cryptonym - definition and examples of cryptonym

cryptonym - definition and examples of cryptonym Definition A cryptonym is a word or name thats secretly used to refer to a particular person, place, activity, or thing; a code word or name. A well-known example is Operation Overlord, the cryptonym  for the Allied invasion of German-occupied western Europe during World War II. The term cryptonym is derived from two Greek words meaning hidden and name. See Examples and Observations below. Also see: Name That -nym: A Brief Introduction to Words and NamesPseudonym Examples and Observations Cryptonyms are  often temporary, are known to only a select group of people, and are usually of unrelated or at best covert meaning. Some  cryptonyms are  simply combinations of letters and figures.(Adrian Room,  An Alphabetical Guide to the Language of Name Studies. Scarecrow, 1996)Reinhard was the cryptonym for the German plan to exterminate the Jews of Poland.(MichaÅ‚ Grynberg, Words to Outlive Us: Voices From the Warsaw Ghetto. Macmillan, 2002) White House CryptonymsThe Oval Offices next occupant opted for this moniker [Renegade] after being presented with a list of names beginning with the letter R. As custom dictates, the rest of his familys code names will be alliterative: wife Michelle is known as Renaissance; daughters Malia and Sasha are Radiance and Rosebud, respectively.(Renegade: President-elect Barack Obama. Time magazine, November 2008) CIA CryptonymsThe true identities of  cryptonyms are  among the most precious secrets of the Central Intelligence Agenc y (CIA).- The CIA often used multiple cryptonyms for the same entity to strengthen operational security and maintain compartmentalization of the information.In the CIA nomenclature, cryptonyms always appear in capital letters. The first two letters were used for cryptographic security and were based on factors such as the geography or type of operation.  The rest of  the cryptonym  was a word selected randomly from a dictionary, in principle with no particular relation to the place or person  the cryptonym  was supposed to mask. However, it is not difficult to imagine tongue-in cheek CIA officers picking words like wahoo for Albanian, drink for Greece, credo for Rome, gypsy for communist, roach for Yugoslavia, crown for United Kingdom, steel for Soviet Union, and metal for Washington, D.C.(Albert Lulushi,  Operation Valuable Fiend: The CIAs First Paramilitary Strike Against the Iron Curtain. Arcade, 2014)- Vladimir I. Vetrovwho had the cryptonym FAREWELLreported to Weste rn intelligence services that the Soviets had placed bugs on the printers used by the French intelligence service for communications.(Ronald Kessler, Inside the CIA. Simon Schuster, 1992)- The longtime personal physician of the Castros mother and some of her daughters was a reporting source. Bernardo Milanes, known to  the Agency by  his cryptonym  AMCROAK, was recruited in December 1963 in Madrid. At the time he and others were plotting an assassination attempt against [Fidel] Castro.(Brian Latell,  Castros Secrets: The CIA and Cubas Intelligence Machine. Palgrave Macmillan, 2012)-  The Farm was known officially by the  cryptonym  ISOLATION. The names of places and operations were a special language in the Agency.(Don DeLillo,  Libra. Viking, 1988)-  Flower was the overall top-secret code-name designator given to anti-Qaddafi operations and plans. Only about two dozen officials, including the President and Casey, were given access.Under Flower, Tulip was the code name for a CIA covert operation designed to topple Qaddafi by supporting anti-Qaddafi exile movements.(Bob Woodward, Veil: The Secret Wars of the CIA, 1981-1987. Simon and Schuster, 2005) Pronunciation: KRIP-te-nim

Schedule Instagram Posts Along With Everything Else - CoSchedule

Schedule Instagram Posts Along With Everything Else With its 500 million active users, Instagram can help you reach your audience in a social network they already love. But†¦ the in-the-moment nature of posting to Instagram makes it difficult for marketers to strategically capture the opportunity. With for Instagram, the newest feature in your favorite marketing calendar, you’ll go from spontaneous to strategic.  That  means you’ll quit forgetting to post on Instagram! Now you’ll post to Instagram with a few easy clicks, schedule your Instagram content where you plan everything else, and collaborate with your team better than ever. Start scheduling to  Instagram with now! Finally! Plan all of your content + social media in one place! Including #Instagram!Quit Forgetting To Post On Instagram Already! Get notified on your phone when it’s time to post  so you don’t miss out on consistently reaching your followers. Begin by scheduling  Instagram posts in your  calendar where you organize everything else. Then rock  the all-new for  Instagram app on your mobile device, available on the Apple App Store and Google Play Store. Quit forgetting to post on #Instagram with !Youll receive push notification reminders when youve scheduled  messages for  Instagram! Your reminders come with a beautiful  preview, so youll know exactly what youre posting at a glance. Now youll  proactively schedule your Instagram content so you quit forgetting to post on Instagram! Post To Instagram With A Few Easy Clicks Eliminate copying and pasting your messages by using the tool designed to do it for you! Get content from your calendar into Instagram with an easier process than ever before. The for  Instagram mobile app not only reminds you when its time to post. It gives you the content  youve planned so you can share to Instagram with a few easy clicks. You can also post, reschedule, or delete missed messages in seconds. 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Conventional Vs. True Beauty Movie Review Example | Topics and Well Written Essays - 1750 words

Conventional Vs. True Beauty - Movie Review Example This means the thin model wearing the clothes and makeup that the gatekeepers of fashion say are beautiful, displayed on TV and in other forms of mass media. On the other hand, there is the idea of true beauty, which reflects the existence of an absolute set of standards for what is beautiful, separate from what the masses say is beautiful, and separate from the social conventions of any given period in history. True beauty may or may not jive with what the conventional notions of beauty are at any given time, but one understands that there are eternal qualities associated with true beauty, that stand the test of time. This true beauty requires a different kind of vision for sure than what people ordinarily possess in the movie 'American Beauty'. The implicit message in the movie is that the perception of true beauty requires a certain kind of intelligence, and a certain kind of knowing and vision that is also more elevated and removed from the conventional. This paper asserts that a key take from the movie is that , one can say that far from refining and elevating aesthetic sensibilities, conforming with the rules of society deadens rather than sharpens that vision that allows for the glimpse of true beauty. In the end, with Lester dead, and all of the pressures of family and society removed, with Lester free, he is able to find out what beauty really is (IMDb.com; Smith). II. Discussion From Lester's life and the life of his family we see how the film portrays conformism as a dead end that leads to the deadening of life and the sapping away of that vital force that forges relationships and bonds people. Conformism saps away joy and the fun out of life. This seems to be the initial message of the movie. In it too is lost the conception of beauty that makes life at least bearable and worth living. Ricky, young and full of life, seems to be blessed in this regard, that not having to conform, he is free to pursue joy, and to see beauty. On the other end of the sp ectrum are repressed lives. Not everything is as it seems. Angela, the young girl who is outwardly beautiful, in herself is inwardly insecure and unsure of how to go about life. She herself lacks a certain vision and certainty, not having experienced any kind of direct vision of joy or beauty that would have pacified her and put her on a more solid footing. This is evident in the way she ended up wanting to have sex with Lester, even though in the end too it became clear that she did not know what she wanted. She was just a confused kid. Carolyn too had drifted from a more carefree and fun life into the life of a career woman obsessed with mantras of material success, all the while missing out on the happiness and beauty that could be had by simply being in the moment and enjoying the time with her daughter Jane. Jane in her way was also suffering from this joy-deprived and loved-deprived environment, and who wouldn't? Her parents were living dysfunctional lives devoid of the beauty and the joy that comes from being close to something more vital. Having lost that, and themselves, they had no joy nor vision of beauty to impart on their poor daughter. In Col. Fitts' lonely life too, there is that same missing element, and where people are less true to themselves, and are bound by conventions that blind them from a truer and more fulfilling life, what happens is that the people around them suffer. Col. Fitts' wife had to bear the emotional and psychological trauma

Research Proposal Essay Example | Topics and Well Written Essays - 1500 words - 3

Research Proposal - Essay Example All the countries round the world are concerned about the carbon footprints and its effects. The developed countries have already taken various measures and adopted policies under the Kyoto Protocol. The other developing countries are taking steps towards reduction of greenhouse effect but none of them have accepted the international legal bindings to do so (Ackerstein, and Katherine, 2007; Ginsburg, and Bloom, 2004). This study would be focusing on green marketing, which would not only include the corporate strategies of the multinationals towards manufacturing and selling their products in an eco-friendly manner, but also analyze the other functions of the companies, which also depict their eco-friendly initiatives such as adoption of green accounting, and eco-friendly promotional strategies. Few well-known multinational companies would be chosen to discuss their green strategic framework within which environment friendly production, operation, promotion, supply chain, and even fin ancial practices would be comprehensively discussed. 1.2 Research Objectives The aim of this research study is to scrutinize the eco-friendly marketing strategies that are adopted by the multinational companies. The major objectives would be to recognize the green or eco-friendly strategic framework of few multinational companies, and evaluate the benefits that these companies enjoy for such an initiative. 1.3 Research Questions The research questions have been formulated in line with the aims and objectives of this research study. They are stated below: Q1: How does the multinational companies segment their target market on the basis of customers; preference for green marketing or products? Q2: What prerequisites are considered for selecting green marketing strategies in these companies? Q3: How does the marketing mix change when the company chooses to shift towards green marketing? Q4: What benefits or advantages companies enjoys after adopting eco-friendly strategies? Q5: How doe s green accounting benefit multinational companies? Chapter II: LITERATURE REVIEW Literature review assist in evaluation of scientific theories and literature that has been identified through research. These are information available through existing database on green marketing and related strategies adopted by the companies in the past and also during the present business environment. These information or data in turn also assist in laying foundation for further research studies. Ginsberg and Bloom (2004), stated in order to proceed with conducting a research on the stated research question, firstly, a rich understanding on green marketing and the preferences of the customers for it, has to be gained. Various research studies show that in order to identify the target market in this case, there is requirement for customers’ tendency towards green marketing (Fuller, 1999; Coddington, 1993). There is no fixed green marketing strategy on the basis of which all the companies desi gn their strategic framework. It depends on the aims, objectives, mission, and vision of the company (Polonsky and Charter, 1999). The consumption of energy and change in climate are closely related. Multinationals

Company Law Essay Example for Free

Company Law Essay It has been a long established principle of Company Law that the corporate personality is a separate legal entity distinct from its members. (Salomon v Salomon Co. (1897) However, there are circumstances in which the courts might find it appropriate to dispense with this principle and ignore the principle of separate corporate personality by ‘lifting the corporate veil’ so to speak. Yet, the courts have not been as prepared to pierce the veil of the corporation as they have been to protect it. Salomon v Salomon Co. gave birth to the separate legal personality of the corporation. In this case, Mr. Salomon, who was conducting business as a leather merchant formed a company which he called Salomon Co. Ltd in 1892. His shares were distributed among his wife and children, each of whom held one share each, for Mr. Salomon. This was necessary at the time because the law requires that the company consist of at least seven shareholders. It is also important to note that Mr. Salomon was the managing director of the company. (1897) Salomon Co. Ltd. purchased the leather business which Mr. Salomon estimated to be worth 39,000 pounds. Mr. Salomon based this valuation on his view that the business was bound to be a success rather than the actual value at the time of purchase. The funds were paid as follows: 1) 10,000 pounds worth of debenture stocks leaving a charge over all of the assets of the company and 2) 20,000 pounds in 1 pound shares and 9,000 pounds in cash. At this juncture, Mr. Salomon paid off all of the creditors of the business. As a result, Mr. Salomon held 20,001 shares in Salomon Co. Ltd. and his wife and kids held the remaining 6 shares. Also, as a result of the debenture, Mr. Salomon was a secured creditor of the company. (Salomon Salomon Co. Ltd. 1897) The leather business floundered and within a year Mr. Salomon ended up selling all of his debentures so as to salvage the business. This did not work out the way Mr. Salomon planned and the company was unable to pay its debts and consequently went into insolvent liquidation. The company’s liquidator alleged that Salomon Co. Ltd. was nothing but a sham serving as an agent for Mr. Salomon. Therefore Mr. Salomon should be held personally liable for the company’s debts. The Court of Appeal agreed with this finding and held that a company’s shareholders were required to be a bona fide organization with the intention of going into business rather than just for the purpose of meeting the statutory provisions for the number of shareholders. (Salomon Salomon Co. Ltd. 1897) The House of Lords reversed the decision of the Court of Appeal holding as follows:- 1) It was not relevant for the purposes of determining the genuineness of a company’s formation that some shareholders were holding shares for the purpose of forming the company pursuant to relevant statutory provisions. In fact, it was perfectly legal for the procedure for registration to be used by a person for the purpose of conducting a one-man business enterprise. 2) Moreover, a company that was formed pursuant to the regulations provided in the Companies Acts is a separate legal person and was not therefore an agent or trustee for the controller. Therefore the company’s debts were its own and were not the debts of its members. The liability of the members would be limited in proportion to the shares that they each held. (Salomon Salomon Co.  Ltd. 1897) Salomon v Salomon Co. Ltd. has stood up well against the test of time. In Macaura v Northern Assurance Co. [1925] AC 619 the House of Lords held that in the same way that the company’s liabilities are the company’s and the shareholders, the assets are also the company’s rather than the shareholders. (Macaura v Northern Assurance Co. [1925]) In Barings Plc (In Liquidation v Coopers Lybrand (No. 4) [2002] 2 BCLC 364 a parent company suffered a loss as a consequence of the loss incurred by one of its subsidiaries. It was held that the subsidiary was the proper party to commence an action in respect of the loss. This rationale followed the rationale in Salomon v Salomon Co. Vis-a-vis the loss was that of the subsidiary and was therefore that company’s liability rather than the parent company’s liability. The subsidiary was a separate legal entity from its parent company. (2002 p 364) This ruling was closely followed in both Gile v Rhind [2003] as well as Shaker v Al-Bedrawi {2003]. In Re Southard Co Ltd Templeton [1979] 3 ALL ER 556 at 565 LJ said that A parent company may spawn a number of subsidiary companies, all controlled directly or indirectly by shareholders of the parent company. If one of the subsidiary companies, to change the metaphor, turns out to be the runt of the litter and declines into insolvency to the dismay of its creditors, the parent company and other subsidiary companies prosper to the joy of the shareholders without any liability for the debts of the insolvent subsidiary. ’(Re Southard Co Ltd Templeton [1979] 3 ALL ER 556 at 565) Lee v Lee’s Air Farming, a New Zealand case, is another good example of the court’s reluctance to pierce the corporate veil. In this case, in 1954 Lee started a company called Lee’s Air Farming Limited. Lee owned all of the shares of the company and was the company’s Governing Director. In addition, Lee worked for the company as its chief pilot. He died in a plane crash while flying the company plane and his wife tried to claim damages via the company’s insurance scheme under the Workers’ Compensation Act. (Lee v Lee’s Air Farming [1961]) The New Zealand Court of Appeal rejected the widow’s claim that Lee was a worker within the meaning of the Workers’ Compensation Act and the case went to the Privy Council. The Privy Council found that Lee’s Air Farming Limited was an entirely different legal entity from Lee and legal relationships between the two were perfectly permissible. Moreover, the Privy Council found that Lee, as Governing Director could indeed give order to himself in his capacity as chief pilot. Therefore a master/servant relationship did exist between the two and Lee was in that respect a ‘worker’ within the meaning of the Act. Indeed, as seen in the cases discussed above the courts aggressively protect the separate legal identity of the corporate citizen. However, there have been legislative intervention whereby specific situations have been defined where it would be appropriate to pierce the corporate veil. For example Sections 213 and 214 of the Insolvency Acts make it possible for the lifting of the corporate veil in cases of fraud and wrongful dealing. (The Insolvency Act 1986 Sections 213 and 214) Section 213 is often referred to as the ‘fraudulent trading’ provision. (Dignam Lowry 2006 Ch. ) This section arises if the court is satisfied that company carried on any of its business ventures with the intention of defrauding the company’s creditors or the creditors of anyone else. Section 213 will also arise if the court finds that the company acted for any other fraudulent reason and persons involved in those fraudulent ventures can be found liable for the company’s debts. In order to satisfy the court of the existence of fraud Section 213 requires proof of ‘actual dishonesty, involving, according to current notions of fair trading among commercial men, real moral blame’. The . Section 214 does not impose as onerous a burden or standard as does Section 213. It is not necessary to prove an intention to defraud. Section 214 applies to the period just before a company begins winding up procedures. Section 214 arises when the court is satisfied that the directors either knew or ought to have known that the company was becoming insolvent and continued to trade anyway. The director can be liable for the company’s debts in these instances. (The Insolvency Act 1986 Section 214) Section 227 of the Companies Act 1985 makes further provision for lifting the veil of the corporation. This section arises in instances where it is necessary to require the production of group members or group accounts to verify whether or not a subsidiary’s financial activity is that of the holding company. (Companies Act 1985 Section 227) The judiciary has also demonstrated a will to lift the corporate veil whenever the ends of justice desire it to be done. The circumstances in which the court will ignore the corporate veil are ill-defined and the impression is that these circumstances are developed on a case by case basis. Professor Gower said that ‘challenges to the doctrines of separate legal personality and limited liability at common law tend to raise more fundamental challenges to these doctrines, because they are formulated on the basis of general reasons for not applying them, such as fraud, the company being a sham or facade, that the company is the agent of the shareholder, that the companies are part of a single economic unit or even that the interests of justice require this result. ’ (Davies 2003 p 184) Adams v Cape Industries Plc [1990] Ch 433 is viewed by Gower and Davies as the leading case on the exceptions to the corporate veil. In the case the Court of Appeal said that it is not satisfied that the ‘court is entitled to lift the corporate veil as against a defendant company which is a member of a corporate group’ merely on the grounds that the company was used to shield a member of that group from future liabilities of the company. As a matter of fact, the Court of Appeal maintained that this was a legal right by adding ‘whether or not this is desirable, the right to use a corporate structure in this manner is inherent in our corporate law. ’(Adams v Cape Industries Plc [1990] Ch 433) The courts tend to be rather inconsistent with its position on the grounds upon which it will displace the laws protecting the corporate veil. While Adams v Cape Industries Plc was very strict in its position in favor of safeguarding the corporate veil, the House of Lords was rather liberal in DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852. In the latter case Lord Denning speaking of a parent company and its subsidiary holdings said, ‘these subsidiaries are bound hand and foot to the parent company and must do just what the parent company says’. He went on to say ‘this group is virtually the same as a partnership in which all the three companies are partners. They should not be treated separately so as to be defeated on a technical point’. (DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852) It wasn’t long before the courts departed from the position taken by Lord Denning. Woolfson v Strathclyde R. C [1978] SLT 159 the House of Lords took issue with Denning’s view on the nature of holding companies and the groups under them. The Lords maintained that the corporate veil would not be displaced unless it was shown that the company was a facade. (Woolfson v Strathclyde R. C [1978] SLT 159) In Trustor AB v Smallbone (No. 2) [2001] 1 WLR 1177 the court was adamant that the corporate veil would only be lifted in three circumstances. They were, 1) if the court was satisfied on the evidence that the company was a mere sham or facade, 2) the company itself was involved in some impropriety or 3) where the interest of justice required it. (Trustor AB v Smallbone (No. ) [2001] 1 WLR 1177) Earlier cases identified appropriate circumstances where the court might find that a company was indeed a facade. In Gilford Motor Company Ltd. v Horne [1933] Ch 985 the court found that the company was a facade. In this case an employee bound by a covenant not to solicit the business of his employers, left his employment and set up a company which he used to breach the covenant. The employee argued that while he was bound by the covenant, the company was not. (Gilford Motor Company Ltd. v Horne [1933] Ch 985) In another case the defendant signed an estate contract with the plaintiff for the sale of realty to him. The defendant changed his mind and formed a company, transferring the realty to the company. He claimed that he was no longer the owner of realty and therefore no bound to the terms of the estate contract. The court found that the company was a mere facade for the defendant and he was ordered to sell the realty as per the estate contract. (Jones v Lipman [1962] 1 WLR 832) The Court of Appeal identified three instances in which it would be appropriate for the corporate veil to be lifted. The court said, ‘save in cases which turn on the wording of particular statutes or contracts, the court is not free to disregard the principle of Salomon v A. Salomon Co Ltd [1897] AC 22 merely because it considers that justice so requires. Our law, for better or worse, recognises the creation of subsidiary companies, which though in one sense the creatures of their parent companies, will nevertheless under the general law fall to be treated as separate legal entities with all the rights and liabilities which would normally attach to separate legal entities. (Adams v Cape Industries Plc [1990] Ch 433) Adams has effectively narrowed the circumstances in which the courts will intervene and lift the corporate veil. This is unfortunate since changing times together with the complex development of both the corporate structure and company law, the Salomon v Salomon Co. rule is in reality perhaps out of place today. (Gallagher Zeigler 1990) Although there have been times when the courts have shifted away from this ruling it remains the poster child for the criteria to be met when determining whether or not to life the veil of the corporation. The prevailing attitude is to safeguard against lifting the corporate veil. Question 2b) The doctrine of majority rule has been a long established principle of Company Law within the English Legal System and makes it difficult for minority shareholders to take legal action in respect of majority shareholder improprieties. That said, Rebecca as a minority shareholder is protected to a limited extent by the provisions of Section 459(1) of the Companies Act 1985. The development of the common law doctrine of majority rule was enunciated in Foss v Harbottle. The rationale behind Foss was that any difficulties within the structure of the company ought to be dealt in the general meetings of the company by ratification by the majority shareholders. The prevailing attitude of the courts was one of nonintervention. It would only step in if it was for the purpose of dissolving the business. The facts of Foss v Harbottle reveal that in 1835 a company, Victoria Park Company purchased land in the Manchester primarily for residential purposes. Thomas Harbottle, a director of Victoria Park Company had purchased the property and resold it to Victoria Park Company who eventually developed the property. Richard Foss and Edward Turton, shareholders of Victoria Park Company brought an action against Thomas Harbottle alleging breach of fiduciary duties in that he sold the property to the company at an inflated price. Turton and Foss also claimed that, acting outside of their powers as directors the directors had burrowed funds in the name of the company. The court held that plaintiffs had no locus standi, and that they were required to have obtained the company’s approval to commence legal action. This approval is properly obtained by virtue of a general meeting. In Foss v Harbottle, Wigram VC explained that ‘the corporation should sue in its own name and in its corporate character, or in the name of someone whom the law has appointed to be its representative. ’ It would therefore only be permissible in exceptional cases of serious abuse that minority shareholders could sue the company as a defendant. This explains the relatively strict approach adopted by the courts in deciding representative forms of actions in the guise of minority shareholder oppression. Jenkins LJ in Edwards v Halliwell explained the justification of the majority rule doctrine in Foss v Harbottle when he said ‘the rule in Foss v Harbottle, as I understand it, comes to no more than this. First, the proper plaintiff in an action in respect of a wrong alleged to be done to a company or association of persons is prima facie the company or the association of persons itself. Secondly, where the alleged wrong is a transaction which might be made binding on the company or association and on all its members by a simple majority of the members, no individual member of the company is allowed to maintain an action in respect of that matter for the simple reason that, if a mere majority of the members of the company or association is in favour of what has been done, then cadit quaestio’. This is where Section 459(1) of the Companies Act 1985 is important to Rebecca in respect of what appears to be ‘insider dealing’, mismanagement and perhaps even fraud. Section 459(1) of the Companies Act 1985 provides as follows:- Any member of a company may apply to the Court by petition for an order under this section on the grounds that the affairs of the company are being or have been conducted in a manner which is unfairly prejudicial to some part of the members (including at least himself) or that any actual or proposed act of omission of the company (including an act of omission on its behalf) is or would be so prejudicial. ’ David Partington, notes rather bluntly, that the discretion contained in Section 459 is very broad and perhaps infinite. ‘The breadth of s. 459 means that there must be an infinite range of situations in which it may be employed. Partington goes on to say that the courts have been extremely flexible in their application of the term ‘unfairly prejudicial. ’ The test for ascertaining whether or not conduct is ‘unfairly prejudicial’ is an objective test rather than a subjective one. The defendant’s motives are often times not of paramount importance to the courts. In Re Bovey Hotel Ventures Ltd. it was held that ‘the test . is whether a reasonable bystander observing the consequences of (the defendants) conduct would regard it as having unfairly prejudiced the petitioners interests. The remedies are no longer limited to ‘winding up’ procedures and this of course explains the wider discretion for commencing an action by minority shareholders. Among the remedies available are, rectification, injunctive or ‘buyout relief. ’ By virtue of ‘buyout’ relief, the court makes an order requiring the company to purchase the shares of the petitioning minority shareholders. This is perhaps the best course for Rebecca to follow. She might not wish to remain a part of a company in which she has all but lost faith in. Re Sam Weller Sons Ltd. rovides some useful guidance as to the kind of conduct that might amount to ‘unfairly prejudicial’ within the meaning of the 1985 Act as amended. For example, failing to pay a dividend in the absence of a sound commercial explanation for such a failure amounts to ‘unfairly prejudicial’ conduct’. In Sam Weller’s case the dividend had already been covered 14 times with the company declaring it for the past consecutive 37 years. In interlocutory proceedings, Gibson LJ denied the company’s application to strike out the petitioner’s claim noting that the company had a case to answer.

The Need for the Expulsion of All Illegal Aliens Essay -- Illegal Immi

American taxpayers spend billions of dollars annually on illegal immigrants (Camarota). Illegal immigrants pose many risks to the American public. These risks range from financial distress to terrorism. Therefore, the United States government should deport all illegal immigrants from its borders. Most importantly, illegal immigrants drain the American economy. The many costs of illegal immigration create an unmanageable debt for the American public. For example, legal Americans pay taxes to the government that help pay for various government programs and projects; however, illegal aliens in America typically do not pay taxes to the government but still use these programs. The costs of illegal alien’s use of these programs annually amounts to â€Å"more than 26.3 billion dollars† (Camarota), a debt that seriously hampers the United State’s economy’s ability to advance in the global market place. Although proponents of illegal immigration argue that amnesty of all illegal aliens will balance these expenses, studies have shown that illegal immigrants â€Å"tend to make very modest tax payments† (Camarota) once granted amnesty. However, the fiscal burden illegal immigrants bring originates itself from their home countries, mainly Mexico and Cen tral America, where â€Å"at least three million† (Cosman) illegal aliens come from annually. Problems such as the lack of an education that many illegal immigrants have affected the United States economy by taking away jobs from poorly educated legal Americans. Due to the fact that â€Å"fifty-seven percent of illegal immigrants† (Camarota) lack a high school education, they perform undesirable tasks for little money (Camarota). These jobs taken from ill educated Americans leave these legal citizens unemployed ... ... Viewpoints Critical Thinking. Gale. Houston High School. Web. 14 Nov. 2010. Camarota, Steven. â€Å"Immigrants Burden Social Services.† Opposing Viewpoints: Immigration. Ed. Susan Musser. Detroit: Greenhaven Press, 2009. Opposing Viewpoints Resource Center. Gale. Houston High School. Web. 15 Nov. 2010. Cosman, Madeline. â€Å"Illegal Immigrants Threaten U.S. Health Care.† At Issue: What Rights Should Illegal Immigrants Have?. Ed. Lori Newman. Detroit: Greenhaven Press, 2006. Opposing Viewpoints Resource Center. Gale. Houston High School. Web. 14 Nov. 2010. Kirkwood, R. â€Å"Illegal Immigrants Are Dangerous for America.† Contemporary Issues Companion: Illegal immigration. Ed. Paul Hina. Detroit: Greenhaven Press, 2008. Opposing Viewpoints Resource Center. Gale. Houston High school. Web. 14 Nov. 2010. The Need for the Expulsion of All Illegal Aliens Essay -- Illegal Immi American taxpayers spend billions of dollars annually on illegal immigrants (Camarota). Illegal immigrants pose many risks to the American public. These risks range from financial distress to terrorism. Therefore, the United States government should deport all illegal immigrants from its borders. Most importantly, illegal immigrants drain the American economy. The many costs of illegal immigration create an unmanageable debt for the American public. For example, legal Americans pay taxes to the government that help pay for various government programs and projects; however, illegal aliens in America typically do not pay taxes to the government but still use these programs. The costs of illegal alien’s use of these programs annually amounts to â€Å"more than 26.3 billion dollars† (Camarota), a debt that seriously hampers the United State’s economy’s ability to advance in the global market place. Although proponents of illegal immigration argue that amnesty of all illegal aliens will balance these expenses, studies have shown that illegal immigrants â€Å"tend to make very modest tax payments† (Camarota) once granted amnesty. However, the fiscal burden illegal immigrants bring originates itself from their home countries, mainly Mexico and Cen tral America, where â€Å"at least three million† (Cosman) illegal aliens come from annually. Problems such as the lack of an education that many illegal immigrants have affected the United States economy by taking away jobs from poorly educated legal Americans. Due to the fact that â€Å"fifty-seven percent of illegal immigrants† (Camarota) lack a high school education, they perform undesirable tasks for little money (Camarota). These jobs taken from ill educated Americans leave these legal citizens unemployed ... ... Viewpoints Critical Thinking. Gale. Houston High School. Web. 14 Nov. 2010. Camarota, Steven. â€Å"Immigrants Burden Social Services.† Opposing Viewpoints: Immigration. Ed. Susan Musser. Detroit: Greenhaven Press, 2009. Opposing Viewpoints Resource Center. Gale. Houston High School. Web. 15 Nov. 2010. Cosman, Madeline. â€Å"Illegal Immigrants Threaten U.S. Health Care.† At Issue: What Rights Should Illegal Immigrants Have?. Ed. Lori Newman. Detroit: Greenhaven Press, 2006. Opposing Viewpoints Resource Center. Gale. Houston High School. Web. 14 Nov. 2010. Kirkwood, R. â€Å"Illegal Immigrants Are Dangerous for America.† Contemporary Issues Companion: Illegal immigration. Ed. Paul Hina. Detroit: Greenhaven Press, 2008. Opposing Viewpoints Resource Center. Gale. Houston High school. Web. 14 Nov. 2010.

Identification of Key Problems in Panera Bread Essay

Synopsis of the situation Panera Bread is a fast food company that aims to provide a quality product. They make and sell specialty breads, salads and soups. They started strong in 1981, and currently have over 1800 stores with company managed and operated as well as franchised locations (Panera Bread, 2012). The company jumped into the frontline of restaurant chains and has gained, with great effort, a good number of customers. If you go to any one of their restaurant locations you will find similar services in each and every store. There is always a choice to dine indoors or outdoors, a fire place which aims to make you feel at home while reading your paper or drinking you coffee in the morning, especially in the winter months. They are also known for their services of free refills on coffee, tea or fountain drinks as well as complimentary water with slices of lemons. There is also free access to the internet through Wi-Fi, making Panera locations a great study environment for college students. It is also well equipped with screens that display the  product they offer which adds another great feature to their appealing design. Although they have been growing so fast, they still maintain a competitive place in the market. This is all due to their great design, dining atmosphere, fresh products, reward cards, accessible study and work environment, and efficient services. The experience that a customer is provided with at Panera is unique in the fast food industry. All of their competitors, such as McDonalds and Burger King for instance, only offer a fast product that may be cheaper in monetary price than Panera, but at the expense of health and sometimes quality. Panera Bread combined all of their competitor weaknesses and now provide fast food services, with quality, healthy products to millions of customers and this is the secret to the business’s success (Panera, 2014a). Key issues For us to identify the key issues at Panera Bread, we have to look at them from a competitor stand point and compare them to what others have. It is necessary to first examine Panera Bread. Panera Breads’ focus is on small neighborhood environments and will rarely be found in a major or large city. When lunch time comes and we start to think about what and where we should go for lunch, then Panera Bread is one of the options. After finding one and driving there, you will be shocked with how busy the place is and will doubt that you will have time in the one hour lunch to wait on line to place an order and pay around 11-13 dollars for a quality meal. Then, due to the large number of customers, they usually give a machine that vibrates and flashes when your order is ready. By that time, you should run to your car and eat your meal while driving because this meal might cost you your job, on top of what you just paid. Even if you have time and decided to dine in, there will be no place to sit because most tables have been occupied by others and will probably resemble a library, since most people are sitting with their laptops open or reading a book. A regular value meal costs a minimum of 11-13 dollars. This is their â€Å"You Pick two† value meal, which includes two items of your choice; your choice combinations of sandwich, pasta, and soups, which all come with a small  piece of French bread (Panera, 2014c). The same amount of money would probably feed 2 people at McDonalds with desserts, two at Quiznos, and possibly one at Applebee’s. Being identified as a fast food chain, just like McDonalds and Quiznos, Panera Bread involves a longer wait time. Finding a location, then parking your car and walking in to just wait on a huge line to make an order and then wait for your meal to be ready takes time. Even though they are efficient at their job, it still is not as fast as the other fast food competitors. Panera Bread is very attractive environment for someone looking to spend the day especially with their unlimited free refills of drinks both cold and hot. A college student might sit there from sunrise to sunset studying, just like what I am doing right now, working on my assignments and leaving no place for a family or group to sit. Identification of one key problem and the opportunity The problem: College students mostly are sitting on most of the tables without any space left for the neighborhood families or the other short term customers. In some way Panera has replaced the libraries for a lot of students due to their free drinks, as mentioned earlier. Panera is proud of their achievement of having established these types of customers. As long as they are not interfering with the other type of customer, then it is a great idea asset. However, in reality, when most of who are sitting and occupying the tables are students and almost no other type of customer, then the business operation will be compromised. When you buy a meal, you need to be able to sit to consume it and this is not possible when everything is occupied, which creates unhappy customers who are less likely to return. The opportunity: It is possible to be able to accommodate both types of customers by making parameters to serve the needs of both parties of these types of populations. What attracts students is the free Wi-Fi that Panera provides and by intelligently controlling this feature, they can actually control the student population in the establishment and create a balance  between these two populations by serving both of their needs. The solution made through Wi-Fi control is an opportunity after identifying the problem that Panera is having. The solution involves shutting down the Wi-Fi service during lunch peak hours. At the beginning students will probably relocate and then they will most likely adapt to the change and come right back since they know they cannot get what they get at Panera at any other place. So the new lunch time hours without free Wi-Fi would be from 11am-2pm. It is important for Panera not to scare their current student population away, because these are already established customers. When it is not peak hours and the place is filled with these students, this helps to create a relaxing and a very attractive dining that is only linked with Panera locations. This opportunity and approach will serve both of these customer populations and help build a healthy relationship with both types. This is better than just targeting one population over the other and makes it possible for both to be happy and have a good experience at Panera. Alternative solutions to the one key problem There are some other available strategies to deal with the issue of too much student population occupying the tables at Panera. A fee for the Wi-Fi could be charged. This would, however, make them less likely to choose Panera as their study spot. This solution will not only decrease the number of student occupants, but it will also have an impact on the environment that Panera created in their locations as being known for their special dining experience and this will hurt their reputation in the long run as a friendly and welcoming restaurant. Many of the Panera locations already have a limit of half an hour on Wi-Fi in lunch peak hours, which has left some unhappy customers (Panera, 2014b). These customers argue that Panera is advertising free Wi-Fi, but not providing the service. In reality, thirty minutes is not enough for anything. Also, Panera bread is well known as a casual place for meetings for some businesses and workers and limiting the Wi-Fi to 30 minutes is  limiting the ability for customers to treat the restaurant as a work environment. This could easily transform Panera from a friendly experience to an unfriendly one (Graham, 2012). This type of control of Wi-Fi will not solve the problem in reality. Thirty minutes of Wi-Fi is not enough and it will only make people run away and be reluctant to bring their computers. Another potential solution to this problem would be to enforce table sharing by students. Instead of one student spreading his or her papers all over a big table, he or she could sit comfortably with having someone else sit and share the table. This will make more seats available for usage by both populations of students and regular everyday customers. Another possible solution is to identify the number of regular customers that the restaurant gets on a daily basis and know how many table is needed to serve them appropriately. Or they may just chose a number of tables that is only selected for students to sit in and limit their access to other tables. This is done by placing flags on the tables or by just disabling the electric outlet on these tables, since most students require an electric outlet to access their computers. Selected solution and why it was chosen Panera Bread should accurately identify the amount of tables needed to accommodate all of the different populations of customers. After that, they should determine the number of tables needed to accommodate for students and the other customers who might remain seated for long periods of time using the free internet services. Then, they should mount a flag in the middle of these dedicated tables that says â€Å"Student Friendly. â€Å" This way, the student customers will respond better and not feel as if they are being chased out of the restaurant. This will also help maintain the environment and Panera’s image as a friendly and welcoming restaurant. As a matter of fact, the customers will show more loyalty to the business. When I go to Panera Bread myself, I notice how many student customers are sitting at the tables and the number is overwhelming. It is hard to only think about one consumer base and neglect the other, as both are important to the business. As a matter of fact, the student customers are actually  the one that gave Panera Bread its unique image. Some important questions that need to be answered include: What would a Panera manager do in a location where the number of student customers would interfere with the business of the short term customers, especially during peak hours? Regardless of the answer, whether that is to leave them alone, ask them to leave, or limit their internet use, there is actually no good permanent solution for the future success of Panera to be maintained. Recommendation(s) on how to implement the selected solution In order for the selected solution or change to be successful it has to be done smoothly without interrupting any of the current customers’ population. This is done by taking the necessary steps that would make the change as smoothly as possible. Also, this change has to happen at all of Panera’s locations. Since Panera keeps a record of a large number of customers through their reward cards, they should have access to their emails. They should start by sending emails to their customers informing them about the current change at least a month prior to the actual change. This announcement should also take place at all of their locations by posting signs and giving out fliers notifying customers to the new change. These fliers could be given with a customer’s receipt. The notification would have to explain what the change is and the reasons behind it. Panera has to clearly state that they are willing to accommodate both types of customers and be able to satisfy them at all levels without significantly affecting the environment of the business and trying to keep a balance between both types. If this is done, the change will be smooth and with just little effort it can effectively implement the change with the least amount of stress on the customers. When this is complete, the needs of both types of customers are met without significant interruptions. Most importantly, Panera will still be recognized as having respect for all of their customers without forcing them to new changes that they might not like. This will lead to effectively utilizing the tables for both types of customers. For students, sharing will be a possibility to a maximum number matching the number of chairs on each table as opposed to only one student sitting and unnecessarily occupying the  whole table. Summary Panera bread is a very successful business that was established a long time ago, with a great and unique environment that they created to suit customers of both types. They have some key issues that are still waiting to be solved but the main issue and the most important one is how to control the effect of student customers, who are utilizing the business tables as libraries, with keeping the balance of not hurting the regular everyday short-term-stay customers. For the problem to be solved, they have to find a solution that will serve both types of customers without significantly changing the current services that both get. One of the solutions would be to control the Wi-Fi access in a way that will serve the everyday short term customer and without significantly altering the access of Wi-Fi that is attracting the student consumer base and at the same time not compromise the business operation. The best possible solution involves limiting the number of tables that the student custom ers could use after identifying the number of tables needed to serve this purpose. References Panera (2014a). (n.d.). Our History. Our History. Retrieved July 14, 2014, from https://www.panerabread.com/en-us/company/about-panera/our-history.html Panera Bread. (2012, June 25). Nation’s Restaurant News, 46(13), 27. Retrieved from http://go.galegroup.com/ps/i.do?id=GALE%7CA295171410&v=2.1&u=lom_davenportc&it=r&p=ITOF&sw=w&asid=593729bfd26cc732941cbf2cefe738ed Panera (2014b). (n.d.). You’re connected to the Panera wi-fi network.. WiFi. Retrieved July 14, 2014, from https://www.panerabread.com/en-us/wifi.html Graham, J. (2012, May 17). Talking Tech: Customers clog Panera’s free Wi-Fi. USATODAY.COM. Retrieved July 15, 2014, from http://usatoday30.usatoday.com/tech/columnist/talkingtech/story/2012-05-16/panera-bread-wifi/55028144/1 Panera (2014c). (n.d.). You Pick Two. You Pick Two. Retrieved July 15, 2014, from https://www.panerabread.com/en-us/featured-menu/you-pick-two.html

Evolution as Fact & Theory` by Stephen Jay Gould Essay

This article talks about evolution as it relates to science and religion, philosophically. Gould talks about the fact that the arguments for creationism and evolution have not changed much, the science and religion are the same. He links the recent debates opposing the theory of evolution as the result of right wing politics that has taken hold of today’s society and political world. Gould states that today’s politicians talk about â€Å"scientific creationism â€Å"as if it is based in science. The creationists also jump on the term â€Å"theory â€Å"when used by evolutionist as if theory implies proof of guesswork, â€Å"only theory†. Gould explains the term â€Å"theory† as a string of ideas and facts. He provides examples of widely accepted theories in an attempt to debunk the creationist objection to theory. He provides similar explanation of the term â€Å"fact†. Darwin’s theory and detailed explanation are reviewed in the article, as this is central to today’s debate regarding creationism versus evolution. Gould’s view is that creationists attempt to argue against evolution is based entirely on arguing rhetoric. They use an argument style of Popper’s, which focuses on falsifying the evolutionist claims. Gould asserts that what the creationist lack is the ability to assure proves their own principles of creationism. Gould concludes that what keeps creationists firm in their belief system is dogma, not science. Thomas S. Kuhn – The Structure of Scientific Revolutions Like Gould, Kuhn takes on the debate between science and dogma. Kuhn is a scientist, clearly a believer in the scientific process though he takes pains in his article to examine the issues raised by proponents of dogma. Kuhn also believes that the opposition to evolution is based on poking holes in theories and finding loopholes, rather than convincing one with actual science. This article is largely focused on disproving dogma and supporting the scientific method. Kuhn’s overall belief as expressed in the article is that scientific theories always win arguments with dogma. This work includes a discussion on experience and perception and the relationship to presupposition. Kuhn reviews the process of scientific theory and discovery, and the philosophy behind the process.

Good Health Essays

Good Health Essays Good Health Essay Good Health Essay Physical appearance: A topic of little concern? In recent years our society has identified the importance of being healthy with being beautiful. Moreover, lifestyle, diet and exercise have been shown to have a profound impact on people’s health, both in the short term and over the course of a life time. In their pursuit of physical attractiveness, human beings think immediately of good health and shapeliness. For some, appearance is a superficial matter and a topic of little concern as they believe there are more important matters in their lives, whereas for others, the importance of one’s good appearance is – or should be – and important short-term goal. According to a survey report based on the matter of how important physical appearance is, it was confirmed that for a good number of people having a positive physical image is a topic not worthy of undue discussion. Although they are aware that being beautiful has an advantage professionally or socially, they can clearly distinguish their body image from their personal characteristics. : Thus, working out all day long in the gym and going on weight-reducing stressful diets have become the most important rule of what not to do. Accordingly, they define beauty as every quality that a person has, which not only includes physical qualities but inner qualities, too. This includes treating the body, mind and spirit as a whole. Physical attractiveness, then, is not a topic to be ignored but just a component to be taken into account. On the other hand, there is an opposite attitude towards one’s appearance. In comparison with the less attractive, some people seem obsessed about their body image since they believe that a person with good looks is liked more, is attributed more socially desirable characteristics and receives better jobs. In a recent survey of Psychology Today, doctors state that people who are happy with their bodies may be more confident and likeable than those who have a negative body image. Unfortunately, they also explain that for some people having a good look is seen as a crucial aspect in their lives and that instead of having a healthy life they may prefer to become slaves to their own bodies. In conclusion, people will have to reassess their way of living and question whether having almost a perfect look is acceptable. At the same time we have to say that it is true that people look for a good-looking appearance but it is also true that their intellectual abilities are equally important. Personally, I believe that people should try to keep an appropriate balance between being healthy and being beautiful. Although it is terribly negative to be obsessed with one’s appearance, it is very important to be well-groomed and especially careful about one’s health.

Hamlet Thesis

Hamlet Thesis Hamlet Thesis Hamlet ThesisHamlet is one of the most well-know tragedies written by Shakespeare. Even if you have never this play, you are undoubtedly aware of the key characters, the plot, as well as the theme. This article is written with the hope to assist you in the process of Hamlet thesis writing from scratch. Hamlet Thesis Writing While writing a hamlet thesis, you should decide on the specific elements you want to cover. For example, you may write a Hamlet thesis about symbols, try to understand the actions and words of the main characters, to explore the relationships between the main characters, to trace the complexity of images, dissect conversations among the characters, to analyze the themes, the plot, or literary devices.As you can see, the choice of the Hamlet thesis writing direction is rather wide and you can definitely decide on the specific issue. If you need professional advice on Hamlet thesis writing, if you are looking for expert assistance with Hamlet thesis, do not hesitat e to order professional Hamlet thesis writing service at our site. We are ready to help you 24/7 and you will be pleasantly surprised with our custom thesis prices!Hamlet Thesis Topic IdeasInward and onward conflict in drama. Which type of conflict is more apparent?Character of Hamlet. Is he insane or pretend to be the one in order to carry out his plan?Is revenge the main topic in drama? What are the additional themes in the play?What is not normal in the relationship between Hamlet and Gertrude? Is the setting of the play important for the topic development? How?Is Hamlet in love with Ophelia? Is she in love with Hamlet? Is love a topic in Hamlet? Compare the characters of Claudius and Macbeth. Are they similar or different?What is the role of the ghost in the play? Was it the first sign of Hamlets insanity?Hamlet Thesis Writing HelpIf you have no time to devote to Hamlet thesis writing, you may rely on our professional writing services and get your Hamlet thesis written from scratch by professional thesis writers. We can impress you with the quality of our professional thesis writing service!

Murdering Heroism The Advent of Immoral Heroes In Graphic Novels (the Essay

Murdering Heroism The Advent of Immoral Heroes In Graphic Novels (the cause and effects of graphic novels and manga which employ the use of immoral heroes (i.e - Essay Example By telling her story in this way, Childress is able to strip away her characters' self-deceptions and balance every plausible accusation against an equally plausible countercharge. The novel begins with Benjie's description f his neighborhood. It is a dismal place: Poverty and drugs are everywhere; rampant crime makes young and old alike afraid to leave their homes; most families have been torn apart by divorce or death. It is important for the reader to see Benjie's world through this character's own eyes and to develop sympathy for him at the very beginning f the novel. If Childress did not structure the plot in this way, the reader might be tempted to dismiss Benjie as merely a thief and an addict. As the author suggests, however, Benjie's situation is quite complicated. While he is, admittedly, a drug user, he also has a number f admirable qualities that make him a likable character. (Koppleman 20-25) In the second monologue, Butler Craig indicates that Benjie's use f drugs is more extensive than Benjie has indicated. Butler mentions that Benjie is now "into stealin" and has sold items belonging to his own family in order to support his habit. Though Butler does not condone Benjie's behavior, he does express genuine affection for the boy. One by one, all the characters interpret Benjie's problem in terms f their own relationship to him. Jimmy-Lee Powell reflects upon the close friendship that he and Benjie once had; he regrets that Benjie's use f heroin has caused a gulf to form between them. Benjie's grandmother feels that the use f drugs can only be cured through prayer and intense religious faith. Nigeria Greene, one f Benjie's teachers, sees addiction as resulting from the oppression imposed by whites upon all African Americans. Benjie's mother is saddened by her son's inability to speak openly about his problem; at the same time, she reveals her own inability to convey her true feelings to Benjie. (Killens 20-21) All the characters grasp some part f Benjie's situation, but none f them sees it in its entirety. Childress wants the reader to understand that many factors have caused Benjie to experiment with drugs. While he cannot solve his problems until he admits his own responsibility, the poverty and violence f his neighborhood have also been a major factor in making drugs available to him. When Benjie arrives at school one day obviously under the influence f drugs, Nigeria Greene and Bernard Cohen set aside their personal differences in order to help the boy. They take Benjie to the principal f the school and arrange for Benjie to enter a drug-treatment program. This quick action brings about a temporary improvement in Benjie's situation. Nevertheless, Benjie still finds it difficult to accept Butler as a replacement for his natural father. He regards Butler as a failure and treats him with contempt. The two f them quarrel, and Benjie again begins to think about buying heroin. Finding no money in the house, he pawns Butler's only overcoat and suit. This theft proves to be the last straw for Butler. He leaves Rose and moves into a different apartment in the same building. This decision deprives Benjie f one f the few male role models from whom he could