Managing a Global Team Term Paper Example | Topics and Well Written Essays - 750 words

Managing a Global Team - Term Paper Example This induced resentment towards the manager as well as the whole company. UAE team also complained that they did not have much face-to-face time with their immediate boss, James. Direct contact is important with the team leader no matter how geographically apart the two ends are. Employees need to be appreciated and motivated by their leader rather than just designated their tasks. James was not able to manage the difference in time zones while conducting his weekly meeting. Although it was a good approach to get everyone together on one platform once a week but it was not handled in the most appropriate manner. The time of the meeting forced the Indian team to work till 22:00 at times. This proved to make their days excessively long when their day already started as early as 6:30 IST. The early morn presence was also important because they had to be briefed about the work before the US office closed down. James was not able to see everyone’s problems therefore he was not able to provide them effective solutions. ‘We against them’ attitude was generated among the team members as a result of their issues and resentment. Another mistake that was done by James in terms of discussing issues was that all the team members were not made a part of the discussion in the emails. The US team would be a part of the email threads that would discuss important matters. The other teams complained that they were the last ones to be included in the emails to simply notify them of the solutions and decisions that had taken place. This way they did not get a chance to become a part of the discussions and just had to accept the solution that would be decided by James and US team. This kind of an approach is not suitable in the management of global teams since email correspondence is one the most common modes of communication. The team members are not able to meet in their daily routines in the cafeterias etc to discuss

Road to Independence Notes Essay Example for Free

Road to Independence Notes Essay People are reconsidering the policy of colonialism. 1. After WWII, people questioned whether dictatorship was a good idea. 2. â€Å"All nations should be free from the power of other nations. † 3. Keeping colonies had a high cost. It wasn’t worth it. 4. Colonized people pressed harder for freedom. Ex: British-held India II. A Movement Toward Independence A. The Indian’s strive to freedom intensifies. 1. British had power over India for 2 centuries. 2. Britain drafted Indians into WWII in 1939 without the consent of the the colony’s representatives. . Gandhi launched civil disobedience and many who followed were arrested. 4. To gain favor of the Indians, Britain promised government changes after WWII, but didn’t offer freedom. Besides colonialism, India struggles with internal conflict. 1. They have religious disagreements. 350 million Hindus 100 million Muslims 2. The Congress Party (aka Indian National Congress: India’s national political party) was made up mostly of Hindus, and a few Muslims. C. The Muslim League is created. 1. The Muslim League (1906) is the organization against the mostly Hindu Congress Party, aimed to protect Muslim interest. . (The leader) Muhammad Ali Jinnah asked all Muslims to leave the Congress party. He would not accept independence from Britain if it meant staying under Hindu rule. III. Freedom Brings Turmoil A. The decision of who receives power is being made. 1. The British lost much wealth after WWII, and was ready to turn over their power, since keeping up with colonies was costly. 2. The power will either be given to Hindus or Muslims. B. Muslims resisted Hindu domination. 1. Rioting broke out and in 1946, there were 20,000 casualties in a 4 day clash in Calcutta. C. Pakistan was created. 1. To maintain peace, Britain decided to partition (division of Indian religions into separate nations; idea first brought up by Muslims) India. 2. North western and eastern part of India became Pakistan which was dominated by Muslims. D. Everything in India was being divided. 1. British granted India and Pakistan a month of independence in July 16, 1947. 2. Princes had to decide which nation they’d join. 3. The civil service (courts, military, railways, police) was divided. 4. The differing religions had to decide where to go. E. One million people died during the move to their new nation. 1. Muslims killed Sikhs moving to India. 2. Sikhs and Hindus killed Muslims going to Pakistan. 3. Gandhi went to the Indian capital (Delhi) to ask for mercy, but was killed by a hindu extremist in January 30, 1948. F. Hindus and Muslims fight for Kashmir. 1. Kashmir is at the northern point of India next to Pakistan. 2. It had a Hindu ruler, but the majority of people living there was Muslim. 3. Fighting continued until UN arranged cease-fire in 1949. 4. One-third went to Pakistan (Muslims) and the rest to India (Hindus). IV. Modern India A. India has become the world’s largest democracy. 1. India gained independence in August 15, 1947. 2. Jawaharlal Nehru (the independent nation’s first prime minister) addressed India’s freedom. B. Nehru is the leader. 1. He served the first 17 years of India’s independence as leader. 2. He was a devoted follower of Gandhi. 3. He emphasized democracy, unity, and economic modernization, and became very popular with all Indian groups. C. Nehru pushed India forward. 1. He led newly independent nations into making alliances with other non aligned nations. 2. He reorganized the states by language and pushed for industrialization and social reform. 3. He raised the status of those in lower class (lower castes and women). D. A new leader came. 1. Nehru died in 1964. 2. His daughter, Indira Gandhi, became prime minister in 1966, left office, and was re elected in 1980. E. Challenges set on Indira caused more violent acts and death. 1. Sikh extremists wanted an independent state. 2. The Golden Temple was the Sikh’s religious center. 3. The Sikhs attacked symbols of Indian authority, so Indians troops overran the Golden Temple, killing 500 Sikhs and destroying sacred property. 4. Indira was gunned down by Sikh bodyguards and another murder spree occurred, killing thousands of Sikhs. . Indira’s son, Rajiv, became prime minister, but lost power because of corruption. He was then killed. F. Atal Bihari Vajpayee faced problems. 1. The leader of the nationalist party of India, Vajpayee, faced challenges of overpopulation and strife among religions. 2. The struggle between India and Pakistan was bad, now that they became nuclear powers. India exploded a nuclear device in 1974. For 24 years, India improved nuclear capability in private. In 1998, 5 nuclear tests were conducted. Pakistanis also showed they had nuclear capabilities. The nuclear weapons of both rival groups became an international concern, especially because of Hindus and Muslims continuous struggle over Kashmir. V. Pakistan Copes with Freedom A. Pakistan was already very turbulent and had differences between West Pakistan and East Pakistan. B. The two regions of Pakistan struggled with each other. 1. A tidal wave hit East Pakistan and killed 266,000 residents in 1970, calling for international aid that West Pakistan was not eager in giving. 2. East Pakistan protested and called to end all ties with West Pakistan. C. Pakistan undergoes its own partition. 1. On March 26, 1971, East Pakistan became Bangladesh. 2. Civil war broke out. Indians sided with Bangladesh and Pakistan surrendered. 3. 1 million people died. 4. One-seventh of area and one-half of the population in Pakistan was lost. D. Pakistan is instable. 1. After the death of the first governor general of India, the nation had no strong leader and went through many military coups. First in 1958 by Ali Bhutto Second in 1977 by General Zia Third Benazir Bhutto, Ali’s daughter, became prime minister. Fourth, Sharif in 1997. VI. Bangladesh and Sri Lanka Struggle A. Bangladesh faces many problems. 1. War brought economic and communication issues in Bangladesh. 2. Sheik Mujibur Rahman became the first prime minister of Bangladesh. Interested more in power than making reparations 3. Bangladesh tries to become democratic and fraud and corruption was common. Recently, it has been more stable and Begum Khaleda Zia became prime minister in 2001. 4. Natural disasters were troublesome. Bangladesh (low-lying) is subject to cyclones, tidal waves, massive storms which floods lands, ruins crops, takes lives, and homes. 5. Rapid growth in population put stress on the economy. There is civil strife in Sri Lanka. . Sinhalese Buddhists and Tamil Hindus make up the two main groups in Sri Lanka. 2. Tamils wanted to become a separate Tamil nation and violence occurred in order to do so. Rajiv Gandhi and the president on Sri Lanka made an agreement that called Indian troops to disarm Tamil rebels. A civil war between Tamils and Sri Lankans still exists. New Nations in Africa: Chapter 34 Section 3 I. Setting the Stage A. Africa was also a nation victim to colonization. B. Like India, they were unwilling to return to colonization after WWII, so they also won their independence and went on to creating new African nations. II. Achieving Independence A. A movement is made for Black Heritage. 1. The French-speaking Africans and West Indians grew pride for traditional Africa. 2. The Negritude movement (movement to celebrate African culture, heritage, and values) was formed. B. WWII changed the views of colonies and colonizers, which helped Africa gain independence from 1950s-1960s. 1. The African joined Europeans in WWII to defend freedom, and were unwilling to return to colonization. 2. The European colonizers developed morale and wondered whether it was a good idea to still hold colonies. In addition to morale, maintaining colonies was costly and wasn’t viewed as something worth losing money for. C. Africa achieved independence in a unique way. 1. Unlike other colonized areas that pushed for independence, Africa was colonized indirectly and directly. Those who were ruled indirectly were able to enjoy limited self-rule and were ruled by local officials. They achieved independence more easily. Those ruled directly were governed at all levels by foreigners and did not have any self rule. To get independence, they had to fight wars. D. Africa struggled even after they gained their independence. . They had to start from scratch: creating a new gov. , and establishing postcolonial economy. 2. Internal conflicts made it hard create stable nations. When colonized by Europeans, Africa was separated by random and many tribes who shared the same culture were divided and enclosed with rival groups, causing violence. III. Ghana Leads the Way A. The Gold Coast, a British colony, achieves full independence. 1. The Gold Coast (South of the Sahara) achieved independence, so British allowed for Africans to be nominated for legislative council. 2. However, they wanted full freedom and created a group. . Kwame Nkrumah (leader of the nonviolent group) organized strikes and boycotts, and was also imprisoned many times, (starting in 1947) eventually being able to liberate the Gold Coast from the British government. B. Good intentions called for opposition against Nkrumah. 1. The Gold Coast became Ghana (from the Ghana Kingdom of Africa) after it received its independence in 1957. 2. Nkrumah, th e first prime-minister and president for life, pushed for industrialization by building new roads, schools, and health facilities. 3. His programs were too costly, and people began to oppose him. C. Ghana still continues to struggle. 1. Nkrumah was criticized for neglecting economic issues. 2. When in China (1966) he was replaced by the police and army in Ghana. 3. The power shifts between civilian and military rule, and Ghana struggles economically. 4. 2000 marks the first open election in Ghana. IV. Fighting for Freedom A. The British is forced to allow Kenyan self-government. 1. The British were unwilling to give Kenyans independence because they’ve taken over prized farmland in the northern highlands of Kenya. 2. The Kenyans had 2 developments which forced British to surrender. Jomo Kenyatta’s (Kenyan nationalist) strong leadership. The Mau Mau, a secret society of mostly native Kenyan farmers forced out of the highlands by British people. B. The Mau Mau fight for independence. 1. Guerilla tactics were used to push out the British from the highlands. 2. Kenyatta had no connection to the Mau Mau but did not stop them from fighting for their freedom. 3. Kenyatta was imprisoned for about a decade. 4. Kenya was granted independence in 1963, however, 10,00 Africans and 100 settlers died. C. After gaining independence, Kenya still faced some struggles from poor leadership. 1. Kenyatta became the president and worked to reunite various groups in his nation, but he died in 1978. 2. He was succeeded by a weak leader, Daniel arap Moi. 3. Under Moi’s leadership was opposition to his one-party rule, corruption, and conflicts between ethnicities killing hundreds and making thousands homeless. 4. He left office in 2002, and a new party gained power through elections. D. Algeria wins independence through battle. 1. Algeria had a population of 1 million French and 9 million Arabs and Berber Muslims. 2. French did not want to share political power with the natives even after WWII. . The FLN (Algerian National Liberation Front) would fight for freedom, and upon hearing this, the French sent half a million troops to fight the FLN. 4. The FLN won and gained independence in July 1962. E. Uncertainty within Algeria calls for civil war. 1. The FLN leader, Ahmed Ben Bella, becomes president and attempts to make Algeria follow socialism, but is overthrown. 2. From 19 65-1988, Algeria tried to modernize, but failed. Religious fundamentalists wanted to make Algeria an Islamic state because they were dissatisfied with the current government and high unemployment rates. 3. The Islamic Salvation Front (FIS) won elections in 1990 and 1991, but the government and army refused the results. 4. Civil war broke out between Islamic militants and the government, and goes on and off until this day. V. Civil War in Congo and Angola A. The people of Congo were unprepared for independence, and it led to turmoil. 1. Belgians colonized and plundered Congo taking all its riches and resources such as rubber and copper. 2. They gave no social services to the natives of Congo, and did not prepare them for independence. 3. They granted Congo (aka Zaire from 1971-1997) independence in 1960, which cause upheaval, and civil war. B. Congo goes through two leaders. 1. Years of civil war sprung up, and Mobutu Sese Seko (aka Colonel Joseph Mobutu) seized power in 1965. He renamed Congo to Zaire and ruled it for 32 years. He held control over Zaire with force, one-party rule, and bribing supporters with gifts. He withstood rebellions. 2. In 1997, he was overthrown by Laurent Kabila (rebel leader). Zaire was renamed The Democratic Republic of Congo. C. Kabila wasn’t the leader people hoped for, and a new leader rises. 1. He became president and promised a democracy, but never delivered it. 2. Civil war broke out again, and rebel groups wanted to overthrow Kabila. . He was assassinated by a bodyguard in 2001. 4. Joseph Kabila, his son, took power and pushed for peace. 5. Rebels stopped rebelling in 2002 in hope that the peace may come. D. Angola (South West of Congo) fought for independence. 1. Angola was ruled by the Portuguese who were unwilling to let go of their colony. 2. An independence movement broke out and Portugal sent 50,000 troops to end it, which wiped out half of Portugal’s budget. 3. The cost of war and the war’s opposition in Portugal called for them to withdraw from Angola in 1975. E. Civil war broke out in Angola. 1. Angola became a new nation, and the MPLA (Communist leaning â€Å"Popular Movement for the Liberation of Angola†) declared itself as the government. 2. Rebel groups fought against the government for power. 3. 50,000 Cuban troops and Soviet Union supported the MPLA. 4. South Africa and the U. S. supported the UNITA (the major opposition to the MPLA; â€Å"National Union for the Total Independence of Angola†) 5. The MPLA and UNITA abandoned many cease-fire agreements, but in 2002, a peace accord was agreed to and the civil war ended. Conflicts in the Middle East: Chapter 34 Section 4 I. Setting the Stage A. By the end of WWII, Jewish finally gained its own state, which proved to have bad consequences. 1. The Jewish gained a state that was located by the Mediterranean Sea. 2. It consisted of mostly Arabs who rejected the creation of a Jewish state. 3. Palestinians claimed Jewish states to be theirs, therefore opposing Jewish states. 4. Wars were fought between Jews and Arabs, and Jews and Palestinians. II. Israel Becomes a State A. Palestinians, Jews, and Arabs all claim the same lands (Israel, West Bank, and the Gaza Strip in modern day Palestine). 1. Jews’ reason: 3,000 before, Jewish Kings ruled the lands from Jerusalem. . Palestinians’ reason: land was theirs since Jewish exile on A. D. 135. 3. Arabs’ reason: their conquest of the lands in the 7th century (600s). B. The Jews wanted to return to Palestine and gain a Jewish state centuries after their exile. 1. The Jewish were unable to gain their own state after their exile, and dispersed around the world (Diaspor a). 2. Zionists (people who favored a Jewish state in Palestine) started returning to their homeland during the 19th and 20th centuries (1800s-1900s). C. A British idea of creating a Jewish homeland in Palestine cause sparks between the Jews and Palestinians. 1. The British directed Palestine (League of Nations’ commands) as a result of the loss of the Turkish Ottoman Empire in WWI. 2. Many Jews were in Palestine, and pressed for their own nation. 3. Palestinians opposed the idea, so when Secretary Sir Arthur Balfour of Britain proposed creating a Jewish state while keeping the rights of non-Jewish communities (Balfour Declaration) and the plan failed, tensions rose between Palestinians and Jews. D. The U. S. and many European nations felt sympathy towards the Jews, who were targeted in the Holocaust, so they devised a plan that would give Jews what they desired. 1. The UN General Assembly voted for partition in Palestine, one part being a Palestinian state, the other being a Jewish state, and Jerusalem being an international city owned by no one. 2. The Jews made up 34% of the population but gained 55% of the land. E. The partition was set, although Muslims and Palestines rejected it. 1. â€Å"The UN has no right to make such a proposal without first consulting the majority who will be affected by it. †- Muslims and Palestinians. 2. David Ben Gurion (leader of Jews in Palestine) announced that the independent nation of Israel was formed on May 14, 1948. III. Israel and Arab States in Conflict A. War broke out between Israeli and Arab states. 1. The first one (won by Israel) was a day before Israel became a nation, where Islamic states (Egypt, Iraq, Jordan, Lebanon, Saudi, Arabia, and Syria invaded Israel. B. The partition wasn’t fully effective because of fighting. 1. Israel seized half of Palestine in 1948-1949. 2. 600,000 Palestinians left to nearby UN sponsored refugee camps. 3. Arabs also seized Palestinian lands. C. War broke out in 1956 during the Suez Crisis. 1. Egypt seized the Suez Canal. 2. Gamal Abdel Nasser (Egyptian president) sent troops to seized the canal controlled by British because he was angry that the U. S. and British stopped financially supporting Egypt’s Aswan Dam. 3. Britain formed an alliance with France and israel to regain the Suez canal. 4. Israel defeated the Egyptians using air support of their European allies. 5. The war ended when the U. S. and Soviets forced Israel and Europeans out of Egypt, ultimately giving Egypt the Suez Canal by the end of the Suez Crisis. D. Another war broke out in 1967, called the Six-Day War. 1. Nasser and Arab allies, equipped with Soviet tanks and aircraft were ready to confront Israel and close off Israel’s outlet to the Red Sea, the Gulf of Aqaba. 2. Israelis knew Arabs would attack, so the struck airfields in Egypt, Iran, Jordan, and Syria, and ground forces defeated Arab states in this Six-Day War. 4. Israelis gained the lands around them (Jerusalem, Sinai Peninsula, The Golden Heights, and the West Bank). 5. They served as buffers for future attacks. 6. Palestinians living in Jerusalem chose Jordanian citizenship, and others not living in Jerusalem went other Jewish control. E. A fourth War broke out in October 1973, called the Yom Kippur War. 1. Anwar Sadat,(Egyptian president who succeeded Nasser) planned an Arab attack on Israel during Yom Kippur. . Sadat was able to reconquer land lost in the Six-Day War. 3. Golda Meir (prime minister of Israel during the Yom Kippur War) counterattacked and regained most the land. 4. After weeks of fighting, a truce was declared. F. Palestinians pushed for recognition and its own state. 1. The UN had given Palestinians its own state during the partition, but the land given was seized by Is raelis during their vast amount of wars. 2. The PLO (Palestine Liberation Organization) was organized by Palestinian officials in 1964, and initially consisted mostly of social workers, like teachers, lawyers.

The Doctrine of ‘Personality Rights’ in the UK

The Doctrine of ‘Personality Rights’ in the UK The United Kingdom has never acknowledged a specific doctrine of ‘personality rights’; the law provides neither coherent nor consistent protection, as the courts are ‘sceptical about creating monopoly rights in nebulous concepts such as names, likeness or popularity’.[1] Therefore celebrities and other high-profile individuals rely on a combination of passing off, trademark, copyright and privacy laws for protection of the commercial value of their personality. None of these were invented to protect personality rights; however they are gradually developing to adjust to the commercial reality of the value of celebrity merchandising and endorsements. Misleading the public by giving a false impression of endorsement of a product by a celebrity has been to commit the tort of passing off for over a decade.[2] The tort of passing off was traditionally defined as ‘nobody has the right to represent his goods as the goods of someone else’.[3] The ‘ classical trinity’ is necessary to succeed in passing off: ‘the goodwill or reputation must be attached to the products or services of the plaintiff, the misrepresentation must lead to the confusion as to the source of the goods and services, and this confusion must cause damage to the claimant’.[4] In the case of Fenty Ors v Arcadia Group Brands Ltd (t/a Topshop) Anor,[5] high street fashion retailer Topshop licensed an image of popstar Rihanna’s face from a photographer and printed it on a t-shirt without either her permission being sought nor obtained. Rihanna then sued for passing off. Mr Justice Birss applied the doctrine to the dispute. Although on very particular facts, Birss J found in favour of Rihanna and established a general principle that arguably goes against any celebrities who might have hoped to see the creation of a doctrine of personality rights. This decision develops the tort of passing off to small degree whilst emphasising that, in each case, the facts are decisive.[6] The debate about the recognition of personality rights in the UK is gathering impetus in the wake of Fenty with academics like Walsh questioning if ‘personality rights are finally on the agenda’.[7] In the 1970s the UK courts were regularly unwilling to find false impressions relating to merchandising resulted in misrepresentation because of the need to show that they were engaged in a ‘common field of activity’. This introduced a somewhat blunt test for confusion and there often would be no proximity between, for example, a radio broadcaster and a cereal manufacturer.[8] Until the test was discarded, at least as an absolute condition,[9] it limited attempts to expand the categories of misrepresentation to cover licensing connections.[10] Where the absence of a common field of activity was not conclusive the court for example held the use of the name of the pop group Abba on merchandise did not amount to passing off on the basis that there was no real possibility that the public would be confused into thinking that Abba had approved the goods merely because their name or photograph appeared on them.[11] Likewise the use of a photograph of the Spice Girls on the cove r of a sticker collection was held not to constitute passing off.[12] An important exception came when it was held passing off had been established where cartoon characters, the Teenage Mutant Ninja Turtles, were on clothing without authorisation, since the public did expect the goods to be licensed.[13] This case was distinguished from the Abba scenario on the basis that it was brought in the context of the unauthorised reproduction of images of cartoons in which copyright existed, rather than the image or name of a celebrity. Yet the decision is generally viewed as opening up character merchandising law in the UK. In the seminal case of Irvine Laddie J held passing off covered cases of false endorsement, like where Talksport had altered an image of racing driver Eddie Irvine to have him hold a branded Talksport radio for advertising purposes without his permission. Laddie J considered the increasingly popular marketing practice of personality licensing, including the licensing of a personality’s name or likeness outside a celebrity’s area of expertise as a common and lucrative practice for them, to reject the ‘common à ¯Ã‚ ¬Ã‚ eld of activity’ condition. Laddie J identified the inherent flexibility of passing off by saying ‘the sort of cases which come within the scope of a passing off action has not remained stationary over the years†¦passing off is closely connected to and dependent upon what is happening in the market place’.[14] Although Irvine was celebrated as a turning point in the protection of personality rights, the important limitation in the judgment was that passing off was limited to false endorsement and excluded merchandising cases. The classic celebrity-merchandising situation seems similar: the celebrity has a reputation and the public knows that it is common practice for celebrities to market their popularity by granting merchandise licenses.[15] Laddie J differentiated between cases of endorsement and merchandising, however in Fenty Birss J approved Laddie J’s reasoning but made it clear there is no difference in merchandising cases and that the legal principles apply equally well in passing off if the public had been deceived into thinking the celebrity had authorised the product. Rihanna easily established sufficient goodwill in the fashion industry, as a style icon because of her ‘cool, edgy image’.[16] This was demonstrated in her endorsement contracts with Nike and Gillette, her fashion design and promotion work with rival retailer River Island, and she had worked with HM, Gucci and Armani to collaborate on and design clothing. Birss J therefore stated Rihanna’s ‘identity and endorsement in the world of high street fashion was perceived†¦to have tangible value by an organisation well placed to know’.[17] Misrepresentation was the key issue. Topshop argued the clothing was simply a t-shirt bearing an image of Rihanna and the public had no expectation that it was authorised by her, whereas Rihanna contended that the particular facts of the case meant customers were misled into believing she had endorsed the t-shirt herself. The court considered the point in depth, addressing the various circumstances before considering the issue as a whole. Certain evidence considered was found to be neutral to finding a misrepresentation. The fact there was other unauthorised clothing bearing Rihanna’s image on sale did not imply that the public would necessarily believe that such clothing was authorised. Topshop had sold both clothing bearing authorised images and clothing, which was approved or endorsed by celebrities. Overall, its customers were neutral: having no positive expectation either way when considering clothing bearing a celebrity’s image. Also the t-shirt was fashionable an d on sale in a high street retailer. Certain factors indicated finding in Topshop’s favour. Some of Rihanna’s official merchandise included an ‘R slash’ trademark logo or her name, the t-shirt lacked both, and apart from a few days online the word ‘Rihanna’ was not used at all. There was also no genuine evidence of actual confusion. However on balance, significant factors supported RIhanna. Topshop had made considerable effort to emphasise connections in the public consciousness between the store and celebrities notably Kate Moss, and now more importantly Rihanna. This made it more likely purchasers would conclude that the t-shirt was authorised and being a fashion retailer, consumers would reasonably expect Topshop to publicise and sell products authorised by celebrities. Topshop’s prior association with Rihanna was important as Topshop ran a competition in 2010 to win a personal shopping appointment with Rihanna. Rihanna also visited Topshop in 2012 which they chose to publicise by tweeting to their 350,000 Twitter followers, just before the t-shirt went on sale – a significant commercial communication in the eyes of Birss J, to a demographic who valued social media highly. Topshop had therefore repeatedly associated itself and it products with Rihanna in a high-profile manner and this demonstrated Topshop were looking to take advantage of Rihanna’s position as a style icon. The image on the t-shirt was taken during the video shoot of RIhanna’s single ‘We Found Love’ from her 2011 ‘Talk that Talk’ album. Importantly, it showed Rihanna with the same hairstyle and headscarf as the album cover. This meant that the image was not just recognisably Rihanna but looked like a promotional shot for the music release. The court found that it was entirely likely that, to her fans, the image might be regarded as part of the marketing campaign. This was a critical point in the de cision. Although Birss J believed a ‘good number’ of purchasers would buy the t-shirt without considering the question of authorisation, he concluded that, in the circumstances, a substantial proportion of those judging the t-shirt (specifically Rihanna fans) would be encouraged to think that it was clothing authorised by the popstar. They would have recognised that particular image of Rihanna not simply as an image of her but as a particular image of her connected with the particular context of the album. Many of these purchasers would have bought the product because they thought that Rihanna had authorised it; others would have bought it because of the value of the perceived authorisation itself. In each case, the idea that it was authorised was part of what motivated them to buy the product and in each case they would have been deceived. The test for damage was also easily satisfied. If a substantial number of purchaser’s were deceived into buying the t-shirt because of a false belief that it was authorised by Rihanna herself, then that would have damaged Rihanna’s goodwill, both by way of sales lost to her merchandising business and a loss of control over her reputation in the fashion sphere.[18] Considering the particular facts, it is not surprising Birss J found in Rihanna’s favour. The classical trinity of passing off were fulfilled, however this decision is unlikely to open the floodgates for cases to be brought every time a celebrity’s image is used without a merchandising license, as it was made clear ‘the mere sale by a trader of a t-shirt bearing an image of a famous person is not without more, an act of passing off’.[19] Birss J was eager to emphasise that ‘there is today in England no such thing as a free standing general right by a famous person (or anyone else) to control reproduction of their image.’[20] The judgment is useful as a confirmation of the general principles of passing off applied to unauthorised use of celebrity images.[21] If the UK is approaching the creation of a doctrine of personality rights in some form, it is necessary to analyse the justifications and gauge whether they are robust enough to validate the subsequent restraints that would be placed upon society. The justifications suggested in support of personality rights fall largely into three groups: moral, economic and consumer protection arguments. The labour-based moral justification is founded on John Locke’s theory of property.[22] Essentially, itprovidesthat an individualhasamoralrightintheobjectofvaluetransformedbecauseoftheir efforts. Nimmer supported this point by contending that the person who has ‘long and laboriously nurtured the fruit of publicity values’ and has spent ‘time, effort, skill, and even money’ in their creation, is presumably allowed to enjoy it.[23] Professor McCarthy feels personality rights are ‘a â€Å"common-sense†, self-evident right needing little intellectual rationalisation to justify its existence’.[24] However, Madow deconstructs these arguments by contending that fame is something ‘conferred by others’ and is not necessarily down to the efforts of the individual.[25] Moreover according to Madow the labour argument ignoresthe fundamentalrole themediaplayinthecreationofcelebrities.He uses the example of Einstein andobservesthatth emedia selectedhim becausehedidinterviews, wasquotable and hehadtheright‘look’.[26]TheimageofEinsteinthat is familiar today,what itmeanstothe pubic themadbutpleasant scientistwith bushywhitehairandmoustache wasa personality createdby themedia. Therefore only when the media and public take notice and attach importance to a personal image can it fully enter into the market place.[27] Thus contrary to the statement by McCarthy, it would appear a celebrity cannot justify that they solely created their public image and consequently cannot stake an indisputable moral claim to the exclusive ownership or control of the economic value that comes with it. Personality rights can also be justified on economic arguments. Economic theory proposes persons should be economically incentivised into ‘undertaking socially, enriching activities’ such as creating a persona that benefits society culturally,[28] and this creativity can only be encouraged if the person is given exclusive right to control their creations, because this ‘provides incentive for performers to make economic investments required to produce performances appealing to the public’.[29] However Carty doubts whether personality rights would produce increases in ‘economic activity’ or ‘innovation’.[30] Following Madow’s ideas, the UK is currently without a personality right, yet celebrities still gain significant income from their publicity values and failure to introduce such a right in the future will not stop individuals profiting from the income already gained through endorsements and merchandising officially authoris ed by them.[31] According to Madow such protection also has ‘distributional consequences’,[32] whereby personality rights elevate the price of merchandise and advertising in general, placing more wealth in the hands of a select few, who already derive significant income, and away from the mass of consumers making up society.[33] Another justification for personality rights is the consumer protection argument focusing on the idea that without protection, the public will be misled about the authorisation of a celebrity’s association with a product or service. At first sight the consumer protection argument appears advisable, joining protection of the celebrity’s success with protection of the consumer, and it mirrors the traditional rationale for trademark and passing off.[34] However personality rights would allow celebrities to stop commercial uses of their personas that are not fraudulent or deceptive, and Professor Shiffrin states personality rights give celebrites power ‘to control the dissemination of truth for his or her own profit’.[35] On another level, Madow argues the degree to which personality rights would stop the consumer being misled is generally superfluous,[36] because in situations where there is a realistic chance that, consumers will be deceived or confused about a celebrity’s association or endorsement, legal mechanisms better adapted for that reason already exist, notably passing off. In conclusion, the extent to which Fenty constitutes a creation of a doctrine of ‘personality rights’ is limited. In the words of Roberts ‘this judgment does not change the law; and it does not create an â€Å"image right†. It simply applies the existing doctrine of passing off to the evolving commercial reality of the value of celebrity endorsements’.[37] The decision is important as it improves a flaw in the Irvine verdict,[38] in the same way that Irvine marked the first time that passing off was applied to false endorsement, Fenty is the first time it has been applied to false merchandising featuring a real person, with merchandising claims having only previously succeeded in relation to fictional characters,[39] and indicates that UK courts are slowly recognising the need to protect the commercial value of celebrity merchandising. It is clear from the case that the result was carefully balanced on particular facts and that if for example Rihanna had not been a fashion icon or the image was different she would have less chance of being successful. Fenty highlights the issue of misrepresentation is however always one of fact, and the false belief of the purchaser is key: to constitute passing off, a false belief incited in the mind of the prospective purchaser must play a role in their choice to buy. Although there are persuasive advocates of the creation of a doctrine of personality rights,[40] and there is also no definite rationale for an absolute rejection,[41] it would seem the decision in Fenty should be welcomed because there are substantial drawbacks in the moral, economic and consumer protection justifications put forward. The decision develops passing off to a small degree to keep up with modern business practice without creating personality rights, which are not necessary as celebrities are already sufficiently protected. The tort of passing off has again demonstrated its inherent flexibility and that it is ‘ closely connected to and dependent upon what is happening in the market place’. To sum up, ‘without an element of consumer deception, English law in this area remains characteristically cautious’,[42] and this should be welcomed. [1] J. Klink, ’50 years of Publicity Rights in the United States and the Never Ending Hassle with Intellectual Property and Personality Rights in Europe’, (2003), 4 IPQ 363, p.366. [2] Irvine v Talksport Ltd [2003] EWCA Civ 423 [3] Reddaway v Banham (1896) 13 RPC 218 at 244 per Lord Halsbury [4] Reckitt Colman v Borden [1990] 1 WLR 491 at 499 per Lord Oliver [5] [2010] EWHC 2310 (Ch) [6] D. Meale, ‘Rihanna’s face on a T-shirt without a licence? No, this time it’s passing off’, (2013) 8(11) JIPLP 823, p.823. [7] C. Walsh, ‘Are personality rights finally on the UK agenda?’, (2013) 35(5) EIPR 253, p.253. [8] McCulloch v Lewis A May [1947] 2 All ER 845 [9] Lyngstad v Anabas Products [1977] FSR 62 at 67; [10] Wombles Ltd v Wombles Skips Ltd [1975] FSR 488 Ch D; [11] Lyngstad v Anabas Products [1977] FSR 62 [12] Halliwell Ors v Panini Ors (6 June, 1997, unreported) [13] Mirage Studiosv Counterfeat Clothing [1991] FSR 145 [14] [2002] FSR 60 at para 13-14 [15] J. Klink, op.cit., p.375. [16] Fenty v Topshop [2013] EWHC 2310 (Ch) at [46] [17] Ibid at [42] [18] Ibid at [72] [19] Ibid at [75] [20] Ibid at [2] [21] H. Beverley-Smith and L. Barrow, ‘Talk that tort†¦of passing off: RIhanna, and the scope of actionable misrepresentation: Fenty v Arcadia Group Brands Ltd (t/a Topshop), (2014), 36(1) EIPR 57, p.61. [22] J. Locke, The Second Treatise of Government, (New York: Liberal Arts Press, 1952) [23] M.B. Nimmer, ‘The Right of Publicity’, (1954) 19 Law and Contemporary Problems 203, p.216. [24] J.T. McCarthy, The Rights of Publicity and Privacy, (New York: C.Boardman, 1987), s.1.1[B] [2] at 1-5; s.1.11[C] at 1-46. [25] M. Madow, ‘Private Ownership of Public Image: Popular Culture and Publicity Rights’, (1993), 81 CLR 125, p.182. [26] Ibid, p.190 [27] J. Fowles, Celebrity Performers and the American Public, (Washington D.C.: Smithsonian Institute Press, 1992), p.84. [28] J.T. McCarthy, ’Melville B. Nimmer and the Right of Publicity: A Tribute’ (1987) 34 UCLA LR1703, p.1710. [29] D.E. Shipley, ‘Publicity Never Dies: It just Fades Away, (1981) 66 Cornell LR 673, p.681. [30] H. Carty, ‘Advertising, Publicity Rights and English Law’, (2004) 3 IPQ 209, p.251. [31] M. Madow, op.cit., p.211 [32] Ibid, p.218. [33] Ibid [34] H. Carty, op.cit., p.252. [35] S. Shiffrin, ‘The First Amendment and Economic Regulations: Away from a General Theory of the First Amendment’, (1983) 78 NW ULR 1212, p.1258. [36] M. Madow, op.cit., p.233. [37] J. Roberts, ‘Face off: Rihanna wins â€Å"image rights† case’, (2013), 24(8) Ent LR 283, p.285. [38] A. De Landa Barajas, ‘Personality rights in the United States and the United Kingdom – is Vanna too much? Is Irvine not enough?’, (2009) 20(7) Ent LR 253, p.258. [39] J. Roberts, op.cit., p.285. [40] S. Bains, ‘Personality rights: should the UK grant celebrities a proprietary right in their personality? Part 2’, (2013) 18(6) Ent LR 205 [41] [42] H. Beverley-Smith, op.cit., p.61.

Sending Technology Back in Time :: Exploratory Essays Research Papers

Sending Technology Back in Time The hot sun was shining high in the sky, as wind picked up dirt and threw it through the air. A tall, dark haired man stepped carefully behind a wooden plow. The animal that pulled the wooden, manmade creation was a shaggy, dark-gray donkey. The field is approximately two acres, and will probably take from sunrise to sunset to plow. In the distance, a brown horse and buggy slowly move along a flat dirt road. The long and tedious trip to the nearest town will take all day. John, the man guiding the plow, will have to take the same journey in a few days. For the most part, John is able to stay on the farm and perform daily tasks. The farm is self-sufficient. The lives of John and his family are devoted to taking care of the farm; without it, they would have nothing. Days are long on the farm and the five children that are old enough work a full day. The oldest children help in the fields with the plowing or planting. The younger children help with the simpler tasks and the two youngest run and play. The work is laborious and time consuming, and John's body aches after each day of work. The setting sun in the west tells John that it will soon be time to stop. When the only light that revealed any of the outside world was from the small glow of a gas lantern, John finally called it quits. Glad that the day was over, he headed back in the house. Dinner was already on the table, and all the kids were seated around it, hands and faces washed. John's wife, Anne, spent nearly the whole day preparing the meal of foods that were all acquired from their farm. When all the food was cleared from the plates, John headed to bed. He dreamed of little, knowing that all he had to wake up to the next morning was more work. As the sun began to creep through the blinds of the windows, a loud, obnoxious beep rang through his room. John woke with a jump to find that the noise was coming from a small box with a clock face on the front. The beeping continued until, John was finally able to find the off switch. The sound was still ringing in his ears, as he took a glance around his room.

South Africa Is Our Only Real Mother

The hand that rocks the cradle, Is the hand that rules the world. These are the wise words of William Wallace. I agree with him: A mother knows how to educate her children. For us South Africa is our only real mother. Plinks said: People undertake great Journeys to faraway places to see things that they don't appreciate in their own country. Our Mother South Africa cares about us, and therefore she takes us to her Art Museum filled with all her beautiful treasures of nature. Table Mountain with its cloudy table-cloth, is the beacon where a new nation was born.Then she takes us on the Garden Route through Cornerstones with its bonbons and protease. According to the description of the poet Liana Spies, Unequalled is the place where God's seed sachet was leaking†¦ When Spring starts, the earth is covered with thousands of colored flowers that take your breath away! From there she takes you on a game drive to the big five. Nowhere else in the world will you find this unique variety of wild life: Lions, Elephants, Rhino, Buffalo's and Leopards. It is the dream of every hunter to have a trophy of one of these animals as part of his hunting collection- Says PeterWeakened in the magazine â€Å"Go† of Cot 08. A mother definitely spoils her child. South Africa has many resources. If you open the tap, the water is running. If you drive into the countryside, you see the crop fields, vineyards, fruit orchards, vegetable farms and plantations that provide food and oxygen to Mother Africans children. If you walk out the door and see children play, you realize that that is a privilege – Says Urdu van Wok in ROI Rose of July 08. Oversees cluster houses with no garden at all, are the normal way of living. So, appreciate the open blue, African Sky!Ecologist Sydney Wright said: The earth is our playground. Mother South Africa nurtures us. We are all caught up in the rat race against time. We run around like mad dogs, being uptight and stiff-lipped. Then Mother S outh Africa puts her arms around us and takes us on a trip to the beach where we can revivalist our souls. It doesn't matter what we enjoy most: The fresh sea breeze, the deep blue ocean, the hot white sand, or the hot brown bodies†¦.! South Africans are known as the sun-seekers of the world. And when the sun sets, we turn to the company of a barbecue with friends and loved ones. Amp steak and the call of the hyena†¦ No wonder the English Pompoms me. Y us and try to copy-cat our â€Å"brainless. † I call their poor excuse for meat on a TV-briar, a â€Å"Barbie†! Ladies and gentlemen†¦ According to National Geographic, South Africa has 5 of the world's top rated nature reserves. We are lucky that Mother South Africa cuddles us with her beautiful scenery. She spoils us by keeping our food stores full, And provides us with exotic places to relax and revivalist. Mother South Africa is a country that provides us with what the Afrikaans poet – C Louis L eopold – describes as: â€Å"Summer, sun and sapphire for me!!

Cultural Conservatism essays

Cultural Conservatism essays Culture in ancient times was defined as the sum total of the equipment of the human individual, which enables him to be attuned to his immediate environment on the historical past on the other. It reflects in effect what humans have added to nature. It comprises the spiritual, material, intellectual and emotional features of a society and includes, in addition to the arts and letters, the value systems, traditions, modes of life and beliefs of the society. Through these aspects it is evident that the basis of growth and establishment of human culture is addition and change. However, in modern America this growth of culture is often resisted until it can no longer be held at bay. Many conservatives see these social changes as threatening because they feel that it will ultimately degrade the religious or social ethics which they personally hold. However, to put it simply, and it's not a problem that only conservatives have, conservatives very often confuse ethics and aesthetics. When people such as Gertude Himmelfarb, a conservative Christian historian, attack our, as she perceives it, "amoral," "sexually deviant," and "perverse" culture they are primarily responding to something that they find culturally foreign and aesthetically threatening. I agree that values are oftentimes a good thing, but only when they are born of an ethical and realistic perspective, not an aesthetic one. We are all trying to make out an existence in unbelievably confusing circumstances. Given our biological inheritance, we need to be more tolerant of ourselves and more tolerant and compassionate in our dealings with others. The standards that we have for human behavior are at times noble, but at times quite absurd. We are genetically designed to be lustful, aggressive, gregarious, productive creatures, and it can be a good thing to hold ourselves to high community standards of behavior, but we need to deal with ourselves as who and what we ...

Thomas Malthus Biography

Thomas Malthus Biography Early Life and Education: Born February 13 or 14, 1766 - Died December 29, 1834 (see note at the end of the article), Thomas Robert Malthus was born on either February 13 or 14, 1766 (different sources list both as a possible date of birth) in Surrey County, England to Daniel and Henrietta Malthus. Thomas was the sixth of seven children and began his education by being home schooled. As a young scholar, Malthus excelled in his studies of literature and mathematics. He pursued a degree at Jesus College in Cambridge and received a Masters of Art degree in 1791 despite a speech impediment caused by a hare-lip and cleft palate. Personal Life: Thomas Malthus married his cousin Harriet in 1804 and they had two daughters and a son. He took a job as a professor at the East India Company College in England. Biography: In 1798, Malthus published his best known work, Essay on the Principle of Population. He was intrigued by the idea that all human populations throughout history had a section that were living in poverty. He hypothesized that populations would grow in areas with plenty of resources until those resources were strained to the point that some of the population would have to go without. Malthus went on to say that factors like famine, war, and disease in historical populations took care of the overpopulation crisis that would have taken over if left unchecked. Thomas Malthus not only pointed out these problems, he also came up with some solutions. Populations needed to stay within appropriate limits by either raising the death rate or lowering the birth rate. His original work emphasized what he called positive checks that raised the death rate, such as war and famine. Revised editions focused more on what he considered preventative checks, like birth control or celibacy and, more controversially, abortion and prostitution. His ideas were considered radical and many religious leaders stepped forward to denounce his works, even though Malthus himself was a clergyman in the Church of England. These detractors made attacks against Malthus for his ideas and spread lies about his personal life. This did not deter Malthus, however, as he made a total of six revisions to his Essay on the Principle of Population, further explaining his points and adding new evidence with each revision. Thomas Malthus blamed the declining living conditions on three factors. The first was the uncontrolled reproduction of offspring. He felt families were producing more children than they could care for with their allotted resources. Second, the production of those resources could not keep up with the expanding population. Malthus wrote extensively on his views that agriculture could not be expanded enough to feed the entire population of the world. The final factor was the irresponsibility of the lower classes. In fact, Malthus mostly blamed the poor for continuing to reproduce even though they could not afford to care for the children. His solution was to limit the lower classes to the number of offspring they were allowed to produce. Both Charles Darwin and Alfred Russel Wallace read Essay on the Principle of Population and saw much of their own research in nature being mirrored in the human population. Malthus ideas of overpopulation and the death it caused was one of the main pieces that helped shaped the idea of Natural Selection. The survival of the fittest idea not only applied to populations in the natural world, it also seemed to apply to more civilized populations like humans. The lower classes were dying due to lack of resources available to them, much like the Theory of Evolution by Way of Natural Selection proposed. Charles Darwin and Alfred Russel Wallace both praised Thomas Malthus and his work. They give Malthus a large portion of the credit for shaping their ideas and helping to hone the Theory of Evolution, and in particular, their ideas of Natural Selection. Note: Most sources agree Malthus died on December 29, 1834, but some claim his actual date of death was December 23, 1834. It is unclear which date of death is correct, just as his exact date of birth is also unclear.

Free Essays on Spanish-American War

The weeks that have elapsed since that fatal event of February 15th have been making history in a manner highly creditable to the American government and to our citizenship. Captain Sigsbee, the commander of the Maine, had promptly telegraphed his desire that judgment should be suspended until investigation had been made. The investigation was started at once, and 75 million Americans have accordingly suspended judgment in the face of a great provocation. For it must be remembered that to suppose the destruction of the Maine an ordinary accident and not due to any external agency or hostile intent was, under all the circumstances, to set completely at defiance the law of probabilities. It is not true that battleships are in the habit of blowing themselves up. When all the environing facts were taken into consideration, it was just about as probable that the Maine had been blown up by some accident where no hostile motive was involved, as that the reported assassination of President Barrios of Guatemala, a few days previously, had really been a suicide. . . . It has been known perfectly well that Spanish hatred might at any time manifest itself by attempts upon the life of the American representative at Havana, Consul General Fitzhugh Lee. This danger was felt especially at the time of the Havana riots in January, and it seems to have had something to do with the sending of the Maine to Havana Harbor. The Spaniards themselves, however, looked upon the sending of the Maine as a further aggravation of the long series of their just grievances against the United States. They regarded the presence of the Maine at Havana as a menace to Spanish sovereignty in the island and as an encouragement to the insurgents. A powerful American fleet lay at Key West and the Dry Tortugas, with steam up ready to follow the Maine to the harbor of Havana at a few hours' notice. All this was intensely hateful to the Spaniards, and particularly to the Army of... Free Essays on Spanish-American War Free Essays on Spanish-American War The weeks that have elapsed since that fatal event of February 15th have been making history in a manner highly creditable to the American government and to our citizenship. Captain Sigsbee, the commander of the Maine, had promptly telegraphed his desire that judgment should be suspended until investigation had been made. The investigation was started at once, and 75 million Americans have accordingly suspended judgment in the face of a great provocation. For it must be remembered that to suppose the destruction of the Maine an ordinary accident and not due to any external agency or hostile intent was, under all the circumstances, to set completely at defiance the law of probabilities. It is not true that battleships are in the habit of blowing themselves up. When all the environing facts were taken into consideration, it was just about as probable that the Maine had been blown up by some accident where no hostile motive was involved, as that the reported assassination of President Barrios of Guatemala, a few days previously, had really been a suicide. . . . It has been known perfectly well that Spanish hatred might at any time manifest itself by attempts upon the life of the American representative at Havana, Consul General Fitzhugh Lee. This danger was felt especially at the time of the Havana riots in January, and it seems to have had something to do with the sending of the Maine to Havana Harbor. The Spaniards themselves, however, looked upon the sending of the Maine as a further aggravation of the long series of their just grievances against the United States. They regarded the presence of the Maine at Havana as a menace to Spanish sovereignty in the island and as an encouragement to the insurgents. A powerful American fleet lay at Key West and the Dry Tortugas, with steam up ready to follow the Maine to the harbor of Havana at a few hours' notice. All this was intensely hateful to the Spaniards, and particularly to the Army of...

Research Paper - War and Peace Example | Topics and Well Written Essays - 1250 words

- War and Peace - Research Paper Example This paper will bring out the views and opinions of people who are justifying war in some form or the other through their literary work. Also, the paper will provide an analytical view on what makes them believe that war is justifiable and in what circumstance they consider war acceptable, whether it really deserves the kind of importance that is given to it. War and peace are the two important aspects that rule the political, social and economic aspects of the world and thus it proves to be one of the most significant areas as a whole. Many dimensions are given to this form of belligerency between two states. As per the definition provided by Dinstein in War, Aggression and Self Defense (2011), â€Å"War is a hostile interaction between two or more States, either in a technical or in a material sense.† On technical front, war is a formal way to declare war whereas in the material sense, it means the usage of armed conflict by either of the party. Thus, it has a wider reach th en what it is often thought out to be. The term ‘war’ has got a wider connotation than its literal meaning and if often used against anything against social or economic problem as well. There are instances were people address terms like ‘war against drugs’ and ‘war against terrorism’. It is used in general parlance and adds a poetic touch over the intensity of the issue. Thus, there seems to be a sort of belief that war is not something that needs to be avoided altogether rather it is a means to survive. According to Softich (2010, pp. 3-64), the writings of Noah bring out the mixed feelings that are the outcome of the war scenario. He conveys it effectively through the book, The Short and Noble Life of Specialist Noah Charles Pierce. Noah Charles Pierce, a Veteran of Iraq War, had written many poems on war. He shot himself dead after returning back home from Iraq. All his poems surround the war scenario and bring out the true essence of war. A ll his poems are touching and provides with a detailed account of the life at the war site, the challenges and hardship that the soldiers had to face. He provides a justification that whomever is in front of him, if he was an enemy, he had not choice but to kill him. Through his writings, he reflects the inner feelings that surround him during the course of war and after he had done his duty as a responsible citizen. Justification is given that war, ultimately, is aimed at providing a greater sense of protection though in its course a lot of life is taken. If we take an account of the history, it becomes clear that war, though not liked, was considered to be an inevitable part of life. Richard Regan observes in his book, Just war: principles and cases (1996) that wars are the means to preserve the interests of a society or an individual. He further contends that â€Å"†¦wars are the ‘natural’ consequence of individual and societal acquisitive appetites.† The justification is made based on the aspects that no moral and ethnical details matters when the subject of self-interest comes into play. The author goes in-depth when analyzing the aspects of war and provides an excellent stance that the goodness and badness of a war can be determined on its success or failure to protect the societal interests or not. Thus the justification that war is not bad in itself and only the intention behind the war needs to be looked up to is put across through a more analytical approach. On one of his editorial contributions, When You Have to Shoot First

Curriculum Design for Inclusive Practice is Central to Effective Essay

Curriculum Design for Inclusive Practice is Central to Effective Learning and Teaching - Essay Example This not only soothes him but wakes in him a wish to excel in his academic life. This is called inclusive practice. The students’ participation in the teaching process is also a form of outcome as is considered as important as the teaching and the learning process itself. The whole process is beneficial enough for the educator as well because knowledge is being shared by working with students and thus improved learning is made possible. The learners or those who are using the services bring out their own ideas and innovation and thus the teacher tends to be at a more informed teaching position. According to Ross (2006), â€Å"Inclusive Practice is good practice, and is also about human rights and anti discriminatory approach to mental health. Inclusive practice underpins  anti discriminatory  practice and is  the practical way  in which we put our equality   policies/agenda into action.† 4. Curriculum Design for Inclusive Practice An ideal curriculum design fo r inclusive practice in schools with the aim of improving children’s health and social care should, according to linear tradition theory, help the students make predictions and decisions and efficiently solve the problems by bringing out examples from real life. For example, the curriculum should be flexible enough to accommodate paper and pencil discussion along with the use of the latest technology based tools. It should eliminate the gap (as proposed by the gap theory) between the teacher and the students. Moreover, an ideal curriculum should encourage the students to work in groups in an informal environment where teacher does not act as a boss or a dictator; rather, the students act their own instructors. They discuss the topic among themselves; ask each other questions; and, try to... This report approves that an inclusive practice curriculum design not only focuses on lesson plans and syllabus, it also arranges extracurricular activities for the children and â€Å"includes approaches to teaching, learning and assessment, the quality of relationships within school, and the values embodied in the way the school operates†. A good curriculum maintains an easy but intellectual assessment criterion to assess the capability level of children as to what they have learnt. It should be able to accommodate the latest technology based teaching and expertise so that the disabled children are also able to get individual learning offered by the ICT tools. It should provide opportunities to the students to better cooperate with the teachers and with peers. This essay makes a conclusion that designing a perfect curriculum that guarantees inclusive practice, especially in children residential schools and care houses, is a huge responsibility on the shoulders of the concerned school authorities. It as â€Å"a continuous, cyclic process† which involves an extensive decision-making process so as to meet the learners’ needs efficiently. The curriculum should be able to adjust both the curricular and non-curricular activities so that the students tend to learn different aspects of life and try to apply this learning in different areas of their personal lives. This way, not only they will be able to meet the academic demands of their curriculum, but also they will be able to excel in their everyday lives. Thus, inclusive practice is vital to engage students in the teaching process to eventually enhance their learning process.

Consideration in Law of Contract Essay Example | Topics and Well Written Essays - 1250 words

Consideration in Law of Contract - Essay Example 6. Promise to perform an existing contractual obligations is a valid consideration. Definition of Consideration: Sir Frederick Pollock, defined consideration as "An act or forbearance of one party, or the promise thereof, is the price for which the promise of the other is bought, and the promise thus given for value is enforceable." Lord Dunedin ratified this definition in Dunlop v Selfridge Ltd [1915] AC 847, Patteson J defines Consideration in Thomas v Thomas [(1842) P 118)] case as "Consideration means something which is of some value in the eye of the law, moving from the plaintiff; it may be some detriment to the plaintiff or some benefit to the defendant, but at all events it must be moving from the plaintiff. [Contract Cases and Materials by H.G.Beale, W.D.Bishop and M.P.Furmston. Chapter 6 p.93] Consideration is defined by Lush J. in the case of Currie v Misa [(1875) LR 10 Exch 153, 162.] as "A valuable consideration, in the sense of the law, may consist either in some right, interest, profit or benefit accruing to one party or some forbearance, detriment, loss or responsibility, given, suffered or undertaken by the other". [Contract Cases and Materials by H.G.Beale, W.D.Bishop and M.P.Furmston. Chapter 6 p.93] Evaluation of this definition with reference to the Court of Appeal's understanding of consideration in Williams v Roffey Bros &Nicholls (Contractors) Ltd (1990) 1All ER 512, Court of appeal. [Contract Cases and Materials by H.G.Beale, W.D.Bishop and M.P.Furmston. Chapter 6 p.107] Before we attempt this it is necessary to know brief facts of the case. In this case Roffey Bros. are the Principal contractors undertaken the carpentry work in an apartment. In the principal... Consideration in Law of Contract The Dictionary meaning of Consideration is "Consideration means something which is of value in the eyes of the law, moving from the plaintiff, either a benefit to the plainiff or detriment to the defendant. Consideration is not to be confounded with motive." (Black's Dictionary) Consideration means "Something that is legally regarded as the equivalent or return given or suffered by one for the act or promise of another". Adequate consideration means, "Legally sufficient, lawfully and reasonably sufficient". (Webster's third new International dictionary) The word "Adequate" means fully equal requirements or occasions, commensurate, but in its primary and not more popular significance, nothing can be said to be 'adequate' which is not equal to what is required, suitable to the case or occasion, fully sufficient, proportionate, and satisfactory". Therefore the definition of consideration as defined by Lush J. in Currie v Misa case is perfectly fulfilled in this case. Hence the courts have rightly adjudicated the case in favour of the plaintiff. Another point to discuss in this case is whether there is a promissory estoppel. Before we discuss this it is better to under stand the promissory estoppel. Estoppel is an equitable doctrine: Courts apply this doctrine as discretion. It is not a remedy at law. When one party did said something to induce the other party to make a promise. At later stage if he differs as unlawful and not enforceable. The court can apply its discretion of Estoppel on sufficient proof.

Planning and Managing for the Future - Inverleith Hotel - Edingburgh Assignment

Planning and Managing for the Future - Inverleith Hotel - Edingburgh - Assignment Example In addition, the managers and employees are identified to be focusing on the preferences of the customers facilitating in attracting more customers, which in turn aids towards the development of the hotel (Annual Report, 2014). One of the weaknesses of hotel is the limited sales volume and number of rooms, which is affecting the visibility of the brand name of the hotel. The major opportunity of the hotel is the competency of the employees based on which the hotel is able to perform its operations in a competitive manner. The entrance of new hotel can be one of the major threats for B&B. The owners and managers play a vital role towards the improvement of the performance of the hotel based on their good managerial skills. The owners and managers always support the employees in their work, so that the employees can perform their work effectively for meeting the satisfaction level of the customers (Annual Report, 2011). In the context, the assignment focuses on evaluating the plans as well as objectives of Inverleith Hotel (B&B) for having a better understanding of the performance of the company. Accordingly measures are needed to be adopted for implementing the changes effectively for enhanced growth as well as development of the hotel. The current business objectives and plans of Inverleith Hotel (B&B) are to increase exposure and expand market by using new and advanced technology. Other current business objective and plan is to increase the number of customers with the aim of increasing the profit as well as economic growth of the hotel. The hotel has planned to improve the quality of food products and also provide the best services to the customers based on the requirements of the customers (Annual Report, 2013). The business plans to hold a strong market position in the international market. The current business objectives and plans have been to enhance the performance of the hotel. To improve the current performance, the owners and

Case Study Example | Topics and Well Written Essays - 750 words - 1

Case Study Example While this move is anticipated to benefit China’s trading partners, since they will be in a position to reap the benefit of a flexible currency exchange rate, which includes increasing the value of their exports to China, there is some dissent view amongst some economists, that doing that will have a negative implication on China and consequently on its trading partners (Alfaro and Tella, 7). On the event that China would make its currency exchange rate more flexible, a high rate of deflation will be experienced in China, which would result to economic decline. This is because; making the exchange rate flexible would mean that the Chinese currency will lose some value relative to other currencies, such as the US dollar. This would mean that the cost of doing business in china will increase, since the multinational corporations and other foreign investments to china will be force to cater for the cost of increased inflation. This might result to having most of the foreign inves tments or the multinational companies moving out of the Chinese market, and seeking to invest in other countries, where the cost of doing business will be relatively lower (Alfaro and Tella, 18). ... The Chinese economy operated under the principles of communism, until reforms were introduced to make it a socialist economy, with private ownership of property and increased reforms in agriculture, state-owned enterprises, banking sector, trade and foreign investment policies, which saw China increase its GDP growth by 9.5% annually, and increase its trade from 10% of GDP to 79% of GDP between 1978 to 2004 (Alfaro and Tella, 15). The most significant change was in foreign investment policies, where China pursued policies that allowed for high foreign investment, resulting to having 50% of Chinas exports being produced by foreign investors by 2004 (Alfaro and Tella, 16). China pursued foreign direct investment into its economy more than borrowing loans, an aspect that saw the FDI account for more than 70% of its capital inflow in the early 2000s. However, the pressure of investment into china reached to a position of imbalance with the household consumption, prompting the Chinese gov ernment to slow down its pursuit for investment, to encourage household consumptions, so that the pressures of investment and consumption would level off. Thus, as opposed to focusing on revaluing the exchange rates, the Chinese government started focusing on domestic policies that would enhance consumption starting 2005 (Alfaro and Tella, 22). Both the domestic policy and the exchange rate revaluation have the impact of increasing deflationary pressure, while increasing the cost of doing business for foreign investors. This calls for a further adjustment to such businesses, which may include increasing their sales in China to cover up for the increased costs, or shifting their businesses to other countries which have less cost of doing business. Therefore, as much as there

Video case report Essay Example | Topics and Well Written Essays - 1000 words

Video case report - Essay Example However on this day, to everyone’s amazement, calls, emails and letters started flooding in, with every customer expressing dissatisfaction on various areas such as: product dissatisfactions, service delivery, the speed of the response and attention offered to the customers towards their complaints. The results were drastically affecting every sector within the firm, such as reduction on the sales, disruption on our production and dismissal of various workers. To provide a permanent solution, the firm had to put various factors in to account by laying out strategic measures to curb that occurrence ever repeating itself again. According to (Meredith 2010), a customer makes the business run and there is no particular firm that can chase away customers willingly; but the simple mistakes that various firms normally make, may be acts that result in chasing away customers in disguise. In every firm as many business people always put it, the â€Å"customer is the king† but may be this is what our firm didn’t establish or didn’t have established. ... According to (Zairi 2000), â€Å"Customers are the main purpose for running a firm, plus rather than them depending on the firm, the firm depends on them†. This indicates the importance of a gentle attachment between the firm and the customers. For (Hansemark and Albinsson 2004), they defined satisfaction as â€Å"overall customer attitude towards a service provider or the emotional reaction on what customers anticipate in relation to what they receive on their desired needs†. According to (Anderson 2000), customer loyalty is actually the result of an organization creating an atmosphere conducive to customers becoming repeat shoppers so that they can maintain or increase sales. Customer loyalty can only be achieved by providing and delivering what the customers desire and expect. Also (Oliver 1997), termed customer loyalty as that deep commitment to re-purchase a certain preferred product or service consistently in the future despite changes or influences with possibili ty of causing a change in the marketing behavior. Hokanson {1995), explains various factors that affect the level of customer satisfaction. This includes: employees’ knowledge on the product, friendliness, courteous and helpful staff, competitive pricing, good value of the product, billing clarity, timeliness and accuracy and quick service delivery. The most affected area as depicted in our firm by the dissatisfaction of the customers was on the profitability. According to (Hoyer 2001), satisfied customers provide the foundation of every successful business organization as it leads to repeat purchases and loyalty on the brands supplemented by a positive word of mouth. According to various researchers’, dissatisfaction of customers leads to

Planning and Managing for the Future - Inverleith Hotel - Edingburgh Assignment

Planning and Managing for the Future - Inverleith Hotel - Edingburgh - Assignment Example In addition, the managers and employees are identified to be focusing on the preferences of the customers facilitating in attracting more customers, which in turn aids towards the development of the hotel (Annual Report, 2014). One of the weaknesses of hotel is the limited sales volume and number of rooms, which is affecting the visibility of the brand name of the hotel. The major opportunity of the hotel is the competency of the employees based on which the hotel is able to perform its operations in a competitive manner. The entrance of new hotel can be one of the major threats for B&B. The owners and managers play a vital role towards the improvement of the performance of the hotel based on their good managerial skills. The owners and managers always support the employees in their work, so that the employees can perform their work effectively for meeting the satisfaction level of the customers (Annual Report, 2011). In the context, the assignment focuses on evaluating the plans as well as objectives of Inverleith Hotel (B&B) for having a better understanding of the performance of the company. Accordingly measures are needed to be adopted for implementing the changes effectively for enhanced growth as well as development of the hotel. The current business objectives and plans of Inverleith Hotel (B&B) are to increase exposure and expand market by using new and advanced technology. Other current business objective and plan is to increase the number of customers with the aim of increasing the profit as well as economic growth of the hotel. The hotel has planned to improve the quality of food products and also provide the best services to the customers based on the requirements of the customers (Annual Report, 2013). The business plans to hold a strong market position in the international market. The current business objectives and plans have been to enhance the performance of the hotel. To improve the current performance, the owners and

Video case report Essay Example | Topics and Well Written Essays - 1000 words

Video case report - Essay Example However on this day, to everyone’s amazement, calls, emails and letters started flooding in, with every customer expressing dissatisfaction on various areas such as: product dissatisfactions, service delivery, the speed of the response and attention offered to the customers towards their complaints. The results were drastically affecting every sector within the firm, such as reduction on the sales, disruption on our production and dismissal of various workers. To provide a permanent solution, the firm had to put various factors in to account by laying out strategic measures to curb that occurrence ever repeating itself again. According to (Meredith 2010), a customer makes the business run and there is no particular firm that can chase away customers willingly; but the simple mistakes that various firms normally make, may be acts that result in chasing away customers in disguise. In every firm as many business people always put it, the â€Å"customer is the king† but may be this is what our firm didn’t establish or didn’t have established. ... According to (Zairi 2000), â€Å"Customers are the main purpose for running a firm, plus rather than them depending on the firm, the firm depends on them†. This indicates the importance of a gentle attachment between the firm and the customers. For (Hansemark and Albinsson 2004), they defined satisfaction as â€Å"overall customer attitude towards a service provider or the emotional reaction on what customers anticipate in relation to what they receive on their desired needs†. According to (Anderson 2000), customer loyalty is actually the result of an organization creating an atmosphere conducive to customers becoming repeat shoppers so that they can maintain or increase sales. Customer loyalty can only be achieved by providing and delivering what the customers desire and expect. Also (Oliver 1997), termed customer loyalty as that deep commitment to re-purchase a certain preferred product or service consistently in the future despite changes or influences with possibili ty of causing a change in the marketing behavior. Hokanson {1995), explains various factors that affect the level of customer satisfaction. This includes: employees’ knowledge on the product, friendliness, courteous and helpful staff, competitive pricing, good value of the product, billing clarity, timeliness and accuracy and quick service delivery. The most affected area as depicted in our firm by the dissatisfaction of the customers was on the profitability. According to (Hoyer 2001), satisfied customers provide the foundation of every successful business organization as it leads to repeat purchases and loyalty on the brands supplemented by a positive word of mouth. According to various researchers’, dissatisfaction of customers leads to

The World That Trade Created Essay Example for Free

The World That Trade Created Essay The topic of The World That Trade Created by Kenneth Pomeranz and Steven Topik is mostly dealing with society, culture and economy. The book takes place all over the world from 1400 to present. The time periods are so interesting because it relates to the modern day economy. It also shapes how our economy came to be, where these ideal strategies for industry and etcetera originated- the cultural and traditional background of societies first using these tactics- and an overall extensive, lively history of economics. The modern day results in success and that is helpful for readers living within the new age society. Corporations are widely discussed today and take on a big role in the growing debate about the role of corporations should have in society today. â€Å"Why did the seventeenth- century Europeans create the worlds first corporations?† demanded Pomeranz and Topik. â€Å"looking back from 2005 the answer seems obvious: the corporation seems like such a logical way to do business..† but corporations had a violent birth. The first corporations didn’t have a permanent life, nor did they self-liquidate. Other Europeans, like- Middle East, India, South East Asia, Japan and China all through the eighteenth century had no need for the corporate form. Northern Europeans would need to seize and fortify and arm ships to patrol the waters, to be in play with the Asians. Europe however couldn’t create monopolies. After years of conflict and many revolts by shareholders who wanted the company to wind down rather than grow, the company was re-chartered rather than liquidated after twenty-one years, the directors got the flexibility to lower dividends (amongst partners) when they needed to build up capital, and Dutch investors learned to operate like shareholders today.†Ã¢â‚¬  The idea of companies that took care of their own protections costs did not last, of course.† â€Å"by the 1830’s all these companies had collapsed, and their colonies had been taken over by governments-just as a new era of capital-intensive industry was about to create more productive uses or the corporate form that they had pioneered.† The World That Trade Created is a history of society, culture, and economics. It taps in tp the painful and brutal truth of our global economy system. Modern world emerges with varied foods, advanced societies, a background of poverty and violence and monopolies and so on and so forth. The society aspect touches base on the trade of slaves. These slaves would mine necessities like gold, silver, cotton, tobacco, coffee, tea, sugar and rubber on plantations in different regions. Culture like Christianity came ion hand with the law. Culture and central planning were works in progress acting on one another’s evolutionary development. The economy of it all deals with so many trade tactics. It helps readers understand that economic activity cannot be divorced from social and cultural contexts. It was made from flesh and blood to its relevance today. The relevancy of the books information today outlines moral economy and how its being held somewhat fair today. It also relates to market economy to understand our world. Nature and culture continue to transform economics today. As much understanding there is of economics it is still playing out and unwinding today. It continues to have situations that need fixing and is still being debated over today. Economy ultimately impacts society.

Impacts of media violence on violence against women

Impacts of media violence on violence against women Media Violence as a Causal Agent for Violence Against Women Through Desensitization, Reinforcement of Gender Roles for Women, and Social Learning Theory. Media Violence as a Causal Agent for Violence Against Women Through Desensitization, Gender Roles of Women, and Social Learning Theory In the span of about one century the western world has made significant strides to amend the discrepancy in equality between women and men (Crow Gotell, 2004). Beginning with the first wave of feminism in the nineteenth and early twentieth century, the official rights of women were sought and established, resulting in important and favourable amendments to the existing legislation, such as womens right to vote (Johnson-Odim, 1991). Nonetheless, inequalities between women and men were not confined to court documents and legislation, rather they extended further into the community (Johnson-Odim, 1991). As a response to this the second wave of feminism took precedence to address unofficial, social issues including those related to sexuality, the workplace, and reproductive rights (Johnson-Odim, 1991). Yet, and despite the contributions made by both movements, several issues remain on the changing and diverse identity of women (Crow Gotell, 2004).In response to this, the third wave of feminism was dedicated to refuting the notion of a universal female identity and instead prioritizing diversity among women (Crow Gotell, 2004). Ultimately, however, the forms of violence and aggression toward women have evolved, become more subtle and implicit, but equally unjust (Rice, 2005). That is, although womens rights and freedom are made present on the surface, there continues to be questionable events that threaten the dignity of women (Rice, 2005). Specifically, popular media has played a significant role in facilitating, as well as perpetuating, violence against women (Bocock, 2006). With liberalism becoming more adamant in western culture, the visual depictions of women to capitalize on products and services has become normalized (Bocock, 2006). As a result, women are often directly associated with sex and sexuality, completely negating the rest of their being (Bocock, 2006). Currently, there is a large body of research dedicated to exploring the relationship between violent media and aggression, but few studies have been done to specifically address the transition between exposure to violent media and committing acts of violence towards women (Ferguson, San Miguel, Hartley, 2009). Because this issue is still a relative novelty, it is important to be cognoscente of extra variables that influence violence towards women in real life, all of which should be considered and weighed. However, the intent of this review is to decons truct the ways in which violence in the media, specifically in television, can facilitate and perpetuate violence towards women in real life. The type of real life violence under consideration focuses on physical and sexual violence, as well as negative stereotypes and attitudes about women. Although several perspectives and paradigms can be used to explain the contributions to violence towards women, this review will detail the mechanisms of psychological desensitization, reinforcement of womens gender roles, and social learning theory to analyze the role of violent media as a contributing factor in violence towards women. To begin, and as aforementioned, the exploration of the relationship between media violence and real life violence is not a new subject, rather an ongoing quest to further break down the phenomenon. A common reoccurrence is the issue of media violence and the desensitization of traits that allow us to associate inappropriate acts with human suffering (Fanti, Vanman, Henrich, Avraamides 2009). Fanti et al (2009) define desensitization as diminished emotional responses to a negative or adverse stimulus after repeated exposure to it. Essentially, repeated exposure to media violence can habituate adverse reactions, voiding a persons innate and natural negative response when viewing violence (Fanti et al, 2009). One plausible explanation for the way desensitization works is that exposure to violent media eliminates inhibitions to violence, which in turn may foster pro-violence attitudes and lower empathic responses (Fanti et al, 2009). This proposal further confirmed by Fanti et al (2009 ) in their empirical study, in which they exposed young adults to violent or comedic television clips. They hypothesized that repeated exposure to violent media would not only lower the empathic responses of participants, but also increase their levels of enjoyment when watching violent media (Fanti et al, 2009). Ultimately, their study showed that desensitization to media violence can occur after repeated exposure to media violence, and that these results can be seen in a short-term period (i.e. desensitization does not need extensive time to develop) (Fanti et al, 2009). In addition the researchers found that with repeated exposure to violent media not only was the psychological impact and sympathy of the participants reduced, but they reported an increased enjoyment of viewing violent media (Fanti et al, 2009). To further strengthen their results, the researchers were also able to discount existing personality traits (i.e. aggressive individuals) as being correlated with desensit ization (Fanti et al, 2009). However, there is an extensive body of research that counters the argument that media is accountable for violence, and instead analyzes other factors that have a heavier contribution to anti-social acts like violence. To illustrate this, a study by Ferguson et al (2009) looked at 603 youths in Texas, half of which were male and half female. Their aim was to evaluate the multiple variables that are associated with violent behaviour in youth (Ferguson et al, 2009). They found that in comparison to exposure to violent television, the most influential factors on the existence of aggressive behaviour were: delinquent peer influences, anti-social personality traits, depression or depressed mood, and parents or guardians who use psychological abuse in their personal relationships (Ferguson et al, 2009). These results undermine the argument, as proposed by Fanti et al (2009), that violence in the media is the most influential agent in desensitization, leading to violent real-life behaviour by the viewer. Although it is certainly important to consider the multivariate relationship linked with acts of violence or aggression it is important to acknowledge how detrimental violent media can be. The argument that violent media can desensitize individuals and disinhibit their violent impulses or behaviour can be supported within a biological framework (Strenziok, 2010). In a study by Strenziok et al (2010) 37 healthy male participants were tested to analyze the relationship between their exposure to media violence and left orbitofrontal cortex density (LOFC) as mediated by synaptic pruning. Because the orbitofrontal cortex is responsible for important regulatory functions, such as decision-making, social adjustment, and inhibition, any changes that occur in the cortex as a result of pruning can have significant effects (Strenziok et al, 2010). When synaptic pruning occurs the process happens within context (Strenziok et al, 2010). That is, the en vironment plays a major role in selecting which neuronal connections will be pruned and which will be maintained (Strenziok et al, 2010). Strenziuok et al (2010) found that there was a negative correlation between exposure to violent media and left orbitofrontal cortex density. Their findings suggest that media violence can facilitate synaptic pruning in the LOFC, which then short-circuits/decreases neuronal connectionsultimately disrupting normal orbitofrontal cortex functions and allowing for anti-social violent behaviour (Strenziok et al, 2010). Furthermore, the desensitization process and the serving biological functions can be applicable to violence towards women. In a society that upholds equality, freedom, and rights as priorities, there continues to be sensationalized displays violence in the media. One study aimed to examine the effects of repeated exposure to sexually violent films on emotional desensitization toward victims of domestic violence and abuse within sample of 138 males. (Mullin Linz, 1995). The results showed a decrease in emotional response, physiological arousal, and ratings of how sexually violent the films were with repeated film exposure (Mullin Linz, 1995). These statistically significant results were relative to the results of the control group, and lasted for three days. That is, when re-evaluated three days after the initial experiment, the results remained static (Mullin Linz, 1995). However, it is important to also acknowledge that these results did not extend further than three days (Mullin Linz, 1995). When tested again five days after the initial experiment, participants baseline responses were restored, essentially suggesting that the effects of sexually violent films were only maintained for a limited and short-term period (Mulling Linz, 1995). The authors suggest that the results may reflect a lack of ecological validity in the study, since exposure to violent media is longer and more continuous over time compared t o exposure in a clinical setting (Mullin Linz, 1995). What this implies then, is that in a real life setting these results may be inapplicable and possibly irrelevant to violence towards women. Above differential perspective, what this study ultimately supports is the existence of a strong relationship between exposure to gender-based, sexually violent films and overall desensitization (Mullin Linz, 1995). Lastly, a study by Linz and Adams (1989) measured physiological desensitization (i.e. heart rate) and its relation to cognitive, affective, and attitudinal components of desensitization. Participants were exposed to either a videotape depicting violence against women or a videotape of non-violent, but exciting content (Linz Adams, 1989). Then all participants watched video clips of violence towards a woman, with a male as the aggressor (Linz Adams, 1989). Linz and Adams (1989) found that heart rates of participants in the violent videotape condition were lower during the final 90 seconds of each violent video clip compared to the control group. In addition, participants in the violent videotape condition attributed less injury to the female victims portrayed in the media in comparison to the control group (Linz Adams, 1989). To further delineate the contrast between the experimental and control conditions, the control condition experience significant increases in hostility, anxiety, and depression during the violent video clips- a testament of their adverse responses to and disapproval of violent media (Linz Adams, 1989). Ultimately, based on the growing body of literature on violence and media, there is significant evidence to support the role of exposure to violent media and its facilitation of real life violence, as it pertains to women. Such evidence not only addresses sociological perspectives of desensitization, but also provides psychophysiological support to explain the biological processes that enable such a relationship. Because humans tend to be swayed from and influenced by several variables, it is important to further analyze sociopsychological and cultural variables in the relationship between media violence and women. Specifically, gender norms and roles as they relate to women will be discussed in the context of media and real life violence. Although these roles and norms are an integral part of our identity beginning from birth, one must consider the unanticipated consequences. Often times with such social and cultural standards there runs a risk of placing individuals into very concise and finite societal niches, which may be difficult to break free from. For example, in western societies, the moment a baby is born he or she is often assigned a colour, according to gender appropriateness, be it pink or blue. The process of socialization begins from the moment an infant is introduced into society. From that moment onward, the child is brought up to meet societal and cultural standard of correc t ways of being, according to their sex. Unfortunately, this strenuous and confining process is difficult to stray away from, and individuals who attempt to establish themselves as persons first, rather than male or female, often experience disapproval, backlash, and even social isolation. In addition, the role of the media has been another influential means by which to enforce norms and roles in western worlds. Specifically, recent literature has proposed arguments that violent media reinforces the self-image of women in accordance with gender roles, and can even foster intra-female real life violence. What this implies then is that not only is violence towards women a reality, but that women themselves are now engaging in their own demise and contributing to the same hegemony that oppresses them. Although it was traditionally understood within the scientific realm that aggression is primarily related to males, and that aggression is singular in nature (i.e. direct, physical), rece nt literature is debunking this claim. Specifically, indirect aggression, which is not physical or explicit, in female-female relationships has take centre stage (Bjorkqvist, 1994). In theory, there is no reason to suggest that women are as violent as men, considering their physical ability. In reality, however, women have adapted to this difference by using indirect hostility and aggression by way of verbal and social manipulative (e.g. spreading rumours, excluding peers, etc) acts as a means of being violent ( Bjorkqvist, 1994, Cote, 2007). Bjorkqvist (1994) suggests that this indirect aggression can even be considered more sophisticated and powerful than conventional aggression (i.e. physical) because the aggressor is able to harm another person without being identified. However, the nature of aggression displayed by women and men cannot be solely attributed to biological or physiological differences. Social and cultural variables, and their influence on learning help perpetuate these modes of aggression (Bjorkqvist, 1994). With violent media being so pervasive and omnipresent, particularly as it relates to women, it is important to explore its effects on real life actions. Ringrose (2006) examines the way in which media sensationalizes indirect violence, now being referred to as the mean girl phenomenon and the implications it brings forth. This novelty depiction of women poses a bilateral problem, in that aggression is often synonymous with power but remains as a type of behaviour frowned upon in women. For example, Gonick(2004) proposes that the stereotypical vulnerable girl has now been replaced by the mean girl in the public eye. What would be ideal is to avoid polarizing womens behaviour, or homogenizing them into black or white categories, figuratively speaking. Nonetheless, what is ideal is rarely reality. Although the recent creation of the mean girl in the media appears to provide equality between women and men, as it provides an over reactive res ponse and antidote to the idea that women are nurturing and not aggressive, there a are serious side effects to this new sensation (Gonick, 2004). The pervasive presence of this construction of the mean girl in the media is now redefining normal behaviour for women and girls, allowing femininity and aggressive behaviour to be re-pathologized (Ringrose, 2006). Now that popular media, specifically televised and print media, is disguising indirect female-female aggression behind the facade of female empowerment, a new template of appropriate girl and women behaviour is being inherited by newer generations. The media often portrays indirect violent behaviour as exciting, dramatic, sexy, and especially as a marker of status and power. For example, feature films such as Mean Girls and Thirteen glorify indirect and relational aggression, depicting relating such behaviour to physical attractiveness, popularity, and success. Not only are such media positing that such behaviour is appealing a nd even glamorous, but is also negates all other equally important aspects of existence, such as stable family relationships, and a breadth of education. In addition to assigning indirect aggression as a vehicle of power, violent media also sets up such aggression to take place in female to female social relationships. It is often said that a civilization destroys itself from within rather than being conquered by outsiders and the western female population exemplifies this heuristic. That is, because violent media sensationalizes indirect aggression in female-female relationships, the integrity with which women relate and identify with one another is compromised. As such, this population is left vulnerable and more susceptible to patriarchal standards of life, and is once again turned into a commodity that can be regulated according to trends and demands. A study by Lavin and Cash (2000) demonstrates the complex relationship between violent media portrayals of women and real life in direct aggression in female-female interactions. They conducted an experimental study to break down and examine the effects of mass media and womens body-image experiences (Lavin Cash, 2000). In this study 66 college women were made to listen to one of two audio tapes: one containing information on the subject of appearance stereotyping and discrimination and the other containing information on television violence aggression (control condition) (Lavin Cash, 2000). At the conclusion of their study they found that although neither condition differed in the altered mood of the participants, exposure to t he appearance-related condition versus the control condition yielded significantly less favourable body-image evaluations (Lavin Cash, 2000). The results, produced by Ten Visual Analogues Scales and the 14-Item Appearance Schemas Inventory, demonstrate the ways in which western media showcases beauty and physical attractiveness in conjunction with covert and overt social benefits (L avin cash, 2000). In addition, the violent media often depict strong associations between beauty and desirable traits. That is, women are learning that beauty is good, and that is it the most important factor in leading a fulfilling life is the virtue of beauty. Because of this trend in the media of using womens physicality as commodities and means to capitalize and turn a profit, women become more invested in their aesthetic selves. In turn, women who have deep psychological investments with their self aesthetics become more susceptible to adverse social events, such as negative feedback about their weight or comparison cues (Lavin Cash, 2000). Such events become critical experiences, and pose the possibility of increased body dissatisfaction. For example, the images of dismembered women in print ads are rampant. What is meant by dismemberment is that only parts of womens bodies are used to sell a product of service. A good illustration of this is the prototypical beer print ad, in which the only thing visible is a womans torso with specific attention paid to the bust, followed by a posing hand holding a beer bottle. Such media pays no attention to the woman in question, rather reduces her to specific anatomical parts, in total disconnection to her individual self. In fact, a face is not only unnecessarily in such violent media, but is also obstructive because violence is more acceptable when identity is unknown (CITATION). Ultimately, violent media not only encourages and portrays indirect aggression as a means of power and representation of status, but also regulates its usage in womens relationships with one another, such that women become active participants in their own oppression and violence. To add to this, women also internalize their roles in western society as portrayed by the media. That is, women begin to see themselves and their bodies in terms of their sexual and aesthetic worth, disregarding other important aspects of their lives. Clearly, t he role of violent media cannot be ignored in light of the consequences it brings. This is not to imply that violent media the sole cause of such effects, as there are other variables to consider. There is a significant amount of research that supports the argument that exposure to violence and aggression enacted in parental relationships in the home have the most significant impact on violence inRather, the aforementioned information should be used to support the significant contributions and influences between violent media and violence towards women. Another mechanism by which violence in the media influences violence in real life violence is through the social learning theory. Bandura (1978) defines the social learning theory as a process in which people learn new behaviours by observing the behaviours of others, and assessing the benefits of exhibiting that behaviour to determine whether the behaviour will be sustained over time. That is, if the behaviour in question results in positive outcomes, then the observer is more likely to display this behaviour (Bandura, 1978)