Business Strategy High School Essay Example | Topics and Well Written Essays - 750 words

Business Strategy High School - Essay Example Their size has left them helpless against progressively adaptable rivalry that can deliver at a lower cost. Openings: They have a perfect chance to significantly extend their piece of the pie in the cordless market. Despite the fact that the merchant organize is presently a shaky area, Smith and White has a chance to rebuild their dissemination to their advantage. Their enormous size and brand acknowledgment would offer them the chance to shape channel organizations or enter direct showcasing outlets, for example, through a site. Dangers: Their biggest rival, Makatume, can contend on cost. Makatume has more established battery innovation, yet has the cost structure to grow new innovation, enter that advertise, and pre-empt Smith and White. Smith and White would be constrained into an adherent situation on innovation and cost. Likewise, Able is not too far off with a solid cordless item. They have been looking for a buyout or merger, which could revive them as a significant danger. There are likewise a few littler organizations that have no obstructions to growing and enhancing. Smith and White needs to take 3 forceful activities: Reduce costs, enter the battery showcase, and separate the expert line. This would be practiced by making the expert and customer lines separate specialty units. Migrate the assembling of the expert line to a lower cost condition. Build up a prevalent cordless line for the expert items to contend straightforwardly with Makatume and re-brand it with a comparable however increasingly strong picture. The rebranding would have the necessary crucial changes to the item to make a positive market acknowledgment (DeYoung 2006). The brand acknowledgment and battery innovation would separate the item. This would hold off the need to contend on value (Day and Reibstein 1997 p.36). Smith and White would be in a prevalent situation with more up to date innovation and higher voltages. Smith and White should then utilize the battery innovation and move it to their shopper brands and take piece of the overall industry from Able Co. These items could be sold through wholesaler accomplices. Assets would should be devoted to revamping the merchant relationship, yet this will be essential. The long-go plans would incorporate remodel or movement of the customer business to a lower cost zone. SWOT Analysis: Strategic Planning Makatume Qualities: Makatume's predominant spot in Japan's market gives them an incredible power for passage into the US advertise. They can without much of a stretch increment their income by catching portions of the US showcase. They would not be in a situation to need to spend assets ensuring a current position. They likewise have the benefit of their new plants and their minimal effort structure. Their devotion to the expert market has streamlined turn of events and advertising. Shortcomings: Though their devotion to the expert line can be a quality, it is additionally an impediment. It restrains the market and limits the outlets. Their present battery configuration is old and necessities redeveloped. This will deplete assets in the close to term. They additionally experience the ill effects of low brand acknowledgment in the US. Dangers: The most quick danger is the conversion scale vacillation. It might make it hard to obtain or fund any development. They are additionally undermined by the few contenders that have a little piece of the pie. Makatume has no specific preferred position over them.

Us Postal Service – Insolvency

The United States Postal Service: At the Brink of Insolvency Business 510 †Managerial Economics Final Project Submission February 25, 2012 Executive Summary this report investigates the United States Postal Service budgetary issues, which carried it to the verge of bankruptcy, in the wake of losing more than $25B over the most recent 5 years. It examines variables and execution and hypothesizes remedial activities to take USPS back to budgetary dissolvability. Both microeconomic and macroeconomic variables influencing the firm were examined while distinguishing its qualities, shortcomings, openings and threats.USPS items and administrations exhibit its qualities with its restraining infrastructure of the mailing business and as an administration establishment with an open credit extension with the Federal Financing Bank of up to $15B. Shortcomings remember need or next to no decent variety for its items and administrations, extremely prohibitive conveyance plans and ordered enor mous conveyance focuses. Open doors for USPS incorporate expanding its item decent variety exploiting the web and other creating advancements it can use to improve its working costs. USPS is additionally encountering outer and inside threats.One of these dangers is the more extensive acknowledgment of computerized innovation particularly with the web and email, cell phones and portable web, soaring working expenses and powerlessness to roll out convenient improvements and reactions to moderate proceeded with misfortunes without experiencing the Postal Regulatory Commission and Congress. Taking into account this, USPS is prescribed to adopt a multi-prong strategy to improve its incomes by expanding item valuing with its transportation administrations while remaining serious, utilizing the hypothesis of value flexibility of interest to fittingly value its mailing administrations and broadening its products.Reduce working expenses by diminishing quantities of representatives, improving its armada of vehicles to more eco-friendly vehicles or utilizing substitute vitality and furthermore by lessening oversaw offices and conveyance plans. Lastly USPS needs to demand Congress to give it position to impact value changes coming about because of strange changes in cost of fuel and different materials and assets utilized in satisfying its command of offering a key postal support to the country. Outline Establishment and General Business Description Article 1, Section 8, proviso 7 of the United States Constitution builds up the U.S. Postal Service. The present mail station association is working under the arrangements of the Postal Reorganization Act of July 1, 1971 assigning the US Postal Service (USPS) as a free foundation of the official part of the Government of the United States. The Postal Accountability and Enhancement Act, Public Law 109-435 made further modifications and the administering rule is systematized in Title 39 of the United States Code. A similar open law made the Postal Regulatory Commission (PRC) offering the PRC with administrative and oversight commitments in the administration and activity of the U.S. Postal Service (USPS Annual 10-K Report, 2011). The command of the USPS is to offer a â€Å"fundamental postal service† to the whole country at reasonable and sensible rates affirmed by Congress. This order is satisfied by offering diverse degree of mailing and delivery benefits all through the nation. As of September 30, 2011, all out representatives number to 557,251 vocation workers, down 4. 6% from the prior year of 583,908 and 88,700 non-profession representatives (Annual Report to Congress, 2011).More than 85% of vocation representatives are secured by aggregate bartering understandings through one of the accompanying four administration associations: American Postal Workers Union (APWU), National Association of Letter Carriers (NALC), National Postal Mail Handlers (NPMHU) and National Rural Letter Carriers (NRLCA) . Items and Services The United States Postal Service isolates their administrations into two general classes: Market predominant mailing administrations and serious delivery administrations. Mailing administrations incorporate First Class Mail, Standard Mail, Periodicals and Package Services.Shipping Services incorporate yet not restricted to Priority Mail, Express Mail, Bulk, Parcel Post and Bulk International Mail. Mailing administrations have set floor costs however by and large doesn’t have any set maximum price tag up to the permitted most extreme size and weight limits (generally 70 pounds for each bundle). Similar remains constant for transportation administrations. Every one of these administrations are offered through a system of in excess of 32,000 Post Offices, stations and branches, in addition to a large number of agreement post units, Community Post Offices, Village Post Offices, retail foundations selling postage stamps and different administrations including the web, www. sps. com. Extra administrations offered are offer of Postal Money Orders, renting of Post Office boxes and offer of post cards or welcome cards. Universal mail and bundle administrations are likewise accessible to in excess of 190 nations (Annual Report to Congress, 2011). The present First-Class Mail stamp costs $0. 45 expanded 2. 1% beginning in January 2012 that was declared in October 18, 2011. Postal Service Mail evaluating is set by the Board of Governors and affirmed by the PRC. Delivery administrations valuing is set by law taking care of both the institutional costs assignment and inferable costs.The institutional expenses allotment is dictated by the PRC and is presently set at 5. 5%. Along these lines the transportation cost is the aggregate of 5. 5% institutional costs (practically identical to exchange costs) and inferable expense, speaking to the immediate expense of the mailing or delivery administrations based from the weight and size of the bundle (USP S Annual 10-K Report, 2011). Current Financial Statement For the monetary year finishing September 30, 2011, the United States Postal Service announced an overal deficit of $5. 067B from their activity, an improvement contrast with the past year’s loss of $8. 505B. This is in spite of a decrease of 4. % in the quantity of its vocation representatives from 583,908 to 557,251 (USPS Annual 10K Report, 2011). Much the same as some other private organizations, the USPS was additionally extraordinarily affected by the worldwide economy particularly the profound and delayed financial downturn of 2008. Furthermore, with progress in innovation, more extensive accessibility of web broadband administrations, lower cost of PCs, pervasive utilization of web based banking and furthermore flood in offering of online finances moves, which offers comfort and speed as well as for all intents and purposes free, has legitimately contend and prevailed upon a portion of the mailing administrations of the USPS.Mail volume conveyances have diminished by 5% over the most recent two years, 2011 and 2010 and the prior year, in 2009, the lessening was an amazing 12. 8% (USPS Annual 10K Report, 2011). The extension of portable web combined with advanced cells will just compound USPS declining mail volume later on. At long last, one of the greatest working costs of USPS other than transportation expenses and plant gear and offices is representative wages and retiree benefits. USPS business costs makes up around 80% of its complete working expenses (Kosar, 2012).Employee wages and retiree benefits costs are altogether affected by wage expansion, medical advantage premium expands, retirement and workers’ remuneration projects, and typical cost for basic items remittances. Over the most recent 5 years, the USPS endured an absolute total deficit of more than $25 billion including $21 billion of costs for the pre-financing of the Postal Service Retiree Health Benefits Fund (PSRHBF ) commanded by Public Law 109-435 (USPS Annual 10K Report, 2011). USPS current all out obligation as of September 2011 is at $13B which is just $2B from its legal constraint of $15B set by 39 U.S. C 2005(a) (Kosar, 2012). Budget summaries answered to Congress for the financial year finishing September 30, 2011: Years finished Sept. 30, 2011Percent change from going before year (dollars in millions) 2011 2010 2009 2011 2010 2009 Operating income $ 65,711 67,052 $ 68,090 (2. 0%) (1. 5%) (9. 1%) Operating costs * $ 70,634 $ 75,426 $ 71,830 (6. 4%) 5. 0% (7. 6%) Loss from tasks $ (4,923) $ (8,374) $ (3,740) Operating edge (7. 5%) (12. 5%) (5. 5%) Net deficit $ (5,067) $ (8,505) $ (3,794) Purchases of capital $ 1,190 $ 1,393 $ 1,839 (14. 6%) (24. 3%) (7. %) Property and hardware Debt $ 13,000 $ 12,000 $ 10,200 Interest cost $ 172 $ 156 $ 80 Capital commitments of $ 3,132 $ 3,132 $ 3,087 U. S. Government Deficit since revamping $ (22,072) $ (17,005) $ (8,500) Total net lack $ (18,940) $ ( 13,873) $ (5,413) Number of vocation workers 557,251 583,908 623,128 (4. 6%) (6. 3%) (6. 0%) Mail volume (pieces in millions) 167,934 170,860 176,744 (1. 7%) (3. 3%) (12. 8%) New conveyance focuses served 636,530 739,580 923,595 *P. L. 112-33 had a net effect of a $5. 5 billion decrease of costs in 2011.P. L. 111-68 had a net effect of a $4. 0 billion decrease of cost in 2009. Graphical portrayal of USPS working incomes and costs from FY 2004 †FY 2011 Market Structure Monopoly Salvatore D. (2012) characterized an imposing business model market as â€Å"an association in which a solitary firm sells an item for which there are no nearby substitutes† (p. 388). What's more, of the four wellsprings of syndication refered to (Salvatore, p. 390) is one set up by an administration establishment like the United States Postal Service. Not all of USPS items and administrations are monopolized.USPS syndication is just in their mailing administration alluding to as its â€Å"dominan t mailing service†. No other conveyance administration organization in the business is permitted to convey mail. Furthermore, this incorporates conveyance administration organizations like UPS and FedEx. Mailing administrations incorporates First Class Mail, Standard Mail, Periodicals and Package Services. The USPS’s has restraining infrastructure over letter conveyance, post box imposing business model and the capacity to suspend the conveyance in specific regions. It implements this imposing business model with its furnished postal investigators who can direct inquiries and seizures in the event that it associates penetrate with its monopoly.The

Analysis Of Ted Hughes Poems

Investigation Of Ted Hughes Poems As the title proposes, this sonnet is about wind and the dangerous impacts that it has on both the scene and individuals that live in a disengaged house. The storyteller discloses to us how the occupants of the house battle against an incredible and fierce climate. In any case, notwithstanding the endeavors no human is sufficiently able to oppose the outrageous powers of nature. In this manner the connection among Man and Natures power is the key subject in Wind. 3. MUSIC AND LANGUAGE This house/has been/out of sight/ocean/all the night Numerous sonnets have exact examples to follow as rhyme and meter. Be that as it may, Hughes doesnt follow any example since he needs to make the feeling of bedlam as the extraordinary climate does in the sonnet. At that point writing in a free stanza he dismisses all the traditional graceful guidelines. In like manner is important to investigate how the mood impacts the sonnets meaning. As indicated by this we can see that he utilizes a predictable rhyming on the grounds that we can see five beats in each section with substituting unaccented and emphasized syllables. This predictable rhyming makes an irregular beat giving an essentialness to the sonnet that accentuates the breezes highlights. Additionally he utilizes similar sounding word usages, for example, wind employed edge light (6) that helps the hit to remember the breeze and simultaneously proposes that the breeze could strike whenever. There is more similar sounding word usage in the line dark back gull bowed like an iron b ar gradually (16) that passes on a moderate perusing that reflects somehow or another the devastating puff of the breeze. The sonnets language is brimming with words with a specific sound example. He utilizes words wich mean solidarity to portray the intensity of the breeze, for example, blast or flung that transforms the breeze into an awful and brutal nature power, not at all like for example the words trembling and cry used to the people groups depiction and which provide for them an implication of shortcoming. 4. STRUCTURE Wind has a straight story structure in which every one of six verses accommodated by four lines every one. The structure of the sonnet appears to be very straightforward, however in the event that we focus on the finish of the refrains we can see that some of them absences of accentuation. The accentuation is one of the proper perspective that makes simpler the comprehension of a book, dodging uncertain implications and troubles to decipher it. In this manner I imagine that in Wind the artist breaks all the proper shows beginning the lines with capital letter and utilizing the accentuation as he needs so as to stress the impacts of the breeze. He modifies the accentuation shows inciting turmoil, disarray and tumult as the breeze does in the scene and individuals of the sonnet. 5. Symbolism AND FIGURES Symbolism and figures are striking procedures that must be featured in this verse article. They can be found through the entire sonnet so as to expand the quality of the breeze and they help the peruser to envision each occasion in an increasingly sensible manner. In the main verse he is talking about the crush power of the breeze. He utilizes in this verse numerous representations and embodiments underscoring the unprecedented intensity of nature. In the primary line of the sonnet this house has been out of sight ocean throughout the night (1) we can see the illustration of the house out of sight ocean as it was a vessel lost in no place battling against the ocean as the house battles against the breeze. The subsequent refrain shows a clear appear differently in relation to the first. After the earnest utilization of exemplification to improve the force and savagery of the breeze , he depicts a still wide open with an orange sky (5). Following with a similar line till day rose (5), we can see that he is allowing to the day human characteristics indeed. The third verse the artist utilizes the principal individual portrayal. He utilizes this gadget to make commonality in the peruser. For example when it says that he scaled along the house side (9) we can envision the man looking with nature and we come at the situation from his perspective inclination sympathy for him. In the fourth refrain he depicts the scene as being dreadful of the breeze as he says the fields shuddering, the horizon a scowl (13) representing fields and sky so as to underscore upon the feeling of intensity of the breeze. The line The breeze flung a jaybird away and a dark gull twisted like an iron bar (15) is another commitment to the feeling of intensity of the breeze since it can in any event, throw a jaybird away. In the accompanying line he utilizes a comparison to depict the breeze quality saying that it can twist a dark gull like an iron bar (16). The fifth verse talks about the house regarding shortcoming depicting it as fine green challis (17) under the savage breeze, while the hearts of occupants are holding and they attempt to confront the components, however they are frightened to the point that even can't engage book, thought or one another (20). The last refrain feel the roots if the house move (22) can have a two sided connotation, from the outset we can believe that the breeze is solid to the point that can even move the house, yet additionally it tends to be identified with the underlying foundations of the family, his legacy and convention. The house that so much exertion they utilized to manufacture it and where all the family conventions and qualities were settled. The sonnet closes with the call of the stones, implying that something so solid and practically unbreakable as a stone is likewise dreadful in view of the tempest. 6. End There is an extraordinary control of language and symbolism in this sonnet. Through his magnificent utilization of figures and pictures plainly identified with its subject and structure he provides for the breeze the character of a huge and incredible monster making this sonnet an amazingly sonnet. Hughes catches the intensity of the breeze in phrases loaded with a wild and unquenchable vitality accomplishing an incredible intensity of articulation in each line of the sonnet.

The Land Registration Act 2002 and its Impact on Interests in Land - Free Essay Example

A registration scheme far more comprehensive than land charges is found today in the Land Registration Act 2002. The principle significance of this is that the register tells the purchaser who owns the legal estate. The system moreover is not limited to legal estates. Subject to some exceptions (overriding interest), all legal and equitable interest must be entered on the register if they are to bind a purchaser.[1] The first thing to ascertain when dealing with any piece of land is which system of conveyancing is to be applied. And it is clear in the scenario that the land is registered.[2]The purchaser will want to know whether any third parties have rights to the land which might interfere with the intended use of it. Concern about these matters will lead the purchaser to make extensive enquiries before the purchase of the estate is finally concluded.[3] A. Legal leases not exceeding seven years constitute overriding interest and this falls under schedule 3, Para 1 of LRA 2002. Short legal leases are specifically excluded by Para 1 from the category of short leases which override registered disposition. That includes leases which are to take effect in possession more than three months after the date of grant.[4] Polly comes to the cott age after Alisha brought it but Polly was given the lease the previous year. And since Alisha didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t find any belongings in the cottage before buying we can assume that Polly returned after a year to take possession. In that case Sec.4 (1) (d) applies which makes the lease not an overriding interest. Because such leases mean that there is a real risk that the purchaser might buy the estate without discovering that it is subjected to a lease when the tenant is not necessarily in possession of the land. In such scenarios we can conclude that only the facts matters. And if Polly wants her legal lease to be protected knowing that she wonà ¢Ã¢â€š ¬Ã¢â€ž ¢t be in possession of the cottage for some time she should have made a notice[5] in the register about her lease. But certain interests cannot be protected by notice[6] , one such case is when the lease doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t exceed more than three years, interest under a trust of land or restrictive covenants. Sin ce Pollyà ¢Ã¢â€š ¬Ã¢â€ž ¢s lease is for four years it can be entered into the charges register. The fact that an interest is the subject of a notice doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t mean that the interest is valid. However, if the interest is valid, the notice ensures both that it binds any purchaser for valuable consideration[7] , and he knows about it before he takes the estate.[8] It is therefore much safer to protect such interests by notice. Once such an entry has been made the interest losses its overriding status[9] , but of course binds a disponee for valuable consideration. B. It is essential to remember that, it is the rights of the occupiers that bind purchasers and not the occupation itself. The claimant must always prove two elements: actual occupation and an interest in land. In National Provincial Bank v Ainsworth[10] it was held that deserted wifeà ¢Ã¢â€š ¬Ã¢â€ž ¢s equity to be a mere personal right against her husband; her occupation made no difference.[11] Ju dges have regularly emphasized that the question of whether a party is in actual occupation is essentially a question of fact. Lord Wilberforce stated that[12], à ¢Ã¢â€š ¬Ã‹Å"It is the fact that matters and what is required is physical presence on the land and not some entitlement in lawà ¢Ã¢â€š ¬Ã¢â€ž ¢ this was stated in Abbey National v Cann. In LRA 2002 Schedule 3 , Para 2 if occupation is established but the interest claimed was not known to the purchaser , the question will then be whether the occupation was obvious on reasonable inspection of the land.[13] Wilma daily comes home even for a short while and it is very much unclear whether Alisha didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t notice that. And the wedding photograph is good evidence to the fact that Wilma may have a share in the land. A thorough search should have taken place in such risky matters which Alisha didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t. The question is Wilma not being present permanently in the cottage because she was looking after her sick mother which was clearly defined by the case of Chhokar v Chhokar[14]in relation to LRA 1925 were a similar situation has being dealt with. The court of appeal said that it had no difficulty in holding that she was in occupation at the date, and went on to describe her right in the property as an overriding interest. The effect of temporary absence is now being considered by the courts in Link Lending Ltd v Bustard.[15] Occupation of Wilma was obvious enough through the inspection even if Alisha didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t know about it. This means that provided the occupation is discoverable, the disponee may still be bound by an interest of which she doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t know ( Malory Enterprises Ltd v Cheshire [2002] )[16]Nevertheless in Kingsnorth Finance Co Ltd v Tizard[17] provide that there was actual occupation even when the wife was divorced she visited every day to look after her children. Although she was not living there her daily activities might be regarded as sufficient to justify the result. The facts are all important in such a case.[18] The result in Chhokar seems clear, but what if the seller had removed all evidence of the wife. Like in the scenario it is unclear whether Alisha sees possessions of Wilma other than the wedding photograph before sale. And since Bob lies about a divorce Wilmaà ¢Ã¢â€š ¬Ã¢â€ž ¢s claim might be stronger in such a circumstance. The purchaser has a statutory defence to an overriding interest if inquiry is made of the occupier, but the rights are not disclosed.[19] This is a clear hint to a purchaser as to what should be done. Those in actual occupation must be discovered and then asked what their interests are. In practice and in the scenario they tend to rely on the sellerà ¢Ã¢â€š ¬Ã¢â€ž ¢s information. This might be convenient but gives no protection. And when Alisha identified the wedding photograph she should have been careful enough to ask the occupier what their interests are rather than w hether she is present or not. This is because there is no need for overriding interest to be the source of the actual occupation.[20] The scenario doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t state that Wilma and Bob are divorced so this matter can be taken under Family Law Act 1996, s31 (10), that where one spouse or civil partner owns the family home, the other spouse has a right not to be evicted if already in occupation and a right with a leave of the court to enter and occupy if not already in occupation. And this lasts as long as the marriage continues. Under Sec.31 Wilmaà ¢Ã¢â€š ¬Ã¢â€ž ¢s home rights constitute a charge on the estate or interest of Bob and will bind Alisha in the property for valuable consideration if they are protected by a notice on the register of the title. This acts as an exception to overriding interests and thus binds Alisha. C. Easements and profits can be created expressly or impliedly by granting another person a right over oneà ¢Ã¢â€š ¬Ã¢â€ž ¢s land or by r eserving a right over land which one is transferring to another person.[21]Only legal easements are now capable of overriding the register. The LRA 2002 effectively reversed the controversial case of Celsteel Ltd v Alton House Holdings Ltd[22] which held that both legal and equitable easements were overriding within 1925 scheme. But if somehow the deed is registered it loses its overriding status. We can assume that Maxwellà ¢Ã¢â€š ¬Ã¢â€ž ¢s claim satisfy the requirement for a valid easement as laid down in Re Ellenborough Park.[23]A valid easement can be created by prescription which is long use of land and under Sec 2 of the Prescription Act 1832. The use for many years of a right which is capable of being an easement can create a legal easement by prescription.[24] Prescription arises if an easement has been used openly, as of right, without permission and continuously by one fee simple owner against another, provided that the right could have legitimately been granted by the landowner.[25] Maxwell does use the path openly and even notify Alisha of his right and say he has been using it for any years. It is somewhat unclear whether the prescription is by lost modern grant. Finally, we can come to a conclusion which interests bind Alisha and which does not. The legal lease of Polly doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t bind Alisha since thereà ¢Ã¢â€š ¬Ã¢â€ž ¢s lack of physical presence and notice as explained. But the share of Wilma does bind Alisha since she has some equitable rights towards her share of the property. And finally the easement will also bind Alisha through the Prescription Act 1832. Critically examine the rationale for the continued existence of interests which override. à ¢Ã¢â€š ¬Ã…“Overriding interests are important and controversial because they contravene the most basic registration principle: they bind purchasers despite not being entered on the Registerà ¢Ã¢â€š ¬Ã‚  Roger Smith, Elements of Land Law (Pearson Longman 2007) I n a sense overriding interests are rather like à ¢Ã¢â€š ¬Ã‹Å"trump cardsà ¢Ã¢â€š ¬Ã¢â€ž ¢ of the registered land system, taking automatic priority to any rights which are subsequently acquired by a person in the land. Not only that, but they can also lead to alteration of the register with no compensation being payable to the purchase. Little wonder then that a former Chief Land Register referred to them as à ¢Ã¢â€š ¬Ã‹Å"a stumbling blockà ¢Ã¢â€š ¬Ã¢â€ž ¢.[26] When compulsory title registration was introduced, the aim of its creators was to simplify conveyance by placing all the essential information about an estate in land on a register. Thereafter a purchaser intending to buy the land will only have to look up at the register in order to discover all what he needed to know about the property.[27] A major difficulty arose from the category of à ¢Ã¢â€š ¬Ã‹Å"overriding interestà ¢Ã¢â€š ¬Ã¢â€ž ¢. The original notion of land registration was that the register would provide a complete record of the title, so that the purchaser will be able to buy it with minimum or other enquiries or inspections.[28] The fundamental principle behind registered land is the mirror principle, which is to reflect accurately and completely and beyond all argument the current facts that are material to a mans title. Overriding interests represents the greatest breach in the mirror principle. They were not accidentally created but rather deliberately done by the legislature and given automatic effect precisely because they should be obvious to any prospective purchaser or their enforcement is too important to depend on registration.[29] On the other hand the curtain principle is perhaps the most ambitious motive behind the origin 1925 Act and it remains a key principle under 2002 Act. The aim is to keep certain types of equitable interests off the register completely. As Williams and Glynà ¢Ã¢â€š ¬Ã¢â€ž ¢s Bank v Boland shows, if the curtain is not raised the purchaser can easily be bound by such equitable interests. This problem clearly involves striking a balance between protection of the purchaser and protection for the occupier of land and it arose largely due to social and judicial changes.[30] Paragraphs 1 to 3 of Schedule 3 cover three types of interests which were overriding under LRA 1925. They are short leases, rights of persons in actual occupation and easements and profits. Schedule 3, Para 1 shortens the length of a lease from not exceeding 21 years to not exceeding 7 years. And in the future it can reduce to 3 years with the effect of e-conveyancing[31]. The reason why these leases override is that it would be unreasonable to expect short leases to be registered and if they were the register would be cluttered up by them. Under the 1925 Act anyone with proprietary right in property and also in actual occupation could claim an overriding interest. In Williams Glynà ¢Ã¢â€š ¬Ã¢â€ž ¢s Bank v Boland in 1981 defined actual occu pation as à ¢Ã¢â€š ¬Ã…“It is the fact of occupation that matters and what is required is the physical presence in the land and not some entitlement in lawà ¢Ã¢â€š ¬Ã‚ . However, Schedule 3 of LRA 2002 has reduced the extent to which these interests can bind a purchaser on subsequent registration of title so that a purchaser will not be bound if the occupation would not have been obvious on a reasonable inspection of the land at the time of the disposition. Under LRA 1925 s.70 (1) (a) all legal easements and profits and certain equitable easements[32] were overriding. But this wide category was reduced by LRA 2002 under Schedule 3, Para 3 where only legal easements by prescription or implied easements and profits were overriding. The LRA 2002 effectively reversed the controversial case of Celsteel Ltd v Alton House Holdings Ltd[33] which held that both legal and equitable easements were overriding interests within the 1925 scheme. Under LRA 1925 Sec. 70 (1) (f) a squatter could obtain title after 12 years adverse possession.[34] The new rules introduced by LRA 2002 apply to any squatter who had not completed the 12 year imitation period before the Act came into force on 13th October 2003. The rules are designed to protect the rights of the registered proprietor, and as a result the squatterà ¢Ã¢â€š ¬Ã¢â€ž ¢s chances of acquiring title to land are greatly reduced by the new scheme.[35] Finally local land charges override but they should be discovered by a local land charges search carried out before purchase. Moreover other interests, such as chancel repair liability will cease to override on 13 October 2013. Thus the à ¢Ã¢â€š ¬Ã‹Å"snap shotà ¢Ã¢â€š ¬Ã¢â€ž ¢ is becoming more accurate.[36] Why do we have them? At one time it was argued that the register replaces the title deeds and that the registration system should not protect purchasers in respect of interests not generally found in title deeds. Although this seems correct as historical exp lanation[37], the law commission has rejected it as an approach fit for the modern law. Their view is that, à ¢Ã¢â€š ¬Ã…“In the interest of certainty and of simplifying conveyancing, the class of right which may bind a purchaser otherwise than as the result of an entry in the register should be as narrow as possible but à ¢Ã¢â€š ¬Ã‚ ¦ interests should be overriding where protection against purchasers is needed, yet it is either not reasonable to expect or not sensible to require any entry on the register.à ¢Ã¢â€š ¬Ã‚ [38] They are also difficult to discover on an inspection of the land.[39] Not surprisingly the 2002 Act is working towards either minimizing or abolishing some overriding interests but has not yet worked out a strategy to eradicate them once and for all.[40] To make them lose their rights would contravene Article 1 of the First Protocol of ECHR. Active promotion of the advantages of registering interests could work in favor of both the purchaser and the ben eficiaries of these rights. Times have changed and the importance of moving on cannot be underestimated.[41] This surely illustrates the deepening of the crack in the mirror principle of registered land. In order to narrow the crack, the class of overriding interests may be made more certain by narrowing the class. On the grounds of public policy, there will perhaps always be interests which will need protection against the purchaser, where it will be unreasonable to register the interests. Therefore, the extent of the crack can never really get away from third- party interests, which is just as important as having quicker and cheaper conveyancing. Until legislation makes clear specifications on what particular interests can qualify, the concerns of overriding interests will remain. Bibliography Textbooks Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) Roger J Smith,Property Law(7th, Pearson Education Limited, 2011) Martin Dixon , Gerwyn LL H Griffiths and Emma Lees, QA Land Law (8th, Routledge, 2013) Journal Articles Matthew Roach, the end is nigh for Overriding interests -Or is it? [Summer 2013 ] 2 Stewart-Wallace , principles of land registration, p 32 Online resources Mangala Murali, Overriding Interests à ¢Ã¢â€š ¬Ã¢â‚¬Å"a conundrum of English Land Law (Law Brief Update October 10, 2012 ) https://www.lawbriefupdate.com/2012/10/10/overriding-interests-a-conundrum-of-english-land-law/ accessed 1/12/2015 Statues Land Registration Act 1925 Land Registration Act 2002 Prescription Act 1832 Limitation Act 1980 Cases Bakewell Management Ltd v Brandwood Celsteel Ltd v Alton House Holdings [1985] Celsteel Ltd v Alton House Holdings Ltd [1985] 1 WLR 204 Dewan v Lewis [2010] EWCA Civ 1382 Kingsnorth Finance Co Ltd v Tizard [1986] 1 WLR 783 (Ch D) Link Lending Ltd v Bustard [2010] EWCA Civ 424 Malory Enterprises Ltd v Cheshire [2002] National Provincial Bank v Ainsworth [1965] AC 1175 Re Ellenborough Park [1955] 3 All ER 667 Williams Glynà ¢Ã¢â€š ¬Ã¢â€ž ¢s Bank Ltd v Boland [1981] 1 [1] Roger J Smith,Property Law(7th, Pearson Education Limited, 2011) 53 [2]If one is not sure whether a registration has been made it can be found out by making an à ¢Ã¢â€š ¬Ã‹Å"index map searchà ¢Ã¢â€š ¬Ã¢â€ž ¢ which will tell you whether the estate has been registered. Further details may be obtained by making a full search of the register, which since 3 December 1990, can be done without the consent of the estate owner. [3] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 38 [4] S.4 (1) (d) [5] The Act defines a notice as à ¢Ã¢â€š ¬Ã‹Å" an entry in the register in respect of the burden of an interest affecting a registered estate or chargeà ¢Ã¢â€š ¬Ã¢â€ž ¢ S.32(1) [6] S.33 [7] S 32(3) [8] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 106 [9] S 29(3) [10][1965] AC 1175 [11] Roger J Smith,Property Law(7th, Pearson Education Limited, 2011) 254 [12] Williams Glynà ¢Ã¢â€š ¬Ã¢â€ž ¢s Bank Ltd v Boland [1981] [13] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 118-119 [14] [15] [2010] EWCA Civ 424 [16] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 115 [17] [1986] 1 WLR 783 (Ch D) [18] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 115 [19] Sch3 Para 2b [20] Roger J Smith,Property Law(7th, Pearson Education Limited, 2011) 264 [21] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 111 [22] [1985] 1 WLR 204 [23] [1955] 3 All ER 667 [24] The role of this doctrine was summarized in Dewan v Lewis [2010] EWCA Civ 1382 [25] Bakewell Management Ltd v Brandwood [26] Roger J Smith,Property Law(7th, Pearson Education Limited, 2011) 251 [27] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 86 [28] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Pres s, 2014) 86 [29] Martin Dixon , Gerwyn LL H Griffiths and Emma Lees, QA Land Law (8th, Routledge, 2013) 10 [30] ibid [31] The introduction of e-conveyancing will have tremendous significance for the operation of the registered title system. It will only remove the gap between execution and registration which , as we have seen , can cause problems , but will also reduce very considerably the number of interests which can be created à ¢Ã¢â€š ¬Ã‹Å"off the registerà ¢Ã¢â€š ¬Ã¢â€ž ¢. [32] Celsteel ltd v Alton House Holdings [1985] [33] [1986] 1 WLR 512 [34] Even if the squatter is no longer in possession at the date of disposition. [35] Judith-Anne MacKenzie,Textbook on Land Law(15th, Oxford University Press, 2014) 141 [36] Martin Dixon , Gerwyn LL H Griffiths and Emma Lees, QA Land Law (8th, Routledge, 2013) 21 [37] Stewart-Wallace , principles of land registration, p 32 [38] Another important factor permeating the changes introduced by LRA 2002 is the ex tent to which a purchaser may be expected to discover these interests without making extensive inquiries. à ¢Ã¢â€š ¬Ã…“Because overriding interests bind transferees of the land even though they are by definition, not protected on the register, they are widely acknowledged to be potential source of difficulty in registered conveyancingà ¢Ã¢â€š ¬Ã‚  The law commission report no254 1998 [39] Examples include rights of an occupier of land, a lease for a term of less than seven years, profits a prendre (fishing rights or shooting or hunting rights). [40] The rights of persons in actual occupation present formidable challenges for reformists and it is this area of law that professionals must work on to find a conducive solution. [41] Mangala Murali, Overriding Interests à ¢Ã¢â€š ¬Ã¢â‚¬Å"a conundrum of English Land Law (Law Brief Update October 10, 2012 ) https://www.lawbriefupdate.com/2012/10/10/overriding-interests-a-conundrum-of-english-land-law/ accessed 1/12/2015

Capital Punishment Is A Penalty For All Crimes - 1939 Words

Capital punishment has been occurring since the earliest of the ages and has been performed numerous times around the globe by all differently opinionated people. Last year only, 256 citizens have been executed by the hand of law and only more to be uncovered. Capital punishment was part of culture in Babylon where it coded the penalty for exactly twenty-five crimes, Athens where death was suitable for all crimes, and Rome. Since the olden ages, humans are still holding crimes against other people applicable by death. But now, as humanity grows and our minds expand to new ideas and thinking, we have come to the conclusion: As humans, do we really have the right to take away another soul’s life and living? So, as capital punishment makes†¦show more content†¦Capital punishment assesses the perseverance of humanity and its morals. Because, the question is, is the federal government allowed to murder such souls though tainted? But, the question is more, do these victims â€Å"deserve† the cruelty of death? Expressing one’s violence does not suppress it, in fact, it simply enforces the desire to express it. Controlling and demonstrating emotions in such a way that contaminates the good will in humans that is able to understand sentiment. As stated by Thurgood Marshall, the late Justice of the Supreme Court, in in a June 29, 1972 Furman v. Georgia, â€Å"In judging whether or not a given penalty is morally acceptable, most courts have said that the punishment is valid unless it shocks the conscience and sense of justice of the people. Assuming knowledge of all the facts presently available regarding capital punishment, the average citizen would, in my opinion, find it shocking to his conscience and sense of justice. For this reason alone, capital punishment cannot stand. Thinking rationally, while inputting variables into the equation of the justice of capital punishment, you could assume, depending on your variables, that capital p unishment might be of a formidable use. But thinking with your soul is much different. A â€Å"gut-decision†, you may call it. But, why would a functioning being, with a valid reason, chose to voluntarily murder a soul, another one, similar to yours? The government is a social

Strengths & Weaknesses of Cloud Based Solutions-Free-Samples

Question: Write a review of strengths and weaknesses of cloud based solutions. Taking into consideration the environment which the solution would be deployed. Answer: Introduction There are various industries that have been set up in different parts of the globe that comprise of several organizations and business units. Due to the presence of so many different entities, there is a lot of competition that has been witnessed to maintain an edge over the others. Technology plays a major role in the maintenance of this edge over the competitors in the market. It is because of this reason and various other advantages that the organizations are making a move to adapt latest technological elements. Headspace, a healthcare organization that provides medical treatment, assistance and services to the patients has decided to implement a health record system in its organization. Non-Functional System Requirements In any of the automated systems and applications, there are several requirements and specifications that need to be fulfilled. Each of these categories of requirements has their own significance and relevance to the system. Non-functional requirements are also known as the system qualities and these are the requirements that determine the user satisfaction levels and the behavior of the system. The following requirements shall be maintained in the system so that the system behavior and response is adequate and is efficient enough to achieve high levels of user satisfaction. System Usability Any of the automated system or an application that is implemented in an organization is done with a purpose to overcome the existing issues and provide the end-users with amazing user experience. The same holds valid for the automated system that is being developed for Headspace. There shall be an element of usability included in the system so as to make sure that the system is easy to use and navigate and is also equipped with the desired set of functions and features (Lauesen Younessi, 2016). Reliability There are various categories of information that will be associated with the automated system for Headspace. However, the primary category would be the mental health details of the patients and this category of information will be extremely sensitive in nature (Chung, 2016). It would be required to make sure that the system presents the response to the user queries in such a manner that the reliability of the response is always maintained and followed. Performance of the System The automated system shall have utmost levels of performance which shall be determined by indicators and parameters, such as, response time and throughput time. All of these elements must be minimal so that the user does not suffer from any lags or performance issues (Malan Bredemeyer, 2010). Supportability Technology is not stagnant or static in nature and keeps on experiencing many changes and alterations. The automated system that will be developed for Headspace must be designed in such a manner and with the use of such a methodology that such changes and alterations can be easily incorporated in the system and other changes in terms of usage and requirements can also be met with ease (Shaikh Misbahuddin, 2016). List of System Interfaces Set of User Interfaces The design methodology used in the system design phase shall be responsive web design. It is because of the reason that the users expect the present day systems to behave and respond according to their actions and preferences which would be easily made possible by this design method. The use of colors shall be kept simple and light which shall fall in line with the purpose, aim and theme of the system. Visual appeal shall be enhanced by enhancing the interaction level by making good use of responses such as highlights, change of colors, change of text etc. Customization shall be incorporated in the system by allowing the users to change the system theme and the colors used in the application (Fosse Delp, 2016). All the screens on the system shall make sure that the consistency is reflected and shown in terms of the layout that is present along with the size of the text elements, headings, color of the text etc. The flow of the system on one screen or within the screen in terms of scrolling and navigation must be extremely smooth. The use of styles and font face for the headings and the textual content in the body must be kept uniform across all the screens. Set of External Systems/Devices Interfaces Users shall be allowed to send and receive emails which shall be made possible by using protocols like Simple Mail Transfer Protocol. Transmission and sharing of files shall be allowed and made possible by using suitable protocols and mechanisms. Network connections and communications shall be allowed and made possible by using protocols like Transmission Control Protocol. Communication is one of the most important aspects of the system and the same shall be maintained by using and integrating the communication protocols in the system. There shall be health equipment and tools that must be connected with the system so that the users can record the health signs using the same (Conde et al., 2010). Information privacy and security shall be maintained by making use of security protocols at the network and transport layers (Wheatcraft, 2010). System Constraints The source code shall be created in JAVA programming language so that the code is flexible and inter-operatable. NetBeans shall be used as the tool for coding purposes. The back end shall be set up using NoSQL and Cloud databases such as MongoDB. Test creation and execution shall be done by using the tool as TestLink (Dettmer, 2016). Defect logging, tracking and management shall be done through Bugzilla. Cloud Based Solutions Cloud computing plays a significant role in the automated system that will be developed for Headspace. The back end of the system will be entirely dependent upon the cloud database and services. Also, deployment and delivery of the system will be made possible by using and implementing suitable cloud models. For the purpose of system delivery, there are three choices that are present which can be analyzed and selected for this case. These include cloud models on the basis of software, platform or infrastructure. Platform as a Service (PaaS) is the cloud delivery model that has been selected and recommended for this case. There will be many advantages that will be offered by the PaaS model to the automated system for Headspace. These include the upgraded levels of security of the system and the information sets associated with it that will be made possible. There would also be easier management and maintenance that will be possible along with the platform for execution of the operations. This model may score a little higher in terms of the budget but it would otherwise fit to the needs and requirements. Similarly, there are various models that can be selected for the deployment of the system which include hybrid, public and private cloud models. The model that has been recommended for the system is hybrid cloud model. This model has been recommended because it includes the features and benefits of both the public and private cloud models. The handling and management of the information will be accordingly done on the basis of the information type. The deployment services necessary as per the information classification will also be possible accordingly. There are cloud services that are present for information security and privacy as well. Cloud based security solutions in terms of network security, intrusion detection, malware detection and anti-denial tools shall be implemented so that the information is always kept secured and protected from the security threats and attacks. Software Development Life Cycle (SDLC) Approach Many methodologies, techniques and approaches have been designed for the development of the system or software. The two categories of approaches with their features and parameters have been discussed and described below. Predictive Approach In this approach, all the project tasks and activities that shall be executed for the development of the system are determined and listed in the initial phase. The project estimations in terms of the effort, schedule, costs, resources etc. are done during the first phase and the developmental activities are accordingly planned. There is a great degree of dependency of the project activities on the other tasks that is witnessed. The execution takes place in a set of phases and this approach is applicable when the probability of risks and requirements inflation is less. Waterfall model is one of the popular examples of predictive SDLC approach. Adaptive Approach This is the approach that is ad-hoc and adaptive in nature and does not pre-determine any of the tasks or activities. In this case, the execution takes place as per the information available in terms of specifications and requirements. There is no set series or plan that is followed and a number of interactive iterations are used for the purpose of execution. It leads to the ability to easily manage the changes. Agile SCRUM framework is one of the popular methodologies that come under this SDLC approach. Recommendations The report includes numerous suggestions and recommendations in terms of the programming language, database, testing tools, cloud deployment and delivery models, security protocols etc. The most important element of the project that will determine its success or failure is the development approach. The recommended approach in this case is the adaptive approach which shall include agile SCRUM framework for this case. The recommendation is based upon several reasons which include the higher level of interaction with the project client, increased transparency with the customers, higher scalability, supportability and flexibility along with enhanced communication that come along with this approach. All of these elements are a part of the feature list of the agile SCRUM framework which would make it easier for the project team to achieve project goals and objectives. There are also additional benefits that will be offered in terms of decreased probability of risks and better change management. Management, planning and communication are the three elements that also have an extremely significant role to play in the success of the projects. The methodology and approach that is used in these activities also have a lot of relevance. Project Management Body of Knowledge (PMBOK) is the approach that must be used in these areas so that the results that are achieved are positive and the project goals and objectives are met. The project risks and conflict areas will also be managed efficiently by making use of PMBOK methodology. There may be many different conflicts, disputes and problems that may come up among the project resources which will be easily handled along with the management of project costs and schedule. References Agilemodeling,. (2016). UML 2 Use Case Diagramming Guidelines. Agilemodeling.com. Retrieved 04 October 2017, from https://agilemodeling.com/style/useCaseDiagram.htm Bourne, L. (2016). Stakeholder Relationship Management. Retrieved 04 October 2017, from https://www.mosaicprojects.com.au/PDF_Papers/P128b_Stakeholder_Relationship_Management.pdf Chung, L. (2016). Non-Functional Requirements. Retrieved 04 October 2017, from https://www.utdallas.edu/~chung/SYSM6309/NFR-18-4-on-1.pdf Conde, J., De, S., Hall, R., Johansen, E., Meglan, D., Peng, G. (2010). Telehealth Innovations in Health Education and Training. Telemedicine And E-Health, 16(1), 103-106. https://dx.doi.org/10.1089/tmj.2009.0152 Dettmer, H. (2016). Systems and Constraints: The Concept of Leverage. Retrieved 04 October 2017, from https://goalsys.com/systemsthinking/documents/Part-6-SystemsandConstraints.pdf Fakhroutdinov, K. (2016). UML actor is a role played by a human user of the designed system, some other system or hardware that interacts with the subject by using services of the subject.. Uml-diagrams.org. Retrieved 04 October 2017, from https://www.uml-diagrams.org/use-case-actor.html Fosse, E. Delp, C. (2016). Systems Engineering Interfaces: A Model Based Approach. Retrieved 04 October 2017, from https://www.omgsysml.org/System_Engineering_Interfaces-IEEE_2013.pdf Lauesen, S. Younessi, H. (2016). Six Styles for Usability Requirements. Retrieved 04 October 2017, from https://www.itu.dk/~slauesen/Papers/SixStyles.pdf Malan, R. Bredemeyer, D. (2010). Defining Non-Functional Requirements. Retrieved 04 October 2017, from https://www.bredemeyer.com/pdf_files/NonFunctReq.PDF McAtee, M. (2016). A good compliance system takes the administrating out of managing. Qualitydigest.com. Retrieved 04 October 2017, from https://www.qualitydigest.com/nov01/html/paperless.html Rhyous,. (2011). The 8 Types of Technical Documentation and Why Each Is Important. Rhyous. Retrieved 04 October 2017, from https://www.rhyous.com/2011/07/21/the-different-types-of-technical-documentation-for-software-and-why-each-is-important/ Shaikh, A. Misbahuddin, M. (2016). A system design for a telemedicine health care system. Retrieved 04 October 2017, from https://gupea.ub.gu.se/bitstream/2077/10498/1/gupea_2077_10498_1.pdf Walker, D. (2016). Influence, Stakeholder Mapping and Visualisation. Retrieved 04 October 2017, from https://mosaicprojects.com.au/PDF_Papers/P062_Influence_Stakeholder_Mapping_and_Visualisation.pdf Watt, A. (2016). 5. Stakeholder Management | Project Management. Opentextbc.ca. Retrieved 04 October 2017, from https://opentextbc.ca/projectmanagement/chapter/chapter-5-project-stakeholders-project-management/ Wheatcraft, L. (2010). Everything you wanted to know about interfaces, but were afraid to ask. Retrieved 04 October 2017, from https://spacese.spacegrant.org/uploads/images/UserContributedFiles/WheatcraftInterfaces110909.pdf Wick, S. (2016). User Stories and Use Cases - Dont Use Both!. Batimes.com. Retrieved 04 October 2017, from https://www.batimes.com/articles/user-stories-and-use-cases-dont-use-both.html

Movie Analysis North Country Essay Example

Movie Analysis : North Country Paper The movie North Country was based on the book †Class Action: The Landmark Case That Changed Sexual Harassment Law† which tells the story of Lois Jenson, who filed the first class action lawsuit for sexual harassment in American history. In the film, Theron plays the daughter of an iron miner (Richard Jenkins) working in a mine in Northern Minnesota Mesabi Iron Range. When Josey leaves an abusive husband and moves back to her hometown into her parents’ house, she was not welcomed. Her father assumes, without even interrogating his daughter, that it was her infidelity to her husband that had created the situation. Even her own son thinks that she is a whore. What this shows is the tendency to assume that it’s the woman’s fault in any conflict with men. Such biases were more prevalent in the chronological setting of the film, which covers the last few decades of the 20th century (Rosen). All Josey wants is to own a house, eat decent meals and be able to buy her son hockey skates once in a while, which are completely reasonable. But even her father Hank expresses his displeasure to women working in the mines, because it’s not â€Å"women’s work†. He also blames Josey of taking away a job from a man on whom a whole family is dependent. But Hank fails to notice that his daughter too has a family to support. Even the women in the community believe there’s something wrong if she can’t find a man to take care of her. It points to the common acceptance in society, which is women’s dependency and subordination to men (Ebert). We will write a custom essay sample on Movie Analysis : North Country specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Movie Analysis : North Country specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Movie Analysis : North Country specifically for you FOR ONLY $16.38 $13.9/page Hire Writer The most gripping scene in Niki Caro’s off-the-beaten-track drama â€Å"North Country† comes when the lead character, Josey Aimes (played by Charlize Theron) addresses her hostile co-workers at the union meeting to make clear that she does not want the mine closed down, but only the sexual harassment of women to stop (Ebert). Women were as much complicit to such abuses as is evident from the fact that the other female co-workers of Josey choose to bear the humiliation rather than risk losing their jobs. Women felt helpless, in spite of the protection provided by law. This goes to show that the rights granted to citizens of the country as a result of the civil rights movement had still not managed to uproot the patriarchal nature of the society. This is as truer in the 21st century as it was true during the century before. What had decreased is the prevalence and institutionalization of such attitudes and beliefs. Like the court’s decisions on civil rights, it didn’t change everything overnight. Affirmative action was enforced in the Iron Range as late as 1974, when the government finally ordered the steel companies to reserve 20% of their jobs to women and minorities. (Ronning) When Josie takes up a traditional women’s job of a hairdresser, she could earn only a sixth of what she will eventually earn as a miner. This shows the disparity in wages between the two sexes. Women generally don’t get paid as much as men for the same amount of work they do. Another disparity is in the composition of the work force in the mines. Men outnumber women 29 to 1, which is highly disproportionate to the actual population figures. Yet, the ones who do make it through and got the job cannot consider themselves lucky as they were subject to all kinds of sexual harassment by their male co-workers for no fault of theirs. The other women miners are hard-working survivors who tolerate the obscenity and worse, and keep silent because they cannot afford to lose their jobs in trying to make a point (Rosen). During the period when the movie was set, Anita Hill was shown testifying against Clarence Thomas for sexual harassment. What this signifies is the permeation of such beliefs and practices across all layers of the society, including the political offices. The movie showcases the approach and expansion of a legal frontier (Rosen). In the male dominated work environment of the mine, picking on women is all in a day’s work. A woman operates a piece of heavy machinery unaware that a sign is painted on it advertising sex for sale. They find obscenities written in excrement on the walls of their locker room. When finally the union decides to ask for portable toilets for the women, one of the first women to use one has it turned over while she’s inside. Add to that other sorts of touching and fondling, but if a woman is going to insist on having breasts, how can a guy be blamed for copping a feel, goes the logic. It is assumed and widely gossiped that Josey is a tramp, and she is advised to â€Å"spend less time stirring up your female co-workers and less time in the beds of your male coworkers.† (Ronning) The patriarchal nature of the American society in the 20th century is evident from the fact that the retired judge named special master to oversee the trial and to decide the compensation amount to the women, had his own biases. He held traditional beliefs and had a history of sexual misconduct. It was also reported that he frequently fell asleep during the testimony and seemed to enjoy the narrations of harassment when awake. Eveleth Mines’ lead counsel during this phase was a woman, and yet she verbally assaulted the plaintiffs to get the damages reduced. Her strategy involved proving that the harassment was the making of the women themselves due to their provocative behavior towards male coworkers and the plaintiffs were dishonest about the severity and the psychological effects. What this shows is the degree to which women themselves were inculcated to believe in their unquestioning subordination to men (Mishkind 147). Overall, Lois and the other women went through three humiliating trials where their character and personal lives were assaulted over and over again by Eveleth’s lawyers. In addition, they endured the torturous process of litigation, and further torment of the federal court system. The appeals court Judge Donald Lay wrote, â€Å"It should be obvious that the callous pattern and practice of sexual harassment engaged in by Eveleth Mines inevitably destroyed the self-esteem of the working women exposed to it. The emotional harm, brought about by this record of human indecency, sought to destroy the human psyche as well as the human spirit of each plaintiff. The humiliation and degradation suffered by these women is irreparable. Although money damage cannot make these women whole or even begin to repair the injury done, it can serve to set a precedent that in the environment of the working place such hostility will not be tolerated.† (Belton) The status and rights of women during the last century was largely only in paper. Only when Anita Hill testified against Clarence Thomas in October l991, did the United States finally wake up to the reality of sexual harassment. Before that landmark event, few people knew what to call such persistent predatory behavior as it was accepted the norm. If women needed to earn a living, they were expected to grit it out and take it. The idea that sexual harassment could be viewed as a violation of a woman’s civil rights and her ability to earn a living was very slow to catch up with the public (Mishkind 142). The much more fair and balanced sexual harassment policies that we see in corporations and educational institutions today owe in large part, to Lori Benson’s determination to put an end to some of the most shameful sexual harassment ever described in print. Although she had to wait for another 10 years to achieve justice, the suit eventually became the cornerstone of modern sexual harassment law. The much liberated women of the 21st century enjoy their freedom and security due to the perseverance and patience of these women (Belton). Works Cited: Belton, John., American Cinema/American Culture (second edition), McGraw-Hill New York. Ebert, Roger., North Country Review, October 21, 2005. Mishkind, Charles S. â€Å"Sexual harassment hostile work environment class actions: is there cause for concern?.† Employee Relations Law Journal 18.n1 (Summer 1992): 141-147. Rosen, Ruth., Behind â€Å"North Country†, Ronning, G., â€Å"Jackpine Savages: Discourses of Conquest in the 1916 Mesabi Iron Range Strike†, Labor History, Vol. 44, No. 3, 2003

Great Gatsby - Summary of Chapter V essays

Great Gatsby - Summary of Chapter V essays In the night Nick comes home from the meeting with Jordan. Gatsby passes by and asks Nick if he wants to go swimming in his pool. But Nick refuses the offering because he is too tired. In their short conversation they talk also about the invitation of Daisy. They agree on the day after tomorrow. Nick invites Daisy for tea the following day and asks her to come alone. At the day of the meeting Gatsbys gardener cuts Nicks lawn and a greenhouse delivers flowers. At three oclock Gatsby comes over looking exhausted and pale. Nick and Gatsby talk a bit and Gatsby is about to go home as Daisy arrives at four oclock. Entering the living room with Daisy Nick notices that Gatsby is gone. Gatsby knocks a few moments later on the front door and is lead in the room by Nick. Daisy and Gatsby are embarrassed by the presence of each other and they dont really start a conversation. After a tea in a tense atmosphere Nick leaves them alone. When he comes back both are in a happy mood but Daisy seems to have been in a sad mood before. They decide to go over to Gatsbys house, because Gatsby wants to show her his enormous house. Ending up in the bed room Gatsby tells them that he has got a man in England who buys him clothes. Daisy is very fascinated by his great collection of shirts. Gatsby urges Klipspringer to play the piano. According to Nick Gatsby finds out that Daisy does not come up to his dreams. ...

International business MOVIE REVIEW Example | Topics and Well Written Essays - 750 words

International business - Movie Review Example The American population has a record of making quite a huge size of garbage every year that amounts to about 250 million tonnes. The garbage is made up of fruit peels, bald tires, soda cans, frozen food container, etc. The size of the garbage produced is quite big and shocking. Whatever happens with the garbage produce is a subject that ‘Trash Inc: the secret Life of Garbage’ mainly undertakes. This documentary runs for one hour and is aired by CNBC on Wednesday. Carl Quintanilla is the documentary’s host and also known to be an Emmy award winning reporter. A big part of Quintanilla summer is seen through the documentary to be spent wading through garbage from Nevada, Pennsylvania to New York. Quintanilla also visits Beijing and Hawaii in the search of knowledge on garbage handling. Quintanilla tries to find out who handles garbage and what environmentally and economically is at stake. From the documentary, Quintanilla report indicates that garbage is both an oppo rtunity and an epidemic. The garbage industry is estimated to worth $52 billion in a yearly basis. This industry is also considered not be a one-size fit all. Most of America’s garbage is picked and transported to 2300 landfill within America. These landfills at the end make some huge profits towards their operators as some also capitalize on the landfill by piping out trash gas. The trash gas is mainly used within factories in the generation of electricity. Apex within Las Vegas is considered to be the largest landfill within the United States, and ‘Trash Inc.’ makes a visit there to know the operations of landfills. From Apex, the next trip is to Beijing which gives an opposite side of the story. Within Beijing, there are hundreds of dumps which are all illegal cropping up on the outskirts of the city. This dump sites are used to handle the high number of garbage that is produced by the

Sustainability Assignment Example | Topics and Well Written Essays - 750 words

Sustainability - Assignment Example Sustainability is about the balance between the humans and nature. It creates and maintains the conditions for the future generations. It is vital to ensure such resources as the water, materials to be preserved and protected for human health and at the same time, thinking about the environment. Rapid population and economic growth and the consumption of the natural resources created unintended conditions (social, environmental, and economic), under which there is no alternative to sustainable development (Sustainability information, n.d.). These are the main reasons why sustainable development is so important. It is the part of a bigger picture, which means preserving of biological diversity, development and stewardship of the  renewable resources and ecosystems. The absence of sustainable practices will lead the world to the peak of fuel production that will be in ten- twenty years. After that period, fuels reserves will be harder to discover and extract. Beside the possible ener gy crisis, the food provision also calls a certain concern, because sustainability in the face of growing population in the world, especially in the undeveloped countries, requires serious thinking. The majority of new births in such countries cannot support the enhanced population and the food production as well. Non-sustainable practices that concern the environment influence the soil erosion and pollution of the surrounding. Because of climate change, some areas become too wet or too dry, affecting the lifestyle of the whole populations. At the same time, the sustainable development practices, such as land and agriculture, aim to improve the effects of reducing land resources. When the unsustainable living practices cause energy crisis, pollute the surrounding causing the lack of water and land resources of proper quality, social decline enhances as well. In this case, sustainability is meant to preserve not only resources make the world a better

Managerial economics Essay Example for Free

Managerial economics Essay 1. If a firm raises its price for Product X, TR will increase. Uncertain, Total revenue = Price Ãâ€" Quantity Sold. The price elasticity of demand tells us there are two eï ¬â‚¬ects, first is price eï ¬â‚¬ect. If price increase, each unit sold sells for a higher price, which tends to raise revenue. Second is quantity eï ¬â‚¬ect. If price increase, fewer units are sold, which tends to lower revenue. This is determines by which price eï ¬â‚¬ect or the quantity eï ¬â‚¬ect is stronger 2. When MR MC, MP (marginal profit) will be positive.  True, for each unit sold, marginal profit equals marginal revenue (MR) minus marginal cost (MC). Then, if MR is greater than MC at some level of output, marginal profit is positive and thus a greater quantity should be produced. 3. If a 10% increase in price leads to a 5% increase in TR, demand must be elastic. False, if an increase in price causes an increase in total revenue, then demand can be said to be inelastic, since the increase in price does not have a large impact on quantity demanded. 4. If the cross price elasticity is positive for two goods X and Y, X and Y must be complements. False, if the goods are complements, the value will be negative because quantity demanded increases when the price of complement falls. Example, if the price of petrol decreases to RM2 a litre, sales of cars would increase. 5. Maximizing TR is never a desirable goal for a firm.  True, profit is the difference between a firms total revenue and its total opportunity cost. Total revenue is the amount of income earned by selling products. But it does not include the total opportunity costs of all inputs into the production process. Hence, it is never a desirable goal for a firm. Firm should consider maximizing Profit instead of TR. 6. The more inelastic the demand, the more likely it is that a firm can have regular price increases. True, if firm have regular increase in price (refer to Appendix 1) from P4 to P5, the decrease in the quantity demanded is relatively small (from Q4 to Q5). It means that, the more inelastic the  demand, the percentage change in quantity demanded is less than percentage change price. Hence, firm can have regular price increases. 7. If EP = -1.25 for Group A, and EP = -.375 for Group B, and a firm uses price discrimination, Group A should pay a higher price than Group B. False, Group A is elastic and Group B is inelastic. The consumers in the inelastic sub-market will be charged the higher price, and those in the elastic sub market will be charged the lower price. So Group B should pay higher price. Please refer to Appendix 2 for illustration. 8. A consumer spends 1% of her income on Good A and 25% on Good B. Price Elasticity of Demand should be greater for Good B. True, if the consumer spends less of her income, means that Good A is a necessity good and spends more of her income means that Good B is a luxury good. Luxuries tend to more elastic than necessities as there are more options for consumer. 9. Income elasticity for an inferior good is always negative. True, because quantity demand falls as income rises. Quantity demanded and income move opposite directions, inferior goods have negative elasticity. 10. The more inelastic the demand, the flatter the demand curve. False, inelastic demand have steeper curve because quantity demanded does not respond strongly to price changes. Please refer to Appendix 3 for illustration. For a inelastic demand product such as cigarettes, when price increase by 10%, the quantity demanded will fall by 3.8%. 11. If demand goes from P = 1850 .05Q to P = 1700 .05Q, Demand has increased. False. If P = 1850 .05Q then Qd= 37000-20P and if P = 1700 .05Q, then Qd= 34000-20P. The demand curve shift to left and hence, the demand decreases. Please refer to Appendix 4 for illustration 12. If TC goes from TC = 1250 + .5Q to TC = 1200 + .6Q, FC have gone up and VC have gone down. False, because TC=TFC+TVC. From the equation above shows that, the FC decreases leads TFC to fall from 1250 to 1200 and the VC increases leads TVC to gone up from 0.5 to 0.6. Part B (Explain in a short Essay (not more than 1 page each)) 1) Define demand, discuss various determinants of demand. Demand is the quantities of good or service that consumers are willing to buy at various prices within some given period of time. Holding all other factors constant, the price of a good or service increases as its demand increases and vice versa. When factors other than price changes, demand  curve will shift. There are 5 determinants of the demand curve. First factor is price of related goods. A good or service can be related to another by being a substitute or complement. If price of a substitute changes, we expect the demand for the good under consideration to change in the same direction as the change in the substitute’s price. For instance, if the price of coffee rises, the demand for tea should increase. The complement goods are the goods that can be used together. Price of complement and demand for the other good are negatively related. Example, if the price of sugar increases, the demand for coffee will fall. Second factor is income, as people’s income rises, it is reasonable to expect their demand for a good to increase and vice versa, the demand curve will shift right. A fall in income will lead to a decrease in demand for normal goods. Goods whose demand varies inversely with income are called inferior goods. Third determinant is future expectation. If enough, buyers expect the price of a good rises in future, the current demand will increase. Also, if consumers’ current demand will increase, they expect higher future income. For example, in 2005 housing prices rose, but people bought more because they expected the price to continue to go up. This drove prices even further, until the bubble burst in 2006 (Stafffullcoll.edu. n.d.). Forth factor is tastes and preferences. This is the desire, emotion, or preference for a good or service. If consumer preference is favorable change will leads to an increase in demand. Likewise, unfavorable change leads to a decrease in demand. Example, companies spend thousands on advertising to make you feel strongly that you want a product. Last determinant is number of buyer. If the number of buyers in market rises, the demand increases. For example, the housing bubble case. Low-cost mortgages increased the number of people who were told they could afford a house. The number of buyers actually increased, driving up the demand for housing. When they found they really couldnt afford the mortgage, especially when housing prices started to fall, they foreclosed. This reduced the number of buyers, and demand also fell. 2) Briefly explain the concept of Law of diminishing returns? Discuss its assumption and importance? The law of diminishing marginal returns means that the productivity of a variable input declines as more is used  in short-run production, holding one or more inputs fixed. This law has a direct behavior on market supply, the supply price, and the law of supply. The main reasons the marginal product (MP) of this variable input declines is the fixed input. The fixed input imposes a capacity constraint on short-run production. For example, in a sandwich production, the size of the sandwich-producing kitchen and equipment is fixed. The company employs additional workers, the kitchen becomes increasingly crowded. Only so many workers can use the sandwich-preparation counter to prepare sandwich. While adding additional workers do increase total sandwich production, the extra production attributable to these workers is certain to fall as the capacity of the fixed input is limited. In fact, adding too many workers actually results in a negative marginal product, hence, total product falls. The law of diminishing marginal returns is reflected in the shapes and slopes of the total product, marginal product, and average product curves. The most important of these being the negative slope of the marginal product curve. Appendix 5 shows the graph three product curves. The total product (TP) curve shows that the total number of Sandwich Company produced per hour for a given amount of labor. The increasingly flatter slope of the TP is attributable to the law of diminishing marginal returns. Also, the marginal product curve indicates how the total production of Sandwich Company changes when an extra worker is hired. The negatively-sloped portion of the MP curve is a direct embodiment of the law of diminishing marginal returns. Further, the average product curve indicates the average number of Sandwich Company produced by workers. The negatively-sloped portion of the AP curve is indirectly caused by the law of diminishing marginal returns. As marginal product declines, due to the law of diminishing marginal returns, it also causes a decrease in average product. 3) Explain the various economies and diseconomies of scale? Economies of scale are the cost advantages that a business can exploit by expanding the scale of production. The effect is to reduce the long run average (unit) costs of production. Economies of scale have brought down the unit costs of production and feeding through to lower prices for consumers (appendix 6). It could be achieved by buying new machinery, and build a bigger factory. There are two types of economy of scale and depending on the particular characteristics of an industry, some are more important than others. Firstly, internal economies of scale are a  product of how efficient a firm is at producing, that is specific to individual firm. Example, advantages are enjoyed by expansion. Next, external economies of scale occur outside of a firm but within an industry. Example, industry’s scope of operations expand due to better transportation network, will result a decrease in cost for a company working within industry, , external economies of scale have been achieved. Diseconomies of scale are the forces that cause larger firms to produce goods and services at increased per unit costs. The concept is the opposite of economies of scale to a situation which economies of scale no longer function for a firm. Rather than experiencing continued decreasing costs per increase in output, firms see an increase in marginal cost when output is increased (appendix 6). When a firm expands its production scale beyond a certain level, it suffers certain disadvantages. These disadvantages are called internal diseconomies of scale. The result of these diseconomies of scale is a fall run average cost. There are a number of factors that might give rise to inefficiencies as the size of the firm grows. As the size of the firm grows beyond a certain level, organization, control and planning is needed. This makes the managerial responsibilities more difficult. Delegation of the management functions to lower personnel becomes very common. Since the lower personnel lack the adequate experience to undertake the task, it may result in low output at higher cost. All these lead to an increase in the long-run average cost. Further, the external diseconomies of scale are beyond the control of a company increases its total costs, as output in the rest of the industry increases. The increase in costs can be associated with market prices increasing for some or all of the factors of production. For instance, high competition for labor, when there is more firms in industry, there will be increased demand for labor, making the best workers harder to keep (Keat and Young, 2009). References Stafffullcoll.edu. n.d. DETERMINANTS OF DEMAND. [online] Available at: http://staffwww.fullcoll.edu/fchan/macro/1determinants_of_demand.htm [Accessed: 28 Mar 2014]. Keat, P.G. and Young, P.K.Y., 2009 ‘Managerial Economics: 6th ed. Economic Tools for Today’s Decision Makers’. Pg. 266-268

Causes of The Great Depression Essay -- essays research papers

The Great Depression It is said that the cause of the catastrophic stock market crash known as the great depression was due mostly to uncontrolled political and industrial systems otherwise known as capitalism. However, the timeline leading up to the Great Depression proves that many other factors played a role in the stock market crash that occurred in the decade of the 1930's. So lets take a look at rather four, factors contributing to the great depression that we will further discuss in the following paragraphs. Four of the main causes that led up to the great depression were unequal distribution of wealth, uncontrolled political and industrial systems, high tariffs and war debts. Money was distributed mostly between the rich and the middle-class, in the United States, and between the U.S. and Europe. This imbalance of wealth created an unstable economy this type of the economy eventually lead up to large market crashes. These market crashes, caused the American economy to be overturned. The total income in the United States rose from $74.3 billion in 1923 to $89 billion in 1929 this rise in the economy was due to the Coolidge Prosperity(Business and Industry was flourishing and big business became bigger so the stock market went up greatly) even after this boost in the stock market the money wasn’t making its way around equally because most farmers were still poor. United States maintained high 1. tariffs on goods imported from other countries, at the same time that it was making foreign loans and trying to export products. This combination could not be sustained: If other nations could not sell their goods in the United States, they could not make enough money to buy American products or repay American loan... ... June 1939 7.2 10.4 + 7.9 17.2 1940 6.9 9.9 1941 7.7 12.1 1942 10.3 24.8 1943 13.7 44.8 1944 21.7 45.3 1945 21.3 43.7 As you can see, Roosevelt began to bring the people out of the depression and that resulted in some astonishing growth numbers. (Roosevelt's average growth of 5.2 percent during the Great Depression is even higher than Reagan's 3.7 percent growth during his Seven Fat Years ) When 1936 saw a phenomenal record of 14 percent growth, Roosevelt eased back on the deficit spending, overly worried about balancing the budget. Between 1940 and 1945, the Growth Deficit Product nearly doubled in size, from $832 billion to $1,559 billion in constant 87 dollars. And this occurred as deficit spending soared, to levels Keynes had earlier and unsuccessfully recommended to Roosevelt

A comparison between cardiac CT scanning and cardiac digital subtraction angiography (DSA)

Abstract Coronary artery disease affects nearly one tenth of the UK population and remains the leading cause of death in the western world. To investigate and provide interventions for coronary artery disease, imaging of the coronary arteries to enable visualisation of atheromatous plaque is required. This review looked at the techniques of cardiac computed tomography scanning and cardiac digital subtraction angiography, and their contribution to the investigation of coronary artery disease. Comparison of the procedures considered technique, radiation exposure, contrast agent, clinical indications and efficacy in diagnosis of coronary artery stenosis. On comparison of the effectiveness of the techniques, both were shown to have been effective non-invasive procedures that may be used to rule out diagnoses and avoid inappropriate use of invasive angiography. The research shows mixed evidence for cardiac computed tomography angiography as a test of high specificity, however sensitivity and speci ficity of cardiac digital subtraction angiography is high, and therefore suggest that the techniques may be useful in low risk patients. Introduction Coronary artery disease remains the main cause of death in the UK and western world (Hacker, 2013; Liu et al., 2002) and contributes a substantial disease burden, affecting 7% of men and 5% of women in the UK in 1999 (Liu et al., 2002). Coronary artery disease results from the build up of atherosclerotic plaque within the arteries supplying the myocardium. This plaque limits the flow of blood through the arteries, and can cause ischaemia of the heart muscle. If the plaque becomes unstable and ruptures, this may lead to thrombus formation and the complete occlusion of an artery, resulting in a myocardial infarction (McClure et al., 2009). Acute coronary syndrome (ACS) is a sub-classification of coronary artery disease and encompasses unstable angina, non-ST elevation myocardial infarction and ST elevation myocardial infarction. ACS represents a range of conditions that result from thrombus formation in coronary arteries, and if untreated has poor prognosis and high mortality (NICE, 2010). To investigate and provide information for interventions for coronary artery disease and ACS, visualization of the coronary arteries and any lesions caused by atherosclerotic plaque is required. Advances in technology have given rise to several sophisticated perfusion analysis techniques, which provide greater prognostic value than morphological imaging (Hacker, 2013). Perfusion analysis allows the blood flow through the coronary vessels to be observed and any abnormalities in the perfusion can be interpreted as a functional consequence of atherosclerotic changes within the vessels (Hacker, 2013). Currently, UK guidelines (NICE, 2010a) recommend coronary angiogram as first line management for patients presenting with ACS. This enables imaging of the coronary arteries to assess perfusion. It is important to assess the circulation as arteries can be affected from the earliest stages of endothelial dysfunction to high-grade coronary artery stenoses (Hacker et al., 2010; Bugiardini et al. 2004; Kaufmann et al., 2000), and this provides the information necessary for prognosis and intervention. With the advances in technology, there are now various diagnostic tests available to assess coronary artery disease, including coronary angiography and computed tomography (CT) scanning (Gorenoi, Schonermark & Hagen, 2012). This review aims to review the literature on coronary CT scanning and digital subtraction angiography, their clinical applications, techniques and comparative value in coronary artery assessment and diagnosis. Cardiac Digital subtraction angiography Coronary angiography is the conventional diagnostic procedure used in coronary artery disease. It is a minimally invasive technique, whereby a catheter is placed into the radial or femoral artery and is advanced through the arterial system to the coronary arteries. A contrast agent is then injected at the aortic root and allows visualization of the arteries using x-ray in real time at up to 30 frames per second. This allows a view of the extent, location and severity of coronary obstructive lesions such as atherosclerosis and enables prognostic indication (Miller et al., 2008). Coronary angiography also enables catheter placement either side of the lesion to assess pressure changes and determines the degree of flow obstruction (Miller et al., 2008). . Digital subtraction angiography (DSA) again works by introducing a contrast agent into the coronary arteries and taking x-rays in real time, however a pre image is taken by x-ray. This allows for the post images to be subtracted from the original mask image, eliminating bone and soft tissue images, which would otherwise overlie the artery under study (Hasegawa, 1987). Unlike conventional angiography, it is possible to conduct DSA via the venous system, through accessing the superior vena cava via the basillic vein (Myerowitz, 1982). This removes the risks associated with arterial cannulation (Mancini & Higgins, 1985). The procedure can also be performed with a lower dose of contrast agent and be done more quickly therefore eliminating constraints of using too much contrast during a procedure (Myerowitz, 1982). Whilst DSA is the gold standard in arterial imaging of carotid artery stenosis (Herzig et al., 2004), the application of DSA to the coronary arteries is limited due to motion artefacts associated with each heartbeat and respiration (Yamamoto et al., 2009). There are numerous cardiac clinical applications of DSA, it can be used to assess coronary blood flow (Molloi et al., 1996), valvular regurgitation (Booth, Nissen & DeMaria, 1985), cardiac phase (Katritsis et al., 1988), congenital heart shunts (Myerowitz, Swanson, & Turnipseed, 1985), coronary bypass grafts and percutaneous coronary intervention outcomes (Katritsis et al, 1988; Guthaner, Wexler & Bradley, 1985). However, others have suggested that the coronary arteries are not visualized well due to their small size, movement, their position overlying the opacified aorta and left ventricle, and confusion with other structures such as the pulmonary veins (Myerowitz, 1982). Cardiac CT Scanning Development of CT scanning in the 1990s enabled an increase in temporal resolution that was sufficient to view the beating heart, and they now provide a non-invasive technique for diagnostic and prognostic purposes. Cardiac CT scans have clinical applications that go beyond perfusion investigation, and can be used to assess structure and function of the heart (for example in electrophysiology disorders or congenital heart disease) due to its ability to provide anatomical detail (Achenbach & Raggi, 2010). CT scans can be used to assess coronary artery disease with and without injection of contrast agent (Achenbach & Raggi, 2010) by calcium scan or CT angiography. Coronary calcium CT scanning uses the evidence base that coronary artery calcium is a correlate of atherosclerosis (Burke et al., 2003) and is a strong prognostic predictor of the future development of coronary artery disease and cardiac events (Arad et al., 2000; Budoff et al., 2009; Achenbach & Raggi, 2010). Calcium is easily depicted on CT scan due to its high CT attenuation, and is classified according to the Agatson score, which considers the density and area of the calcification (Hoffman, Brady & Muller, 2003). Coronary CT angiography (CTA) allows visualization of the coronary artery lumen to identify any atherosclerosis or stenosis within the vessels. Patients are injected intravenously with a contrast agent and then undergo a CT scan. There are limitations regarding the suitability of patients for coronary CTA due to prerequisites of sinus rhythm, low heart rate and ability to follow breath-holding commands. Additionally, obesity presents a problem for patients that cannot fit into the scanner and affects the accuracy of the procedure. (Achenbach & Raggi, 2010). Comparison of cardiac DSA and cardiac CT scanning The technical differences between cardiac DSA and cardiac CT scanning give rise to differences in the clinical indications for the procedures, their diagnostic efficacy and also different risks or relative benefits to the patients. Due to the nature of the images produced by coronary CTA and DSA, each lends itself to different indications for use. Whilst coronary DSA provides imaging of all aspects of perfusion, CTA used with contrast agent also provides this however has the additional advantage of being able to assess structure and function of the heart. Coronary CTA has been shown to have a high accuracy at detection and exclusion of coronary artery stenoses (Achenbach & Raggi, 2010). In a multicentre trial conducted by Miller et al. (2008), patients underwent coronary calcium scoring and CT angiography prior to conventional invasive coronary angiography. The diagnostic accuracy of coronary CTA at ruling out or detecting coronary stenoses of 50% was shown to have a sensitivity of 85% and a specificity of 90%. This showed that coronary CTA was particularly effective at ruling out non-significant stenoses. Additionally, coronary CTA was shown to be of equal efficacy as conventional coronary angiography at identifying the patients that subsequently went on to have revascularisation via percutaneous intervention. This was shown by an area under the curve (AUC), a measure of accuracy of 0.84 for coronary CTA and 0.82 for coronary angiography. Miller et al.’s (2008) study included a large number of patients at different study sites , and additionally represented a large variety of clinical patient characteristics. The author’s claim that these factors contribute to the strength and validity of the study findings, and suggest that in addition to using patients with clinical indications for anatomical coronary imaging, should be used as evidence that coronary CTA is accurate at identifying disease severity in coronary artery disease. Miller et al. (2008) did however,, find that positive predictive and negative predictive values of coronary CTA were 91% and 83% respectively and therefore suggested that coronary CTA should not be used in place of the more accurate conventional coronary angiography. A low positive predictive value (in relation to the prevalence of disease) was proposed to be due to a tendency to overestimate stenosis degree as well as the presence of artefacts leading to false positive interpretation (Achenbach & Raggi, 2010). Other research providing comparison between coronary CTA and conventional coronary angiogram has highlighted variability in results. A meta-analysis conducted by Gorenoi, Schonermark and Hagen (2012) investigated the diagnostic capabilities of coronary CTA and invasive coronary angiography using intracoronary pressure measurement as the reference standard. The authors found that CT coronary angiography had a greater sensitivity than invasive coronary angiography (80% vs 67%), meaning that coronary CTA was more likely to identify functionally relevant coronary artery stenoses in patients. Despite this,, specificity of coronary CTA was 67%, compared to 75% in invasive coronary angiography, meaning that the technique was less effective at correctly excluding non-diagnoses than invasive coronary angiogram. This research appears to contradict the power of cardiac CTA at excluding diagnoses of coronary artery stenosis as suggested by Miller et al. (2008), he study did combine evidence from over 44 studies to provide their results and therefore had a large statistical power. The authors interpret the results in light of the clinical relevance of cardiac imaging, suggesting that patients with a higher pretest possibility of coronary heart disease will likely require invasive coronary angiography for revascularisation indicating that coronary CTA may be a helpful technique in those patients with an intermediate pre-test probability of coronary heart disease that will therefore not require invasive angiography. Goldberg et al. (1986) investigated the efficacy of DSA in comparison to conventional coronary angiography in 77 patients. They found that the two angiograms agreed within one grade of severity in 84% of single cases and 90% of multiple cases, identifying both patent and lesioned arteries. The results led the authors to conclude that there was no significant difference between the two methods and that DSA could be used in selective coronary angiography to find results comparable to that of conventional angiography. In addition to being a small study into the efficacy of DSA, the study also had several sources of inherent variability that should be considered when interpreting the results. These included differing sizes of digital imaging screen and non-use of calipers, meaning that the interpretation of the images could vary throughout the study. The authors also suggest that whilst showing strong support for the use of DSA in coronary artery disease, the technique may not actually p ermit better prognostic determinations or clinical judgements that are better than conventional angiography, and therefore the further implementation of the techniques may not be founded or necessitated. More recently, there has been further research looking at the effectiveness of DSA as a way of measuring coronary blood flow. Whilst motion artefacts have proven a problem in lots of past research (Marinus, Buis & Benthem, 1990; Hangiandreou, 1990), recent research has developed methods to minimise these. Moilloi and colleaues (1996) showed that using a motion-immune dual-energy digital subtraction angiography, absolute volumetric coronary blood flow could be measured accurately and thus provide an indication of the severity of any arterial stenosis.This may provide further suggestion for clinical implementation of DSA. Although these studies provide evidence for the efficacy of cardiac DSA and CTA, they often make comparisons to conventional angiography. This is useful as a baseline comparison, however it is difficult to make comparisons between the two procedures directly due to less available evidence making direct comparisons. Lupon-Roses et al. (1985) conducted a study investigating both coronary CTA and venous DSA. The study looked at the efficacy of both techniques at diagnosing patency of coronary artery grafts compared to the control conventional angiography. CT was shown to diagnose 93% of the patent grafts and 67% of the occluded grafts whereas DSA correctly diagnosed 98% and 100% of patent and occluded grafts respectively. Interestingly, the DSA picked up the 11 grafts that were misdiagnosed by CTA and the CTA picked up the 2 grafts misdiagnosed by the DSA. This data may suggest that individually, DSA has a better profile for diagnosis of coronary artery occlusion, however if the two procedures are used in combination exclusion of patent arteries and diagnosis of occluded arteries would be effective (Lupon-Roses et al., 1985). Coronary DSA and CTA are both non-invasive procedures (unlike the conventional coronary angiography where a wire is placed in the coronary vasculature). With the only invasive part of the procedure being the injection of the contrast material into a vein. This presents a significant advantage to both procedures over that of conventional angiography, and may even permit investigation on an outpatient basis (Meaney et al., 1980). Similarly, both DSA and coronary CTA are favoured because of their intravenous approach, eliminating the risks of bleeding or arterial injury from an intra-arterial catheterization and being able to be used in those with limited arterial access. However, although the intravenous approach used in cardiac DSA makes it favourable, it does lead to difficulty with visualisation of the coronary arteries due to the overlying iodinated pulmonary and cardiac structures (Mancini & Higgins, 1985). Therefore,, intra-arterial DSA is also sometimes used (Yamamoto et al., 20 09). As with all CT scanning, coronary CTA carries with it a dose of ionizing radiation (Brenner & Hall, 2007). Studies have estimated that for diagnostic CT scanning, patients are on average exposed to 12mSv of radiation during the procedure, the equivalent of 600 x-rays (Hausleiter et al., 2009). Estimates of radiation doses associated with conventional coronary angiography are lower than that of coronary CTA at 7mSv (Einstein et al., 2007). Additionally, DSA technique reduces the radiation dose from that of conventional coronary angiography as the vessels are visualised more clearly (Yamamoto et al., 2008). The dangers of radiation exposure are increased risk of developing cancer, skin injuries and cateracts (Einstein et al., 2007). It is therefore important that the benefits of conducting the procedure greatly outweigh the risk of radiation exposure. CT calcium scanning provides a low radiation dose at around 1mSv (Hunold et al., 2003). Cardiac CT calcium scanning does not require administration of a contrast agent, unlike in coronary CTA and DSA that use iodine based contrast agents. The risks associated with contrast agent include nephrotoxicity and risks of hives, allergic reactions and anaphylaxis (Maddox, 2002). The amount of contrast agent used is partly dependent on the length of the procedure and how clearly the arteries can be visualised. For this reason, both cardiac CTA and DSA use less contrast agent that conventional coronary angiography (Brant-Zawadzki, et al., 1983). CT calcium scanning of the coronary arteries is therefore recommended in those with less likelihood of coronary artery disease (NICE, 2010). Both coronary CTA and DSA require interpretation by trained physicians, and the importance of training and achieving intra-rater reliability should not be underestimated (Pugliese et al., 2009). Conclusion Overall, both coronary CT and DSA have been demonstrated as effective procedures for the imaging of the coronary arteries in CAD (Achenbach & Raggi, 2010; Miller et al., 2008; Moilloi et al., 1996; Goldberg et al., 1986). Whilst cardiac CT scanning does provide a wider range of clinical applications, allowing assessment of perfusion as well as cardiac structure and function (Achenbach & Raggi, 2010), coronary DSA has many applications that allow assessment of coronary blood flow (Molloi et al., 1996; Katritsis et al, 1988; Booth, Nissen & DeMaria, 1985; Guthaner, Wexler & Bradley, 1985; Myerowitz, Swanson, & Turnipseed, 198). Both cardiac DSA and CTA procedures have their advantages. As non-invasive procedures, these techniques pose less risk to patients, and enable the possibility of outpatient investigation, to be used to rule out diagnoses and to avoid inappropriate invasive coronary angiogram (Gorenori et al., 2012). Additionally, intravenous access is preferential to arterial cannulation for the contrast infusion, removing the risks associated with bleeding or intra-arterial injury. Cardiac DSA exposes the patient to a lower dose of radiation that coronary CTA (Hausleiter et al., 2009; Yamamoto et al., 2008; Einstein et al., 2007), which is beneficial at reducing the risk of genetic mutations and cancer. Cardiac CTA and DSA also have their common disadvantages. The use of contrast agent may present side effects for the patient including kidney damage and risk of allergic reactions and anaphylaxis (Maddox, 2002). For this reason, calcium CT scanning can be useful in patients that are not at high likelihood of coronary artery disease (NICE, 2010b). Additionally, both cardiac DSA and CTA are subject to motion artefacts from respiration and heart beats, which can cause difficulties with interpretation (Achenbach & Raggi, 2010; Yamamoto et al., 2009). In the case of cardiac CTA, this excludes a subset of patients that are unable to follow commands and those who have high heart rates. Overall, cardiac CTA and cardiac DSA are effective, non-invasive imaging techniques for assessment of coronary artery disease. Whilst they are not the gold standards in cardiac monitoring, they can provide important diagnostic information without exposing patients to the risks of invasive angiography. Due to this, their use should be weighted against clinical need, the risks of the procedures, and the suitability of the patient. Interpretation of cardiac CTA and DSA imaging should be by trained individuals. References Achenbach, S., & Raggi, P. (2010) Imaging of coronary atherosclerosis by computed tomography. European Heart Journal. 31:1442 Arad, Y., Spadaro, L. A., Goodman, K., Newstein, D., & Guerci, A. D. (2000). Prediction of coronary events with electron beam computed tomography.Journal of the American College of Cardiology, 36(4), 1253-1260. Booth, D. C., Nissen, S., & DeMaria, A. N. (1985). Assessment of the severity of valvular regurgitation by digital subtraction angiography compared to cineangiography. American heart journal, 110(2), 409-416. Brenner D. J., & Hall EJ. Computed tomography: an increasing source of radiation exposure. N Engl J Med. 2007;357(22):2277-2284 Budoff, M. J., McClelland, R. L., Nasir, K., Greenland, P., Kronmal, R. A., Kondos, G. T., †¦ & Blumenthal, R. S. (2009). Cardiovascular events with absent or minimal coronary calcification: the Multi-Ethnic Study of Atherosclerosis (MESA). American heart journal, 158(4), 554-561. Bugiardini, R., Manfrini, O., Pizzi, C., Fontana, F., & Morgagni, G. (2004). Endothelial function predicts future development of coronary artery disease a study of women with chest pain and normal coronary angiograms.Circulation, 109(21), 2518-2523. Burke, A. P., Virmani, R., Galis, Z., Haudenschild, C. C., & Muller, J. E. (2003). Task force# 2—what is the pathologic basis for new atherosclerosis imaging techniques?. Journal of the American College of Cardiology,41(11), 1874-1886. Einstein, A. J., Moser, K. W., Thompson, R. C., Cerqueira, M. D., & Henzlova, M. J. (2007). Radiation dose to patients from cardiac diagnostic imaging.Circulation, 116(11), 1290-1305. Goldberg HL, Moses JW, Fisher J, Tamari I, Borer JS (1986). Diagnostic accuracy of coronary angiography utilizing computer-based digital subtraction methods; Comparison to conventional cineangiography. Chest 90, 793–797, Gorenoi, V., Schonermark, M. P., & Hagen, A. (2012). CT coronary angiography vs. invasive coronary angiography in CHD. GMS health technology assessment, 8, Doc02-Doc02.. Guthaner, D. F., Wexler, L., & Bradley, B. (1985). Digital subtraction angiography of coronary grafts: optimization of technique. American journal of roentgenology, 145(6), 1185-1190. Hacker, M., Jakobs, T., Hack, N., Nikolaou, K., Becker, C., von Ziegler, F., †¦ & Tiling, R. (2007). Sixty-four slice spiral CT angiography does not predict the functional relevance of coronary artery stenoses in patients with stable angina. European journal of nuclear medicine and molecular imaging,34(1), 4-10. Hangiandreou N. J. (1990) Coronary Blood Flow Measurement Using Digital Subtraction Angiography and First Pass Distribution Analysis. Madison, Wis: University of Wisconsin-Madison; Thesis. Hasegawa, B. (1987). Physics of Medical X-Ray Imaging 2nd Edition. Medical Physics Publishing Corporation. Hausleiter, J., Meyer, T., Hermann, F., Hadamitzky, M., Krebs, M., Gerber, T. C., †¦ & Achenbach, S. (2009). Estimated radiation dose associated with cardiac CT angiography. Jama, 301(5), 500-507. Herzig, R., Burval, S., Krupka, B., Vlachova, I., Urbanek, K., & Mares, J. (2004). Comparison of ultrasonography, CT angiography, and digital subtraction angiography in severe carotid stenoses. European Journal of Neurology, 11(11), 774-781. Brant-Zawadzki, M., Gould, R., Norman, D., Newton, T. H., & Lane, B. (1983). Digital subtraction cerebral angiography by intraarterial injection: comparison with conventional angiography. American Journal of Roentgenology, 140(2), 347-353. Hoffmann, U., Brady, T.J., & Muller, J. (2003). Cardiology patient page. Use of new imaging techniques to screen for coronary artery disease. Circulation 108 (8): e50–3. Hunold, P., Vogt, F. M., Schmermund, A., Debatin, J. F., Kerkhoff, G., Budde, T., †¦ & Barkhausen, J. (2003). Radiation Exposure during Cardiac CT: Effective Doses at Multi–Detector Row CT and Electron-Beam CT 1.Radiology, 226(1), 145-152. Katritsis, D., Lythall, D.A., Cooper, I.C., Crowther, A., & Webb-Peploe, M.M. (1988) Assessment, of coronary angioplasty: Comparison of visual assessment, hand?held caliper measurement and automated digital quantitation. Catheterization and cardiovascular diagnosis, 15(4), 237-242. Kaufmann, P. A., Gnecchi-Ruscone, T., Schafers, K. P., Luscher, T. F., & Camici, P. G. (2000). Low density lipoprotein cholesterol and coronary microvascular dysfunction in hypercholesterolemia. Journal of the American College of Cardiology, 36(1), 103-109. Liu, J. L. Y., Maniadakis, N., Gray, A., & Rayner, M. (2002). The economic burden of coronary heart disease in the UK. Heart, 88(6), 597-603. Lupon-Roses, J., Domingo, E., Marinez-Vazquez, J. M., Lopez-Moreno, J. L., Montana, J., Permanyer-Miralda, G., †¦ & Soler-Soler, J. (1985). Direct non-invasive techniques for assessing coronary bypass graft patency. The International Journal of Cardiac Imaging, 1(3), 181-188. Maddox, T. G. (2002). Adverse reactions to contrast material: recognition, prevention, and treatment. American family physician, 66(7), 1229. Mancini, J. G. B., & Higgins, C. B. (1985). Digital subtraction angiography: a review of cardiac applications. Progress in cardiovascular diseases, 28(2), 111-141. Marinus, H., Buis, B., & Van Benthem, A. (1990) Pulsatile coronary flow determination by digital angiography. International Journal of Cardiac Imaging, 5, 173-182 McClure, K. H., McGivern, J. P., Stultz, M. R., & Whitehurst, T. K. (2009). U.S. Patent No. 7,481,759. Washington, DC: U.S. Patent and Trademark Office. Meaney, T. F., Weinstein, M. A., Buonocore, E., Pavlicek, W., Borkowski, G. P., Gallagher, J. H., †¦ & Maclntyre, W. J. (1980, August). Digital subtraction angiography of the human cardiovascular system. In Application of Optical Instrumentation in Medicine VIII (pp. 272-278). International Society for Optics and Photonics. Miller, J. M., Rochitte, C. E., Dewey, M., Arbab-Zadeh, A., Niinuma, H., Gottlieb, I., †¦ & Lima, J. A. (2008). Diagnostic performance of coronary angiography by 64-row CT. New England Journal of Medicine, 359(22), 2324-2336. Molloi, S., Ersahin, A., Tang, J., Hicks, J., & Leung, C. Y. (1996). Quantification of volumetric coronary blood flow with dual-energy digital subtraction angiography. Circulation, 93(10), 1919-1927. Myerowitz, P. D. (1982). Digital subtraction angiography: present and future uses in cardiovascular diagnosis. Clinical cardiology, 5(12), 623-629. Myerowitz, P. D., Swanson, D. K., & Turnipseed, W. D. (1985). Applications of digital subtraction angiography in cardiovascular diagnosis. The Surgical clinics of North America, 65(3), 423-437. National Institute for Health and Care Excellence. (2010a). Unstable angina and NSTEMI: The early management of unstable angina and non-ST-segment-elevation myocardial infarction. CG94. London: National Institute for Health and Care Excellence. National Institute for Health and Care Excellence. (2010b). Unstable angina and NSTEMI: Chest pain of recent onset: assessment and diagnosis of recent onset chest pain or discomfort of suspected cardiac origin. CG95. London: National Institute for Health and Care Excellence. Pugliese, F., Hunink, M. M., Gruszczynska, K., Alberghina, F., Malago, R., van Pelt, N., †¦ & Krestin, G. P. (2009). Learning curve for coronary CT angiography: what constitutes sufficient training?. Radiology, 251(2), 359. Yamamoto, M., Okura, Y., Ishihara, M., Kagemoto, M., Harada, K., & Ishida, T. (2009). Development of digital subtraction angiography for coronary artery. Journal of digital imaging, 22(3), 319-325.