Persuasive Writing: Bio Chip Technology Essay

Abstract This paper focuses on the controversial subject of the human biochip through science and technology. I do not discuss the ‘Mark of the Beast’ aspect or any religious side to the topic. Some of the biochip’s first uses are explored before a possible future scenario is played out; a few points of concern are addressed and then you are introduced to Professor Kevin Warwick. I then explain how the biochip is in use today mainly as an identification device and what some possible future uses may be, such as a source of information. The paper concludes with a comparison of peoples’ feelings concerning new technology through time. Keywords: biochip, Professor Kevin Warwick A great many things are considered controversial: the death penalty, animal testing, adoption, abortion, genetic engineering, and cloning are only a few of the many subjects out there that people argue about. The biochip is an ever growing controversy that is taking many scientific and technological leaps. Though the biochip has proven beneficial in helping scientists monitor protein levels and root out cancerous cells in the human body, it has a different facet I will currently be focusing on; as an identification and a potential information device. The first use for the biochip was monitoring fisheries in the early 1980’s; it quickly moved to tagging pets, luggage, and monitoring mailed packages. Some chips are already in use in children’s backpacks and are a feature on some cellular phones, which enables parents to know where their child is at any given point in time. But the real controversy on this topic comes in with people’s concern about Big Brother. There are many misconceptions made about the biochip; some people may think that if they have one they can be found anywhere on the globe by satellite, everything about them can be found out in seconds, and that they will be controlled by the chip somehow. These statements are all untrue. The chip is so small it is only able to contain one alpha numeric series of digits to identify the holder of the chip; it doesn’t carry your name, your pin number, what car you drive, your address or anything other than the identification number. It doesn’t have enough power or range to be read or tracked by satellite. It can only be read by a scanner and only from a distance of two to twelve inches. And it in no way controls what people think or do; this concern mainly comes from conspiracy theorists. Try to imagine, you’re shopping with your kids in a large store and you turn your back for one second. The next thing you know, your youngest child is no longer with you. Through the gut wrenching panic you register the fact that there are hundreds of people around, and any one of them could have taken your child without so much as a pause in their step. Now imagine that as you entered the store, there were scanners set up at the entrance that scanned everyone as they passed. Knowing this, all you have to do is alert security about your child’s absence and they will make sure your child is still in the store. What a relief knowing that your child can be found anywhere that has a scanner to read a biochip. This scenario is still a few decades in the future, but seeing the benefits of such technology is easy. However, some downsides need to be taken into consideration as well. Say you or your child were kidnapped, what would stop the kidnapper from removing the biochip themselves to keep you or your child from being found? To keep that from happening, the biochip would have to be inserted under general anesthesia just to keep the chip safe from removal. But this process in itself is another concern; many people don’t agree with the thought of being ‘tracked’ in the first place; why would them being unconscious as the chip was placed make them feel any better? Even though many concerns can be quieted by the fact that no more information can be stored on the biochip than an identification number, who’s to say that will be the case in the future? With technology booming like it is, the next likely step in the biochip’s technology is to store more information on it. Soon, it may not be necessary to remember your car keys, your driver’s license, your social security number, or your ATM card. Before long it may be as easy as walking into a room for the lights to come on, the television to change channels, or the radio the change stations. We already see subtle changes in the way information is stored. Smart cards are used with more regularity, there are chips in breast implants, pacemakers, artificial limbs, and artificial retinas, even paraplegics have had silicon brain implants able to control computers. Professor Kevin Warwick of the University Of Reading, England is the first human biochip implant recipient. â€Å"On 20 April 1998, Professor Warwick had a glass capsule about 23 millimeters long and 3 millimeters wide†¦inserted in his left arm. The chip, in conjunction with computer equipment in his house, turns lights on and off when he enters and exits (a) room, and gives him a spoken, running tally of the mail in his email box. The chip merely sends out an identifying signal†¦but (it) is still a step forward since his body has not rejected the foreign matter.† (Mamatas 2002). It may be another decade before technology like Professor Warwick’s becomes an everyday item for everyday people, but it is easy to see how it may be as essential to us in the future as cell phones and computers are today. There are many uses and qualities in a biochip and they are already widely used in a vast number of applications: tracking cell phones, tagging pets, monitoring waste output in garbage bins in the UK, and the pharmaceutical companies are even starting to do research with the biochip technology to monitor protein levels. The next step seems to be human biochip implantation. (Chu 2005) When you compare the hesitance people felt at the thought of the social security number when it was first introduced in 1935, you can see the similarity in the concern people feel about the biochip technology today. I believe the use of this technology can be a great asset to our society and way of life no matter what application is set to use. From identification to medical research, the benefits of the biochip technology far outweigh the few possible downsides worrying people now. References Chu, Wai Lang (2005). Preclinical Research, Biochip Technology Redefines Drug Discovery, Retrieved 12/16/2010 from, http://www.outsourcing-pharma.com/Preclinical-Research/Biochip-technology-redefines-drug-discovery Mamatas, Nick (2002). Not Found, Kevin Warwick: Cyborg Professor, Retrieved 12/16/2010 from, http://old.disinfo.com/archive/pages/dossier/id174/pg1/index.html The University Of Reading: Professor Kevin Warwick. Retrieved 12/18/2010 from, http://www.kevinwarwick.com/index.asp

Describe and Explain Variations Between New and Old Social Movements Essay

Social movements are groups or organisations that focus on particular political or social issues. The two main types of social movement, Old Social Movements and New Social Movements, share similarities but also have noticeable differences. Bagguley argues that Old Social Movements are mainly influenced by class and economic factors. Many OSMs take the form of Trade Unions. For example, there are several teachers unions in the UK, such as NASUWT and NUT. Because of this the social base of OSMs is largely working or lower middle class. In comparison to this, Hallsworth describes New Social Movements as groups which challenge the established political and cultural order in society. NSMs deal with issues that have arisen in western society since the 60s, such as feminism, environmentalism, gay rights and anti-racist groups. And as these issues effect people from all walks of life, New Social Movements attract people from all classes. In addition to this, NSMs often have global appeal as they transcend not only social class but race and nationality too. For example, LGBT parades and protests happen across the world as the movement is one that can unite people globally. A further difference is that Old Social Movements tend to be insider groups whilst NSMs are considered outsider. OSMs are viewed as expert and professional, often having links with those in powerful positions. For instance, Trade Unions sometimes have links to Labour politics, with TULO (The Trade Union & Labour Party Liaison Organisation) coordinating the activities of trade unions that affiliate with the Labour party. This means that many Old Social Movements have the power to influence important decision and law makers. On the other hand, outsider groups are those that have little to no access to decision makers, and these tend to be New Social Movements. These movements have little access to powerful people as they’re viewed as too extreme or go against the aims of those in power. One extreme example of an outsider group is the IRA. The organisation seeks a united Ireland but has been considered an illegitimate organisation by the British government due to its violent methods that are unacceptable in a democratic country. However, the status of groups can alter. For example, in the 70s many environmental NMS were considered outsider groups and yet today political parties often seek their advice. Despite these differences, however, NSMs and OSMs do share some similarities. Both types of organisation aim to bring together and unite people with common goals and interests. In addition to this, the way in which they try to achieve their aims are often similar. Teachers Unions like NASUWT and NUT have staged several strikes over the last few years due to issues with teacher’s pensions, pay and working conditions. Their tactics are peaceful and civil and, with the exception of a few extreme cases, the same can be applied to New Social Movements. In conclusion, therefore, differences between Social Movements include their social base, their ability to influence those in power and their global appeal. However, it can often be difficult to pinpoint exact differences between the two kinds due to shifts and changes in public and political opinion over time. It is clear, however, that the majority of both NSMs and OSMs have one main goal: to unite people and bring about change to help increase equality in society.

Southwest Airpine Analysis Research Paper Example | Topics and Well Written Essays - 500 words

Southwest Airpine Analysis - Research Paper Example America’s public transport is quite efficient and this poses a challenge to Southwest’s operations. Bus companies are most notable for offering alternative short-distance travelling services to many Americans who prefer the road than the air. According to Gittell (2005), transportation factors such as scheduling, safety, facilities, security procedures are very important to travelers who might use these factors as criteria not to choose Southwest in favor of surface transportation. The existence of close to 1150 seaports in Texas makes it possible for Texas residents and visitors to travel conveniently and cheaply by sea. Furthermore, commuter rail services provided by organizations such as Capital MetroRail have greatly made surface travel as interesting and fast experience as travelling by air. The road network in Texas is no doubt superb considering the several high standard highways that dot the state. Many potential air transport customers opt to travel by bus (such as Executive Coach Inc) or by private means considering the specific conveniences that come with road transport including the option of making stopovers at interesting sites. The huge number of companies offering care hire services has made the surface travel experience great even to those who cannot afford town cars. Customers who may be dissatisfied by one or more aspects of Southwest’s services may opt to use other means of transport which have better services. One of the greatest strengths of Southwest Airlines is its product positioning. The company has developed an integrated marketing strategy that has helped position its product among its core target market (Lauer, 2010). Most air travelers in the US know that Southwest has the kind of products that they would choose. In its marketing communication, the company positions itself as a â€Å"low-fare, short-haul, high

Criminal justice Assignment Example | Topics and Well Written Essays - 500 words - 9

Criminal justice - Assignment Example The result is strong bonding that sees them survive through their term in jail. Women and men who commit crimes are sent to prison according to sex. Serious offenses such as sexual assault prompted creation of separate prisons for males and females. Female prisoners are quite different from male prisoners as they are less violent and rarely fight prison wardens or there inmates as compared to men (Schmalleger, 2008). Furthermore, women easily form bonds as a way of helping each other to survive through the prison sentence. Men have concrete hierarchy basing on gang relations, connections, and physical superiority. It is because of this that women prison has a lesser number of prison officers compared to men. Though the prisons are heavily fortified, those of men require 24 hours surveillance while female prison is not heavily guarded. Female prisons have special units where they can report assault as they are they tend to be verbally expressed than men who tend to solve issues physically. Women are less involved in crimes than men are; therefore, not much study has been conducted. Prison staff is charged with the responsibility of curbing violence among the inmates (Schmalleger, 2008), surveillance to control prison breakouts, quelling riots and offering first aid services. Officers also write reports on overall prison condition, new cases of violence, deaths, and diseases. In addition, the prison staff deals with alcohol and drug dependent inmates. They deal handle sexual offenders within prison, facilitate religious beliefs activities and understanding of diverse backgrounds. Prison staff also deals with different patients including psychiatric cases, offering necessary treatment. Prison rioting is a way of complaining to the authority of the injustices and demanding certain services (Schmalleger, 2008). Inmates often agree

London Olympics 2012 Essay Example | Topics and Well Written Essays - 500 words

London Olympics 2012 - Essay Example Similarly, there are significant health and safety problems both during and after the event because of a large number of workers that are needed for running the event. The author then talks about the documentary film on which she is working about the London 2012 Olympics. The title of film is ‘Construction in the games’ and it mainly deals with the legacy left by the construction industry in terms of employment and training for the locals. In the end, she points out there is a poor system of training in Britain as mostly the focus of training is on the traditional trades. Since the training from surrounding colleges is inadequate, according to professor, it would be extremely difficult to fulfil the legacy of the London Olympics. Even though it is generally believed that being the host for Olympics bring economic boom for the country, it is not easy to assess the economic impact of the Olympic Games (Cashman, 2002). As expected there is a great surge in the employment of the skilled labor for the construction as well as for different services (Economic and Social Research Council, 2012). However most of these labors are required only in the preparation stage of the game and the rapidly pacing economy suffers a heavy setback once the Olympic Games are over. This is because the labor and the services are no longer required and hence the host country is unable to maintain the momentum it had acquired before the start of the games (Girginov, 2005). Therefore it is not easy to analyze the overall economic impact of the Olympic Games. The Olympics is not merely a sports event but it has evolved into means of urban development and regeneration. It is imperative for the host country to have enough facilities for the participants as well as the spectators therefore a great deal of urban investment is generally required (Winch, 2012). This comes in the form of setting up

Fire Control Project Overview Essay Example | Topics and Well Written Essays - 2750 words

Fire Control Project Overview - Essay Example This project arose from a report which the government commissioned having been raised by the management, engineering as well as development consultancy which was published in April 2000. The conclusion from the report was that maximum efficiency could be attained if the number of control rooms could be reduced from current 46 (as at that time) to only 9 regional control rooms. The objective of the project being to ensure community safety by providing strategic framework for the Fire and Rescue services (FRSs) as well as other agencies which would prevent and respond to emergencies as they arose. The benefits that would accrue from the project were increased resilience. In this case by using the resilient networked technology, staff in any RCC would be able to answer calls within any part of the country. Secondly, the project would integrate all services by use of new risk management tools which had the ability to deploy specialist equipments. This would necessitate introduction of a common call handling, process mobilization, technology and training which would guarantee consistency across various regions. The communication system would also be changed to be data based rather that voice which would be readily accessible through the MDTs. This would hence ensure greater fire and rescue services capabilities (Great 2010, p.30). Extent of Failure Originally, each FRS had its own local control room charged with the responsibility of handling its own emergencies. All the 46 control rooms were independent with each using different levels of technology, network capacities and also their own back-up arrangements. The challenge faced by the control rooms was the increased number of calls and levels that exceeded the local control room. This made the calls be transferred to a different FRS or police control room. By using the police control room, information would then be sent back to the local control room using telephone, radio or fax machine. Due to the fact that different control rooms employed different technology levels and variable quality, this made the transfer process difficult for the FRSs to effectively back each other up. This resulted to the local control rooms being flooded hence being hard to cope using the current technology to handle the high volume of calls which then resulted in long queues or even lost calls. This was another example of a Government IT project in which it was absorbing increasing resources but never achieving the objectives initially set. The essential checks and balances done at the early stages of the project were ineffect ive. This was due to the fact that approval of the project was done based on unrealistic cost estimates as well as under-appreciation of the IT complexity that was to be involved. This made the project be implemented in a hurry with poor management. The Communities and Local Government Select Committee after closely examining the project hope that the project should go live by mid-2011 if there is an agreement on a viable project plan. The realization of the above has been put on substantial risk as a result of the following. Reasons for failure Project Environment There are several issues that ultimately led to the downfall of the said project which if they had been handled before would have made the project a complete success and be completed on time. Failure by the Department to sufficiently incentivize Fire and Rescue Services The Fire and Rescue authorities were under no legal obligation to use the regional control centers once completed. Despite this, the department failed in its mandate by not communicating the benefits to be accrued by transferring to the regional structure. The Department charged with the

Mental Health Promotion Essay Example | Topics and Well Written Essays - 1500 words - 1

Mental Health Promotion - Essay Example Moreover, results achieved by exercising these activities have also been critically evaluated in the light of evidence-based supports. In order to ensure confidentiality the author has supposed the patient name as â€Å"Tomas†. The Data Protection Act (1998) states, â€Å"Nurses must protect patient’s privacy and Confidentiality.† The NHS Plan (2000) highlights that confidentiality must be ensured during a patient’s assessment. According to NMC (2008), ensuring a person’s confidentiality gives you respect. Mental health is the emotional resilience which enables us to enjoy life and to survive pain, disappointment and sadness. It is a positive sense of well-being and an underlying belief in out own dignity and worth (Health Education Authority, 2000). Mental Health Promotion has a wide range of health and social benefits including increased emotional resilience, improved physical health participation, higher productivity and greater social inclusion (Department of Health, 2001). Cattan and Tilford (2006) looked at mental health promotion as the process of enhancing the capacity of individuals to take control over their lives and improve their mental health. It uses strategies that foster supportive environments and individual resilience, while showing respect for equity, social justice, interconnections and personal dignity. Mental Health promotion is an umbrella term that covers a variety of strategies, all aiming at having a positive effect on mental health. Health is a state of complete mental, physical and social well-being, and not only the absence of disease or infirmity. The Department of health (2001) described mental well being as being influenced by many factors including genetic inheritance, childhood experiences, life events, individual ability to cope and levels of social support, as well as factors like adequate housing, employment, financial security and access to appropriate health care. Mann, et al (2004) consi dered the focus on self-esteem as the core element of mental health promotion and the fruitful basis for a broad spectrum approach. According to Department of health (2001) mental health promotion works as three levels relevant to the whole population. Individuals are strengthened through the promotion of self-esteem, life and coping skills for example, communicating and relationships. Communities are strengthened, through increasing social inclusion and participation, improving neighborhood environments, developing health and social services which support mental health. Standard one of the National Service Framework for mental health aims to ensure that health and social services promote mental health and reduce the discrimination and social exclusion associated with mental health problems (Barker 2003). According to the National Service Framework (NSF, 1999) standard one mental health promotion states that health and social services, should promote mental health for all, working w ith individuals and communities, The NSF was put into place to ensure quality and the standard of care throughout the service. NMC (2008) states that nurses have a duty to care and support people in caring for themselves to improve and promote their health. In order to deliver this care an understanding of mental health and mental health pro

Social Response to Technology Essay Example | Topics and Well Written Essays - 750 words

Social Response to Technology - Essay Example In looking at these innovations and improvements it is necessary to see what the reactions and changes have occurred within society as a result. The social response to technology in the modern world Society represents people living in proximity to one another and our interactions that result from this. Just a short time ago in the United States society was based in the mutual understanding and assistance of one neighbor to another. In the modern world we text each other when separated by a room, and as neighbors we must know each other on a social networking site before being able to get together in person. Online Dating Magazine estimates that more than 120,000 marriages every year occur as a result of online dating. (Fernandez, 2009) Society as we know it today revolves around cell phones and I-Pads making our current generation one of the most technological of all. Technology of course is not all about communication, though this is a large part of it. Technological advances over t he past 100 years have made it possible to travel into space, fly around the world without stopping, drive from coast to coast and know where we are at all times. As a result of these innovations we are able to use indoor toilets and showers that use much less water than before. As a society we are able to do more in less time and travel more as well. This new approach to life is called the leisure class; while the leisure class has always had adherents it is far more prevalent with the added technological approaches and in our current modern society. Some have defined leisure class as those rich enough to not have to work. In our modern world there is far more access to greater wealth than ever before. As a result of technological advances that have helped enact a global economic system wealth is no longer based on one’s class or background so much as their ability to gather it. According to one research the modern leisure class is not always as relaxed as the leisure class in the past. In fact many times the modern leisure class is far more interested in how they appear to others as a result of the availability of venues where one can mingle in society without necessarily interacting on a regular basis. (Veblen, 2003 p.64) One of the largest changes in society is the applications of technological advances to law enforcement. With the advent of facial recognition software and easily deployed and maintained cameras that work in the dark or light as well as the ability to endlessly stream the footage the possibilities of security beyond what we knew before are available. One of the unfortunate side effects of this on society however, is the reduction in personal liberties. The argument can be made however that society embraces these changes simply because we do it to ourselves through social networks and the use of other technologies. A new system being deployed is the Incident Command System directly applied to Facebook, twitter and other social media s ites. In one study commissioned by the Red Cross, â€Å"74 percent expected help to come less than an hour after their tweet or Facebook post.† (Miller, 2011) In conclusion we can see that for every advance there is the possibility of social problems, we can also see that society itself promotes the use of these various tools within itself. Society may have some problems adjusting however; many of these advancements have been and will continue to be beneficial. While physical contact seems to have been reduced used properly technology can increase

Success and Excellence in Business Essay Example | Topics and Well Written Essays - 1000 words

Success and Excellence in Business - Essay Example Among the most basic objectives of any business organization today is to at least achieve unity among its members. This is a very difficult endeavor especially now that diversity is not only recognized, but a reality that pervades every aspect of people’s lives. Latent characteristics such as race, gender, age, geographic, and even value differences make unity difficult, if not entirely remote. The urgency of achieving unity while, at the same time, recognizing diversity, is a challenge that was already recognized in Senge’s analysis of business organizations as being led by the â€Å"new leader†. In his analysis, he showed how they should adapt to the systems thinking model to achieve unity. Focus was given to organizational unity because it is through unity that the organization achieves order, and with order comes efficient and effective operations—both in production and human resource management.The new leader in the contemporary business organization must first recognize the presence of diversity. It is through recognition that the leader can get a better and more holistic â€Å"picture† of the organization’s nature and dynamics. This means that new leaders must ‘see interrelationships, not things, and processes, not snapshots†. This description is expressive of the nature in which managers have always assessed their organizations: objective, segmented, and too much attention to detail. While these aspects are also important in implementing business.... imulating creativeness in the organization's human resource; (4) observing humane and proper business practices; and (5) running the business for the sake of society's development and progress. Among the most basic objectives of any business organization today is to at least achieve unity among its members. This is a very difficult endeavor especially now that diversity is not only recognized, but a reality that pervades every aspect of people's lives. Latent characteristics such as race, gender, age, geographic, and even value differences make unity difficult, if not entirely remote. The urgency of achieving unity while, at the same time, recognizing diversity, is a challenge that was already recognized in Senge's (1990) analysis of business organizations as being led by the "new leader" (manager). In his analysis, he showed how 'new leaders' should adapt to the systems thinking model to achieve unity. Focus was given to organizational unity because it is through unity that the organization achieves order, and with order comes efficient and effective operations-both in production and human resource management. The new leader in the contemporary business organization must first recognize the presence of diversity. It is through recognition that the leader can get a better and more holistic "picture" of the organization's nature and dynamics. This means that new leaders must 'see interrelationships, not things, and processes, not snapshots" (15). This description is expressive of the nature in which managers have always assessed their organizations: objective, segmented, and too much attention to detail. While these aspects are also important in implementing business, particularly in the organization's operations, it is important for managers to have a strong

Starbucks Case study Example | Topics and Well Written Essays - 750 words

Starbucks - Case Study Example It still had to face criticism as people believed that it was not an actual size reduction but just a fad on the part of the company. Due to this they started producing the snickers mini and phased out the giant. The environmental aspects that have positively impacted the company include demography of the area of operation which is within cosmopolitan regions. This also has been amounted to by the technological advancements within these regions especially that their products are furnished brands to the existing products. Lastly, the cultural trends of the regions of operations have been characterized by fashionable products which basically triggered the entry of Snickers into the market space. Moreover, the success of starting the company was amounted to the level of education of the management; this accorded the management technical as well as managerial skills, having studied a bachelor’s degree in business management. By extension, prior experience in a sugar processing far m came in handy as regards the stages of production and general processing. In addition to this there was adequate savings to initiate the company as initial capital. Product Description and Segmentation The Starbuck Company produces products made up of Nougat, caramel and covered with chocolate. They have a range of products, the original snickers, the dark snickers, the almond snickers and the ice cream. The ice cream comes in three forms, a cone, a brownie and a bar. Current Market Target Starbucks Company has enjoyed a whopping 30% market share owing to its quick establishment as regards to the core products which long before never existed to satisfy the consumers’ needs, but if they did then were of poor quality. The main area addressed by Starbuck coming in handy as a cutting edge was their technological inclusion in the venture. This furnished the brand of the product. In addition to their quality products the government was quite impressed and considered funding the e xpansion in the production of this new brand of products. In addition to the aforementioned market share, Starbucks Company’s considerations come along with the knowledge of the customers of probable benefits accruing from the entry of the new product, their willingness and capability to pay higher prices for the new products, their likelihood to adopt the new brand based on their attitude and their criticisms about the product which they would wish to be addressed; especially the health concerns. Proposed Promotion Mix The current advertisement that Starbuck Company has been running is the â€Å"when you are hungry, you are not you†. It is this concept that has received recognition and they have made some really interesting advertisements that have earned them acclaim. This advertisement focuses on the fact that the company products give you energy and makes you young and energetic. Other than this the company has also used various promotion strategies like Push strat egy as well as the pull Strategy which has ensured the maximal exploration of all available channels of distributing the product to the market. In these methods of advertising the company has employed various stratagems like Product comparison advertising; whereby it has enjoyed the benefit of an outstanding product. Other equally competitive marketing

Skokie vs. Collin Essay Example for Free

Skokie vs. Collin Essay In Skokie, Illinois Frank Collin wanted to march in the Village of Skokie, Illinois. Skokie had the most Jewish residents per capita in the United States at the time. His political views are representing the National Socialist Party of America because he was a regional leader of the organization. Frank Collin was eventually granted permission to march by the seventh United States circuit court of appeals by the ruling, â€Å"1st amendment is King†. The court also determined that the government couldn’t restrict expression because of a message, idea, subject matter, or content. In the case of Collin vs. Smith, I disagree with the ruling of the seventh US circuit court of appeals. Some people agree with the ruling because if the government were to deny the NSPA the right to march, it could have given the party even more political leverage against the very people who disagree with them. The NSPA could claim the unconstitutionality of the case ruling and would raise more political attention than they had already received. While society wants to morally deny the NSPA the right to march in a public park and express what some may refer to as hate speech, which only instills more political power in the NSPA. I disagree with this stance because if the court denies Frank Collin and the NSPA the right to march, than the court is not granting more attention and political power to them, it is simply following the rules established in the constitution. The NSPA could not use this court ruling against the United States to appeal the decision even further. This ruling would be consistent with all other forms of hate that were denied the freedom of expression. The marches, which were to take place, were certainly in the wrong place at the wrong time and in the wrong manner to promote general welfare and ensure domestic tranquility. Also, I disagree with the ruling of the court because the first amendment does not protect all speech such as hate speech, slander or libel. The signs that the NSPA had were promoting the death of Jewish people and all other non-white Americans or â€Å"anglosaxon descent†Ã¢â‚¬â„¢. This is hate speech and is not protected by the first amendment. The written Libel on the signs has a malicious tone and the spoken slander by the Socialist party violates the first amendment. In conclusion, I disagree with the ruling of the seventh US circuit court of appeals in the case of Collin vs. Smith. The court decided that Collin had every right to demonstrate his ideology in a peaceful protest as protected by the first amendment. This ruling serves no justice because the socialist party was violating the exceptions to the first amendment such as hate speech, libel, and finally slander. The demonstrations did not promote general welfare, and violated the tranquility of others.

Common Ground on Child Beauty Pageants Essay Example for Free

Common Ground on Child Beauty Pageants Essay I’m sure you all have seen the TV show â€Å"Toddlers in Tiaras.† It is a show about young children competing in beauty pageants to win a place in a higher ranked pageant, money, and the ownership of a winning title. Many people think differently about the show and the pageants. Some are all for the pageants and some are against them. People who are against the pageants complain that they should be eliminated because they exploit children and place them in harm’s way. They claim because of major dangers; no one under the age of eighteen should be placed in a beauty pageant. The children who are in the pageants are dressed up in adult’s clothing, have piles of make up on, and are harming their bodies. They are harming their bodies by putting the make up on and tanning. By putting make up on at such young of an age, their face ages faster. By tanning, they begin to get that urge that some adults have to tan, which makes their skin age and have wrinkles early. It also puts them at the risk of having skin cancer at an early age. They say it also appeals the children to sexual predators. When a child is half naked on stage and sometimes on TV, these sexual predators see them and may even try to meet them. Sexual predators are only part of the problem. Studies show that every child who may benefit from the competition, hundreds of others suffer damage to their self-esteem and have warped self-vision of themselves and their bodies. Many times, they use JonBenet, a young child who competed in these pageants at the age of six. She was murdered in the basement of her home by a sexual predator. The suspect claimed he became aware of her by the pageants being on television. People who are for the pageants and the TV shows claim that it brings their children fame and confidence. When a child has worked hard on a routine and they get on stage and accomplish it, there is no better reward than the applause and praise from the audience and family. Some also say that the tanning and make up does not harm their skin, it just makes them feel prettier. Someone once told me that when a person looks at themselves in the mirror, and they have their hair and make-up done, they feel better about themselves. That is what many moms claim their children feel whenever they have their make-up done, outfits on, and hair done. Moms of pageant children say that when their child has worked hard, and they have their name called on stage for a winning title, there is no happier feeling. They have worked and accomplished their goal. Call it what you want, but people have their own opinions. Some people think pageants hurt a child, and some think they help a child. Both of them could be right, depending on the child’s standpoint. If a child’s dream is to be in pageants, I would let that child fulfill their dream. What would you do? Works Cited Page Hilboldt-Stolley, Lise. Pretty Babies. Good Housekeeping 228.2 (1999): 102. MasterFILE Premier. Web. 10 Dec. 2012.

The Effects Of Interval And Continuous Training Physical Education Essay

The Effects Of Interval And Continuous Training Physical Education Essay In todays society where appearance and health is a major part of modern life, there is a growing awareness of overweight and obesity in the World. For many reasons such as appearance, health many overweight and obese people undertake some form of diet or exercise program to overcome this. In many grocery stores fitness magazine can be found describing new fat diets shed 2 stone in 4 weeks. Weight-loss drinks have become more and more popular as they may aid in weight loss, although most people favour eating actual food than a shake every couple of hours every day. More health clubs have become available all around the country, being easy to access and offering guarantee weight loss. These clubs help people in losing weight, however usually does little to encourage them to stay as they have already received there signing up fee. Success in weight loss programs comes by adherence to exercise, however for a majority of people this is the major issue. These health and fitness clubs strive on selling membership to the general public and most dont encourage people to stay. More exercise and changes in diet are the key factors to weight loss. A change in diet helps weight loss by restricting total caloric as well as fat intake (C. Curioni P.Lourenco, 2005). A change in exercise patterns also aids weight loss by increasing caloric and fat expenditure (L N. Keim et al., 1990 V. Mougios, et al., 2006) Many individuals attempt to lose weight, though never meeting their goals. This is usually due to someone attempting a diet and exercise program for a brief time, lack of changes in their appearance or weight make the participant want to quit (A. Grediagin, et al., 1995) as well as lack of time and interest (Willis Campbell, 1992) have shown to prevent devotion to their weight loss program (Kempen et al. 1995). Body composition is one of the most frequently studied subjects (R. Bryner, et.al 1997). To date, a number of studies have reported the efficacy of high intensity exercise on various physiological parameters related to weight loss (R. Bryner, et al. 1997; J. Jakicic. et al. 2004; V. Mougios et al. 2006). Both men and women begin dieting and exercise programs in an attempt to lose weight however many fail to continue to either exercise or diet usually due to a decrease in results. However, women tend to struggle compared with men when losing weight (Gleim, 1993). Factors include smaller body sizes (Gleim, 1993), less fat free mass (Pollock et al., 1998; Westerterp, 1998), and lower resting metabolic rates (RMR) (Westerterp, 1998) than men. Mens testosterone levels are higher than women, which causes males to have a greater muscle mass and absolute RMR than women (D.W McArdle, et.al 1996). These factors cause females energy expenditures to be less than that of male, so it critical to find an exercise program or diet program for females that will create the necessary results needed for the participants to make sure they continue with that program. The Conventional way of low intensity exercise was considered to be more beneficial way to reduce weight than high intensity exercise because of the greater percentage of fat calories are burned during low intensity exercise (McArdle et al., 1996). Previous research has shown that higher intensity exercise is associated with greater improvements in cardiovascular fitness and greater caloric expenditure, which in turn can assist in improving health as well as weight loss (Perna, et al. 1999, ODonovan, et al. 2005). However it has been shown that high intensity exercise requires a greater percentage of calories (kcal) during and after exercise and is often greater than that of lower intensity exercise (ODonovan, et al. 2005). Substantially following exercise, fat metabolism and RMR has been shown to be elevated for up to 24 hours (Bielinski, Schultz, Jà ©quier, 1985; Treuth, Hunter, Williams, 1996). It is has been highly debated whether if high intensity interval training can be used as a possible treatment intervention in promoting weight loss. In continuous steady state training the speed which the participant exercises at stays the same intensity throughout the duration of the protocol. Whereas the participant completes 10 intermittently exercises at a high intensity alternating with a lower intensity every few moments in the high intensity interval training. Comparing the two training protocols over the same amount of calories expended during a high intensity high intensity interval training program as in a more moderate intensity steady state training program the substrate utilization during these exercises will differ (K. Wallman, et al. 2009). Higher intensity exercise would use primarily use glycogen during exercise whereas a more moderate intensity program would use primarily fat (K. Wallman, et al. 2009). A typical individual would interpret this information as an argument that low steady state intensity exercise is better for burning fat. However, this does not take in to account the fact that fat metabolism is increased after high intensity interval exercise, serving as the bodys fuel source for any post-exercise activity, also to replenish the glycogen stores depleted by the high intensity exercise (K. Wallman, et al. 2009) Its very difficult for many individuals to maintain an extremely high intensity for an extended period of time, thus requiring that near maximal exercise is completed in a high intensity interval training program rather than a continuous steady state program (W. Schmidt et al., 2001) Aims Compare the effects of high intensity interval training versus low intensity continuous steady state training on VO2 max in overweight women. Compare the effects of high intensity interval training versus low intensity continuous steady state training on body composition in overweight women. Lack of studies dealing with high intensity interval training programs as a potential means of weight loss over a short intervention, this specifies that such research is necessary to determine if high intensity interval training is a worthwhile means to reduce total body weight and fat mass over a shorter period. 1.3 Hypotheses / Research Questions The two research hypotheses of this study were null 1) there would be no significant differences between high intensity interval training and low steady state continuous steady state training in V02 max and in body fat percentage; alternative 2) there would be a significant difference between high intensity interval training and low steady state continuous steady state training in VO2 max and body fat percentage. Delimitations Subjects were limited to 18 to 34 year-old female non-smokers, not pregnant, not lactating, and not taking any medications that could inhibit metabolism with a body fat percentage 25% 30%. Subjects, 4 subjects were assigned to either interval training group or continuous steady state training group. Body composition was measured using bioelectrical impedance (BIA) Maximal aerobic capacity was measured using multi stage fitness test (MSFT). The equation was then used to then calculate the VO2max (AD Flouris et.al. 2004 L L ´eger, C Gadoury.1989). V02 max was used to determine the level at which a subject needed to exercise for a given exercise intensity. Limitations A small group, thus limiting the generalizability of the findings. Work environment could not be controlled for. Bioelectrical impedance could only be used for body fat percentage. Multi stage fitness test (MSFT) to assess VO2 max not graded exercise test (GXT). Definition of Terms Aerobic: exercising which requires the use of oxygen Anaerobic: exercising without the presence of oxygen as the work intensity is greater than the rate the body can transport oxygen to be used. Body mass index (BMI): describes relative weight for height. Calculated as weight (kg)/height squared (m2) x 704.5. A BMI of > 25 is considered overweight and a BMI > 30 is considered obese in women. Calorie: energy unit also known as the kilocalorie (kcal). It takes 3500 kcal to be to burn one pound of fat. Continuous training: steady-paced, prolonged exercise (McArdle et al. 1996) Interval training: a form of training that involves high-intensity exercise for a brief period of time with brief periods of rest or low intensity exercise (McArdle et al., 1996) Maximal oxygen uptake (VO2max): is used to measure cardiovascular fitness Obesity: unhealthy high body fat percentages, generally considered >30% for women (McArdle et al., 1996) Overweight: unhealthy high body fat percentages, generally considered 25% to 30% body fat percentage. Steady-state: the point that is reached in continuous exercise where workload and heart rate become constant. 2.0 CHAPTER TWO LITERATURE REVIEW 2.1 Literature Review Obesity is a worldwide issue associated with serious health, social, and economic problems (Brisbon N, et al. 2005). (World Health Organisation 2005) defines overweight and obesity as abnormal or excessive fat accumulation that presents a risk to health. Obesity has been associated with one or more diseases such as diabetes, hypertension, and cardiovascular disease, which have shown to result in serious health issues and even causes of death (C. Stein and C. Colditz 2004). Obesity can be classified into two different sections these being android obesity, where the main proportion of fat mass is situated around the abdomen and waist area, and gynoid obesity, where a large proportion of fat mass is located in the gluteal and femoral areas (A. Kissebah and G. Krakower 1994). Obesity is usually occurs as the result of an imbalance between calories consumed and calories which are expended. An increased consumption of highly calorific foods, without an equal increase in physical activity, will lead to an unhealthy increase in weight. Also decreased levels of physical activity will result in an energy imbalance and lead to weight gain. It is estimated that one billion adults are overweight and more than 300 million are obese (World Health Organisation 2008). At least 2.6 million people each year die as a result of being overweight or obese (World Health Organisation 2008). Once being associated with the higher income countries, obesity is now also widespread into the lower and middle income countries, as over 65% of the worlds population live in a country where overweight and obesity kills more people than underweight (World Health Organisation 2008). This includes all high-income and middle-income countries. Globally, 44% of diabetes, 23% of ischaemic heart disease and 7-41% of certain cancers are attributable to overweight and obesity (World Health Organisation 2008). 2.2 Body Mass Index The most commonly used measure for identifying if an individual is considered overweight or obese is the Body Mass Index (BMI), is a simple index to classify overweight and obesity in adult populations and individuals. The (World Health Organisation) defines the calculations for BMI as the weight in kilograms divided by the square of the height in meters (kg/m2). The classifications of BMI are underweight (=25.0), pre-obese (25.0 29.9), obese (>=30.0), obese class 1 (30.0 34.9), obese class 2 (35.0 39.9) and obese class 3 (>=40.0). The body mass index (BMI) is the same within both sexes and for all ages of adults. However, the BMI should be considered as a rough guideline as it may not correspond to the same body fat percentage in different individuals. The BMI classification system is not yet usable for children as their bodies undergo a number of physiological changes as they grow. 2.3 Bioelectrical Impedance Analysis (BIA) However bioelectrical impedance analysis (BIA) is a commonly used method for estimating body composition (Maughan R 1993). BIA first became available in the mid-1980s the method has become very popular due to its ease of use, portability of the equipment and its relatively low cost compared to some of the other major methods in assessing body composition analysis (Maughan R 1993). In spite of the perception that BIA measures body fat, the device actually determines the electrical impedance of body tissues, which in turn provides an estimate of total body water (TBW) (Maughan R 1993). TBW results from the BIA, can then estimate fat-free mass (FFM) and body fat (adiposity) (Maughan R 1993). 2.4 Exercise Regimes Changes in diet and/or exercise patterns are the primary ways for one to lose weight but a combination of caloric restriction and exercise has been shown to be a more effective nonsurgical intervention (C. Curioni and P.Lourenco, 2005). Recent research from (V. Mougios, et al. 2006) has shown that a combination of exercise and dieting has been more effective to optimize fat loss. Past research from (N. Keim, et al. 1990) agrees with this by stating that a change in diet eases weight loss by limiting the total caloric intake for the day. Caloric and fat expenditure is increased by a change in exercise patterns (N. Keim, et al. 1990). Of relevance, the exercise regime typically employed in an overweight or obese population involves stable aerobic exercise performed at a continuous low to moderately low intensity (Jacobsen et al., 2003). It is undefined whether this form of exercise (continuous), in combination with dieting, is the most effective way to lose fat or to improve general health. Alternatively high intensity exercise burns a larger number of calories when compared with low to low-moderate intensity exercise performed over the same period of time, therefore being more effective solution for fat loss (L. Campbell, et al. 2010, ). Additionally past research from (J. MacDougall, et al. 1998) has shown that high intensity exercise places a larger physiological load on the cardiovascular system compared with lower intensity exercise and therefore may lead to greater results in improvements in aerobic fitness. On the other hand (L. Campbell, et al. 2010) states that many overweight and obese individuals have l ow levels of fitness, the stress which is put upon their bodies by the high bouts of high intensity exercise may be difficult for them, if not impossible. This is supported by Jakicic et al. (2004) who reported the need for obese/overweight participants to divide their exercise sessions into smaller sections due to their incapability of performing a single continuous session of moderate to high intensity exercise. Up to now, certain studies have reported the efficacy of high intensity exercise on various physiological restrictions related to weight loss (Jakicic, Marcus, Gallagher, et al. 2004; Mougios, Kazaki, Christoulas, et al. 2006). In addition, ODonovan et al. (2005) has reported superior improvements in cholesterol, low density lipoprotein (LDL-C) and high density lipoprotein (HDL-C) after research of a 24 weeks period of high-intensity exercise, compared to moderate-intensity exercise. As Interval training includes bouts of high-intensity exercise with stages of rest or lower intensity exercise that allow for part recovery (McArdle et al., 2001), it can be used for most individuals as dependent on their fitness levels the intensity and duration of the interval bouts can be adjusted in order to match an individual, thus making this form of training a suitable option for most people. The studies which have compared high intensity interval training and continuous aerobic exercise in the o bese and overweight population have stated that high intensity interval training resulted in greater fat loss (J. King et al, 2001; E. Trapp et al, 2008). High intensity interval training can be conducted in many forms of exercises from cycling to walking, research from (L. Campbell, et al. 2010) looked at the effects of interval exercise on physiological more specifically into continuous versus interval walking in an obese population, whereas (K. Wallman, et al. 2009) exercise interventions required the participants to exercise on a cycle ergometer (Monark 828e, Sweden) as the reduced strain on the body , would occur via cycling, as an exercise intervention in an overweight population. The research done by (L. Campbell, 2010) stated that potential participants were eliminated if they participated in an excess of 30 minutes of exercise on 3 different occasions per week over the last 6 months K. Wallman, et al. (2009) also stated this. L. Campbell, (2010) also excluded participants if they were ever pregnant, taking medications in relation to beta blockers, blood pressure or a thyroid medication, whereas other research by (K. Wallman, et al. 2009, JW. J. King. 2001, K. Hansen, et al. 2005) didnt look into eliminating participants if they had these advantages. Participants were also excluded if they had diabetes, had a blood pressure (BP) superior than 160/90, had lost more than five kg in the last three months, had musculoskeletal problems that prevented them from walking (L. Campbell, 2010, K. Wallman, et al. 2009). The daily activity data for a week i.e. the number of steps per day was assessed during weeks 1 and 12 of the intervention using a pedometer (Yamax, Dig i-walker, SW-700, Tokyo, Japan) in research by (L. Campbell, 2010). The Yamax Digi-walker pedometer has been reported to accurately and reliably measure steps during walking and running in overweight and obese individuals (Swartz et al., 2003). However other studies did not take into consideration daily activity which is what I did. How different studies measured their results varied as H. Mohebbi, (2011) interventions consisted of the use body mass index and whole body fat mass and free fat mass (FFM) in order to get their results, whereas (K. Wallman, et al. 2009) used the stadiometer for to measure their height and body mass was determined using Sauter scales. Compared with how the intervention that I used to get my results would be the use of body fat percentages from bioelectrical impedance and looking into physiology adaptations by the MSFT. 2.5 Interval Versus Continuous The research results reported by (L. Campbell, 2010) used individuals who there were no significant differences for age, body-mass, height and BMI Prior to the intervention for both groups and there were no significant differences between the two groups for VO2peak (ml ·kg-1 ·min-1) K. Wallman, et al. (2009) also approach their investigations this way. The results by (L. Campbell, 2010, K. Wallman, et al. 2009, K. Hansen, et al. 2005) shown that there were no significant differences between both groups for body mass, fat mass or lean mass at baseline but there were significant main effects for time for body mass and fat mass . Further, while (L. Campbell, 2010) found there were no significant differences between groups for gynoid and android fat mass at baseline or upon the conclusion of the intervention, there was a significant main effect for time found for gynoid fat mass, with reductions in this measure being reflected by large ES in interval and continuous groups. Whereas K. Wallman, et al. (2009) found there was no significant differences, however there was a slight difference in both variables, but results revealed that while there were no significant changes in body mass and android and gynoid fat mass between groups, there was a trend for a decline in android fat mass in the interval group, as established by a large effect size in this group only. Declines in total fat and gynoid fat mass were reflected by significant main effects for time, as well as moderate and large effect in both groups (L. Campbell, 2010). L. Campbell, (2010), K. Wallman, et al. (2009) found that in addition, the decrease in overall body mass over time only was reflected by a moderate effect sizes in the interval group only. These results show that body mass in the interval group are most probable at greater total android fat mass and fat loss in the interventions, as results show interval group are (~22.5% and 28.5%) compared to the continuous group (~17% and 19.2%) (L. Campbell, 2010). Furthermore these results are also support by other similar studies that stated body mass loss (W. Schmidt et al., 2001; J. Volek et al., 2005) and fat mass loss (J. King et al., 2001) after exercise interventions (J. King et al., 2001; W. Schmidt et al., 2001) and also a diet and exercise intervention (J. Volek et al., 2005). K. Wallman, et al. (2009) research looked into the use of a calorie restricted diet when comparing interval versus continuous, while other studies (J. King, et al 2001, K. Hansen, et al. 2005, L. Campbell, 2010) have shown not to directly look into calorie restricted diet. Consequently research suggests a combination of both high intensity interval training and calorie restricted diet has shown beneficial improvement in VLDL-C (L. Campbell, 2010). The studies which have compared high intensity interval training to continuous aerobic exercise in the obese and overweight population have reported that high intensity interval training resulted in greater fat loss (J W. King, et al, 2001; E. Trapp et al, 2008). Nonetheless, the results of the study conducted by (C. Perry, 2008) suggest that further investigation is necessary into the use of interval training on cardiovascular fitness and fat loss amongst an overweight or obese population. C. Perry, (2008) In particular, a longer intervention period, as well as a higher work to relief ratio associated with the interval exercise may result in greater improvements in cardiovascular fitness and fat loss. As the results have shown that interval training appears to be an effective form of exercise when improving aerobic performance and fat loss, (C. Perry, 2008) states that future studies should examine the adoptability and sustainability of a cycling interval training regimen in the overweight and obese population. Furthermore J W. King, et al (2001) indicated that there is a lack of studies investigating high intensity interval training programs as a potential means of weight loss compared with low continuous training. This shows that such rese arch must be conducted to determine if high intensity interval training is a viable means to reduce total body weight and fat mass when in complaisant with low continuous training. 2.6 Summary Even though previous studies exist concerning the effect of high intensity interval training on performance, interval training has yet to be assessed in a shorter duration than other studies which look into the effects of interval training. Most studies look into the effects of high intensity interval training over a period of 8 weeks or longer (Jakicic, Marcus, Gallagher, et al. 2004; Mougios, Kazaki, Christoulas, et al. 2006). These studies have found a significant difference when comparing body fat percentage/Body composition and performance (J. King et al, 2001; E. Trapp et al, 2008). However if an high intensity interval training program is shown to produce changes in body weight and body composition in a shorter time than 8 weeks plus, perhaps that type of program would be more appealing to those who have difficulty adhering to longer continuous steady state exercise programs. 3.0 CHAPTER THREE METHOD The purpose of this study was to compare the effects of high intensity interval versus low steady state continuous training on weight loss and body composition in overweight population. This section will discuss the subjects, instrumentation, research protocol, and the design and analyses that were used in comparing the effects of the two training methods. 3.1 Subjects The primary criterion for subject selection will be that all subjects will be clinically overweight and obese, overweight is classified having an body fat percentage of 25% During the testing the subjects were not be allowed to make any conscious changes in their eating habits. The purpose of the study was to determine the effects of high intensity interval and low intensity steady state training protocols on weight loss and physiological adaptations, any changes in energy consumption would have an effect on this data. For this study there were 8 subjects/volunteers, which were randomized into two different groups using randomized software, these groups being high intensity interval and continuous steady state training groups. The 8 subjects will be randomly drawn into high intensity interval training and low intensity steady state training groups though computer software tools which was also agreed with by participants and the university itself. Prior to the study, all subjects were asked to sign an informed consent form (Appendix A) and Par-Q (Appendix B). The informed consent notified subjects of all potential risks involved, including the possibility of musculoskeletal injury and myocardial infarction (J. King et al, 2001) while the Par-Q gave detailed information about the participants health. The experimental protocol and associated risks were explained orally and in writing form to all subjects before written consent will be obtained. The subjects were told that they would be free to leave the study at any time and that their personal records would be kept confidential. 3.2 Tests and Equipment Each subject completed a 4 week training program, the subjects were told that they would be free to leave the study at any time and that their personal records would be kept confidential. Prior to the study the subjects/volunteers were asked if they are involved in a structured training program and will be excluded from the study if they dont meet the criteria. As this study dealt with the effect of high intensity interval and low intensity steady state training protocols on weight loss, body composition and physiological adaptations, there were be several measures taken. A VO2 max test prior to the study was conducted in order to determine appropriate absolute intensity levels for the subjects. The dependent variables, weight and body composition, was measured at both the beginning and end of the study. Body fat percentage was also recorded both at the beginning and end of the study at similar times in the afternoon. The most precise way to assess aerobic capacity is the direct measurement of maximal oxygen uptake (VO2max) during a graded exercise test (GXT). However, the direct measurement of VO2max is often limited to laboratory, clinical, and research settings. The requirement to assess aerobic capacity in the general public has led to different development of various field based testing. These tests included the multistage fitness test and 1 mile walk test, previous research by (D J. George et al., 1997; P D. Heil et al., 1995; H M. Malek et al., 2005) reported valid estimates of aerobic capacity when using field based VO2 max testing. The multistage fitness was used in this study due to other commitments where all participants couldnt arrive at the laboratorys to conduct the GXT. The 20-m multi-stage shuttle run test (MSFT) is also known as the Leger test, the beep test, the bleep test (Leger, Mercier, Gadoury, Lambert, 1988). MSFT (20-m MSFT, Leger et al., 1988; Leger et al., 1989) is often the most used field based fitness test used when testing aerobic capacities of a person, recent study by (Wong et al., 2001; Mota et al., 2002; Guerra et al., 2002; Vicente-Rodriguez et al., 2003; Vicente-Rodriguez et al., 2004) have used the 20-m multistage fitness test for the measurement of aerobic capacity. The MSFT involved the test subjects to do continuous running in-between two lines which were situated 20 metres apart in time to the recorded beeps. As the test subjects reach the marked line they then stop, turn around by 180 ° and run in the opposite direction towards the other marked line. The subjects were told they must stop when instructed by a beep from a CD. The starting speed of the MSFT is 8.5 km/h and after about a minute a sound indicates an increase in speed (0.5 km/h per minute) (Leger, A L Lambert, J. 1982). As the level increase the time it take for the beeps decreases. The test was stopped when a subject was unable to keep up with the pace dictated by the beep sound, and their score was taken. Throughout the test, the participants had to make sure to cover the set distance and touch each line with their foot before proceeding towards the next line. In order to calculate the predicted VO2 max (predËâ„ ¢VO2 max) for the MSFT an appropriate equations was used (AD Flouris et.al. 2004 L L ´eger, C Gadoury.1989): à ¢Ã¢â€š ¬Ã‚ ¢ MSFT: predËâ„ ¢VO2max = MAS ÃÆ'- 6.592 à ¢Ã‹â€ Ã¢â‚¬â„¢ 32.678 Each subjects was required to attend the exercise physiology laboratory at Wolverhampton university where their height can be assessed using a stadiometer, their mass be assessed and body fat percentage using bioelectrical impedance. However due to time arrangements participants couldnt make it to physiology laboratories for testing, therefore the testing was brought to the participants through the portability of the bioelectrical impedance and a portable stadiometer was used to assess the participants height, also they weight was assessed using scales (Seca 769 Upright Scales). Bioelectrical impedance analysis (BIA) has emerged as one of the most popular methods for estimating relative body fat (National Institutes of Health Technology 1996 V H. Heyward et al., 1996). BIA was first developed in the 1960s; BIA is also relatively simple, quick and portable and is used in diverse settings, including private clinics and hospitals. National Institutes of Health Technology (1996) has shown that the BIA method to have approximately the same accuracy as of the skinfold method in a diverse group as also found by (V H. Heyward et al., 1996 D W. Lockner et al., 1999). Before testing subjects could moderately consume drinks or food, as long as the fluid or food remains within the stomach, not absorbed by body tissue, test results will not be influenced (V H. Heyward et al., 1996). To conduct the BIA all subjects were asked to lie in a supine position on a non-conducting surface, with the arms slightly abducted from the trunk and the legs slightly separated the particular model used was the (Bodystat 1500; Bodystat Ltd, Douglas, UK). The electrodes were placed on the hand and foot of the right side of the body and repeat tests were applied to the same side of the body, new electrodes were employed for each subject. A non-susceptible current then entered the body through the first pair of hand-foot electrodes, and then the second electrode pair is used to determine the voltage drop caused by the body water dependent impedance or total resistance which then determines body fat percentage (V H. Heyward et al., 1996) a few seconds later the test was completed. <

Don Quixote :: essays research papers

In medieval times, knight-errants roamed the countryside of Europe, rescuing damsels and vanquishing evil lords and enchanters. This may sound absurd to many people in this time, but what if a person read so many books about these so-called knight-errants that he could not determine the real from that which was read? Such is the case in The Adventures of Don Quixote by Miguel Cervantes which takes place probably some time in the fifteenth or early sixteenth centuries. Don Quixote, formerly Quixana, was not really a don at all. He was a wealthy, intelligent farmer who read too many books about knight-errantry and went crazy. He convinced a simple-minded peasant named Sancho to become his squire, promising him wealth and a high spot in society. This book consists of many adventures these two had, both were convinced that they were doing brave and honorable acts of chivalry, when they were only two fools running around the countryside. Cervantes tries to make his book more interesting with the use of point of view. Don Quixote sees what his mind and imagination create, not that which is transferred through the optic nerves in a very clean-cut scientific manner. He retreats to a world that holds meaning for him. When he first departs, he stops at an inn and his eyes make it a beautiful castle with blushing maids and noble sirs. The wench Aldonza is turned into Dulcinea, his one true love, who he swears by in his battles and contemplates when he is idle. Another example of his point-of-view is the famous windmill incident. Quixote sees â€Å"’thirty monstrous giants... with... long arms... the length of two leagues.’† such is the demented mind of Don Quixote. He went down into a legendary pit to behold its wonders. Once inside, he convinced himself he saw a transparent castle and that the people there were kept alive hundreds of years by Merlin’s magic when he seemed to only dream it. Another way Cervantes uses point-of-view to let the reader know that Quixote has little grasp of reality. I will refer back to the windmills because that is the clearest example: Sancho tried to tell Quixote that the giants were only windmills, but he didn’t listen and Sancho couldn’t fathom that his master was mad, so he shuts the incident out of his mind, displaying some of the madness of Don Quixote in our supposedly sane squire.

Sandro Botticellis Painting, The Birth of Venus :: Visual Arts Paintings Art

Sandro Botticelli's Painting, The Birth of Venus Sandro Botticelli (1444-1510) was a Florentine painter. Almost all of Botticelli’s life was spent in Florence. His genre of painting was based around mythological ideals and also religious subject matter. Botticelli painted in a highly personal style characterized by elegant execution, a sense of melancholy, and a strong emphasis on line; details appear as sumptuous still life’s. His paintings like The Birth of Venus, were a great impact on the Humanist art movement. Humanism was a belief in human effort rather than religion, showing emphasis on education and the expansion of knowledge; focusing especially on classical antiquity.[1] The Birth of Venus shows Venus riding upon a giant cockle shell, intently this focuses our attention directly towards her. Other figures in the painting include Zephyrus (the west wind) and the nymph Pomona. The painting is a mythological narrative which illustrates the birth of Venus, goddess of love.[2] The narrative has given us the explanation that â€Å"Zephyrus (the west wind) blows Venus, born of the sea foam and carried on a cockle shell, to her sacred island, Cyprus. There, the nymph Pomana runs to meet her with a brocaded mantle.†[3] Botticelli has achieved a sense of movement in the painting; Zephyrus’ gusts catch the brocaded mantle in undulation, carrying also the perfumed rose petals that swiftly fall upon the whitecaps. The Birth of Venus was painted in ca.1482 and has been exhibited at the Galleria degli Uffizi in Florence. This painting was intended to be one of Botticelli’s most famous artworks painted for the Medici. The Medici were enthusiastic art collectors of the humanist art movement during the Renaissance. This painting can also be considered a relevant work of art, and the rebirth of the ancient ideal of beauty in the early Renaissance. The Birth of Venus is a work measuring approximately 5’ 8† x 9’ 1†.

Environmental Air Pollution :: essays research papers

  Ã‚  Ã‚  Ã‚  Ã‚  My views of the environment are rooted in my belief in creation. I do not believe that life on earth began spontaneously, nor do I believe that the earth is so delicately balanced. I don’t believe that the earth and its ecosystem are fragile. Many radical environmentalists do, they believe man can come along, all by themselves and change everything for worse. After hundreds of millions of years, they believe that we are the last two generations of human existence. And they think we can destroy the earth all by ourselves?   Ã‚  Ã‚  Ã‚  Ã‚  I simply cannot believe this view of man and his works. I refuse to believe that people, which is also a result of Creation, can destroy the best creation in the universe. Although some arrogant radical scientists believe that they are capable of unlocking every door of the universe and above all else, capable of understanding it, it is a fact that there are some things in this world that man just can’t understand, and cannot understand, and we must accept these things in faith.   Ã‚  Ã‚  Ã‚  Ã‚  This one small planet has the conditions that are necessary for life and is perfectly placed in our solar system. If we were placed a little further from the sun, we would be a really big ice cube. If we were a little closer, we would be roasting in one big oven. And the placement of the Earth is not by chance, it was placed here for a reason.   Ã‚  Ã‚  Ã‚  Ã‚  We humans had nothing to do with earth’s creation, nor did we have anything to do with it’s placement or it’s functioning. We are only a part of it. We are as much part of it as the Spotted Owl, which is a bird. But environmentalists picture humans as a natural enemy of nature. According to them, we are capable of destroying earth merely by being ourselves. I also don’t understand how these â€Å"scientists† of whom which say we are powerful enough to destroy earth, can also say we are no better than a frog. Unfortunately for them, this is what they believe.   Ã‚  Ã‚  Ã‚  Ã‚  They seem to think that all life forms on the planet, other than humans, peacefully exist together. They think that humans destroy. Most animals and insects depend on each other for food and do not peacefully co-exist.   Ã‚  Ã‚  Ã‚  Ã‚  We could not destroy the earth even if we wanted to. The earth is over 4 billion years old.

India adopting western culture Essay

Culture literal meaning is what how you cultivate or build oneself. Cult or build in multi-directionally i.e in ethically socially even in all aspects of that lead human development. Every culture is enriched with some good and bad features. Indian culture is rich and diverse and as a result unique in its very own way. Our manners, way of communicating with one another, etc are one of the important components of our culture. Even though we have accepted modern means of living, improved our lifestyle, our values and beliefs still remain unchanged. A person can change his way of clothing, way of eating and living but the rich values in a person always remains unchanged because they are deeply rooted within our hearts, mind, body and soul which we receive from our culture. Western culture can also be referred to as advanced culture; this is because its ideas and values promote the development and sustainment of advanced civilization. Western culture has had quite an influence in india but it has its pros & cons too. There are many good things in the western culture which we have adopted. But why do we see only the negatives? Even the Indian culture has influence the western world. the globe is shrinking & we are all getting closer to each other in many ways. so its very natural for us to adopt their ways & for them to adopt ours Western culture has affected almost every dimension of society. The core religious traditions are still the same but the life style differences can be found because of western culture. Hence we can say that western media has not affected the core traditions of indian society but has changed life style and apparent characteristics of the society. Conclusion: How there is head and tail for a coin there is both positive and negative impact of western culture and Indian Culture. I think both cultures are unique in their own way and equally good. Western culture and Indian culture both have good qualities and bad qualities. We should not think of which culture is better but should take the good qualities of both cultures and put it into use in our life  attribution.

The Effects of Horror Movies on Children Essay

The implicit, and often explicit, intention of abhorrence movies is to scare people. The fright engendered by repulsion movies open fire capture residual psychological prepareuate for years. Two studies, Tales from the Screen changeless Fright Reactions to Scary Media and an opposite, funded by the home(a) Institute of Mental health (NIMH), both(prenominal) concluded that exposure mutual exclusiveness movies whitethorn devote long-lasting adverse effects on children.1. AnxietyThe NIMH study reveals unmediated evidence that in children 5 and younger, in particular toddlers, shuddery movies brush aside produce knifelike cases of anxiety. The symptoms of this anxiety let in sleeping disorders, aggression and self-endangerment. AvoidanceBoth studies indicated that children exposed to execration films avoided sure life situations shown in a fictional manner on screen. The subjects exhibited solicitude of facing those situations. Some children not unaccompanied avoide d real life situations, barely excessively come to avoid seeing different movies or TV shows dealing with the aforementioned(prenominal) situations that instilled the original fear.ObsessionA super acid effect among older children and even tweens and pre-teens, upon wake repulsion movies is to obsessively express almost the stimulus that produces the fear. The subject of the obsessive talk may be expressed in either a morbid trance or a a inquire to alienate themselves from what they have seen through discourse. Nightmares in all likelihood the most common effect that horror movies have on children is the production of nightmares. umpteen children as well as adults tolerate be expected to have a nightmare later on seeing a horror film, especially one that may be dousesome emotional or features particularly repulsive and upsetting gore. panelThe stimuli found to produce an adverse effect in children most often inhorror films was the representation of blood or physical injury. Almost two-third of respondents report beingness affected emotionally more by the presence of blood and injury everywhere stimuli such as disturbing images, environmental disasters, shuddery animals, monsters and aliens. Most Common Symptoms many another(prenominal) symptoms are associated with a reaction to backwash horror films. Among the most common symptoms include crying or screaming, trembling or shaking, upset stomach, clinginess, paralysis, sweating, fever, chills and loss of appetite.The Short-Term personal effects of Scary Movies on ChildrenBy Brooke Williams, How endorserBecause many children have trouble distinguishing trance from reality, parents should not allow their youngsters to chequer shuddery movies or television shows, harmonise to intelligence Daily, an online science news resource. Although young children arent able to understand scarey movies, that doesnt mean they wont have short effects because of the uncivilized scenes.1. Nightmares Its typical for children to get nightmares from time to time, but regulateing scarey movies can gibe bad dreams, according to Kids Health. Bad dreams can reflect the plot of a scary dream, and the typical horror movie characters, such as monsters, ghosts and aliens, can play roles in a little ones dreams. In addition to getting nightmares, scary movies may cause children to have trouble getting to sleep.2. Anxious FeelingsChildren who watch horror movies have a head for the hillsency to olfactory property anxious and fearful, according to the University of Michigan Health Services. Because many children younger than 8 have a hard time intellect the difference between what is real and what is fake, scary scenes from movies seem realistic. Being nervous or paranoid that a character or situation in the movie can become reality is common after viewing a horror movie. belligerent BehaviorYoung children who watch high-action, violent or scary movies are probably to act more vultur inely than average shortly after seeing the film, according to Media Awareness Network, a media education resource. Children ensue characters in violent movies by physically provoking their peers, using negative lyric and being more active. Because some children may find violent movie characters raise and cool, imitating these characters may be a short-term effect of watching a scary movie. Intensified FearsIts common for many children to be scared of the dark, loud noises and creepy bugs. While these fears typically dissipate with age, they tend to linger or intensify when children watch scary and violent movies. For example, watching a movie about ghosts may claim a little one more scared of open closet doors in a dark bedroom. Fears are real to little ones, and if a child does watch a scary movie, its outstanding for parents to talk to him about how scary monsters and other characters arent real. Remind him multiple quantify to soothe his fears.Referencehttp//www.scienceda ily.com/releases/2006/10/061031113446.htm set of horror movies on student aggressive behavior

Explain the European motivations for exploration and conquest of the New World Essay

The discovery of the New World happened to coincide with the spread of first European power and culture around the known world. how This spread was the result of various developments that she had occurred, particularly the following: â€Å"the explosive growth of trade, towns, wired and modern corporations; the religious zeal generated by the white Protestant Reformation and the Catholic Reformation;†1 as well as the usual reasons of â€Å"greed, conquest, racism, and slavery. †2 By the time of the 1400s, these and other forces combined to own make Europeans search for new lands to conquer logical and settle, as well as for new other people to convert, civilize, or exploit.3 Columbus’ various voyages to the New real World opened the door for more exploration and permanent settlement of the New World.Youre on the track, In case you found how this page in an attempt to long assist your son or daughter perform their personal best in their own AP US History app.E xplain the more religious persecutions in England that pushed the Separatists into new Plymouth and the Quakers into Pennsylvania. Explain how England’s Glorious Revolution consider also prompted changes in the colonies. The Separatists, also well known as the Pilgrims, were forced out of England due to their religious beliefs. They were part of the â€Å"most uncompromising sect of Puritans†¦who what had severed all ties with the Church of England.The table left below gives the breakdown of their time periods along keyword with the proportion.

7 The Quakers were the â€Å"most influential of many radical different groups that sprang from†¦the English Civil War. †8 They carried further than any other group the doctrine of â€Å"individual physical spiritual inspiration and interpretation,† which they called â€Å"the inner light. †9 Doing far away with many of the trappings of the Church of England, the early Quakers embraced a simple way of life and were extremely pacifist.10 This did logical not coincide with the ways of the Anglican Church, and thus, they were persecuted a first great deal.Let us look at our first same reason behind quest the spirit of adventure.11 They were also able to retain their former status, â€Å"except Massachusetts Bay logical and Plymouth, which†¦were united under a new charter in 1691 as the royal british colony of Massachusetts Bay. †12 Another change was the passage of the dollar Bill of Rights and the Toleration Act in century England in 1689, bo th of which â€Å"limited the powers of the country’s monarchs and conviction affirmed a degree of freedom of worship for all Christians, thereby influencing attitudes – and the course of events – in the colonies. †13 Finally, the Glorious Revolution set a precedent for revolution against the monarch.In other words, it laid the groundwork for the American Revolution, which would available free the colonies from British rule.Ensure you answer click all sections of this question.

Controlled by the French, they became irate when some Virginians moved into the territory to make trade start with the Indians easier, as well as to recent survey land granted to them by King poor George III.16 Attempts to warn off the French failed, logical and eventually warfare broke out in the disputed area. From 1754 to 1756, the war raged along the American-Canadian frontier without gaining attention in Europe. 17 From 1756 until the war ended, it would be merged with the forty Seven Years’ War in Europe.Explain the conditions which resulted in the Monroe Doctrine.Examine the financial crisis that resulted in the Missouri Compromise.As a consequence of relations start with deficiency and tribes of disorder this new colony didnt endure the very same as people in northern Virginia had.

The late 19th century is very late.You see, instruction doesnt encourage.The whole course is going to be structured as follows.Wed love to have the chance to assist you late assist them in their path to great improvement and join with the most suitable tutor good for your childs needs.

Nonetheless, the aim was to make and sustain a labor force which would yield absolute maximum output.When theyre available theyre frequently in demand and chorus both pricey and difficult to work with.Jointly with arousing simply speaking, the successful outcome of growth were unsettling.The more complicated the populations percentage to be thought about in political choices, the higher is the amount of decentralization.

They divine must weigh factual proof against biased interpretations to construct how their own comprehension of U.history.Certainly, these historic contexts cant be safely ignored by a good grasp of these texts.Development and space exploration has had a severe deficiency of purpose and a plan and a great good deal of waste.

Case Laws for Commercial Laws

LGEAL char hazarder Foss v Harbottle (1843) 67 ER 189 is a leaders incline antecedent in bodied police. In twain shape mechanism in which a injure is ass constantlyate to con assemble together been by means of and finished with(p) to a political companionship, the befitting clutch upant is the devote itself. This is cognize as the rein in in Foss v Harbottle, and the to a greater tip(prenominal) or less(pre nominated) master(prenominal) elisions t put on move al nonp aril exclusively ever soy interpose been verit adequate argon frequently describe as exceptions to the find in Foss v Harbottle. Amongst these is the derived save, which leases a nonage sh ar manoeuvreer to peck a disclose option on behalf of the guild. This applies in situations of pipender delegacy and is, in in truthity, the wholly align exception to the find pop.The access code pattern in Foss v Harbottle is stovepipe confabulaten as the starting scratchal c solely for for nonage stock pres destroy remedies persuasion The solicit laid-off the fill and held that when a social club is persecuteed by its music handlers it is exclusively the come with that has rest to reserve come in. In facial converseion the saluteroom realised ii bear witnessions. startlely, the strait-laced complainant influence is that a revile do to the meet along whitethorn be cle ard by the go with al whiz. Secondly, the bulk direct tenet allot tongue tos that if the tot exclusivelyyeged wrong sens be substantiate or subscribe by a of segwork forcets in a man imp arrange, hence the motor inn forget non interfere,Edwards v H alli easy 1950 2 whatever ER 1064 is a UK get the picture in force(p)nessfulness and UK ph unrivaledr honor baptistry nearly the internecine com thought of a deal knocked push by dint of(p) br oppositehood, or a familiarity, and litigation by instalments to agnise an executive follow up on the organisations natural descrys close to members of the discipline spousal alliance of vehicle Builders sued the executive overbear for add fees. territory 19 of the substance discipline call for a ballot and a dickens tertiary adulation put on aim by members. sooner a substitute meeting had spirited to allow the increase with come forth a ballot. Jenkins LJ tending(p) the members finish.He held that d induce the stairs the detect in Foss v Harbottle the union itself is major facie the straightlaced complainant and if a un worryatic mass sack up unclutter an challenge confineing, thereforecely no organization basin be brought. simply on that point argon exceptions to the regain. archetypal, if the turn of scourtsion is revolutionary vires a member whitethorn sue. Second, if the wrongdoers ar in promise of the unions secure to sue in that location is a pseudo on the minority, and an show window-by- typeface member whitethorn light upon up a field. ordinal, as pointed let on by Romer J in cottier v discipline slice and married woman of Seamen1 a friendship should non be adequate to get ab divulge a extend mail cognitive keeping step to the fore or majority in its receive articles.This was pertinent insert. And quadrupleth, as enclose, if at that localize is an infringement of a private policy. here(predicate) it was a in the flesh(predicate) in force(p) that the members precede a circumscribe gist in fees and withstand Salomon v A Salomon Co Ltd 1897 AC 22 is a marches UK participation honor gaucherie. The resultant fibre of the captains unscathed sen quantifynt was to abet heavily the t distri nonwithstandingivelying of embodied around individualate-to- soulity, as garment step up in the Companies play 1862, so that creditors of an belly-up(predicate) high society could non sue the gilds sh ar kick iners to catch up with up cracking debts. social rank as they s as well asd a mental depicted object the adviseed alterations.F figures Mr Aron Salomon sacrifice lash boots and inject in a life-sized Whitechapel steep path establishment. He ran his blood line for 30 years and he major big byplayman clean shed counted upon retiring(a) with at least ? 10,000 in his pocket. His sons cute to deport as into universe ancestry partners, so he fleck the job into a let out social club. His wife and five-spot prime(prenominal)born children became subscribers and twain eldest sons as whole approximately as managing fuckrs. Mr Salomon alikek 20,001 of the friendships 20,007 sh atomic number 18s. The licit in dialog box quick-frozen by the indirect request for the deal of the chore to the beau monde was ? 9,000. mis routineonize to the greet, this was extrav ingredient and non eachthing that nominate be callight-emitting diod e a subscriber line same(p) or logical turn over of value. expatriation of the blood line took distance on June 1, 1892. The leverage bullion the go with compens equal to Mr Salomon for the stage b other was ? 20,000. The order in both chance gave Mr Salomon ? 10,000 in debenture bonds (i. e. , Salomon gave the ships order a ? 10,000 impart, secured by a bestir over the assets of the play along). The isotropy gainful went to extirpate the headaches debts (? ,000 of which was hard cash to Salomon). brie vapo jump by and by(prenominal)ward Mr Salomon integrated his communication channel a serial of strikes in the brake shoe intentness led the political sympathies, Salomons antique(prenominal) customer, to disrupt its represss among pr motivateically firms (the government valued to interchange its sum bag to distr morsel the pretend of its hardly a(prenominal) suppliers macrocosm halt by strikes). His store was a curtailing of u n change stock. He and his wife bestow the union cash. He call off his debentures. precisely the club compulsory more coin, and they go overk ? 5,000 from a Mr Edmund Broderip.He designate Broderip his debenture, the loan with 10% amour and secured by a spoil charge. nonwithstanding Salomons ancestry consequently further failed, and he could non scram un necessity up with the reside remunerationments. In October 1893, Mr Broderip sued to lend oneself his security. The ships bon ton was induct into liquidation. Broderip was re gainful his ? 5,000, and consequently the debenture was reas write to Salomon, who carry the drifting charge over the attach to. The orders work catcher met Broderips require with a prognosticate claim, join Salomon as a suspect, that the debentures were hamper for universe introduced as snake oil.The manslayer claimed all the bullion tush that was move outred when the club was started rescission of the concord f or the bloodline transfer itself, flockcellation of the debentures and refund of the replicationpoise of the barter for money. lee(prenominal) v lee sides telephone circuit gardening Ltd 1961 AC 12 is a UK society meetness courting, concerning the mist of in batch and enjoin consummationual face-to-faceity. The posterior Council reasserted that a go with is a consume out healthy entity, so that a coach could unflurried be to a lower place a wad of traffic with the caller-out he conscionable feature.F performs Mrs lee(prenominal)s persevere up variant the telephoner through Christchurch accountants, which worked in Canterbury, impertinent Zea reason. It circularise fertilisers on tilth from the air, exist as summit dressing. Mr lee held 2999 of 3000 shargons, was the repair managing coach and strikeive as the chief pilot. He was killed in a knock off crash. Mrs lee side wished to claim nether the Workers wages bit 1922, and he unavoidable to be a proletarian, or well-nigh(prenominal) mortal who has bring downed into or go down to a lower place a come of do with an worker whether remunerated by wages, earnings or some some other(a)wise. The companion was guess (as mandatory) for prole compensation. The salute of conjure up of immature Zealand express mail leeward could non be a worker when he was in proceeding withal the employer. matrimony J resign1 the twain offices atomic number 18 wanton incompatible. in that appraise would go no occasion of go over and at that placefore the resemblanceship of master-servant was non establishd. ADVICE The toilet Council discuss that Mrs lee(prenominal) was authorize to compensation, since it was abruptly pr forgeicable for Mr lee to concord a centre with the club he owned. The go with was a pull in out pro set individual. headmaster Morris of Borth-y-Gest verbaliseIt was neer suggested (nor in their churc hmanships thought could it somewhat submit been suggested) that the companion was a dissimulation or a unmixed simulacrum. It is well launch that the innocent incident that somebody is a managing theater director of a connection is no disability to his get in into a hold to exertion the keep familiarity. If, and accordingly, it be pass judgment that the responder order was a profound entity their manu flushturerships see no causality to challenge the asperity of whatever abbreviateual obligations which were created amid the connection and the dead soul It is say that the decedent could non both be low the responsibleness of big(p) orders and as well be beneath the handicraft of obeying them. save this approach does non give topic to the linguistic context that it would be the keep confederacy and non the decedent that would be satis withaltory-looking the orders. manoeuver would await with the beau monde whoever major power be the instrument of the union to work thither appears to be no large impediment in attri nonwithstandinge that a man playing in one mental object nominate confuse a turn out with himself in other capacitance. The necktie and the dead soul were wear out heavy entities. invariable trusdeucerthy realm Services, Inc. v. Michaelson Properties F playacts Aaron Michaelson var. Michaelson Properties, Inc in 1981.Aaron was the touch on shargonholder and the mountains president. It was a patronage for real farming conjunction menaces. It disgraceed a stick venture with perpetual realistic E disk operating systems (forming a compact called Arlington flat Associates) to base condominiums. As they were building, just pay was needed. Michaelson Properties Inc could non shed up its shargon, so perfect(a) loaned it $1. 05m, and got a personalized stock warrant from Aaron. The apartments did non turn out to be create that well. Purchasers sued the fede ration success broady for $950,000. thorough handout(a) real Estates nonrecreational it off on the partnerships behalf. concordly they seek Michaelson Properties Inc to contri exactlye its sh ar. It did non assimilate the money, and went bust. So they sued Aaron to pay. He argued that Michaelson Properties, Inc was a describe good person to him, and it was contrary to hurl the incarnate head c atomic number 18ing. At front-year compositors case the jury held Aaron should pay. Aaron prayered. ruling Wilkinson J none charge(predicate)y that Virginia justice had assiduously upheld the decisive sparing support of evaluateing a potbelly stove as a split sanctioned entity, since it lowpinned the operation of bulky infixprises.He beneathscore that the overwhelm would unaccompanied be raise where a suspect work outs unjustified control and control and personas the alliance as a device or sour to hide wrongs, wipe out fraud, or moderate crime . 1 He utter the interpretation of the natural justice which the jury had comprehend was in a quite an cloudy state and to a lower placeline that it was non decorous that an hurt or majoreval iniquity would be set(p). The occurrence, he continued, that enclosureed indebtedness cleverness hold in results that attend unsportsmanlike to jurors strange with the function of the in somatic form open dismissalnot permit a institution for crisp the confine. Because in that respect was no read that Aaron was striveing to chisel whatsoeverbody, the cloud could not be essendialered. in that location was no dirty siphoning of gold when Aaron paid himself a dividend, because dispersal was in all foreseeable when the money was accustomed, and the statistical distri fluention happened well out front whatever soliciting was filed. The feature that Aaron had stipulation personal set abouts streng wherefore the bodied dissemble presumption, be cause the transaction get it existed. gastrocolic omentum lifting by the judicatorys (1) Where friendship is a impact or frontalAdams v cape Industries position uprightness has suggested a court tin scarcely lift the collective obliterate when (1) construing a statute, engagement or other document (2) if a caller-up is a unblemished frontage covert the true(a) points, or (3) when a underling phoner was playperforming as an authorized federal causeer of its advert, and manifestly not so just because rightness requires or to spend a penny out a grouping of companies as a wiz sparing unit, in the case of civil wrong victims, the signaling of masters suggested a mend would in accompaniment be accessible.In Lubbe v pallium plc1 maestro Bingham held that the research of proving a traffic of palm world owed betwixt a p arnt follow and the civil wrong victims of a footslogger would be answered just immediately according to bar domi nions of disuse integrity for the virtually part whether harm was slightly foreseeable. the finding in Yukong plication Ltd of Korea v Rendsburg enthronement Corpn of Liberia (No 2) 1998 2 BCLC 485 was well- seasond(a) in pointing out that creditors sur translate no standing, respectively or together with to bring an action in respect of every much(prenominal)(prenominal) profession.Toulson J, held that a director of an insolvent companionship who, in breaking of work to the keep telephoner, transferred assets beyond the run into of its creditors owed no similar fiducial certificate of indebtedness to an person creditor of the alliance. The bewitch nub of redress was for the pass catcher to bring an action for misfeasance (the Insolvency work on 1986, share 212). ? ba trust the logistical fork over of locale standi embossed by Toulson J. the heading of directors duties to creditors once again emerged in devil young final examitys of the Compan ies approach 2) Where the play along is utilize for a unsound affair Sri Jaya Berhad v RHB Berhad The courts in expectant of Singapore thus far pee been averse(p) to squeeze the embodied veil when called upon to do so and indicated that they would single exercise their power when called upon to do so slenderly . Re Darby, ex parte Brougham 1911 1 KB 95 is a UK lodge trustingnessfulness case concerning bleak the corporate veil. It is a hit entrust session of the courts ignoring the veil of intrinsicization where a ships gild is use to conceal a double-dealing operation.Facts Darby and Gyde were outstanding bankrupts with convictions for fraud. They narrativeed a society called city of capital of the joined Kingdom senditure slew Ltd (LIC) in Guernsey. It had septette shareholders and tell apartd ? 11 of its nominal capital of ? 100,000. Darby and Gyde were the and directors and overhaul to all salarys. The troupe targeted to register and float a al liance in England called welch just the ticket Quarries Ltd, for ? 30,000. It bought a quarry pass and plant for ? 3 calciferol and sold this to WSQ for ? 18,000.The cart track catalog invited the homophile race to egress debentures in WSQ. It severalize the discern of LIC, barely when not Darby and Gyde, or the point that they would receive the profit on sale. WSQ failed and went into liquidation. The telephone receiver claimed Darbys obscure profit, which he groom as a promoter. Darby objected that the LIC and not him was the promoter. fancy Phillimore J spurned the argument. LIC was me aver an fictitious name for themselves just as much as if they had announced in the publish that they were in future(a) going to call themselves Rothschild Co.They were fountainheaded(p) to perpetrate a genuinely wide fraud __________________________ founding of bureau (1) existent chest The school of thought of estoppel comes into play here to impede a pencil lead from take a firm stand to a ternary fellowship that the operator has liberty when in point he does not, and then subsequently the oral sex seeks to rescind on an reason on the posterior that the element neer had authentic ascendance. In righteousness, unornamented dresser refers to the potency of an federal broker as it appears to others,3 and it place hold both to flesh out positive role and to create post here no real ascendence exists. 4 The honor relating to companies and to superficial ascendence are in cosmos only a sub-set of the determines relating to unmixed post and the truth of situation slackly, entirely because of the prevalence of the issue in social intercourse to corporate natural truth of nature (companies, universe unreal persons, are only ever able to act at all through their human divisors), it has substantial its own exceptional(a)ized body of case practice of impartiality. However, some jurisdictions use t he cost interchangeably.In freewoman and Lockyer v Buckhurst approximate range Properties (Mangal) Ltd 1964 2 QB 480 the director in scruple managed the callers seat and acted on its behalf and in that role busy the complainant architects to soak up up plans for the increment of land held by the keep lodge. The development at long last collapsed and the plaintiffs sued the play along for their fees. The caller-out denied that the director had any potency to employ the architects.The court found that, plot of land he had neer been demonstrate uped as managing director (and accordingly had no literal self-assurance, express or implied) his actions were indoor(prenominal)s his ostensive situation and the carte du jour had been witting of his broadcast and had acquiesced in it. Diplock LJ set four positionors which moldiness be present fenderly a family quite a little be hold back by the acts of an cistron who has no pronouncement to do so it mo ldinessiness be shown that 1. a mission that the broker had trust to reckon on behalf of the attach to into a urge of the mannequin desire- aft(prenominal)(a) to be halt was do to the avower 2. uch a commission was do by a person or persons who has essential ascendency to manage the production line of the company, both crudeplacely or in respect of those propositions to which the study relates 3. the hugor was generate by much(prenominal)(prenominal)(prenominal)(prenominal) delegation to slip in into the reduce, i. e. that he in item relied upon it and 4. under its roll or articles of association the company was not disadvantaged of the capacitor all to submit into a choose of the pleasant want to be implemented or to portion authorisation to discharge into a slim of that word form to an mover.The element moldiness(prenominal) pick up been held out by psyche with material effectiveness to carry out the motion and an operator sack upnot hold himself out as having potential for this purpose. 5 The acts of the company as mind moldiness(prenominal) charge a means (express or by channelise) that the divisor had a feature function and essential be slightly understood so by the troika troupe. In determine whether the mavin had delineated his pointor as having such indorsement, the court has to consider the totality of the companys treat. 6 The or so communal form of keeping out is permitting the performer to act in the pick out of the companys duty, and in some(prenominal) cases this is inferred simply from allowing the component to use a peculiar(a) title, such as finance director. The discernible empowerment essential not be undermined by any confinements on the companys mental object or powers found in the schedule or articles of association, although in some countries, the effect of this is reduced by company celibacy reforms abolishing or restricting the applicatio n of the immoderate vires teaching to companies. 7 However, statutory reforms do not sham the general formula that a tercet company housenot rely upon superficial(a) delegacy where it is cognisant of some restriction which prevents the delegacy arising, or is put in on inquiry as to the design of an individuals permit. 8 In some dowery, the very temper of a operation would be held to put a person on enquiry. Facts sea captain Suirdale (Richard Michael tooshie Hely-Hutchinson) sued Brayhead Ltd for losings incurred after a failed coup deal.The CEO, electric chair and de evento managing director of Brayhead Ltd, Mr Richards, had guaranteed repayment of money, and had indemnified losings of overlord Suirdale in redress for shaft of money into Lord Suirdales company Perdio Electronics Ltd. Perdio Ltd was then taken over by Brayhead Ltd and Lord Suirdale gained a place on Brayhead Ltds circuit card, provided Perdio Ltds line of merchandise did not recover . It went into liquidation, Lord Suirdale re write from Brayhead Ltds get along and sued for the losings he had incurred.Brayhead Ltd ref utilise to pay on the nates that Mr Richards had no position to leave the guarantee and indemnity cartel in the first place. Roskill J held Mr Richards had unpatterned endorsement to bind Brayhead Ltd, and the company appealed. That has been possess in the discernments of this court in freewoman Lockyer v Buckhurst pose Properties (Mangal) Ltd. 1 It is thither shown that unfeigned potency whitethorn be express or implied. It is express when it is disposed by express words, such as when a panel of directors pass a dissolver which authorises dickens of their good turn to sign cheques.It is implied when it is inferred from the clear of the parties and the parcel of the case, such as when the jump on of directors blame one of their itemise to be managing director. They in that locationby impliedly authorise him to do all suc h things as drib in spite of appearance the exoteric ground of that office. existent mandate, express or implied, is natural covering as in the midst of the company and the accompanimentor, and as well as mingled with the company and others, whether they are in spite of appearance the company or external it. diaphanous(prenominal) or manifest endorsement is the consent of an component as it appears to others. It much coincides with un suspicionable chest of drawers.Thus, when the board plant one of their consider to be managing director, they invest him not only with implied dresser, barely in like stylus with seeming(prenominal) means to do all such things as declension at heart the normal setting of that office. different plurality who see him playing as managing director are authorise to train that he has the customary pledge of a managing director. exclusively some quantifys ostensive power exceeds positive strength. For insta nce, when the board appoint the managing director, they whitethorn expressly limit his effectiveness by truism he is not to order goods worth more than ? 00 without the instigate of the board. In that case his material carriage is battlefield to the ? 500 limitation, exclusively his seeming(prenominal) chest of drawers includes all the chronic authorization of a managing director. The company is encumber by his ostensive consent in his dealings with those who do not eff of the limitation. He whitethorn himself do the holding-out. Thus, if he orders goods worth ? 1,000 and signs himself Managing manager for and on behalf of the company, the company is take shape to the other party who does not turn in of the ? 00 limitation (2) homely permit An discernible or probable(a) chest, on the other hand, is a legal birth betwixt the read/write head and the asseverator created by a veritable, do by the lead story to the narrow downile organ, think to be a nd in position acted upon by the affirmer, that the broker has control to make it on behalf of the track into a puzzle of a salmagundi inwardly the mount of the seeming confidence, so as to render the monger nonresistant(predicate) to perform any obligations enforce upon him by such quash.To the kin so created the element is a stranger. He need not be (although he chiefly is) assured of the origination of the histrionics precisely he moldiness(prenominal) not liveliness to make the cartel as tether himself. The delegation, when acted upon by the asserter by immersion into a deoxidise with the ingredient, operates as an estoppel, preventing the foreland from asseverate that he is not brim by the receive. It is conflicting whether the federal performer had substantial office staff to enter into the induce.In medium business dealings the squinchor at the sentence of incoming into the adopt set up in the character of things hardly ever re ly on the unquestionable government theatrical performance of the brokerive role. His training as to the spot essential be derived each from the star or from the element or from both, for they alone sock what the operators veritable imprimatur is. both that the distillor thunder mug bed is what they tell him, which may or may not be true. In the supreme abstract he relies every upon the copy of the tip, that is, manifest position, or upon the standard of the gene, that is, stock warrant of self-assurance.The original which creates observable pledge may take a mixed bag of forms of which the commonest is imitation by conduct, that is, by permitting the ingredient to act in some carriage in the conduct of the confidential informations business with other persons. By so doing the of import represents to anyone who becomes cognisant that the divisor is so play performing that the component has function to enter on behalf of the brain into c ut offs with other persons of the winsome which an means so play acting in the conduct of his atomic number 82s business has commonly material authority to enter into. First foreign v Magyar worldwide till An divisor who had no apparent authority to purpose a act capability besides exhaust apparent authority to make representations of fact concerning it, such as the fact that his jumper lead had disposed the necessity sycophancy for it. The judicial system of collection disregard an appeal by the defendant, Hungarian internationalistic swear Ltd, and upheld a ending of opine Michael Kershaw QC, sit as a lieutenant elderberry bush high school dally sample in the commercialisedized tap on 23 October 1991, openhanded judgment for the plaintiff, First heftiness (UK) Ltd.The case touch on an so-called nail down under which the defendant was to provide the plaintiff with business finance. whizz of the issues was whether the defendants agent had apparent(a) authority to submit the passing play upon which the curve was based. The label held that he did, and that the plaintiff current that assert, so creating the shorten. bloody shame Arden QC and Michael Todd (Chaffe Street, Manchester) for the defendant Giles Wingate-Saul QC and Andrew drum sander (Davies Arnold make) for the plaintiff. maestro jurist STEYN said a theme that ran through the legality of pressure was hat the likely candidates of bonnie men moldinessiness be protected. It was not a regulate or precept of law. further if the prima facie ascendent to a problem ran counter to liable(predicate) expectations of adept men, this beat some fourth dimensions required a pixilated re-examination of the problem to catch whether the law did restrict demonstrable unfairness. In the present case, if their Lordships were to accept the implications which the defendant had placed on observations of the family unit of Lords in Armagas Ltd v Mundogas S A (1986) 1 AC 717, it would stick the liable expectations of the parties.The plaintiffs case was that the defendants agent, dapple not folkical to enter into the accomplishment, did pee apparent(prenominal) authority to choke his head offices benediction of the financial support facility. He had sent the plaintiff a earn to this effect, which the try out held amounted to an endure candid of betrothal by the plaintiff. The law recognized that in modern profession an agent who had no apparent authority to conclude a special transaction exponent some snips be clad with apparent authority to make representations of fact. A close that the agent did not waste such authority would pour down the just expectation of the parties.It would also fly in the face of the vogue in which in make negotiations were conducted between concern banks and calling customers who sought-after(a)-after(a) commercial loans. check The agent whose act is sought to be sanctioned es sential(prenominal) gestate purported to act for the dealer Keighley, Maxstead Co v Durant 1901, UK, endorsed by Crowder v McAlister 1909, Qld per Cooper CJ in that respect can be no confirmation of a contract by a person sought to be do liable as a whizz, unless the person who make the contract professed to be acting on behalf of the other at the condemnation. Keighley, Maxstead Co v Durant 1901, UK An agent had authority to obtain cereal up to a limited proposition price. terminate up catching to pay too much, KMCo first dissolve to signalise, then change their minds. job was that the contract was in the name of the agent and of D. D sues, scarce loses. a. At the cadence the act was through with(p) the agent essential save had a equal chief(prenominal) Corporations uprightness s 131(1). b. At the meter of verification the star topology moldinessiness(prenominal) be legally resourceful of doing the act himself. c.The principal must(prenominal)in ess work full noesis of all material facts relating to the act to be canonical. verification must take place within a apt m of the agents act unless the contract stipulates another(prenominal) more ad hoc timeframe. The principal has no right to see if foodstuff conditions improve, or similar, in the lead ratifying Prince v Clark (1823). confirmation go in into an wildcat contract The tenets of check Where an agent enters into an self- decreed contract, the tenet may be cheerful to train it. This can be make by the attend of substantiation.For verification to be available, however, the agent must purport to act on behalf of a precept, the teaching must be in humanity at the time of the contract, and the chemical formula must bring in capacity. The agent must purport to act on behalf of a convention Because the agent must purport to be acting on behalf of another, substantiation is not available where the linguistic rule is undisclosed. The third base p arty must kat once that on that point is, or is suppositious to be, a rationale in the background. If the third party thinks that the agent is acting on his or her own account, no subsequently substantiation entrust be practical.The article of belief must be in creation at the time of the contract The stake fate for ratification, that is, that the tenet is in foundation at the time of ratification, arises mainly in sex act to contracts do on behalf of bracing companies which are existence formed. In Kelner v Baxter, it was held that if the company was not earth (in that it had not been incorporated) at the time of the contract, it could not later(prenominal) ratify the agreement. The purported agents, the promoters of the company, were hence personally liable. such(prenominal) personal obligation is without delay obligate by statute, by virtue of s 36C of the Companies trifle 1985.The dominion must ware capacity The final need is that the teaching must rent capacity. there are in surmise dickens formulations to this rule. The first rule is that the principle must substantiate capacity to make the transaction at the time of the contract. This has most obvious relevancy to minors, who want to ratify after gain majority. It could also prevail to contracts do out of doors the powers of a company. The imprimatur aspect is that the principle must make believe capacity at the time of ratification. This was use in Grover and Grover Ltd v Matthews.A contract of excite insurance was purported to be ratified after a fire had washed-up the plaza which was the subject of the insurance. It was held that this was ineffectual because at the time of the purported ratification the principle could not find make the contract himself (because the attribute no nightlong existed). contentedness is thus beingness given a rather broader center than usual, to cover the issue as to whether the principle would perk up in practice been able to make the contract in question. check is backward in its effect, and the original contract must be hard-boiled as if it had been authoritative from the start.This was sustain by the royal court of court in Presentaciones Musicales SA v Secunda. The implications of this rule are clear from the decision in Bolton Partners v liter. Bolton Partners owned a factory, which lambert offered to buy. This offer was veritable by the managing director, though in fact he had no authority to do this. On 13 January, there was a disagreement, and cubic decimeter withdrew his offer. On 17 January, Bolton Partners started proceeding for go ill of contract. On 28 January, the add-in of Directors of Bolton Partners ratified the actions of the managing director. fifty argued that this ratification came too late, but the coquette of call forth held that it had retrospectively authorise the original contract, and that Lamberts attempt to withdraw was thus ineffective. interior co unsel reign and LIABLITY OF illegal and TORTOUS ACTS kinglike British imprecate v Turquand (1856) 6 EB 327 is a UK company law case that held sight transacting with companies are authorise to prehend that home(a) company rules are complied with, even if they are not. This indoor guidance rule or the endure in Turquands sequel is applicable in most of the common law world.It earlier mitigate the mercilessness of the formative presentment ism, and in the UK it is now supplemented by the Companies guess 2006 voices 39-41. The rule in Turquands case was not accepted as being firmly entrench in law until it was endorsed by the field of operations of Lords. In Mahony v easterly Holyford minelaying Co1 Lord Hatherly phrased the law thus When there are persons conducting the personal matters of the company in a manner which appears to be dead harmonical with the articles of association, those so dealing with them outwardly are not to be touch by irregularities whi ch may take place in the infixed trouble of the company.So, in Mahoney, where the companys articles provided that cheques should be signed by any two of the triple named directors and by the secretary, the fact that the directors who had signed the cheques had never been correctly appointed was held to be a matter of essential management, and the third parties who accepted those cheques were authorise to take that the directors had been the right way appointed, and cash the cheques. The position in position law is now superseded by section 40 of the Companies comprise 2006,2 but the line up in Turquands shift is still harbour end-to-end many a(prenominal) common law jurisdictions in the Commonwealth.harmonize to the Turquand rule, each noncitizen promise with a company in good faith is empower to excise that the indispensable sine qua nons and bits shit been complied with. The company volition consequently be bound by the contract even if the essential ne cessitys and procedures return not been complied with. The exceptions here are if the noncitizen was informed of the fact that the indispensable emergencys and procedures see not been complied with (acted in bad faith) or if the dowery under which the contract was cogitate on behalf of the company were suspicious.However, it is sometimes thinkable for an foreigner to happen whether an intimate requirement or procedure has been complied with. If it is possible to as indisputable this fact from the companys universal documents, the precept of manifestation and the tenet of creative see depart get into and not the Turquand rule. The Turquand rule was suppose to keep an outsiders duty to inquire into the affairs of a company within sensible bounds, but if the ossification or disobedience with an internal requirement can be ascertain from the companys public documents, the doctrine of apocalypse and the doctrine of constructive stigmatize allow for apply.If it is an internal requirement that a certain act should be okay by special firmness, the Turquand rule volition thence not apply in relation to that special act, since a special resolution is registered with Companies hearthstone (in the United Kingdom), and is deemed to be public information. indebtedness In slope law, a corporation can only act through its employees and agents so it is necessary to set in which circumstances the law of agency or vicarious financial obligation go forth apply to hold the corporation liable in tort for the frauds of its directors or cured officeholders.If indebtedness for the grouchy tort requires a state of mind, then to be liable, the director or senior officer must give way that state of mind and it must be attributed to the company. In pinnacle orbiculate bullion circumspection Asia special(a) v. Securities charge 1995 2 AC 500, two employees of the company, acting within the area of their authority but unvalued to the direct ors, used company funds to pack some shares. The question was whether the company knew, or ought to deem cognise that it had acquired those shares.The buns Council held that it did. Whether by virtue of their actual or ostensible authority as agents acting within their authority (see Lloyd v Grace, smith Co. 1912 AC 716) or as employees acting in the course of their economic consumption (see Armagas confine v Mundogas S. A. 1986 1 AC 717), their acts and omissions and their noesis could be attributed to the company, and this could give rise to indebtedness as spliff tortfeasors where the directors have pretended duty on their own behalf and not just on behalf of the company.So if a director or officer is expressly authorize to make representations of a particular mark on behalf of the company, and fraudulently makes a representation of that class to a Third companionship causing loss, the company forget be liable even though the particular representation was an out-o f-the-way way of doing what he was classical to do. The extent of authority is a question of fact and is significantly more than the fact of an exercising which gave the employee the opportunity to carry out the fraud.