current Status and Prospects Gerard F. Hawkes Senior Extension Associate Food Industry Management Program Department of Applied Economics and Management College of Agriculture and Life Sciences Cornell University, Ithaca, NY 14853-7801 Teaching †¢ Research †¢ Executive Education IT IS THE POLICY OF CORNELL UNIVERSITY actively to support

A Short Note On Global Advertising Campaign - 2747 Words

AMN 421: Contemporary issues in advertising Research paper Thi Thu Ha Nguyen- N9059393 20 October 2014 STANDARDISATION VESUS LOCALISATION IN GLOBAL ADVERTISING CAMPAIGN 1. Abstract: Standardised advertising seeks to maintain a consistent product image with a uniform message, and capitalises on the scale economy by adopting the same advertising message across markets. It works well for market segments to reach production and marketing goals in term of size. It is greater to standardise an advertisement’s visual elements or delivers a consistent brand image over the globe. In addition, the company sells their brand globally, but using ways that are appropriate for particular culture, thus achieving a balance between global and local. It is called â€Å"Localization†. The case study of Pepsi’s campaign â€Å"Live for now† will show how standardisation and localisation work together. 2. Key words: globalisation, advertising, standardisation, localisation, media 3. Introduction: The research paper focuses on international advertising campaign. It defines and explains how standardisation and localisation strategies work in top-down approach. The literature review shows that most scholars prefer localisation in current context because they think that each market has unique characteristics. However, the case study of Pepsi â€Å"Live for now† demonstrates that they can work together. The standardisation creates global recognition; whereas localisation adapts the uniqueShow MoreRelatedHow Do Ngos Represent Humanitarian Issues Trough Images in Advertising?1603 Words   |  7 Pagesissues trough images in advertising? Negative images of developing countries are a common means adopted by Non Governmental Organisations to raise financial support for those countries. However there has been much discussion as to weather such advertising for fundraising campaigns is really authentic and if the images used represent the issue as it is. More and more NGOs turn their backs on the use of negative images, for example of starving children, and adopting new advertising strategies. When theRead MoreCase Study: Samsung Electronics1366 Words   |  5 Pages†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦4 RESULTS †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.6 RESEARCH OUTCOMES †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦..†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦..10 REFERENCES †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦10 Company introduction: Samsung is the global leader in technology and social change and development for the past 30 years. Samsung Electronics is the worlds largest information technology company measured by 2012 revenues.. Samsung has revolutionized the modern era of technology and is oneRead MoreDemand and Supply of Pepsi1003 Words   |  5 Pagesagainst companies in our industry, a downturn in economic conditions or taxes specifically targeting the consumption of our products. Any of these changes may reduce consumers willingness to purchase our products. See also the discussions under The global economic downturn has resulted in unfavorable economic conditions and increased volatility in foreign exchange rates and may have an adverse impact on our business results or financial condition. and Changes in the legal and regulatory environmentRead MoreSocietal Marketing Concept968 Words   |  4 Pagestrend. Under the Societal Marketing Concept organizations have to balance company profits, customers w ants and the society s interests. The problem is to determine what is best for the society in this case. Because there is a difference between short term consumers wants and long term consumers welfare (Brown, 2005). This issue can be very hard to handle, because it is not all companies market with a social conscience. In one hand consumers say they want healthier foods, but in theRead More Societal Marketing Concept Essay899 Words   |  4 Pagesthis trend. Under the Societal Marketing Concept organizations have to balance company profits, customers’ wants and the societys interests. The problem is to determine what is best for the society in this case. Because there is a difference between short term consumers’ wants and long term consumers’ welfare (Brown, 2005). This issue can be very hard to handle, because it is not all companies market with a social conscience. In one hand consumers say they want healthier foods, but in the other handRead MoreCase Analysis Product RED1261 Words   |  5 PagesBono and Bobby Shriver to engage private companies and citizens to support the common cause (Red, n.d.) . Product RED was a campaign developed with the purpose to raise funds for chronic diseases such as AIDS in Africa (Youngme Moon M. N., 2009).When a consumer buy a product with the RED logo on it, a certain percentage of the profit from the sale of that product goes to the Global fund that provide support to programs that fight diseases such as AIDS, Malaria and Tuberculosis (Hanagan, 2009). ThoughRead MoreJack Link’s Beef Jerky Going Hip and Healthy Essay1280 Words   |  6 Pagessubject to public stereotypes such as they are boring, not cool, eaten primarily by men, and not good for you. 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While advertising for Campbell s Chunky, a soup bolstering flavors such as Philly Cheesesteak, is broadcast during NFL football matches to attract the 18-49 years male target market. To keep up with market trends of increased consumer demand for healthy

William Shakespeare free essay sample

This paper details the many different works of William Shakespeare. This paper is an in-depth analysis and examination of the contribution that William Shakespeare made to the literary world. The author details Shakespeares mysterious life, including speculation as to who he may have really been. The paper covers the many different themes covered in his many plays including ambition, cruelty, justice, reconciliation, madness, betrayal and destiny that were found in Macbeth, King Lear, Hamlet and Julius Caesar. The author finds that Shakespeare also used his plays to comment on political events such as in Julius Caesar, Comedy of Errors and Henry VIII. Throughout the paper the author details his masterful understanding of the human character and unparalleled mastery of the English language, a rich imagination and commentary on life in the early 18th century. Shakespeare also wrote over 150 sonnets and there is some speculation that they may have been autobiographical, but once again the author finds that there is no proof. We will write a custom essay sample on William Shakespeare or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page How is Shakespeare viewed by great figures of the theater? Shakespeare is the greatest discernible influence in the work of Orson Wells (Gottlieb 2000). a theatrical and cinematic director, actor, entrepreneur, public figure, and educational and political activist. Wells describes Shakespeare as embodying the fulfillment of almost utopian personal and sociopolitical desires, a figure of considerable stature, power and popularity, a truly great one who bridges the worlds of critical and commercial success. Shakespeare, in Wells mind, merges individual imagination and artistic independence with tradition and social responsibility, and emphasizes that he has that unparalleled capacity to entertain, educate, transport and ultimately unify divergent audiences, high and low. (Gottlieb)

Simple Diffusion on Cell Transport Mechanisms and Permeability free essay sample

Cell Transport Mechanisms and Permeability: Activity 4: Simulating Filtration Lab Report Pre-lab Quiz Results You scored 100% by answering 4 out of 4 questions correctly. 1. Filtration is a process that You correctly answered: c. is passive. 2. Filtration is dependent upon a You correctly answered: b. hydrostatic pressure gradient. 3. The filtrate You correctly answered: d. All of these answers are correct. An important place that filtration takes place in the body is in You correctly answered: d. the kidneys. 10/04/12 page 1 Experiment Results Predict Question: Predict Question 1: What effect will increasing the pore size of the filter have on the filtration rate? Your answer : c. The filtration rate will increase. Predict Question 2: What will happen if you increase the pressure above the beaker (the driving pressure)? Your answer : a. The filtration rate will increase. Stop Think Questions: The reason none of the solutes were present in the filtrate was that You correctly answered: b. the solutes were all too large to pass through. We will write a custom essay sample on Simple Diffusion on Cell Transport Mechanisms and Permeability or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page After filtration, substances that pass through the filter are called the filtrate, which includes You correctly answered: d. ll of the above. 2. The top beaker in the simulation corresponds to Your answer: d. the kidney tubule. Correct answer: a. the blood capillary. 3. Why was there not 100% recovery of the Na+ Cl- solute with any of the membranes? You correctly answered: c. Some of the solute remained on the membrane filter. 4. An increase in blood pressure would probably initially filtration in the kidneys. You correctly answered: b. increase the rate of 010/04/12 page 3 Review Sheet Results 1. Explain in your own words why increasing the pore size increased the filtration rate. Use an analogy to support your statement. How well did the results compare with your prediction? Your answer: it made for a bigger space for the items to pass through 2. Which solute did not appear in the filtrate using any of the membranes? Explain why. Your answer: powdered charcoil. it;s too large 3. Your answer: it made for a bigger space for the items to pass through 2. Which solute did not appear in the filtrate using any of the membranes? Explain why. Your answer: powdered charcoil. it;s too large 3 Why did increasing the pressure increase the filtration rate but not the concentration of solutes? How well did the results compare with your prediction? Your answer: the pressure forced the solutes through, it did not change what went through. References Widdas, W. F. Transport mechanisms in the foetus. British medical bulletin 17.2 (1961): 107-111. Camenisch, Gian, et al. Estimation of permeability by passive diffusion through Caco-2 cell monolayers using the drugs lipophilicity and molecular weight. European journal of pharmaceutical sciences 6.4 (1998): 313-319. Stevens, Bruce R., Jonathan D. Kaunitz, and Ernest M. Wright. Intestinal transport of amino acids and sugars: advances using membrane vesicles. Annual Review of Physiology 46.1 (1984): 417-433. Stevens, Bruce R., Jonathan D. Kaunitz, and Ernest M. Wright. Intestinal transport of amino acids and sugars: advances using membrane vesicles. Annual Review of Physiology 46.1 (1984): 417-433. Park, C. R., et al. The action of insulin on the transport of glucose through the cell membrane. The American journal of medicine 26.5 (1959): 674-684. Gjedde, Albert. High†and low†affinity transport of D†glucose from blood to brain. Journal of neurochemistry 36.4 (1981): 1463-1471. Gerbeau, Patricia, et al. Aquaporin Nt†TIPa can account for the high permeability of tobacco cell vacuolar membrane to small neutral solutes. The Plant Journal 18.6 (1999): 577-587. Passow, Hermann. Molecular aspects of band 3 protein-mediated anion transport across the red blood cell membrane. Reviews of Physiology, Biochemistry and Pharmacology, Volume 103. Springer Berlin Heidelberg, 1986. 61-203.

Merchant Of Venice Essays (1257 words) - Film, Literature

Merchant Of Venice "How little is the cost I have bestowed in purchasing the semblance of my soul,"(3.5.19-20) is where the heart of this play is in my eyes. Portia doing what she can for her one true love, Bassanio. Money is of no importance to her especially when it comes to the happiness or unhappiness of Bassanio. There are many places in the Merchant of Venice that show Portia and Bassanio's indifference, and what seems to be apathy toward wealth. Many are hidden and many are as clear as day to the reader. I found that reading into The Merchant of Venice was a fun and interesting experience. The way Shakespeare wrote his plays makes people really think about what they are reading; it reminded me of a maze. Portia, an unspoiled Princess to riches, a Princess that doesn't need to think or worry about money. It is something she has an unimaginable amount of, yet it doesn't change who she is or what her values are. Her father seemed to instill in her that money isn't everything to everybody; how you care about people and values are what matter the most in life. When we first see Bassanio, he is telling Antonio of a secret trip he plans to take to win the heart of Portia; yet he has no means to get there due to his extravagant living which has left him in debt to others. At first money seems to be of some importance to Bassanio, but towards the middle of the play his thoughts seem to change. Although Portia's father does not have a so-called character in The Merchant of Venice; his presence is definitely felt through Portia's character, as well as the scrolls on the caskets. In doing this, Portia's father in a way still had a hand helping to choose the right husband for his daughter. When each of the princes come to woo Portia and go into the casket room, they look for what would be the most creative answer in picking out the casket. The gold casket scroll reads "Who chooseth me shall gain what many men desire." (2.7.4-5). When the reader first sees this, he thinks the gold casket would make the most sense. Portia's father would have put her picture in there, because it is gold and full of riches as is Portia. Reading into this the reader might think that Portia's father would not put her picture in this one, because love is richer than gold. The prince that would pick this one is not interested in love only Portia's wealth. The second casket made of silver states "Who chooseth me shall get as much as he deserves." (2.7.7) I have yet to think why any Prince with half a brain would pick this casket over gold or lead. To pick this, deep inside, they did not want to marry Portia. Apparently, the gold wasn't intriguing enough for them yet the lead was too poor. The lead casket would be the most appealing to the Prince who really wants to win Portia's heart and not her riches. This scroll reads "Who chooseth me must give and hazard all he hath." (2.7.9) When Bassanio and Portia discuss his choices she asks him to think about his choices carefully because it will determine their future forever. Bassanio although deeply in debt to moneylenders, can see past the gold and silver of the first two caskets, and hazards his chance with the lead casket. The scroll inside this casket proves this point;" You that chose not by the view, Chance as fair, and choose as true: Since this fortune falls to you, Be content, and seek no new. If you be well pleas'd with this, And hold your fortune for your bliss, Turn you where your lady is, and claim her with a loving kiss."(3.2.130-138) From the beginning of the play, Portia seems for those times more or less of a free spirit. She has been in Belmont all of her life and knows little about Venice and its residents lifestyles. Portia's father seemed to have instilled values and love in Portia from a very young age. She was taught to love and to be kind and that money could not buy love and happiness. Earlier in the play Bassanio borrows 3,000 ducats from Shylock on Antonio's word that it will be paid back in full. Shylock is a stereotypical Jew who is a moneylender that insists on charging interest on monies loaned out. He needed

Current Financial Struggles

Current Financial Struggles Introduction I would wish to raise my concern concerning the trends in demand and supply in the world as I propose that you look at my opinions and cover them in the coming month’s economic magazine. I have been following your articles in the economic magazine and I have realized that the issue has not been covered for a long time.Advertising We will write a custom article sample on Current Financial Struggles specifically for you for only $16.05 $11/page Learn More My interest in this topic has been brought about by the current trends in the micro economic sector. It has become quite hard to predict the trends in demand and supply since the trends have been changing in a very irregular manner. It is therefore important to look at this topic in detail in order to determine the causes of the current trends, the effects they may have in the micro economic sector and the possible solutions. Demand refers to the amount of goods and services that consumers may be willing to purchase at a given price. It is therefore, an economic principle that shows the relationship between the consumers’ willingness and desire to pay for a certain commodity and price. Supply on the other hand is an economic principle that refers to the total number of goods and services at the exposure of the consumer at a given price at a particular time. Demand and supply go hand in hand in that when the demand goes high then the supply is low and that the when the supply is high, the demand goes down. Market Forces of demand and Supply One of the major causes of the current fluctuation of demand and supply in the microeconomic sector is weather which has currently become so unpredictable due to global warming among other issues. Weather mostly affects agricultural products. A good example of the effect of weather is when the cold weather hits Florida; the price of juice rises throughout the nation. This affects the demand and supply of the commodity a grea t deal. It is not likely to attract the supply of the commodity from the producers while the demand goes down as the consumers tries to shy away from the high prices. When the warm weather prevails in summers, prices of hotel rooms in England plummet all as a result of effects of demand and supply Weather also affects the demand and supply of clothing as well as the production of various goods (Mankiw 65). Globalization and changes in technology have also lead to unpredictable fluctuation in demand and supply. This is a very broad topic in that it affects close to all areas of the economy. For example, any disruption occurring in the oil producing countries will affect the world supply of oil and this effect will be felt even in countries which do not produce oil.Advertising Looking for article on business economics? Let's see if we can help you! Get your first paper with 15% OFF Learn More Globalization has made countries depend on each and as a result and this has enhanced the effect of supply and demand forces. Nowadays, agricultural products can be produced at any time of the year using technology such as irrigation and green houses that do not depend on weather patterns. It is therefore hard to predict market trends using weather patterns and in most cases nowadays, other factors leads to such changes. Population has been another major factor contributing to unpredictable fluctuations in demand and supply. When the populations increase a need to supply them with essential products is created. The population in many nations has been falling thus affecting demand and supply. However, there has been a lot of immigration throughout the world and it is hard to predict the future of the population in any country. This has also been affected by political stability in various nations whereby a nation may be under populated today and overpopulated tomorrow as people flee from political instability. This also affects demand and supply a gre at deal. Effects of fluctuating demand and supply to a nation There are various effects of fluctuation of demand and supply to the microeconomic sector in any nation. For instance, price increase and decrease has so much effect on the total expenditure as explained by the price elasticity of demand and supply. This refers to the measure of responsiveness of the supply and demand of a commodity to changes in price (Bernanke 92). The measure of responsiveness depends on the nature of the commodity. For instance, changes in prices of some commodities such as salt may not affect its demand or supply at all. This is because people won’t make to do without this commodity since it does not have complements or substitutes. The expenditure on such a commodity may therefore be very high due to high prices since consumers may not be in a position to do away with them. On the other hand, changes in prices of some commodities may not have so much effect on the expenditure. These are mainl y the commodities which contain complements. For instance, when the price of coffee rises, most consumer will likely shift using coffee substitutes. For commodities which have supplements, when one commodity is on demand, then its supplement’s demand must also rise. Supplements refer to commodities which complete the others. For example, Wheat flour cannot be used without cooking oil thus the demand of one of them promotes the demand of the other.Advertising We will write a custom article sample on Current Financial Struggles specifically for you for only $16.05 $11/page Learn More The effects of unpredictable weather changes have been prevalent so much in the microeconomic sector since it has been hard to plan for the future. The same case applies to globalization, changes in technology and population changes. All these issues have made it hard to predict demand and supply of commodities in the micro economic sectors thus calling for the producers a nd consumers to find solutions to the prevailing problems Solutions The current situation in the world is a challenging situation since most of its causes are issues that are not planned for or are determined by nature. For instance, weather changes are natural though in some instances are influenced by human activities. Human beings therefore need to rectify the source of problems such as reviving water catchment as well as applying their knowledge in better methods of food production. Population changes can be controlled through controlling of immigration and political stability. Finally, globalization and advancing technology are human controlled activities thus cooperation can put them under control in order to solve the problem of demand and supply. Conclusion Demand and supply is a very important issue in the microeconomic sector since it directly or indirectly affects people’s daily lives. It is therefore important to consider the issues surrounding this issue in order to protect the economy as well as the population. Bernanke, Ben. Principles of Microeconomics. China: McGraw Hill, 2008. Print. Mankiw, Gregory. Principles of Microeconomics. New York: Cengage Learning, 2008. Print.

Accounting 1 Essay Example | Topics and Well Written Essays - 500 words - 1

Accounting 1 - Essay Example The organization had elaborate risk assessment about which every employee was cognizant. The organization conducted risk awareness and emergency response training regularly. Fire extinguishers were regularly checked and replaced and there were notices providing information on what do in the event of a hazard. The management routinely supplied employees with the latest information on common and emergent risks. I realized that the organization monitored and reviewed its internal controls periodically. The petty cash was checked at the end of every week and recommendations given on what to avoid and what to improve. Internal controls that were found ineffective or failing after monitoring were replaced and others were improved in order to enhance their functionality. The organization had a comprehensive yet simple way of reporting risks to the relevant officials in which everybody knew the most immediate person to approach. The organization had good information and communication system in place. The management issued memos in good time when calling for a meeting and every employee was issued with a copy of previous meeting’s minutes with the day’s agenda. The management was respectful in the way it summoned employee for disciplinary action and they did not let other employees know about it. The most outstanding element of the organization’s internal controls was its control activities. The duties of different individuals were separated and every individual knew what they were supposed to do and what to forward to the next person. This was most evident in the accounts department where duties such as approval of purchases, reception of deliveries, approval of invoices, review, and reconciliation of financial records were handled by different people. There were clear procedures for transactional authorization where there were officers entrusted with authorizing purchases and payments. No such transactions could be undertaken

Baltimore-City Evaluation Paper Research Example | Topics and Well Written Essays - 2500 words

Baltimore-City Evaluation - Research Paper Example Climate was perfect for agriculture, forest area was large and spacious and the Countryside proved to be very fertile. Baltimore County was first gifted in 1632 by England’s King to George Calvert and the name Baltimore County was adopted in 1639 (City-Data, 2009). The town of Baltimore became established in 1656, primarily due to the booming tobacco industry and the dependence of local economy of tobacco. Baltimore’s has had its share of ups and downs, milling flour and grain, which was affected greatly by the revolutionary war. Being the site of the first public railroad in 1828 Baltimore became connected to the rest of the country, remaining impartial for the most part during the civil war acting as a military depot ;despite Maryland belonging to the Union. The city was able to remain prosperous in World War II as well, being a military supply center and escaped World War I unscathed. Physical Site Baltimore city’s topography is characterized primarily by stre ams and capes, though there are 7 bays, an island, lake, summit and spring (Maryland Hometown Locator, 2012). Baltimore city is actually lies within the coastal plain of the Atlantic and the Piedmont Plateau. Stream valleys run through the almost level uplands (Baltimore Ecosystem Study, 2012). Surrounded nearly completely by the County of Baltimore, waterfront property is available with regional choice property being waterfront and the more distressed property being located further away from the waterfront. Baltimore’s down town area consists of City Center, Inner Harbor, west Side and Camden yards. Inner Harbor allows you easy access to the National Museum and Camden Yards is home to the architecturally acclaimed stadium of the Baltimore Orioles, while the Baltimore Ravens play at M and T Bank Stadium, which is down town with a mile of Inner Harbor. Though not considered downtown Curtis Bay allows the distinct opportunity to experience the feel of historical military sites as Fort Armistead and Battery Irons (Maryland Hometown Locator, 2012). Other recreational opportunities the city provides are multiple shopping venues, fine dining and unique restaurants such as the Bubba Gump Shrimp Company, and multiple parks and natural settings are almost always in close distance (City of Baltimore, 2012). Because Baltimore has a variety of unique entertainment opportunities, allows those who enjoy the water easy access in many locations and is home to many historical sites I rated Baltimore’s physical characteristics an 8. This was primarily due to the fact that Baltimore seems heavily focused on Adult with fewer attractions geared towards children. Street Morphology Downtown Baltimore’s streets follow a grid pattern though their development is suited to the organic nature of the surroundings, located around Inner Harbor. Breaks or deviations in the grid are found around the Harbor as well as numerous parks and natural greenery is located surround ing much of the Harbor. Inlets disrupt the grid and Harbor Bridge walk connects these busy areas which contain the Baltimore World Center and the national Aquarium (Visit Baltimore, 2012). The streets attempt at a Baroque pattern is evidenced around Camden Yards Oriole Park and M and T Bank Stadium though their concepts remain grid in nature major streets do intersect around these large

Effect of Marriages on Crime Rates Article Example | Topics and Well Written Essays - 500 words

Effect of Marriages on Crime Rates - Article Example In this paper the authors through evidence are illustrating that marriage can reduce the crimes committed by an individual as it can involve the individual in social bonds. According to the authors the research done by them is however not accurate as all the figures in an individual's life cannot be kept constant and this restrains the authors to conclude authentically that marriage reduces the crime rates. However the evidence given by the authors supports the notion that rate of crime does get affected because of the bond of marriage. The authors hypothesize that getting involved in social bonds and activities may help one to avoid committing crime. According to the authors marriage is a social bond which inflicts social responsibility and compulsions on one individual which further diverts the individual from committing a crime. The change in routine is also marked as important by the authors as it helps to change the mood and passion of an individual. It makes one individual spend more time with his family rather than friends (Warr 1998: 183). Furthermore the monitoring activity done by the spouses is supposed to be helpful to divert one from criminal activities. The supervision done by spouses can help men to avoid committing any crime (Waite and Gallagher 2000: 24).

Hiv Infected Black African Community Health And Social Care Essay

Hiv Infected Black African Community Health And Social Care Essay Today the epidemic HIV/AIDS has become a universal issue demanding attention of all public sectors. The HIV infection has developed as a major public health importance in the whole world with its increasing prevalence rate. The human immunodeficiency virus (HIV) is a retrovirus which affects the immune system of the body and destroys all its functions where an acquired immunodeficiency syndrome (AIDS) is the most advance phase of HIV infection (World health organisation, 2010). Globally around 60 million people are affected since the start of this epidemic HIV and till now around 20 million people are died due to infection of this virus (UNAIDS, 2005). In the year 2007, it was estimated that around 33.2 million people were living with HIV in the world (UNAIDS, 2007). Similarly in United Kingdom, the prevalence of HIV infected people was 77,400 in 2007 (Health Protection Agency, 2008). The London city continues to be the UKs HIV/AIDS hot spot with leading numbers of HIV cases as compa red to UK. In London, the population of Black Africans are most rapidly increasing in terms of HIV infection and forming the second largest group of HIV/AIDS service users (Erwin and peters, 1999). This essay will try to investigate and analyse the causes of increasing prevalence of HIV infection in Black African people in London Borough of Lewisham. The essay will briefly examine the epidemiology of HIV infection in Lewisham particularly with focusing on Black African ethnicity. This essay will also focus on socio economic determinants of HIV prevalence in Black African community in London borough of Lewisham. With the help of this research the factors influencing HIV/AIDS in Black African population in Lewisham would be studied. This will be an attempt to analyse the strategies and interventions of the issue regarding global, national and mainly the local perspectives. It focuses on black African communities because they are disproportionately affected by HIV infection compared to other minority ethnic groups. The HIV infection is mainly transmitted through unprotected sexual intercourse which can be anal or vaginal. It may also be transmitted through the transfusion of HIV contaminated blood to the healthy individual. Sharing needles has become a most common reason for the spread of this epidemic. It may also be transmitted through the mother having HIV to her child. Breast feeding is also one of the factors which can help to spread the HIV (World Health Organisation, 2010). Still in many areas like developing countries, people are unknown to HIV/AIDS. The illiteracy and poverty are the main causative factors for the spread of epidemic HIV in the world. Being an epidemic, migration is the most common cause for increasing the prevalence of HIV. Sex workers also play a leading role in the spread of HIV because the infection is sexually transmitted. London city has the maximum proportion of population from minority ethnic groups migrated from all over the world. Among these different ethnic groups, Black Africans are one of the fastest growing immigrants in London. East London is one of the poorest areas in London city with having lowest expectation of life, highest unemployment rate and poor housing with low level of education (Elford et al, 2006). In England, late diagnosis of HIV remains a major problem among black Africans. In 2007, about 42 per cent of black Africans diagnosed with HIV were diagnosed late. The evidence shows that late diagnosis of HIV increases more risk of early mortality. The research also conclude some reasons for late diagnosis of HIV in Black African community such as, fear of testing positive for HIV, some of them have a misconception that testing positive would lead to deportation, fear of breaking up the social relationships after testing positive, unknown of testing centres due to lack of information, having fear that life or business pattern will change because of testing positive. Most of Black Africans felt that they had no reason to think they had HIV. Due to HIV related stigma and discrimination Black Africans as compared to White community are the least likely to disclose their HIV status to their partners, family members, employers or friends. Cultural and religious diversity among African c ommunity are the main causes of increase in prevalence of HIV. The evidence indicates that long time stay in England also has an impact on the sexual health of black Africans. Many black African migrates are facing insecure residency status problem. This causes unemployment and mental problems to the community and due to this they are forced into sexual risks, such as prostitution which increases high risk to HIV infection (Race Equality Foundation, 2009). Language barrier is one of the main causes for the increase in prevalence of HIV in Black people. Ineffective communication between people and health care professional causes poor service of the health care. Spirituality is also an important factor in the health and well-being of older Black African people and must also be considered when deciding on methods of engagement (Race Equality Foundation, 2010). In England, It has proved that there are more same-sex relationships than reported among black Africans (Race Equality Foundation, 2009). There is growing evidence to show that African men who have sex with men (MSM) living in the UK are deeply affected by HIV. The article from Audrey Prost, related to sexually transmitted diseases (STIs) highlights the fact that homosexually active men from Black African communities in UK are disproportionately vulnerable to STIs compared to white people community. According to a study conducted by Hickson and his colleagues in 2001, a higher proportion of black African MSM (18%) was living with HIV compared with white MSM with 10% (Aidsportal, 2007). African gay/bisexual men, regardless of their HIV status, are considered hard to reach and reluctant to talk. Various reports indicate that homophobia, both at large and within the black African community may be preventing African men from engaging with HIV prevention initiatives and even discussing their sexual identity with anyone. The racism and homophobia are being very offensive part in Black gay community because Black people have always excluded, harassed, imprisoned and killed often solely because they have black skin where Gay men are also harassed, beaten and killed because they are gay. This explains how difficult it can be being black and gay. In UK, there are some evidences of research studies which are related to Black Caribbean MSM and their problems regarding social lives but there is no evidence of equivalent research which has been has been carried out with African men in UK. Therefore more research is needed urgently for understanding the sexual lifestyles of Afric an MSM, their problems regarding social lives and the best ways to reach them with HIV prevention policies and interventions (Aidsportal, 2007). Commission for Equality and Human Rights (CEHR) presents a real opportunity to address the multiple forms of discrimination faced by Black/African gay men, including racism, homophobia, sexism etc. In London the well established determinants of health care costs for people living with HIV/AIDS such as disease stage and transmission category, socio-economic factors like employment and the support of a living-in partner drastically reduced community services expenses (Kupek et al, 1999). The social responses of fear, stigma, denial and discrimination have accompanied the epidemic HIV/AIDS where the discrimination has increased enormously with maximum anxiety and prejudice against the community who are commonly affected with HIV/AIDS (UNAIDS, 2000). The HIV/AIDS can be treated by some modern therapies but it cannot be cured. The highly active antiretroviral therapy (HAART) is a therapy which uniformly slower down the rate of disease development towards AIDS or the death. In London it is consistently showed that, the Black African people living with HIV are more likely to present with advanced stage of disease, and are therefore less likely to access and get advantage from this therapy. Because of this consequence there is a high mortality rate related to AIDS among the White community but in Black African community it has not yet seen remarkably (Boyd et al, 2005). The main reason for this occurrence is an unawareness of the highly active antiretroviral therapy (HAART) among the Black African community. The information and knowledge regarding demographic characteristics and the stage of HIV in various communities can give important insights like which community should be targeted to provide more intensive educational campaigns t o develop the uptake of HIV testing. The World Health Organisation, UNAIDS and AVERT are the globally leading health organisations which work together and with the government for the prevention of HIV/AIDS. These organisations regularly keep an updates of the prevalence of epidemic HIV/AIDS globally, on national level as well as on the local level. Though these organisations are trying to provide maximum services for HIV infected people, it is proved that, globally only less than one individual in five who are at risk of HIV had access to basic prevention services for HIV (UNAIDS, 2005). As mentioned earlier, the prevalence of HIV is much in African regions. The governments of African countries should act decisively against the increase of HIV infections in the country. In South Africa the government has approved the long-awaited provision of free antiretroviral drugs in public hospitals. The South Africa is the only country in Africa whose government is still obtuse, dilatory and negligent about rolling out treatment ( AVERT, 2010). To fight against an epidemic HIV worldwide, the World Health Organisation and other national and international health organisations celebrates World AIDS Day every year on first December. The theme was established by World Health Organisation in 1988. Worldwide it provides national AIDS programs, faith organisations, community organisations, and individuals with an opportunity to raise awareness and focus attention on the global AIDS epidemic (U.S. Department of Health and Human Services, 2010). In England, the HIV related framework of services has been developed for African communities. This framework is developed to fulfil the vision of NHS plan and meet the standards and goals set out in the National Strategy. This service framework helps NHS staff offering HIV prevention and sexual health promotion advice to African communities. The Department of Health has proposed an ASTOR framework to deal with the diverse black community with different needs. It is a standardised planning tool which can be very helpful to deal with the Black African HIV infected patients. The benefits of ASTORs are for both service commissioners and providers (Department of Health, 2005). To reduce the prevalence of HIV infection in Black African community, the government of England have planned some strategies such as, Reducing the number of people living with undiagnosed HIV with maximum access to testing HIV, improving the health of people living with HIV by providing an antiretroviral therapy to them, preventing the onward transmission of HIV by addressing knowledge and awareness to the infected people (Elam et al, 2006). The African HIV Policy Network (AHPN) is a national umbrella organisation which deals with providing the information of national policies on HIV and sexual health that have implicated for African communities (African HIV Policy Network, 2008). In England the National African HIV prevention Programme (NAHIP) also works effectively delivering prevention interventions for African people living in England. In 1997, the department of health set up a first group of national projects targeted for African community to reduce the prevalence of HIV infection in England. In 2008 the Department of Health instigated a review of the two national HIV Prevention programmes, NAHIP and CHAPS which highlighted the strengths and weaknesses of both programmes and discussed the challenges regarding increasing prevalence in black Africans. In mid 2009, the RBE Consultancy was commissioned to consult with stakeholders in order to develop the NAHIP Strategic Plan 2010 2012. There is a provision of African A IDS Helpline which will become an intervention within NIHIP and the African community. The structure of the plan of NIHIP for 2010-2012 mainly include, the Implementation of the African HIV Prevention Handbook, Putting the Knowledge, The Will and The Power into Practice, relationships with evaluation and development. The aim of AHPN plan is taking into account the needs of African communities and more specifically incorporates Africans living with HIV into local delivery plans where the NIHIP aims to maintain the flow of the previous structure, provide a link for Sub-Contracted Agencies in case of grievances, reduce the length of time between HIV infection and diagnosis, reduce the number of condom failure events by increasing correct use of condoms, increase post-exposure prophylaxis in people who are sexually exposed to HIV (NAHIP, 2010). The Department of Health (2005) planned some interventions to decrease the prevalence of HIV in African communities such as, One to one counselling. Telephone help lines. Provision of sperm washing services. Clinical services to prevent mother-to-child transmission. To maximise the contact with the target group Department of Health made some settings which include, religious groups of African community or churches, African restaurants and embassies etc (Department of Health, 2005). The most prominent initiatives of NIHIP are the Do It Right Africans Making Healthy Choices campaign providing information on sexual health, condoms, and where to access help to the targeted group. The Beyond Condoms campaign of NIHIP promotes debate among African communities about a wide range of issues regarding sexual health and building a safer sex culture. To avoid the language and religious barriers the campaign literature is available in five different languages with targeting different religious groups (AVERT, 2010). The London Borough of Lewisham has large number of black African community with infected by HIV. Each year the NHS of Lewisham treats over 1,200 people for HIV infection. In this borough, around 57% of people are infected through heterosexual sex and 35% are infected through sex between men. The NHS Lewisham is trying to fight against increase in HIV prevalence by implementing different strategies. In 2009, the NHS set a theme for World AIDS Day entitled Universal Access and Human Rights. In the whole borough, the HIV testing is currently available through all GPs on request and four rapid-access HIV testing clinics around the borough. With implementing a new theme for HIV the NHS is piloting a new approach to HIV testing (NHS Lewisham, 2009). To avoid different barriers against HIV treatment the NHS has set 5 spoke providers on the weekly and monthly basis in which Metro is for weekly gay men group and FAWA provides French speaking African monthly group. This can help African commun ity who are infected with HIV (NHS Lewisham, 2009). In London Borough of Lewisham, the service providers for the black African people living with HIV are commissioned through the South London HIV Partnership (SLHP). The HIV services for black African communities commissioned by SLHP are as follows: African Culture Promotion: Prevention work with African communities. SHAKA: Prevention work with Caribbian and African communities. NPL: Prevention work with African communities. LSL African Health Forum: Prevention work with African communities. THT GMFA: Care and support services for gay men. Terrence Higgins Trust: Counselling (NHS Lewisham, 2009). Although Lewisham carries maximum number of HIV patients with black African ethnicity, still there are no specific strategies or policies targeting only for black Africans HIV patients in London Borough of Lewisham. According to the research carried out, the black Africans continue to present with more advanced HIV disease than whites or black Caribbeans. This community is still lacking for the early diagnosis as compared to other ethnic groups. The future strategies should be designed to promote the uptake of HIV testing among black Africans. The future strategies should address the multiple barriers to testing, including misperception of risk, stigma and discrimination and ready access to testing. This study suggests that although being on a high risk group for HIV infection the black Africans generally do not suspect their status. This community delay their uptake for HIV clinic care and test and statutory, voluntary support services. But still after diagnosis they are similar to their white counterparts. The black African community lack informal support networks. This study highlights a desperate need for health promotion work for the black African communities in London Borough of Lewisham, to increase awareness of the benefits of testing HIV and simultaneously to reduce the stigma and discrimination related to HIV/AIDS. These are some barriers which have been illustrated in this study related to HIV testing. The attitudes and practices of NHS and other health care providers, perceptions of patients living with HIV, and official, managerial and economical factors would be very important aspects for the effectiveness of HIV testing and counselling for black African community but yet there is lack of structured information regarding these barriers. The overall barriers described are associated with low-risk perception, access to the health services, reluctance to address HIV, fear and worries and scarcity of economical and properly trained human resources. To conclude the overall study some suggestions would be helpful for the future strategies of health care services. The strategy or the policy should be made which can help strengthen work between the voluntary and statutory sector since the black African community would find it easier to approach their community organisations. The statutory sector should also approach the community directly by reaching them and to hear their personal views. Every newly established structure of the policy should be placed in each sector which will enable the people to attend easily. Considering the examples of the black African gay people, where it is perhaps easier for them to deal with HIV as they have, no baggage of family, these people are generally from the indigenous community therefore there is no immigration status problem, these people are stigmatised but also influential and empowered. If a HIV patient is admitted in hospital, try monitoring him and when he is about to discharged the hospita l ask him to contribute some thoughts once back in the community. Proactive engagement with the black African community would effect in unequal access to services and care with raising the confidence in their own voluntary organisation that the information about their status is held in confidence and will not be breached. A health care service should have culturally competent staff and involves families in the communication process which can be effective and successful. It is also a responsibility of all members of the society. The society should act well with the minority groups living with HIV. They should not be stigmatised by the general people. Being a good human everyone should avoid racism with minority communities like black Africans and the gay people. Remember, the Black African community who have HIV/AIDS are not the problem but the society is. REFERANCES: African HIV Policy Network. (2008) BHIVA/BASHH/BIS HIV TESTING GUIDELINES CONSULTATION Response from the African HIV Policy Network (AHPN). [Online] Available from: http://www.ahpn.org/downloads/policies/Consultation_on_BHIVA_testing_guidelines_V3_0.pdf [Accessed 5th May 2010]. African HIV Policy Network. (2006) HIV and Immigration. [Online] Available from: http://www.ahpn.org/downloads/newsletters/AHPNNewsletter0406.pdf [Accessed 15th May 2010]. Aidsportal. (2007) African HIV Policy network. [Online] Available from: http://www.aidsportal.org/repos/AHPNNewsletterMSMJuly07.pdf [Accessed 25th April 2010]. AVERT. (2010) HIV and AIDS in the UK. [Online] Available from: http://www.avert.org/aids-uk.htm [Accessed 21st May 2010]. AVERT. (2010) History of AIDS: 2003-2006. [Online] Available from: http://www.avert.org/aids-history03-06.htm [Accessed 17th May 2010]. Bevan, K. (2008) HIV in South East London 1995 2006. [Online] Available from: http://www.hpa.org.uk/web/HPAwebFile/HPAweb_C/1212477969757 [Accessed 12th May 2010]. Boyd, A., Murad, S., Oshea, S., Ruiter, A., Watson, C., Easterbrook, P. (2005) Ethnic differences in stage of presentation of adults newly diagnosed with HIV-1 infection in south London. [Online] Available from: http://www3.interscience.wiley.com/cgi-bin/fulltext/118714709/PDFSTART [Accessed 26th April 2010]. Department of Health. (2005) HIV and AIDS in African Communities A Framework for Better Prevention and Care January. [Online] Available from: http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_4099052.pdf [Accessed 13th May 2010]. Elam, G., De Souza, L., Ward, H. (2006) HIV and AIDS in the United Kingdom African communities: guidelines produced for prevention and care. [Online] Available from: http://www.eurosurveillance.org/ViewArticle.aspx?ArticleId=2886 [Accessed 2nd May 2010]. Elford, J., Anderson, J., Bukutu, C., Ibrahim, F. (2006) HIV in East London: ethnicity, gender and risk. Design and methods. [Online] Available from: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1524742/ [Accessed 14th May 2010]. Erwin, J., Peters, B. (1999) Treatment issues for HIV+ Africans in London. [Online] Available from: http://0-www.sciencedirect.com.emu.londonmet.ac.uk/science?_ob=MImg_imagekey=B6VBF-3X70SDJ-6-1_cdi=5925_user=983321_pii=S0277953699002208_orig=search_coverDate=12%2F31%2F1999_sk=999509988view=cwchp=dGLbVzb-zSkzSmd5=b3e0e9a3f108a1a7e8675b1ed11c7ef9ie=/sdarticle.pdf [Accessed 14th May 2010]. Health Protection Agency. (2008) HIV in the United Kingdom: 2008 Report. [Online] Available from: http://www.hpa.org.uk/web/HPAwebFile/HPAweb_C/1227515298354 [Accessed 9th May 2010]. Kupek, E., Dooley, M., Whitaker, L., Petrou, S., Renton, A. (1999) Demographic and socio-economic determinants of community and hospital services costs for people with HIV/AIDS in London. [Online] Available from: http://0-www.sciencedirect.com.emu.londonmet.ac.uk/science?_ob=MImg_imagekey=B6VBF-3WR495S-C-1_cdi=5925_user=983321_pii=S027795369800447X_orig=search_coverDate=05%2F31%2F1999_sk=999519989view=cwchp=dGLzVtb-zSkzSmd5=8f397198cfd5d487e813fcadbf073668ie=/sdarticle.pdf [Accessed 7th May 2010]. Latif, S. (2010) Effective methods of engaging black and minority ethnic communities within health care settings. [Online] Available from: http://www.better-health.org.uk/files/health/health-brief18.pdf [Accessed 3rd May 2010]. National African HIV Prevention Programme. (2010) National African HIV Prevention Programme (NAHIP) Strategic Plan April 2010 to March 2012. [Online] Available from: http://www.nahip.org.uk/downloads/494.pdf [Accessed 28th April 2010]. NHS Lewisham. (2009) HIV Supportive Care in Lewisham. [Online] Available from: http://www.lewisham.gov.uk/NR/rdonlyres/4072F68D-B71C-48EB-8749-CCFBC0B0DB7E/0/cc7f47f87214442b9213e01b0b2a297104HIVCommissioningandsupportprovision.PDF [Accessed 25th May 2010]. NHS Lewisham. (2009) MEDIA RELEASE WORLD AIDS DAY: 1ST DECEMBER 2009. [Online] Available from: http://www.lewishampct.nhs.uk/documents/2244.pdf [Accessed 5th May 2010]. NHS Lewisham. (2009) HIV Supportive Care in Lewisham Report for Healthier Communities Select Committee NHS Lewisham. (2010) HIV Supportive Care in Lewisham. [Online] Available from: http://www.lewisham.gov.uk/NR/rdonlyres/9FE5FD58-9FDD-40F6-8C40-4ECECFBE23D4/0/0f66c646e95c4283b3b14078e7d0214608HIVHealthierCommunitiesSelectCommittee.PDF [Accessed 4th May 2010]. UNAIDS. (2000) HIV and AIDS-related stigmatization, discrimination and denial: forms, contexts and determinants. [Online] Available from: http://whqlibdoc.who.int/unaids/2000/UNAIDS_00.16E.pdf [Accessed 1st May 2010]. UNAIDS. (2005) Intensifying HIV prevention. [Online] Available from: http://data.unaids.org/publications/irc-pub06/jc1165-intensif_hiv-newstyle_en.pdf [Accessed 23rd April 2010]. UNAIDS. (2007) AIDS epidemic update. [Online] Available from: http://data.unaids.org/pub/epislides/2007/2007_epiupdate_en.pdf [Accessed 5th May 2010]. U.S Department of Health and Human Services. (2010) World AIDS Day. [Online] Available from: http://www.hhs.gov/aidsawarenessdays/days/world/ [Accessed 22nd May 2010]. World Health Organisation. (2010) HIV/AIDS. [Online] Available from: http://www.who.int/topics/hiv_aids/en/ [Accessed 15th May 2010].

Ethos, Pathos, and Logos in Keeping Close to Home by bell hooks Essay

Ethos, Pathos, and Logos, bell hooks Style bell hooks ties in the three elements of argument, ethos, pathos, and logos in her essay, "Keeping Close to Home: Class and Education," by telling us about the many events of her life. hooks establishes credibility, or ethos, unintentionally, through descriptions of her achievements and character. hooks appeals to the readers logic, or logos, by giving real world examples from her personal experiences. She also appeals to the readers emotions, or pathos. Pathos is the aspect of argument she uses most heavily. hooks does this by talking about family, peers, feelings, and change. hooks shows us ,in her essay, credibility, logic, and emotion using the stories of her life. bell hooks is a woman who does not concern herself with establishing credibility among her audience or critics. What is important to hooks is that she reaches the people who most need to hear what she has to say. As hooks tells us, "It is important that we know who we are speaking to, who we most long to move, motivate, and touch with our words" (90). hooks has, however, established credibility through her many achievements, such as, attending school at Stanford University, teaching at Yale, writing the book Ain't I a Woman: black women and feminism, and by starting a black women's support group. Although these are great accomplishments, no matter what your race or sex, I feel she best establishes her credibility through her character. hooks tells us that while she often may have needed money, she never had the need for new beliefs or values. She shows great strength in her ability to combine her past life with her new "privileged" life. As hooks says, "It was my responsibilit y to formulate a way of being ... ...anion] wanted to know whether or not I knew them" (91). bell hooks did not personally know these people , but they represent her family and her past. hook finds it unsettling that in her experiences, she has found no black bonds among professors and students. She feels this lack of bonds prevents many brilliant black students from thriving. hooks is disturbed by the lack of positive ties to ethnicity. I feel bell hooks has done an excellent job of showing the elements of ethos, logos, and pathos through her life experiences. She makes very strong points. hooks shows the credibility, logic, and emotion that are needed to get her points across. She relies most heavily and effectively on emotion. In, "Keeping Close to Home: Class and Education", hooks clearly agues ethos, logos, and pathos with a passion to reach people that have never been reached before. Ethos, Pathos, and Logos in Keeping Close to Home by bell hooks Essay Ethos, Pathos, and Logos, bell hooks Style bell hooks ties in the three elements of argument, ethos, pathos, and logos in her essay, "Keeping Close to Home: Class and Education," by telling us about the many events of her life. hooks establishes credibility, or ethos, unintentionally, through descriptions of her achievements and character. hooks appeals to the readers logic, or logos, by giving real world examples from her personal experiences. She also appeals to the readers emotions, or pathos. Pathos is the aspect of argument she uses most heavily. hooks does this by talking about family, peers, feelings, and change. hooks shows us ,in her essay, credibility, logic, and emotion using the stories of her life. bell hooks is a woman who does not concern herself with establishing credibility among her audience or critics. What is important to hooks is that she reaches the people who most need to hear what she has to say. As hooks tells us, "It is important that we know who we are speaking to, who we most long to move, motivate, and touch with our words" (90). hooks has, however, established credibility through her many achievements, such as, attending school at Stanford University, teaching at Yale, writing the book Ain't I a Woman: black women and feminism, and by starting a black women's support group. Although these are great accomplishments, no matter what your race or sex, I feel she best establishes her credibility through her character. hooks tells us that while she often may have needed money, she never had the need for new beliefs or values. She shows great strength in her ability to combine her past life with her new "privileged" life. As hooks says, "It was my responsibilit y to formulate a way of being ... ...anion] wanted to know whether or not I knew them" (91). bell hooks did not personally know these people , but they represent her family and her past. hook finds it unsettling that in her experiences, she has found no black bonds among professors and students. She feels this lack of bonds prevents many brilliant black students from thriving. hooks is disturbed by the lack of positive ties to ethnicity. I feel bell hooks has done an excellent job of showing the elements of ethos, logos, and pathos through her life experiences. She makes very strong points. hooks shows the credibility, logic, and emotion that are needed to get her points across. She relies most heavily and effectively on emotion. In, "Keeping Close to Home: Class and Education", hooks clearly agues ethos, logos, and pathos with a passion to reach people that have never been reached before.

Citizen Kane – Personal Response

Citizen Kane is an American drama film released in 1941. It follows the life of the main character, Charles Foster Kane, and the investigation into â€Å"rosebud† – the last word spoken before his death. Kane was a wealthy newspaper tycoon who lived a reserved lifestyle; he had many possessions but isolated himself from the public eye wherever possible towards the end of his life. The director’s portrayal of the films main themes are shown in such a way that a Year 12 group of students would be able to understand, and therefore can easily make links with society and even their own lives.I would highly recommend Citizen Kane for a Year 12 book club. I will be talking about 2 main points shown in Citizen Kane that I believe are good discussion points for an English class, and which are relevant to our world today. It is an interesting point to note that although the film was released in 1941, many of the ideas can be translated into the present day. First I will ta lk about the idea of â€Å"Loss† in the film, and then I will discuss Materialism and how a group of year 12 students can relate to, and learn from this theme.Loss is a complex idea in the film, as it is not an immediately obvious theme. Defining what â€Å"Loss† is in the film is an interesting thought to discuss. The movie uses flashbacks to tell the story of Charles Kane’s life, this technique is used by the director to show a retrospective view on his life and to emphasise his losses. One of the first flashbacks show him as a child, when he was innocent and happy. In the picture on the screen, what you can see is his Mother handing over custody to Thatcher, who is going to take him to New York to be educated and given a successful life.In the background you can see Kane outside in the snow, he is representing innocence, but the fact that he is framed by the window hints that he is going to become trapped in his new guardianship. This loss continues throughou t the film, he loses his wife, his newspaper company, and his election campaign for governor before eventually losing his life. The film ends with him alone, just like he was at the start of the film. But instead of being happy in the white snow, he is alone in a dark mansion.This is a theme that I think is one that could be discussed in depth by a year 12 book club. Another theme portrayed in Citizen Kane is the idea of materialism, and I believe this is a theme that Year 12 Students would be able to understand and form opinions upon. In the film, Charles Kane lives in a huge mansion filled with many expensive goods. He was an avid statue collector, a hobby only the very wealthy could pursue. Charles Kane said in the film, â€Å"They've been making statues for some two thousand years, and I've only been collecting for five. The director’s uses of depth of focus to exaggerate Kane’s many possessions, and in one shot near the end we can see rooms full of crates with it ems he never unpacked. In his mansion, the rooms are perceived to be large, with dark shadows cast all around. Perhaps this is a metaphor to suggest that Kane’s excessive amount of materialistic possessions have now begun to own him. This leads to a link a Year 12 group of students will be able to make with the modern world today. Advancement of technology has skyrocketed in the past few decades.The invention of smart phones, tablets and other household technologies have created a culture in which it is deemed necessary to own as many of these items as possible. It would seem that Social status is moving from humanitarian values to being based on your materialistic demeanor. Year 12s will be able to relate to the concept that the distinction between ‘need’ and ‘want’ is being clouded by the desire to have these products in order to be ‘accepted’ into modern society.Much like Charles Kane’s obsession with collecting statues, people in society today are becoming obsessed with purchasing the newer, updated version of a product they may already own one, or several of. The film represents his collecting as an obsession, whereas it is deemed normal in today’s world, and this is a point that is open for discussion. Citizen Kane’s representation of materialism provides an excellent starting point for Year 12s to discuss, it is easily relatable and can spark many views and opinions, therefore making it suitable to belong on a class viewing list.Citizen Kane is a film which presents a wide range of themes, and it is these themes which can teach us many things about the lives we live and the world which we live in. The concepts of materialism and loss are ones that are relevant and suitable for a group of Year 12 English students. The imagery and metaphors shown in the film represent issues that can be directly translated into today’s social climate. Therefore I would thoroughly recommend Citizen K ane to a Year 12 book club.

Is Stanford an Ivy League School Is Duke MIT

Is Stanford an Ivy League School Is Duke MIT SAT / ACT Prep Online Guides and Tips Most people have at leastheard of theIvy League, but not everyone knows which schools belong to the venerable group. Is Stanford Ivy League? Is Duke Ivy League? Is MIT Ivy League? In this article, we'll answer these questions and more as we take a look atwhich schools comprise the world-renowned Ivy Leagueand which schools are most often mistaken forIvy League institutions.We'll also explore what being in the Ivy League means for schools and how Ivy League schools compare with those not in the Ivy League in terms ofnational rankings and selectivity. Is Stanford Ivy League? What About Duke and MIT? Contrary to what you might think, none of these schools are in the Ivy League.But thisdoesn't mean that Stanford, Duke, and MIT are not prestigious schools; rather, it simply means they're not affiliated with theIvy League. Confused? Let’s begin by looking at what the Ivy League is and why it was formed. The Ivy League (often called the Ivies) is a consortium of eight private universities based inthe northeast region of the US.Itsmembers are as follows: Brown University Columbia University Cornell University Dartmouth College Harvard University Princeton University University of Pennsylvania Yale University All Ivy League schools are extremely selective and highly ranked- but this wasn’t the initial motivation behind the schools’ unification. The Ivy League (or the â€Å"Ivy Group,† as it was once called) originated as an athletic conference back in the 1950s. Over the years, the phrase has come to be associated with more general notions of prestige, selectivity, and academia due to the esteemed reputations of its members. Essentially, "Ivy League" is nothing more than aname for this particular group of schools- that’s it! While Stanford, Duke, and MIT are all clearly prestigious schools with high national rankings and low selectivity rates comparable to those of Ivy League schools, they are notIvy League schools simplybecause they are not members of the Ivy League. Of course, thisdoesn't stoppeople fromassuming they're Iviesdue to their many similarities! Ultimately, though,no matter how prestigious or competitive a school is, if it’s not one of the eight schools listed above, then it is not an Ivy League school. Even ifa school soundslike it could be an Ivy, that doesn't mean it actually is one! What Schools Are Often Mistaken for Ivy League Schools? Stanford, Duke, and MIT are not the only schools often thought to belong to the Ivy League. Other schools commonly mistaken for those in the Ivy League are those that are: Highly ranked and extremely selective. Ivies are almost always ranked in the top 15 nationally, with acceptance rates below15%. Schools commonly mistaken for Ivies tend to be those with similar rankings and acceptance rates- sometimes despite not even being located in the northeast where the Ivy League is based. Located in or near the northeast. All Ivies are in the northeast, but not all schools in the northeast are Ivies! Highly acclaimed or well-known schools in Massachusetts, New York, Maryland, Pennsylvania, and other nearby states are often mistakenly assumedto belong to the Ivy League. Below is a chart containing all Ivy League schools and those commonly believed to beIvies. I've included each school's location, US News ranking, and acceptance rate so that you can easily compare Ivies with non-Ivies. TheIvy League schools have beenbolded for clarity. School Location US News National Ranking(2019) Acceptance Rate Princeton Princeton, NJ 1 6% Harvard Cambridge, MA 2 5% Columbia New York, NY 3 (tie) 6% MIT Cambridge, MA 3 (tie) 7% University of Chicago Chicago, IL 3 (tie) 7% Yale New Haven, CT 3 (tie) 6% Stanford Stanford, CA 7 4% Duke Durham, NC 8 (tie) 8% UPenn Philadelphia, PA 8 (tie) 8% Johns Hopkins Baltimore, MD 10 (tie) 10% Northwestern Evanston, IL 10 (tie) 8% Caltech Pasadena, CA 12 (tie) 8% Dartmouth Hanover, NH 12 (tie) 9% Brown Providence, RI 14 (tie) 8% Vanderbilt Nashville, TN 14 (tie) 9% Cornell Ithaca, NY 16 (tie) 11% Rice Houston, TX 16 (tie) 16% Notre Dame Notre Dame, IN 18 19% UCLA Los Angeles, CA 19 (tie) 16% Washington University in St Louis St. Louis, MO 19 (tie) 16% Emory Atlanta, GA 21 22% Georgetown Washington, DC 22 (tie) 16% UC Berkeley Berkeley, CA 22 (tie) 17% USC Los Angeles, CA 22 (tie) 16% Carnegie Mellon Pittsburgh, PA 25 (tie) 22% Tufts Medford, MA 27 (tie) 15% University of Michigan Ann Arbor, MI 27 (tie) 27% NYU New York, NY 30 (tie) 21% Boston College Chestnut Hill, MA 38 (tie) 28% College of William Mary Williamsburg, VA 38 (tie) 37% Boston University Boston, MA 42 (tie) 25% Penn State* University Park, PA 59 (tie) 50% Amherst Amherst, MA 2 (National Liberal Arts Colleges) 13% Vassar Poughkeepsie, NY 11 (tie) (National Liberal Arts Colleges) 24% *This school, though not as selective as the others in this table, is sometimes mistaken for the University of Pennsylvania (also called Penn)- one of the eight Ivy League schools- due to its similar name. As you can see, Ivy League schools generally stick to the top 15 positions of nationally ranked universities, with most of them in the top 10.Additionally, all Ivy League schools are extremely selective; the lowest acceptance rate for an Ivy is just 5% for Harvard, while the highest acceptance rate is 11% for Cornell. This table also indicates thatthere are many schools that are just as good as, if not better than, Ivy League schools- which explainswhy schools such as Stanford and MIT are frequently confused for Ivies. For example, MIT and the University of the Chicago are currently ranked #3, tied with Columbia and Yale and beating out five other Ivies! Similarly, Stanford, Duke, Johns Hopkins, and Northwestern are all ranked fairly highly at #7, #8, #10, and #10, respectively, giving them rankings equal to or higher than Dartmouth, Brown, and Cornell. Stanford (not an Ivy) gets the award for most selective school with a mere 4% acceptance rate.That being said, after Stanford, the most selective schools on this list are all Ivies: Harvard (5%), Princeton (6%), Columbia (6%), and Yale (6%). Lastly,this table shows us thatschools are sometimes mistaken for Ivies due to their beingin the northeast.Examples of such schools include the highly selective Johns Hopkins, Amherst, and Georgetown, in addition to someslightly less selective (but popular and prestigious) schools such as NYU and Boston University. Ivies and non-Ivies are like two different flavors of cookies: they may be different, but they're both equally delicious! Recap: Is Duke Ivy League? Is MIT Ivy League? Stanford, Duke, MIT, and many other well-known universitiesare often mistaken for Ivy League schools due to their superior academic reputations and high selectivity. But in reality, the Ivy League consists of just eight extremely selective schools, which are alllocated in the northeast.Once again, these schools are as follows: Brown University Columbia University Cornell University Dartmouth College Harvard University Princeton University University of Pennsylvania Yale University Although the Ivy League is generally associated with prestige and high rankings, this doesn’t mean non-Ivies can't be as good as or even better than Ivies.Many non-Ivies, such asStanford and the University of Chicago, are actually ranked higher than Ivies and maintain similar (or even lower!) acceptance rates. Ultimately,the Ivy League is just a name for a particular group of schools that just so happen to share strong rankings and low acceptance rates.When it comes down to it, any top-tier school- Ivy or otherwise- is an excellent choice for college! What’s Next? Want to make a great impression on the Ivy League?Learn what a good SAT/ACT score is for the Ivy League, and get tips on what classes you should take in high schoolin order to impress admissions committees. Ready to apply to a top-tier school?Awesome!Now all you need is some step-by-step advice. Check out our in-depth guides on how to get into the Ivy Leagueand how to get into Stanford- both written by admitted applicantsto these schools! Want to stand apart from other applicants?Learnhow to score aperfect 1600 on the SAT, so you can increase your shot at getting into the school of your dreams! Want to learn more about the SAT but tired of reading blog articles? Then you'll love our free, SAT prep livestreams. Designed and led by PrepScholar SAT experts, these live video events are a great resource for students and parents looking to learn more about the SAT and SAT prep. Click on the button below to register for one of our livestreams today!

For Fords Sake essays

For Ford's Sake essays Henry Ford is God. Todays definition of promiscuity is tomorrows definition of everyday life. Advancement in science takes precedent to advancement in human emotion. Morality is the antithesis of Aldous Huxleys Brave New World-our present societys unwritten rules regarding brotherly love and modesty are simply unheard of. Many novels parallel the likeness of such an environment. The Philip K. Dick novel Do Androids Dream of Electric Sheep? aims at providing its reader with a gloomy, excessively scientific future. Dick demonstrates a world in which synthetic clones of humans, called androids, are invented in order to perform work for the humans but end up rebelling and nearly outsmarting their masters. Additionally, living animals are a commodity and traded on the black market because they have become endangered due to lack of care from humans and one religious leader takes grasp of the entire Earth. George Orwells 1984 presents Earth as being on constant watch by the governm ent, called big brother. Huxley gives us this stone-cold forecast of the future through imagery that presents a pale and rather lifeless atmosphere, through symbolism where historical people, events or discoveries represent major elements of the Brave New Worlds simplistic system of human existence, and through irony in which our current beliefs and basic ethics are utterly ridiculous. First, Huxleys knack for creating dull, comatose imagery provides the reader with a connection between the warm reality of our current world and the cold dystopia of the brave new world. Since Huxley is trying to communicate that this new world is unfulfilling and worthless, it is necessary that he use such a literary tool. For instance, the first sentence of the second paragraph describes an enormous room... Cold for all the summer beyond the panes, for all the tropical heat of the room itself, a ...

'There is more to volunteering than just doing unpaid work' Discuss Essay

'There is more to volunteering than just doing unpaid work' Discuss - Essay Example iduals who stand up to volunteer are themselves members of the community, and eventually derive a benefit which, although not financial, extends to them in some way along with the to rest of society. In the Unites States, for example, it has been estimated that services provided by volunteering teenagers contribute more than 34 billion dollars to the U.S. economy (Gay, 2004, p. 2). Alcock (2004, p 4) shows that charitable and voluntary action were considered essential components of the welfare state by the Government, as long ago as 1909. People volunteer for many different reasons. The most obvious reason is to give back to society - volunteering seems tied to the concept of moral duty to help with a good cause. However, the time, resources and efforts spent on volunteering are often significant, and altruism alone is not the only motivating force for a person willing to work for a cause without financial gain. Volunteering can involve rewards other than financial, and people choose to volunteer for many different reasons. For example, volunteering can include activities or consequences that have significant value in the person’s life. A person who is attached to animals may volunteer at a shelter for stray cats. For this person, the emotional satisfaction gained by tending to the animals, ensuring their care and safety, would have more significance the same time spent working and earning a few extra dollars. For many volunteers, this activity is the best means for them to socialize with people of similar interests. For example, Oxfam used young volunteers interested in music to recruit local young musicians and raise money for charity through concerts – the activity gave the volunteers a channel to put their passion for music to a good cause (Mahony, 2007). Volunteering is in some cases, very inherently associated with financial gains. A student hoping to land a job at a particular firm would, for example, choose to volunteer and spend his spare time

Starbucks Coffee Company Essay Example | Topics and Well Written Essays - 1250 words

Starbucks Coffee Company - Essay Example Board of Directors. Starbucks Coffee Company was actually established by three of the partners in the year 1971 but at present there are in total ten members in the Starbucks’ Board of Directors (Starbucks Corporation, â€Å"Starbucks Corporation Board of Directors†). All the members of the Board of Directors possess a distinct background. The present Chief Executive Officer (CEO) Howard Schultz was the Chairman, Chief Executive Officer and President of Il Giornale Coffee Company. William Bradley was the managing director of an investment banking firm. The other director Mellody Hobson was also the president of an investment management firm. Apart from these three directors, the other seven directors also acquired respectable positions in the various management firms or other industries. Most of the board of directors is serving the coffee company since 1990 till the present day. The members of the board of directors have been ascertained to be reputed individuals in th e country. In the strategic management process, Howard Schultz occupies the key responsibility as a leader to direct different activities. It has been determined that the different members in board of directors were selected based on their merit and immense experience in the corporate world. Top Management. The board of directors was mainly hired from the other firms except the three founders of the company who were also acting as the directors. The three of the founders also the directors were the top management in the company and possessed immense knowledge and experience in the related field as they have long been serving the coffee company. The Chief Executive Officer of Starbucks, Howard Schultz is an American, born in the year 1953. Initially, he was serving as a sales trainee at Xerox. After three years, he had joined a Swedish company which sold coffee maker to the retailers in the market. In the meantime, he had visited Starbucks for selling the machine. After the visit, he was attracted to the company and wished to be a part of their long-term ventures. Thus, in 1982, he joined Starbucks as a director of retail operations and marketing (Wheelen and Hunger 471-475). VII. IMPLEMENTATION Starbucks Coffee Company had opted for international expansion and thus in 19 94 Starbucks International was formed. Initially, it had expanded its business in the Asian countries of the world such as Japan and China. The aim of their expansion was to create a desire to prefer the western brands among the consumers, to make certain strategies to compete effectively with their competitors and to gain the position of the highest coffee seller. In the past few years, it has also been viewed that the company is trying to expand its business in India. Initially, when the concerned officials had visited India they were unable to find the appropriate partner for entering the Indian market. During this period of time, India was going through a number of economic changes such as the reduction of the tariffs, along with dealing with the government policies as well as the liberalization of the foreign investment. These changes had also discouraged the officials of the Starbucks and the other facet that was noticed that the consumption of coffee was stable up to 50,000 t ons since 1996. There were other renowned coffee sellers

Culture and custom Essay Example | Topics and Well Written Essays - 250 words

Culture and custom - Essay Example As far as American traits are regarded in comparison to the German traits, we can find some similarities and some contrasts. All the people living in this world adopt certain habits and characteristics on the basis of social setup of their own land. Americans like Germans also adopt certain features such as they are also fond of eating like Germans, they are also friendly but they are somewhat arrogant on the basis of their standing in this world. In today’s world, America is regarded as the top most nation with maximum opportunities to gain success, therefore, the people also carry this opinion and consider themselves unique due to which, arrogance can be noticed in their routine attitudes. However, all people cannot be categorized as the same. Americans also speak good English but English is their native language and speaking it nicely is their compulsion. Americans and Germans carry some characteristics that are similar such as eating fondness, speaking good English while their good humor and good nature is not considered as their

Criminal Investigation Essay Example for Free

Criminal Investigation Essay By general definition, an informant is an individual who gives privileged or highly valuable informations regarding a certain person, organization, or group to a certain agency (usually the law enforcement agencies such as the police or the military), without the knowledge of that person, organization, or group that disclosed the information. Based on the definition alone, I think that one of the most common stereotypes that I can hold regarding informants is that they are untrustworthy. Other terms or stereotypes used for informants are rats, snitches, or whistleblowers, which indicate that they will always divulge any valuable piece of information they obtain to the person or organization they are working for. While it is true that informants are very useful in the investigations of police and military operations, there are also times when they prove to be highly dangerous and threatening to a persons life. For example, a person posing as an investigator but is actually an informant may casually ask questions about someone close to me. Little do I know, the informant is working for a criminal organization who is after one of my friends or one of the people I know. Basically, these views towards informants would compel me to be more cautious when dealing with people likes these especially if I notice that they are asking too much information that is seemingly out of place. However, if the informant claims that he or she is assisting a pending police investigation, then I would first verify the authenticity of his or her position before I would disclose any information to him or her. In other words, when dealing with people, especially those whom I have recently met, I would be very careful whom I trust.

The Marketing And Sales Departments :: Business Marketing

Marketing and sales department is responsible for making sure customers know about the business. This may include market research, advertising and sales promotions, the creation and development of a website (although it maintenance maybe undertaken by I.T support staff). The sales departments responsible for selling the items to the customer and keeping sales records. The areas of responsibility are Market Research, Promotional Activities and Sales. Market research aims to find out customers needs and views on new products and services also old products and service, Promotional Activities is because businesses need to promote their products and services otherwise customers would be aware that they exist, the range of available methods including advertising, sales promotion etc, sales, merchants are employed by companies making house hold products to visit supermarkets to persuade them to stock their brands. The advantages of the marketing and sales department is that they will research information find new trends that will sell, also promote products that are attractive as well as best selling. The problems that occur within the marking and sales department are the research being wrong so instead of profit they lose, products could be out of date and rotten also the advertisements for a product will cost money The marketing and sales department helps achieve the aims and objective of EA^T by making profit margins larger and to increase stock if products sell fast and by that happening it could happen it could help them reach their target price. The departments communicate two ways internally and externally, I will give two examples of internal and external communication. Internally they communicate by informing customer’s service department of a new product that they will sell and this would be communicated either by telephone or e-mail, they would communicated it this way because this are the ways that new products are most seen or heard because they are not really avoidable i.

Sylvia Plath :: Biography Biographies Essays

Sylvia Plath      Ã‚  Ã‚  Ã‚   Sylvia Plath was a remarkable twentieth century American poet. Her poetry focused on depression, aspects on suicide, death, savage imagery, self-destruction and painful feelings of women. Plath attempts to exorcise the oppressive male figures that haunted her life served as one of the fundamental themes in her poetry.    Her poetry is a good example on how "suffering and transformation could be within traditional poetic contexts" (Initiation p.142). She also believed that a poem "must give an expression to the poet's own anguish because suffering has become the central fact of historical and personal existence" (Initiation p.143). This is what she believed and how she dealt with her problems by expressing her feelings through poetry. Though what was expressed in her poems also portrayed her fate in suicide.    Sylvia Plath was born on October 27, 1932 in Boston, Massachusetts to Otto and Aurelia Plath. Her father, Otto Plath was a German biology professor at Boston University. Her mother, Aurelia, was a high school English teacher, until she married and became a homemaker. When Sylvia was only eight, her father died from complications of undiagnosed diabetes, which also scarred her for life. At this same age she started her career as writer she published her first couplet in the Boston Sunday Herald, and since then has persistently worked on poetry and her writings.    In high school, she was a remarkably intelligent, popular, student. She was the typical "Straight A's" girl. As a member of the National Honors Society, she received a scholarship to attend Smith College in 1950. While studying creative writing and graphic arts in her third year of college, she was a guest editor in Mademoiselle Magazine. Shortly after that, on August 24, 1953, because of extreme depression, she attempted to commit suicide for the first time by taking a large dose of sleeping pills. She was later treated with intense psychotherapy and electroshock therapy in a private hospital. After a long recovery, she returned to Smith College and graduated in 1954. This incident is well described in the Bell Jar, her second published novel.    By now her career as a poet and writer was not going well, after forty-five rejections from newspapers and magazines, Seventeen magazine agreed to have one of her stories to be published. Later, it was announced that she had received third place in Seventeen Magazine's writing contest. Sylvia Plath :: Biography Biographies Essays Sylvia Plath      Ã‚  Ã‚  Ã‚   Sylvia Plath was a remarkable twentieth century American poet. Her poetry focused on depression, aspects on suicide, death, savage imagery, self-destruction and painful feelings of women. Plath attempts to exorcise the oppressive male figures that haunted her life served as one of the fundamental themes in her poetry.    Her poetry is a good example on how "suffering and transformation could be within traditional poetic contexts" (Initiation p.142). She also believed that a poem "must give an expression to the poet's own anguish because suffering has become the central fact of historical and personal existence" (Initiation p.143). This is what she believed and how she dealt with her problems by expressing her feelings through poetry. Though what was expressed in her poems also portrayed her fate in suicide.    Sylvia Plath was born on October 27, 1932 in Boston, Massachusetts to Otto and Aurelia Plath. Her father, Otto Plath was a German biology professor at Boston University. Her mother, Aurelia, was a high school English teacher, until she married and became a homemaker. When Sylvia was only eight, her father died from complications of undiagnosed diabetes, which also scarred her for life. At this same age she started her career as writer she published her first couplet in the Boston Sunday Herald, and since then has persistently worked on poetry and her writings.    In high school, she was a remarkably intelligent, popular, student. She was the typical "Straight A's" girl. As a member of the National Honors Society, she received a scholarship to attend Smith College in 1950. While studying creative writing and graphic arts in her third year of college, she was a guest editor in Mademoiselle Magazine. Shortly after that, on August 24, 1953, because of extreme depression, she attempted to commit suicide for the first time by taking a large dose of sleeping pills. She was later treated with intense psychotherapy and electroshock therapy in a private hospital. After a long recovery, she returned to Smith College and graduated in 1954. This incident is well described in the Bell Jar, her second published novel.    By now her career as a poet and writer was not going well, after forty-five rejections from newspapers and magazines, Seventeen magazine agreed to have one of her stories to be published. Later, it was announced that she had received third place in Seventeen Magazine's writing contest.

Contract Law

Introduction In today’s economic climate businesses often exert commercial pressure during contract negotiation stages. This is a normal part of the process and parties to a contract generally know when pressure being exerted is lawful. Although there is a difference between commercial negotiation and illegitimate pressure, it is often difficult to distinguish between the two. Furthermore, because economic duress can arise from pressure that is not in itself unlawful, parties may be unaware that the pressure they are subjecting a party to a contract is actually economic duress. Despite this, if a court finds that one party to a contract has exerted illegitimate pressure on another party, the innocent party may be able to establish a claim of economic duress. Given how uncertain the economy is at present, hard bargaining is a common form of negotiation, though it is vital that businesses are aware of the risks when exerting pressure that is likely to be deemed illegitimate. It is unclear ho w this distinction can be made, nonetheless, which suggests that further clarity is needed within this area. This study intends to explain the developments that have taken place in the doctrine of economic duress and why the courts perceived a need for a more robust approach in light of the Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 case. Duress Duress is a common law defence that allows a contract to be set aside in instances where one party has been subjected to force or pressure from the other party to enter into the contract. Duress has been defined as â€Å"making someone do something against his will, or making someone perform an illegal act, by using threats, coercion or other illicit means† (Dictionary, 2014: 1). Duress is basically the use of unlawful means to force another to perform an act by either threatening them or performing an act of violence. The party claiming duress will be required to show that they did not have a choice but to enter into the contract (Cserne, 2009: 57). Economic duress, on the other hand, is a fairly new phenomenon that is becoming an important tool for determining whether a contract that has been entered into is enforceable or not. Economic duress happens when a person’s economic interests are damaged from being forced or coerced into entering into a contract. This type o f duress has been defined as the â€Å"unlawful use of economic pressure and/or threats intended to overcome the free will of a person, in order to force him or her to an involuntary agreement or to do something that he or she would not otherwise do† (Business Dictionary, 2014, 1). Economic duress is essentially a contract law defence that allows a person to dispute the formation of a binding contract by arguing that that they were forced to enter into the contract. Previously, parties to a contract could only rely on the doctrine of consideration for protection when they were being subjected to economic duress. Consideration is the price that one party will pay for another party’s promise (Card et al; 2003: 63); Collins v Godefroy (1831) 1 B&Ad 950. The doctrine of consideration does not allow parties in a contract to insist on further payments to perform tasks they are already required to perform under the contract simply because they are in a stronger bargaining pos ition; Stilk v Myrick (1809) 2 Camp 317. Economic Duress and Commercial Pressure It is now widely accepted by the courts that undue commercial pressure can amount to duress. The doctrine of economic duress has evolved significantly from various trade union decisions including; Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 and Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152. In The Universe Sentinel, a trade union, which had blacklisted a ship, forced the owner to provide payment before they would remove the ship from the black list. As there would have been disastrous consequences if the ship could not sail, the owner made the payment. Because the ship owner had no other practical choice but to make the payment, he later brought a successful claim for the recovery of the money by establishing economic duress. Similarly, in The Evia Luck a trade union insisted that a ship owner signed various contractual documents so that his ship could sail, which was fou nd by the court to be a form of economic duress. In order to make an economic duress claim, there are a number of elements the claimant will need to be established. These are; a) that the pressure was illegitimate; b) that the pressure was a significant cause that induced the claimant to enter into the contract; and c) that the practical effect of the pressures means that the claimant has no other choice but to enter into the contract (Ohrenstein, 2013: 2). The claimant will be entitled to avoid the contract and claim restitution of any monies that have been paid under it if these elements can be established. In deciding what amount to illegitimate pressure, the court will take a range of factors into account. For example, in DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 it was made clear that the court will be required to consider whether the breach of contract was an actual or threatened breach; whether the person whom exerts the pressure has acted in good or bad faith; whether the claimant had any real or practical alternative but to give in to the pressure; whether the claimant protested at the time; and whether the claimant sought to rely on the contract. One of the most successful forms of economic duress is a threat to breach a contract. In Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 charterers of two ships threatened to break their charterparties by refusing to pay the agreed charter rate if the rate was not lowered. The owners of the ships had been informed that the charterers had no substantial assets and that the charterers would otherwise go into liquidation if the charter rates were not lowered. This information was not actually true but it caused the owners to reduce the rates nevertheless. It was found that economic duress could apply to this situation as all of the relevant factors were present. Since this decision, the courts seem to have accepted that economic duress is coercive and therefore worthy of the same relief as duress to the person or property (Chen-Wishart, 2012: 316). In spite of this, the practical application of economic duress has been subject to much confusion and it has been questioned when, if ever, renegotiations should be enforced. It would seem, under the doctrine of consideration, that renegotiations can never be enforced on the basis that â€Å"no additional consideration supports the promise to pay more or accept less† (Chen-Wishart, 2012: 316). Under the promissory estoppel doctrine, the promise to pay the same for less can be enforced in limited circumstances, though this does not apply if illegitimate pressure has been exerted. Therefore, if it can be demonstrated that illegitimate pressure has been applied to the renegotiation of a contract, that contract will not be enforceable. Because commercial contracts are extremely competitive, it is likely to be the case that some form of pressure will always be applied. Though the question to be determined is whether the pressure that has been applied is legitimate or not. This is l ikely to be extremely problematic and thus cause a great deal of complexity for the courts. As exemplified in the cases above, threats to blacklist a ship and refuse its release may constitute duress. Further examples of where economic duress has occurred can be seen in the cases of North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 and Pao On v Lau Yiu Long [1979] UKPC 17 where threats to terminate a contract in the absence of a renegotiation is also illegitimate unless it can be legally justified. What will be deemed â€Å"legally justified† is largely a matter to be determined based upon individual facts and circumstances, though there is likely to remain a lot of confliction in this area. In Williams v Roffey Brothers Ltd [1991] EWCA Civ 5 the Stilk case was severely limited by the courts. Here, the consideration requirement was extended to include â€Å"practical benefits† and thereby covered the promise to perform an existing contract. Here, a number of contractors promised to refurbish 27 flats with a sub-contractor performing the carpentry. Before the flats were finished, the sub-contractor realised that he had under-priced the contract and was resultantly facing financial difficulty. The main contractors offered the sub-contractor a financial inducement to finish the contract on time. It is trite law that consideration is needed for a party to that contract to be able to sue on it. Since the sub-contractor was doing no more than he was already bound to do under the contract, consideration was lacking. Surprisingly, it was held by the court that because the contractors had received a benefit from the sub-contractor, in that they avoided the penalty clause of the main contract, the sub-contractors claim was successful. This did not mean that consideration was present as the benefit did not move from the promisee, although there was a clear departure from the orthodox principle of consideration principle. The doctr ine of consideration maintains that a contract will not be supported by the performance of an existing duty unless that duty exists by virtue of a third party contract (Noble, 1991: 141). This decision conflicts with the decision in Stilk which demonstrated that consideration needs to be of economic value to be deemed good consideration and that it needs to move from the promise as also shown in; White v Bluett (1853) 23 LJ Ex 36; Thomas v Thomas (1842) 2 QB 851; Shadwell v Shadwell (1860) 9 CBNS 159; and Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295). It has also been argued by Cheshire et al; that; â€Å"the time has come to recognise formally the alternative definition of consideration and admit that the rationale behind the refusal to enforce some types of consideration is pure policy† (Cheshire et al; 2012; 77). Arguably, it appears that the consideration principle is rather outmoded and in need of reform so that a more robust approach to economic duress can be taken by the courts. At present, much confusion arises as to when economic duress can be used as a defence. Judges thus need to err on the side of caution to prevent commercial pressure being mistaken for economic duress and vice versa. Still, as stressed by the court in Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481; â€Å"the list of matters to be considered in assessing legitimacy is not exhaustive, and the weight to be attached to each of them will depend on the facts of the individual case.† Furthermore, it was also stated in the case that the decision to be made will involve some element of value judgement when considering whether the pressure that was exerted on the claimant crossed the line from that which must be accepted in normal robust commercial bargaining. It is clear from the decision in this case that the courts have made some attempts to provide clarity in this area and that each case will be decided on its own facts. In the more recent case of Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 it was evidenced that a contract variation between a supplier and a customer will unlikely amount to duress if the supplier is unable to perform a contract as a result of financial difficulties that will cause the supplier to become insolvent. Another problem that arises when it comes to economic duress is whether lawful conduct can amount to illegitimate pressure. Whilst it is possible, it is also extremely rare as shown in CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19; GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) and Wright v HSBC Bank plc [2006] EWHC 930 QB. Consequently, economic duress will continue to pose many problems as there will always be a debate as to whether particular circumstances may or may not give rise to a claim for economic duress. Because of the uncertainty within this area, it is evident that a more robust approach needs to be taken so that greater clarity and consistency can be provided. Economic duress has also been criticised for being causation-led, thereby meaning that a lack of causation will prevent a successful claim from being made. In Pao On v Lau Yiu Long [1979] UKPC 2 it was pointed out by Lord Scarman that in deciding whether causation was present, it will need to be considered whether the claimant; a) protested; b) had a practical alternative open to him; c) received independent advice; and d) acted promptly. This decision has been criticised for being inconclusive and failing to take into account the fact that claimants may not think that there is any point in protesting. This was recognised by Chen-Wis hart when it was argued that; â€Å"these factors are inconclusive. The victim may not protest because he sees no point in it or he may not wish to antagonise the coercing party whose performance he needs† (Chen-Wishart, 2012: 318). It is clear that the facts and circumstances of each case will be the determining factor as to whether the claimant has suffered economic duress or not. Because of the uncertainty that exists in this area, however, it is often difficult for those entering into commercial contracts to acknowledge that they are exerting pressure that is considered illegitimate, especially when there is a possibility that lawful pressure will also be capable of amounting to economic duress. As a result of this, Young warns against exerting commercial pressure that the courts may possibly consider economic duress: â€Å"Abusing your upper hand can leave the strong open to claims† (Young, 2012: 23). Conclusion Overall, whilst the doctrine of duress is well established in English law, the doctrine of economic duress still remains largely uncertain. This generally arises from the difficulty of distinguishing between legitimate and illegitimate economic duress. As such, it is up to the courts to decide when a person’s economic interests have been damaged from being forced or coerced into entering into a contract. Hence, the court will be required to consider whether the re-negotiation of the terms of the contract were lawful and whether the person being subjected to the economic duress, should be entitled to rescind the contract that they entered into. This is an important defence in ensuring that parties to a contract have equal bargaining power. Nevertheless, the practical application of economic duress has been subject to much confusion over the years, which may result from the reasoning that has been provided by the courts. There appears to be a lack of consistency that is being pr ovided, which highlights the need for future reform to this area. Whilst there is a difference between commercial negotiation and illegitimate pressure, it has proven extremely difficult to distinguish between the two, especially since lawful conduct can also amount to illegitimate pressure. In order to provide clarity to this area, it seems as though a more robust approach is therefore needed by the courts. References Business Dictionary. (2014) Economic Duress, [Online] Available: http://www.businessdictionary.com/definition/economic-duress.html [07 July 2014]. Card, R. Murdoch, J. and Murdoch, S. (2003) Estate Management Law, OUP, 6th Edition. Carr, N. (2011) Walking the Line – The Balance Between Legitimate Negotiation and Economic Duress, Available [Online]: [07 July 2014]. Chen-Wishart, M. (2012) Contract Law, Oxford University Press. Cserne, P. (2009) Duress in Contracts: An Economic Analysis, Contract Law and Economics, Volume 6, 2nd Edition. Furmston, M. P. Cheshire, G C. and Fifoot, C H. (2012) Cheshire, Fifoot and Furmston’s Law of Contract, Oxford University Press: London. Dictionary. (2014) Duress, [Online], Available: http://www.yourdictionary.com/duress [07 July 2014]. Noble, M. (1991) For Your Consideration, New Law Journal, Volume 141, Issue 1529. Ohrenstein, D. (2013) Key Developments in Contract Law: Economic Duress, Radcliffe Chambers, [Online] Available: http://www.radcliffechambers.com/media/Misc_Articles/Key_Developments_in_Contract_Law_-_Economic_Duress_2013.pdf [07 July 2014]. Young, A. (2012) When Pressure Turns to Duress, Construction Law Journal, Volume 23, Issue 5. Cases Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481 Collins v Godefroy (1831) 1 B&Ad 950 CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19 Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152 DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 Pao On v Lau Yiu Long [1979] UKPC 17 Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295) Shadwell v Shadwell (1860) 9 CBNS 159 Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 Stilk v Myrick (1809) 2 Camp 317 Thomas v Thomas (1842) 2 QB 851 Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 White v Bluett (1853) 23 LJ Ex 36 Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 Wright v HSBC Bank plc [2006] EWHC 930 QB Contract Law Introduction In today’s economic climate businesses often exert commercial pressure during contract negotiation stages. This is a normal part of the process and parties to a contract generally know when pressure being exerted is lawful. Although there is a difference between commercial negotiation and illegitimate pressure, it is often difficult to distinguish between the two. Furthermore, because economic duress can arise from pressure that is not in itself unlawful, parties may be unaware that the pressure they are subjecting a party to a contract is actually economic duress. Despite this, if a court finds that one party to a contract has exerted illegitimate pressure on another party, the innocent party may be able to establish a claim of economic duress. Given how uncertain the economy is at present, hard bargaining is a common form of negotiation, though it is vital that businesses are aware of the risks when exerting pressure that is likely to be deemed illegitimate. It is unclear ho w this distinction can be made, nonetheless, which suggests that further clarity is needed within this area. This study intends to explain the developments that have taken place in the doctrine of economic duress and why the courts perceived a need for a more robust approach in light of the Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 case. Duress Duress is a common law defence that allows a contract to be set aside in instances where one party has been subjected to force or pressure from the other party to enter into the contract. Duress has been defined as â€Å"making someone do something against his will, or making someone perform an illegal act, by using threats, coercion or other illicit means† (Dictionary, 2014: 1). Duress is basically the use of unlawful means to force another to perform an act by either threatening them or performing an act of violence. The party claiming duress will be required to show that they did not have a choice but to enter into the contract (Cserne, 2009: 57). Economic duress, on the other hand, is a fairly new phenomenon that is becoming an important tool for determining whether a contract that has been entered into is enforceable or not. Economic duress happens when a person’s economic interests are damaged from being forced or coerced into entering into a contract. This type o f duress has been defined as the â€Å"unlawful use of economic pressure and/or threats intended to overcome the free will of a person, in order to force him or her to an involuntary agreement or to do something that he or she would not otherwise do† (Business Dictionary, 2014, 1). Economic duress is essentially a contract law defence that allows a person to dispute the formation of a binding contract by arguing that that they were forced to enter into the contract. Previously, parties to a contract could only rely on the doctrine of consideration for protection when they were being subjected to economic duress. Consideration is the price that one party will pay for another party’s promise (Card et al; 2003: 63); Collins v Godefroy (1831) 1 B&Ad 950. The doctrine of consideration does not allow parties in a contract to insist on further payments to perform tasks they are already required to perform under the contract simply because they are in a stronger bargaining pos ition; Stilk v Myrick (1809) 2 Camp 317. Economic Duress and Commercial Pressure It is now widely accepted by the courts that undue commercial pressure can amount to duress. The doctrine of economic duress has evolved significantly from various trade union decisions including; Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 and Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152. In The Universe Sentinel, a trade union, which had blacklisted a ship, forced the owner to provide payment before they would remove the ship from the black list. As there would have been disastrous consequences if the ship could not sail, the owner made the payment. Because the ship owner had no other practical choice but to make the payment, he later brought a successful claim for the recovery of the money by establishing economic duress. Similarly, in The Evia Luck a trade union insisted that a ship owner signed various contractual documents so that his ship could sail, which was fou nd by the court to be a form of economic duress. In order to make an economic duress claim, there are a number of elements the claimant will need to be established. These are; a) that the pressure was illegitimate; b) that the pressure was a significant cause that induced the claimant to enter into the contract; and c) that the practical effect of the pressures means that the claimant has no other choice but to enter into the contract (Ohrenstein, 2013: 2). The claimant will be entitled to avoid the contract and claim restitution of any monies that have been paid under it if these elements can be established. In deciding what amount to illegitimate pressure, the court will take a range of factors into account. For example, in DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 it was made clear that the court will be required to consider whether the breach of contract was an actual or threatened breach; whether the person whom exerts the pressure has acted in good or bad faith; whether the claimant had any real or practical alternative but to give in to the pressure; whether the claimant protested at the time; and whether the claimant sought to rely on the contract. One of the most successful forms of economic duress is a threat to breach a contract. In Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 charterers of two ships threatened to break their charterparties by refusing to pay the agreed charter rate if the rate was not lowered. The owners of the ships had been informed that the charterers had no substantial assets and that the charterers would otherwise go into liquidation if the charter rates were not lowered. This information was not actually true but it caused the owners to reduce the rates nevertheless. It was found that economic duress could apply to this situation as all of the relevant factors were present. Since this decision, the courts seem to have accepted that economic duress is coercive and therefore worthy of the same relief as duress to the person or property (Chen-Wishart, 2012: 316). In spite of this, the practical application of economic duress has been subject to much confusion and it has been questioned when, if ever, renegotiations should be enforced. It would seem, under the doctrine of consideration, that renegotiations can never be enforced on the basis that â€Å"no additional consideration supports the promise to pay more or accept less† (Chen-Wishart, 2012: 316). Under the promissory estoppel doctrine, the promise to pay the same for less can be enforced in limited circumstances, though this does not apply if illegitimate pressure has been exerted. Therefore, if it can be demonstrated that illegitimate pressure has been applied to the renegotiation of a contract, that contract will not be enforceable. Because commercial contracts are extremely competitive, it is likely to be the case that some form of pressure will always be applied. Though the question to be determined is whether the pressure that has been applied is legitimate or not. This is l ikely to be extremely problematic and thus cause a great deal of complexity for the courts. As exemplified in the cases above, threats to blacklist a ship and refuse its release may constitute duress. Further examples of where economic duress has occurred can be seen in the cases of North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 and Pao On v Lau Yiu Long [1979] UKPC 17 where threats to terminate a contract in the absence of a renegotiation is also illegitimate unless it can be legally justified. What will be deemed â€Å"legally justified† is largely a matter to be determined based upon individual facts and circumstances, though there is likely to remain a lot of confliction in this area. In Williams v Roffey Brothers Ltd [1991] EWCA Civ 5 the Stilk case was severely limited by the courts. Here, the consideration requirement was extended to include â€Å"practical benefits† and thereby covered the promise to perform an existing contract. Here, a number of contractors promised to refurbish 27 flats with a sub-contractor performing the carpentry. Before the flats were finished, the sub-contractor realised that he had under-priced the contract and was resultantly facing financial difficulty. The main contractors offered the sub-contractor a financial inducement to finish the contract on time. It is trite law that consideration is needed for a party to that contract to be able to sue on it. Since the sub-contractor was doing no more than he was already bound to do under the contract, consideration was lacking. Surprisingly, it was held by the court that because the contractors had received a benefit from the sub-contractor, in that they avoided the penalty clause of the main contract, the sub-contractors claim was successful. This did not mean that consideration was present as the benefit did not move from the promisee, although there was a clear departure from the orthodox principle of consideration principle. The doctr ine of consideration maintains that a contract will not be supported by the performance of an existing duty unless that duty exists by virtue of a third party contract (Noble, 1991: 141). This decision conflicts with the decision in Stilk which demonstrated that consideration needs to be of economic value to be deemed good consideration and that it needs to move from the promise as also shown in; White v Bluett (1853) 23 LJ Ex 36; Thomas v Thomas (1842) 2 QB 851; Shadwell v Shadwell (1860) 9 CBNS 159; and Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295). It has also been argued by Cheshire et al; that; â€Å"the time has come to recognise formally the alternative definition of consideration and admit that the rationale behind the refusal to enforce some types of consideration is pure policy† (Cheshire et al; 2012; 77). Arguably, it appears that the consideration principle is rather outmoded and in need of reform so that a more robust approach to economic duress can be taken by the courts. At present, much confusion arises as to when economic duress can be used as a defence. Judges thus need to err on the side of caution to prevent commercial pressure being mistaken for economic duress and vice versa. Still, as stressed by the court in Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481; â€Å"the list of matters to be considered in assessing legitimacy is not exhaustive, and the weight to be attached to each of them will depend on the facts of the individual case.† Furthermore, it was also stated in the case that the decision to be made will involve some element of value judgement when considering whether the pressure that was exerted on the claimant crossed the line from that which must be accepted in normal robust commercial bargaining. It is clear from the decision in this case that the courts have made some attempts to provide clarity in this area and that each case will be decided on its own facts. In the more recent case of Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 it was evidenced that a contract variation between a supplier and a customer will unlikely amount to duress if the supplier is unable to perform a contract as a result of financial difficulties that will cause the supplier to become insolvent. Another problem that arises when it comes to economic duress is whether lawful conduct can amount to illegitimate pressure. Whilst it is possible, it is also extremely rare as shown in CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19; GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) and Wright v HSBC Bank plc [2006] EWHC 930 QB. Consequently, economic duress will continue to pose many problems as there will always be a debate as to whether particular circumstances may or may not give rise to a claim for economic duress. Because of the uncertainty within this area, it is evident that a more robust approach needs to be taken so that greater clarity and consistency can be provided. Economic duress has also been criticised for being causation-led, thereby meaning that a lack of causation will prevent a successful claim from being made. In Pao On v Lau Yiu Long [1979] UKPC 2 it was pointed out by Lord Scarman that in deciding whether causation was present, it will need to be considered whether the claimant; a) protested; b) had a practical alternative open to him; c) received independent advice; and d) acted promptly. This decision has been criticised for being inconclusive and failing to take into account the fact that claimants may not think that there is any point in protesting. This was recognised by Chen-Wis hart when it was argued that; â€Å"these factors are inconclusive. The victim may not protest because he sees no point in it or he may not wish to antagonise the coercing party whose performance he needs† (Chen-Wishart, 2012: 318). It is clear that the facts and circumstances of each case will be the determining factor as to whether the claimant has suffered economic duress or not. Because of the uncertainty that exists in this area, however, it is often difficult for those entering into commercial contracts to acknowledge that they are exerting pressure that is considered illegitimate, especially when there is a possibility that lawful pressure will also be capable of amounting to economic duress. As a result of this, Young warns against exerting commercial pressure that the courts may possibly consider economic duress: â€Å"Abusing your upper hand can leave the strong open to claims† (Young, 2012: 23). Conclusion Overall, whilst the doctrine of duress is well established in English law, the doctrine of economic duress still remains largely uncertain. This generally arises from the difficulty of distinguishing between legitimate and illegitimate economic duress. As such, it is up to the courts to decide when a person’s economic interests have been damaged from being forced or coerced into entering into a contract. Hence, the court will be required to consider whether the re-negotiation of the terms of the contract were lawful and whether the person being subjected to the economic duress, should be entitled to rescind the contract that they entered into. This is an important defence in ensuring that parties to a contract have equal bargaining power. Nevertheless, the practical application of economic duress has been subject to much confusion over the years, which may result from the reasoning that has been provided by the courts. There appears to be a lack of consistency that is being pr ovided, which highlights the need for future reform to this area. Whilst there is a difference between commercial negotiation and illegitimate pressure, it has proven extremely difficult to distinguish between the two, especially since lawful conduct can also amount to illegitimate pressure. In order to provide clarity to this area, it seems as though a more robust approach is therefore needed by the courts. References Business Dictionary. (2014) Economic Duress, [Online] Available: http://www.businessdictionary.com/definition/economic-duress.html [07 July 2014]. Card, R. Murdoch, J. and Murdoch, S. (2003) Estate Management Law, OUP, 6th Edition. Carr, N. (2011) Walking the Line – The Balance Between Legitimate Negotiation and Economic Duress, Available [Online]: [07 July 2014]. Chen-Wishart, M. (2012) Contract Law, Oxford University Press. Cserne, P. (2009) Duress in Contracts: An Economic Analysis, Contract Law and Economics, Volume 6, 2nd Edition. Furmston, M. P. Cheshire, G C. and Fifoot, C H. (2012) Cheshire, Fifoot and Furmston’s Law of Contract, Oxford University Press: London. Dictionary. (2014) Duress, [Online], Available: http://www.yourdictionary.com/duress [07 July 2014]. Noble, M. (1991) For Your Consideration, New Law Journal, Volume 141, Issue 1529. Ohrenstein, D. (2013) Key Developments in Contract Law: Economic Duress, Radcliffe Chambers, [Online] Available: http://www.radcliffechambers.com/media/Misc_Articles/Key_Developments_in_Contract_Law_-_Economic_Duress_2013.pdf [07 July 2014]. Young, A. (2012) When Pressure Turns to Duress, Construction Law Journal, Volume 23, Issue 5. Cases Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481 Collins v Godefroy (1831) 1 B&Ad 950 CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19 Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152 DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 Pao On v Lau Yiu Long [1979] UKPC 17 Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295) Shadwell v Shadwell (1860) 9 CBNS 159 Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 Stilk v Myrick (1809) 2 Camp 317 Thomas v Thomas (1842) 2 QB 851 Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 White v Bluett (1853) 23 LJ Ex 36 Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 Wright v HSBC Bank plc [2006] EWHC 930 QB