How do we explain the stance of the Fatimid Empire towards the Essay - 1

How do we explain the stance of the Fatimid Empire towards the Crusades - Essay Example Jerusalem, which was a Christian group, wanted to end the ruling of the region by the Muslims who had controlled the region for numerous periods. The war against the crusades, which was known as the Jihad, lacked organization and diplomacy because of social, religious, and political differences among the Fatimid Muslims (Hillenbrand, 1999). At times, the Fatimids supported the crusades while at other times they opposed the Christian movement. This essay will analyze the different stances taken by the Fatimid Empire towards the crusades. An analysis of the religious origin and differences among the Fatimids is essential because it will help in understanding the stance of the group towards the crusades. Muslims lived as one religious group when they were ruled by Prophet Mohammed before his death in 632 AD (Carl, 1977). However, when the prophet died, his followers split into two groups on the basis of misunderstandings concerning his successor. The groups were the Shia who believed th at the prophet’s successor was Ali, and the Sunni who claimed that the spiritualist had not named anyone to succeed him as the leader. The Shia established the Fatimid Empire by holding onto their belief that Ali was their leader after Mohammed and following the teachings and the rulings of their new spiritualist. The Shia gained fame in the muslim lands of the Middle East when the Ismaili Shiites in the region supported their religious and political beliefs (Brett, 2007). The group built their empire in Tunisia where they had acquired full support then extended to the entire region (Poole, 1968). The rise of the Shia in the Muslim region and the support that they gained from the Ismaili Shiites split their ideologies and those of the Sunni further. The Seljuks who supported the Sunni became open enemies of the Fatimids (Andrea, 2003). The enmity of the groups developed from being only religious into political and social such that they exclaimed their opposition in public. Wh ile the enmity of the Fatimid and Seljuks rose, the Fatimid Empire extended its ruling to Egypt from Tunisia. The group founded an empire in Cairo, in Egpyt, a location that made it possible for them to rule in the whole of the Middle Easter region including Syria, Palestine, Baghdad, Arabia, and the highlands of the Mediterranean (Adib-Moghaddam, 2008). The first crusade took place in Egypt in 1096 when Pope Urban 11 urged Christians to conquer Muslims in the region. The Pope urged Christians to abandon their homes and help in the fight against Muslims so that they could recover Jerusalem from this religion. Christians wanted to recover Jerusalem from the Muslims because it is their Promised Land in the bible (Carl, 1977). The land of Jerusalem was fertile and it produced plenty of food that fed the inhabitants of the town while people from other regions of Europe died from hunger and poverty. Having persuaded the Europeans, the first crusade was made of soldiers from France, Italy , Normandy, and Flanders (Poole, 1968). The first crusade was so organized that the Fatimids were incapable of defending themselves from the brutality and massacres of the European soldiers. The Muslims were incapable of defending themselves partly because they lacked organization like the soldiers of the first crusade, and also because they misunderstood the aim of the arrival of Christians in their land. The misunderstanding of the Christians’

East and Central European countries Essay Example | Topics and Well Written Essays - 2000 words

East and Central European countries - Essay Example uted leaders of technological change are the countries of Western Europe, the United States and Japan, with a high technological culture and monopolize major breakthrough technology of recent decades, in fact already entered the phase of post-industrial development, successfully addressing the socio-economic objectives. In pursuit of the leaders the countries of South-East Asia and China stepped up on the way to build the innovation economy. (Lavigne, 1992) In recent years, many countries of Central East Europe and CIS are actively moving towards the socio-economic modernization and striving for adapting to the rapidly growing processes of globalization, also announced an innovative course as a priority in their development. However, none of the post-socialist countries has been able to integrate in terms of technologically advanced countries, being mainly on the periphery of the global economy. The basis of the structural change and technological upgrading of Central/East European countries is the policy of their governments, aimed at creating a favorable investment climate, ensuring a serious income of foreign investment. In general foreign companies by the end of 2003, invested in the economies of Central/East Europe 162 billion dollars. About the number of foreign investment in national economy of these countries shows the percentage of volume of accumulated investments in GDP, which amounted for Czech Republic 52%, Hungary - 44, Slovakia - 40%. (Inglot, 2008) Among the major foreign investment companies operating in the market in these countries, there are such well-known multinationals as Opel, Volkswagen, PSA, Audi, Toyota, Daewoo, General Motors, Nokia, Philips, Bosh, IBM, Hewlett Packard, General Electric, Electronics, Ford, Suzuki, Sony, Sanyo, Electrolux and others in the field of view of their interests are mainly in the automobile industry, electronics, manufacturing of computer and telecommunications equipment, pharmaceuticals and chemical

Theories for the Evolution of Alarm Calls

Theories for the Evolution of Alarm Calls Alarm Call Evolution: Altruism or Kin Selection? Taylor Rystrom Introduction Humans have always been fascinated by animal communication. One important manifestation of animal communication is alarm calls. Alarm calls, even functionally referential alarm calls, can be observed across many different species. Prairie dogs give alarm calls specific even to the shirt color that a nearby human is wearing (Slobodchikoff 2009). Male blue monkeys give alarm calls that are specific to predator type, distance, and location (Murphy et al. 2013). Even African elephants, who have relatively few predators, give alarm calls when they hear the sound of bees (King et al. 2010). But why did these alarm calls, a seemingly altruistic act, evolve in so many different animal groups? How did some get so specific? Sherman lays out six interesting theories of the evolution of alarm calls. Alarm calls could have evolved to divert the attention of the predator, discourage the predator, alert relatives of the caller, help the group which the caller resides in, reduce the later return of the predator, or warn others who will reciprocating at a later time (Sherman 1977). The main findings have suggested that alarm calls have either evolved as an altruistic act, possibly with reciprocity among the group, or as a mechanism to protect kin (Trivers 1971, Sherman 1977). As for functionally referential alarm calls, meaning that the alarm calls encode specific information about the predator, evolution has been suggested as a response to the need for different escape methods from different predators due to the habitat of the group (Furrer and Manser 2009). Altruism Theory Although Koenig (1988) points out that there is no commonly accepted definition of altruism in behavioral ecology (Koenig 1988), it can be explained for the purposes of this review as an act that has a cost to the individual and a benefit for others. Reciprocal altruism, which Trivers argues to be present in alarm-calling birds (Trivers 1971), would be a type of altruism which benefits the individual only when another party reciprocates the act toward the first individual (Koenig 1988). Trivers suggests that alarm calling in birds is reciprocal altruism because alarm calling keeps predators from specializing on the location and species of the caller (Trivers 1971). However, Koenig points out that reciprocal altruism is still speculative in birds (Koenig 1988). Furthermore, it is unlikely; if alarm calling is altruistic and natural selection acted on the individual that had the novel gene for alarm calling, the animal would have no increase in fitness, the gene would not spread, and t he trait would not evolve (Charnov and Krebs 1975). This being said, if alarm calling is an altruistic behavior, it must have evolved because of some benefit to the caller (Charnov and Krebs 1975). One speculation is that an alarm call could encode the presence of a predator but leave out the location of the predator, thus causing confusion of the dispersal of the flock while the caller knew exactly how to escape the predator (Charnov and Krebs 1975). However, it has been found that male blue monkeys can in fact encode the predator distance and location, thereby giving all immediate information to their conspecifics (Murphy 2013). Problems arise in this theory when specific species of birds are studied more closely. The alarm calls of one species of jay, the Siberian jay, were closely analyzed due to the nature of the groups of this species of jay. In this species, the jays live in social groups comprised of one dominant breeding pair, their offspring, and sometimes non-related immigrant birds (Griesser and Ekman 2004). If alarm calling is altruistic in this species, the dominant breeding pair would call whenever a predator is nearby, regardless of whether they were with immigrants or kin (Griesser and Ekman 2004). However, the results showed that females called only during the breeding season while their kin was present, while males called indiscriminately (Griesser and Ekman 2004). This raises further questions about the intentions of males; do they call indiscriminately to selfishly protect future mates or to dilute a predator attack by providing benefits to immigrants in the group to reduce the caller†™s chance of being attacked? Willow tits also give alarm calls, but Hogstad (1995) suggests that this is a form of mate investment and evolved for this purpose. Males are dominant and breeding pairs last for several years, so if a female dies, especially during the winter, the male partner will likely be unpaired the following breeding season (Hogstad 1995). Adult willow tit males gave alarm calls more frequently when they could see their mates than when they could not; this implies that alarm calling for this species is primarily a form of mate investment (Hogstad 1995). Since the benefit of having a mate the following season is fairly large for a male willow tit, this is not an altruistic act. Studies regarding animals other than birds suggest that alarm calling is not an altruistic act. Alarm calling would only be categorized as altruistic if the calling was costly to the caller in some way (Koenig 1988). Round-tailed squirrels only give alarm calls when they are already retreating, thus not endangering themselves (Dunford 1977). Marmots do not reduce their own chances of survival because they rarely call when exposed to predators, and their calls are acoustically difficult to detect by predators (Barash 1975). There is no real threat to either of these species when they give alarm call, thus destroying the option of alarm calling being altruistic. Furthermore, yellow-bellied marmots can identify who produced an alarm call and will ignore calls after many false alarms (Blumstein and Daniel 2004). Although this seems to support the hypothesis for reciprocal altruism since identification of false callers is important for the reciprocity, there are no known cases of which ro dents take turns calling. Kin Selection Theory The kin selection theory requires that kin be nearby when alarm calls are given for the function of alerting kin of danger. Kin selection is not altruistic because protecting offspring and other kin is a way to protect the future of one’s own genes. The evolution of alarm calls due to kin selection is definitely dependent on the social system of the species. Belding’s ground squirrels have a social system where females generally stay in their natal territory their whole lives and males are polygynous, do not defend any mates or offspring, and emigrate from their natal territory alone, constantly moving after they mate (Sherman 1977). Sherman (1977) found through an extensive observational study that females call frequently when relatives are nearby and do not call at all when they have no living kin; meanwhile, males rarely call. In another study regarding ground squirrels, Dunford (1977) found that males do sometimes call – but this is only when they are juvenil es and their mother and siblings are near. Sherman (1977) hypothesized that the function of alarm calling is nepotism, and that the evolution of this behavior is due to kin selection. Similar results are found with Gunnison’s prairie dogs (Hoogland 1996). Females with kin in the same territory called more often than females who did not have nearby kin. This species has a slightly different social system than Belding’s ground squirrels. Males guard 3-4 females and move between adjacent territories, and it was observed that males give alarm calls regardless of whether or not they had kin in the territory (Hoogland 1996). It is likely that the males had kin in adjacent territory, so these kin could theoretically be close enough to benefit from an alarm calls. These prairie dogs assess their own personal safety before calling, as they are more likely to call if they are farther from the danger (Hoogland 1996). Previously it had been found that male Black-tailed prairie dogs only give alarm calls only after they sire offspring in the territory (Hoogland 1983). These studies show extreme support for the hypothesis that alarm calls evolved as a form of sele cting for kin. A study on chipmunk alarm call behavior offers support that there could be a reciprocal altruism component to the maintenance of alarm calling in the species (Smith 1978). This is because they are one of few species in which all members of the group can and do give alarm calls (Smith 1978). Although kin selection was most likely the basis for the evolution of the behavior since older females with many nearby daughters give the most alarm calls (Smith 1978), it is interesting that both seemingly opposing hypotheses can work together. When yellow-bellied marmots call, the spotted predators almost always leave. However, not all of these marmots call. Blumstein and Armitage (1975) found that the calling is generally a safe activity for these marmots so there is not much cost associated with alarm calls. Their hypothesis is that some individuals do not call because they are trying to reduce reproductive competition (Blumstein and Armitage 1975). Females are the most likely to call, and only when they have vulnerable young. So if another female refrains from calling when she spots a threat, she will reduce the competition for her young since the most vulnerable are the young which are ignorant to the threat (Blumstein and Armitage 1975). Further Extensions and Conclusions There are also factors which affect the complexity of alarm calls, including the level of sociality and habitat composition of species. Sociality and communicative complexity were compared across three different sciurid rodents, and only in marmots did communicative complexity increase with sociality; there was no correlation for prairie dogs or squirrels (Blumstein and Armitage 1997). This implies that alarm repertoire size has many factors, such as facial and laryngeal morphology and habitat acoustics (Blumstein and Armitage 1997). Habitat could influence the evolution of functionally referential alarm calls because if different escape routes are needed for different predators due to the physical nature of the habitat, then it would be beneficial to your survival to have different alarm calls for each type of predator to streamline the escape (Furrer and Manser 2009). However, this hypothesis is not completely supported by data. In Gunnison’s prairie dogs, the habitat does i nfluence the alarm calls; they have been found to change their alarm call dialects for different levels of vegetation cover (Perla and Slobodchikoff 2002). However, meerkats and Cape ground squirrels live in the same habitat yet only meerkats have functionally referential alarm calls; thus habitat does not have a profound influence on the evolution of functionally referential alarm calls (Furrer and Manser 2009). The continuing evolution of alarm calls into more complex communication like functionally referential alarm calls is an important angle of study. How much of alarm call behavior is learned? Female Campbell’s monkeys produce three alarm calls in the wild but only two in captivity, one of which is not observed in the wild (Oattara et al. 2009). This implies that the capacity for alarm calling evolves, but not fully utilized if not needed. This study also suggests that in order for alarm call behavior to be expressed in a population, the threat of predation must be large. Since captive monkeys do not have predators, they have lost vocalizations associated with this danger (Oattara et al. 2009). The evolution of alarm calls is no simple matter. When factoring in the specific ecology of each species studied to give alarm calls, it all comes down to each species’ life history. It makes sense evolutionarily for a species which live in social groups comprised of kin and non-related individuals to call to warn kin, and if only females live near kin, for females to predominantly call. However, if a species lives in a different type of social group, alarm calling does not necessarily have to function as a way to warn kin. Alarm calling in species of many different types of social groups should be studied in regards to the hypotheses offered by Sherman (1977) in order to find support for other evolutionary drivers as well as reciprocal altruism and kin selection. Literature Cited Barash, David P. Marmot Alarm-Calling and the Question of Altruistic Behavior.American Midland Naturalist94.2 (1975): 468. Print. Blumstein, Daniel T. The Evolution of Functionally Referential Alarm Communication: Multiple Adaptations; Multiple Constraints.Evolution of Communication3.2 (1999): 135-47. Print. Blumstein, Daniel T., and Janice C. Daniel. Yellow-bellied Marmots Discriminate between the Alarm Calls of Individuals and Are More Responsive to Calls from Juveniles.Animal Behaviour68.6 (2004): 1257-265. Print. Blumstein, Daniel T., and Kenneth B. Armitage. Does Sociality Drive the Evolution of Communicative Complexity? A Comparative Test with Groundà ¢Ã¢â€š ¬Ã‚ Dwelling Sciurid Alarm Calls.The American Naturalist150.2 (1997): 179-200.JSTOR. Web. 14 Mar. 2014. Blumstein, Daniel T., and Kenneth B. Armitage. Why Do Yellow-bellied Marmots Call?Animal Behaviour56 (1998): 1053-055.JSTOR. Web. 1 Mar. 2014. Charnov, Eric L., and John R. Krebs. The Evolution of Alarm Calls: Altruism or Manipulation?The American Naturalist109.965 (1975): 107-12.JSTOR. Web. 15 Mar. 2014. Dunford, Christopher. Kin Selection for Ground Squirrel Alarm Calls.The American Naturalist111.980 (1977): 782. Print. Furrer, RomanD., and MartaB. Manser. The Evolution of Urgencyà ¢Ã¢â€š ¬Ã‚ Based and Functionally Referential Alarm Calls in Groundà ¢Ã¢â€š ¬Ã‚ Dwelling Species.The American Naturalist173.3 (2009): 400-10. Print. Griesser, Michael, and Jan Ekman. Nepotistic Alarm Calling in the Siberian Jay, Perisoreus Infaustus.Animal Behaviour67 (2004): 933-39.Science Direct. Web. 14 Mar. 2014. Hogstad, Olav. Alarm Calling by Willow Tits, Parus Montanus, as Mate Investment.Animal Behaviour49.1 (1995): 221-25. Print. Hoogland, John L. Nepotism and Alarm Calling in the Black-tailed Prairie Dog (Cynomys Ludovicianus).Animal Behaviour31.2 (1983): 472-79. Print. Hoogland, John L. Why Do Gunnisons Prairie Dogs Give Anti-predator Calls?Animal Behaviour51.4 (1996): 871-80. Print. King, Lucy E., Joseph Soltis, Iain Douglas-Hamilton, Anne Savage, and Fritz Vollrath. Bee Threat Elicits Alarm Call in African Elephants. Ed. Karen Mccomb.PLoS ONE5.4 (2010): E10346. Print. Koenig, Walter D. Reciprocal Altruism in Birds: A Critical Review.Ethology and Sociobiology9.2-4 (1988): 73-84. Print. Murphy, Derek, Stephen E.g. Lea, and Klaus Zuberbà ¼hler. Male Blue Monkey Alarm Calls Encode Predator Type and Distance.Animal Behaviour85.1 (2013): 119-25. Print. Ouattara, Karim, Klaus Zuberbà ¼hler, Eliezer K. Ngoran, Jean-Emile Gombert, and Alban Lemasson. The Alarm Call System of Female Campbells Monkeys.Animal Behaviour78.1 (2009): 35-44. Print. Perla, Bianca S., and C. N. Slobodchikoff. Habitat Structure and Alarm Call Dialects in Gunnison’s Prairie Dog (Cynomys Gunnisoni).Behavioral Ecology13.6 (2002): 844-50.Oxford Journals. Web. 6 Feb. 2014. Sherman, P. W. Nepotism and the Evolution of Alarm Calls.Science197.4310 (1977): 1246-253. Print. Slobodchikoff, C. N., Andrea Paseka, and Jennifer L. Verdolin. Prairie Dog Alarm Calls Encode Labels about Predator Colors.Animal Cognition12.3 (2009): 435-39. Print. Smith, Stephen F. Alarm Calls, Their Origin and Use in Eutamias Sonomae.Journal of Mammalogy59.4 (1978): 888. Print. Trivers, Robert L. The Evolution of Reciprocal Altruism.The Quarterly Review of Biology46.1 (1971): 35. Print.

Butler Lumber Finance Case :: Business, Case Study, solution

Statement of firm’s position Butler Lumber Company is looking for more cash due to a fast-paced lumber market and a shortage of funding. Their regular bank, Suburban National Bank, is not willing to expand their exiting loan to an amount greater than $250,000 without securing the loan with real property. Another loan is being offered by a second bank, Northrup National Bank, for $465,000, with the understanding that the previous loan would be rolled into the second. The interest on the new loan would be prime + 2%. The co-founder, Mark Butler, owes a major note to the other original partner, who Mark bought out. He has a mortgage on his 12-year-old house and no other significant investments. Mark’s personal references indicate that he is hard-working and watches his business very closely. Mark’s current outstanding debts are as follows: Bank note for $247,000 Outstanding debt from trade partners $157,000 Accounts payable $343,000 Accrued expenses $51,000 Current portion of long-term debt $7,000 Long-term debt $43,000 Total liabilities $848,000 Net income is projected at $56,000 based on projected sales of $3.6m. Butler’s business relies more heavily on the repair industry than on new construction, so it is somewhat protected against market fluctuations on new construction. Major recommendations Northrup National Bank should extend the loan to Butler. The company will roll much of its existing debt into the new loan, without extending itself significantly further than it currently is, and at a more favorable rate. Butler has been successful in keeping current on its debts, and based on projections should have the means to start paying these debts down. From the bank’s perspective, there’s little risk involved. With the industry expected to grow so much in the next year, Butler will be in a strong position, and potentially interested in borrowing more at the end of 1991. Butler Lumber Co. should take the short term loan and if necessary roll the $157,000 trade credit into it. Nature of the problem Butler’s short-term loan options are completely maxed out, so the company has no cash flexibility. Inventory levels indicate Mark is ramping up in expectation of the massive influx of sales in the warmer months. More of Butler’s sales are in the warm months, when repairs are easier to make in the Inland Northwest. The loan will give Butler the ability to finance more inventory to meet the expected growth in sales.

Purpose, Audience and Tone

This essay offers explanation to Mahmoud Darwish's, â€Å"A Gentle Rain in a Distant Autumn†. We will go through analysis on what he's trying to tell us, who he is trying to talk to and how he's delivering this message. â€Å"A Gentle Rain in a Distant Autumn† is mainly about three matters. The Poet's feelings and emotions towards the situation in Palestine and how he relates to it, the actual situation in Palestine and his one and only desire. The poet's purpose is to take us on an emotional Journey of his melancholy using simple terms intertwined together to form metaphors and imagery hat best portrait the morbid and sad image of Palestine.He is addressing anyone who has affinity towards the subject of Palestine or otherwise. First, he talks about a major sadness in his poem â€Å"A gentle Rain in a distant autumn† (01 which symbolizes the death of nature, the death of his own country. A thoughtful sadness, mourning and sorrow through the loss of Palestine domi nate. Palestine remains a memory for the author, a distant memory, a cause that is losing, because of the words he uses: â€Å"running away' (14), â€Å"the birds have flown to lime which will not return† (35),†A kiss sent in the post† (40).He even goes further to Express the beauty of his hometown â€Å"birds are blue, blue† (2), â€Å"windows are white, are white† (11) still in a sad manner followed by how demolished it is now â€Å"my country is the Joy of being in chains† (39). There is a sense of imprisonment and lost lives in the poem that describes Palestine today as a country in â€Å"chains†(39), â€Å"seller of aspirin and death†(24YSlaughtered† (42). He mentioned his â€Å"dead a fetus† (26) which means he is dead before having the chance to live because of his sadness to his ountry.Throughout his poem the poet's repetition of metaphors is not for poetrys sake only. It is for us to understand how persiste nt he is, and what he really wants. He mentions his only desire or all that he wants now is his â€Å"mother's handkerchief†. A mother could never imply anything that is not positive. A mother is another symbol of home and security. He only wants to live through this. He doesn't want anything else. He realizes that his country is in chains and he might not be able to help given that is country doesn't listen to him â€Å"from the country that's forgotten the speech of the distant ones† (28).Darwish's imagery and tone are so powerful he was able to make the reader see eye-to-eye what he wants us to live. Once you go through the poem, you are already in a state of surrender and silence. You appreciate the severity of the situation and his emotional set back towards it. It's not one that is calling for all people to stand up and fght. It is rather the acceptance of what is with a great deal of nostalgia to the past. It is also powerful because I was able to live his exper ience y Just reading his words.His words were simple but they went beyond its evident simplicity to serve the poet a favor to deliver his message easily but with a lot of power because his images resonate. In conclusion, the poet took us on a Journey of emotions. We felt the highs and lows. We were able to see through his commitment to be true to form, to share with us his own perception of reality with a dominant surge of sad imagery. His world will always be his words tn best describe his images and the Palestine ne will always love. at

Scholarly Writing Awareness

While the paragraph focuses on the social reaction towards the development and evolution of computers through the years, the reader can immediately notice in the introductory sentence that the author of the paragraph does not provide scholarly research to support the presumptive claim that there is the â€Å"widespread availability of the personal computer. † Had the author indicated a recognized research or study on the widespread availability of the personal computer, the claim that such a widespread phenomenon has been â€Å"one of the greatest breakthroughs in the past 50 years† could have easily been upheld. Further, substantiating the claim that such a widespread phenomenon has been a breakthrough would have also played a contributing role to the latter arguments stated in the paragraph. The second sentence in the paragraph indicates that the personal computer is a â€Å"powerful learning tool† because of two primary stated reasons: one is its revolutionizing influence on commerce and education, and; two is its effect on â€Å"the very way everyone conducts his or her daily lives. While it is good to indicate the reasons behind qualifying the personal computer as a powerful learning tool, the author failed to take note of the other influencing ‘side’ of the personal computer, which is that the use of it has also already turned into an addiction to some people that it has altered their ways of dealing with other people. The exposition of the other ‘side’ of personal computers is important so as to avoid bias in writing an essay with a scholarly voice. Inasmuch as it balances the pros and the cons pertaining to personal computers, providing a view of both negative and positive influences of these tools is equally significant as it gives the reader a broader understanding of the issue at hand. Moreover, the third sentence of the paragraph shows the hasty generalization of the author by denying the fact that there still remain significant debates surrounding the â€Å"digital divide between those who could afford computers and those who could not. By neglecting that fact, the author then proceeds to assert the claim that â€Å"poor people can now save enough to buy their families a computer for home and school use. † In writing scholarly papers, one should avoid using opinion as a premise or evidence for further arguments as it weakens the very arguments of the author. The opinion that there is almost no more â€Å"digital divide† is not enough to stand as a factual evidence and to support the claim that less fortunate individuals can now actually â€Å"save enough† money for them to be able to purchase personal computers. If the target audience of the author is a group of people who experts or who have sufficient knowledge on the effects and history of personal computers, it is highly probable that the audience will be unable to connect with the statements of the author precisely because there is little evidence used to back-up his arguments. Worse, the audience might simply disagree with the author, with the latter failing to convince the audience or failing to send his message across effectively. If, on the other hand, the audience of the author is a group of individuals who have little to no background knowledge about personal computers and are expecting an objective presentation of ideas from the author, it is most certain that the tendency is for the audience to believe in the claims of the author and, eventually, hold these beliefs as close to being treated as facts. Both of these two instances are not commendable as far as scholarly writing and scholarly voice are concerned because both fail to consider the fact that the author’s writing should be fair and objective, or should render no bias and should make use of accepted facts. In essence, the substance of the paragraph can be improved by citing facts and removing opinion. Doing both things can give the paper and the author more credibility and will not be suspect of unsound arguments and invalid points.

Heart Transplant Essay Example

Heart Transplant Essay Example Heart Transplant Essay Heart Transplant Essay My step-father John had a CARDIAC TRANSPLANT at the age of 53. This story is about him and his journey through all of this. He has been through a lot and is lucky to still be with us. John was outside one day cutting the grass on his riding lawn mower. When all of a sudden he started having this really bad chest pain. He went inside told my mom and she called 911. The ambulance came picked him up and took him to the hospital. When he got to the hospital the doctors started running a ELECTROCARDIOGRAM. They announced he was in CARDIAC ARREST and the doctors gave him NITROGLYCERIN, which made him stabilize. The next day he was seen by the CARDIOLOGIST, and was told he had a heart attack due to ARTERIOSCLEROSIS. Three days later he was rushed to the hospital with the same symptoms. The local hospital air lifted him to Duke Medical Center, where he was diagnosed with CONGESTIVE HEART FAILURE and ANGINA. Once he was at duke, he was told he had a major heart attack and was put in the INTENSIVE CARE UNIT (ICU) for EXTENSIVE MYOCARDIAL INFARCTION. He was told he would have to go on the transplant list. To be eligible for the transplant list, he had to go through numerous test to see if he could handle a transplant. During these test he had to see the PULMONOLOGIST due to having DYSPNEA. The pulmonologist used a BRONCHOSCOPY to look at the inside of the lungs. He was then diagnosed with PULMONARY EDEMA, and told he might not be eligible for a transplant due to the fluid in his left lung and a possible hole in his left lung. They used ENDOTRACHEAL INTUBATION to clear the fluid from his lungs. He spent another week in the intensive care unit (ICU) and his lungs cleared up. The doctor found he did not have a hole in his lung, and he was then put on the transplant list. He got his cardiac transplant one month later. While doing the transplant they had to break his STERNUM which took about 6 months to heal. After the transplant he had to go on IMMUNOSUPPRESSIVE medicines to stop the new heart from rejecting. Two of the major medicines he had to go on were COUMADIN and DIGITALIS. He now has a permanent STENT, due to having a BIOPSY done every 6 months to check for REJECTION. It has now been 10 years since the transplant and he is doing very well. John now has to go to the hospital once a year for a STRESS TEST and CARDIAC CATHETERIZATION to check the condition of the heart. The ANGIOGRAM they receive tells everything about the condition of the heart. He also has to see a UROLOGIST to check the kidneys. The anti-rejection medicine he is on shuts the kidneys down. Above all this he is doing very well and glad to be with us.

Press Freedom of Japan Mongolia and North Korea essays

Press Freedom of Japan Mongolia and North Korea essays In the world today, media is presented in many diverse ways. Through radio, television, magazines, books, newspapers, and the Internet, media is everywhere. Freedom of the press and media does not come as easily for some countries of the world as it does for others such as the United States. Japan, Mongolia, and North Korea are examples of how vastly different press freedom can differ between countries. Japan is a small island chain in Eastern Asia. It is located between the North Pacific Ocean and the Sea of Japan, east of the Korean peninsula. The islands include the Bonin Islands, Daitoshoto, Minami-jima, Okinotori-shima, Ryukyu Islands, and Kazan-retto the volcanic islands. A proportional area of Japans total size could be somewhat smaller than California. Japan is entirely surrounded by water and borders no countries (Japan Geography 1996, p.1). The freedom of the press in Japan is considered completely free. Political parties and government organizations do not control the press in Japan, but some unofficial associations between the press and political figures exist (Karlekar Americans, and American occupation began. The American occupation of Japan was a seven-year period in which the Americans restructured the Japanese government. The constitution was rewritten during this time, and communism ended (Costa, 1997, p.1). Japan became a free country and even gave its media freedom of the press. American occupation ended in 1952 and Japan was left to command itself (Penna, 2002, p.1). The size of Japans media structure is massive. They have the biggest newspaper audience in the world (Fujimoto, Kitada, & Scuka, 2001, p. 1). With five national daily newspapers, 65 larger regional papers, over 70,000 books published every year, thousands of weekly and monthly magazines, television, and broadcast radio,...

Reading Comprehension Assessment and Lessons

Reading Comprehension Assessment and Lessons The ability to read is one of the most powerful tools teachers and parents can give students. Literacy is strongly correlated with future economic  and professional success. Illiteracy, on the other hand, exacts a steep price.  The National Center for Education Statistics notes that 43 percent  of adults with the lowest reading levels live in poverty, and according to the National Institute for Literacy, 70  percent of people on welfare have extremely low literacy. Furthermore, 72  percent of children of parents with low literacy will themselves have low literacy, and are more likely  to perform poorly in school and drop out.   Early and elementary education offers  a key opportunity to break this cycle of economic hardship. And while the mechanics of reading and writing are essential building blocks, reading comprehension allows students to move beyond decoding and into understanding and enjoyment. Understanding Reading Comprehension The easiest way to explain reading comprehension is to put a reader in the position of someone who is deciphering letters and words rather than comprehending (attaching meaning to) them. Try reading this: Fà ¦der ureà °u à °e eart on heofenumsi à °in nama gehalgodto-becume à °in ricegeweorà ¾e à °in willa on eorà °an swa swa on heofenum.Urne ge dà ¦ghwamlican hlaf syle us to-deagand forgyf us ure gyltasswa swa we forgifaà ¾ urum gyltendumane ne gelà ¦de à °u us on costnungeac alys us of yfle. Using your knowledge base of phonetic sounds, you might be able to â€Å"read† the text, but you would not understand what you’d just read. You most certainly would not recognize it as The Lord’s Prayer. What about the following sentence? Fox grape grey shoe on land title base. You may know each word and its meaning, but that doesnt give the sentence meaning. Reading comprehension involves three distinct components: processing text (sounding out the syllables to decode the words), understanding what was read, and making connections between the text and what you already know. Vocabulary Knowledge vs. Text Comprehension Vocabulary knowledge and text comprehension are two vital elements of reading comprehension. Vocabulary knowledge refers to understanding individual words. If a reader doesn’t understand the words he is reading, he won’t understand the text as a whole. Because vocabulary knowledge is essential to reading comprehension, children should  be exposed to a rich vocabulary and should always be learning new words. Parents and teachers can help by defining potentially unfamiliar words that students will encounter in texts and teaching students to use contextual clues to understand the meaning of new words. Text comprehension builds on vocabulary knowledge by allowing the reader to combine the meanings of the individual words to understand the overall text. If you’ve ever read a complicated legal document, a challenging book, or the previous example of a nonsensical sentence, you can understand the relationship between vocabulary knowledge and text comprehension. Understanding the meaning of most of the words does not necessarily translate into understanding the text as a whole. Text comprehension relies on the reader making connections with what hes reading. Reading Comprehension Example Most standardized tests include sections that assess reading comprehension. These assessments focus on identifying the main idea of a passage, understanding vocabulary in context, making inferences, and identifying the author’s purpose. A student might read a passage such as the following about dolphins. Dolphins are aquatic mammals (not fish) well-known for their intellect, gregarious nature, and acrobatic abilities. Like other mammals, they are warm-blooded, give birth to live young, feed their babies milk, and breathe air through their lungs. Dolphins have a streamlined body, a pronounced beak, and a blowhole. They swim by moving their tail up and down to propel themselves forward.A female dolphin is called a cow, a male is a bull, and the babies are calves. Dolphins are carnivores that eat marine life such as fish and squid. They have great eyesight and use this along with echolocation to move about in the ocean and locate and identify objects around them.Dolphins communicate with clicks and whistles. They develop their own personal whistle, which is distinct from other dolphins. Mother dolphins whistle to their babies frequently after birth so that the calves learn to recognize their mothers whistle. After reading the passage, students are asked to answer questions based on what they read to demonstrate their understanding of the passage. Young students might be expected to understand from the text that dolphins are mammals that live in the ocean. They eat fish and communicate with clicks and whistles. Older students might be asked to apply information gleaned from the passage to facts they already know. They could be asked to infer the meaning of the term carnivore from the text, identify what dolphins and cattle have in common (being identified as a cow, bull, or calf) or how a dolphin’s whistle is similar to a human fingerprint (each is distinct to the individual). Methods of Assessing Reading Comprehension There are several ways to evaluate a student’s reading comprehension skills. One method is to use a formal assessment, like the example above,  with reading passages followed by questions about the passage. Another method is to use informal assessments. Ask students to tell you about what they read or retell the story or event in their own words. Put students in discussion groups and listen to what they have to say about the book,  watching for areas of confusion and  students who are not participating. Ask students for a written response to the text, such as journaling, identifying their favorite scene, or listing the top 3 to 5 facts they learned from the text. Signs That a Student Is Not Able to Comprehend What Hes Reading One indicator that a student is struggling with reading comprehension is difficulty reading aloud. If a student struggles to recognize or sound out words when he’s reading orally, he’s likely encountering the same struggles when reading silently. Weak vocabulary is another indicator of poor reading comprehension. This is because students who struggle with text comprehension may have difficulting learning and incorporating new vocabulary. Finally, poor spelling and weak writing skills may be a signal that a student isn’t able to comprehend what he’s reading. Difficulty spelling may indicate problems remembering letter sounds, which means that the student is likely also having trouble processing text. How to Teach Effective Reading Comprehension It might seem as though reading comprehension skills develop naturally, but that’s because students gradually begin to internalize the techniques. Effective reading comprehension skills must be taught, but it’s not difficult to do. There are simple strategies to improve reading comprehension that parents and teachers can employ. The most important step is to ask questions before, during, and after reading. Ask students what they think the story is going to be about based on the title or cover. As you’re reading, ask students to summarize what they’ve read so far or predict what they think will happen next. After reading, ask students to summarize the story, identify the main idea, or highlight the most important facts or events. Next, help children make connections between what they’ve read and their experiences. Ask them what they would have done if they had been in the main character’s situation or if they’ve had a similar experience. Consider reading challenging texts aloud. Ideally, students will have their own copy of the book so that they can follow along. Reading aloud models good reading techniques and allows students to hear new vocabulary in context without disrupting the flow of the story. How Students Can Improve Reading Comprehension Skills There are also steps that students can take to improve their reading comprehension skills. The first, most basic step is to improve overall reading skills. Help students select books about topics that interest them and encourage them to  read at least 20 minutes each day. It’s okay if they want to start with books below their reading level. Doing so can help students focus on what they’re reading, rather than on decoding more challenging text, and improve their confidence. Next, encourage students to stop every so often and summarize what they’ve read, either mentally or aloud with a reading buddy. They may want to make notes or use a graphic organizer to  record their thoughts. Remind students to get  an overview of what they’ll be reading by first reading chapter titles and subheadings. Conversely, students can also benefit from skimming over the material after they’ve read it. Students should also take steps to improve their vocabulary. One way to do so without disrupting the flow of reading is to jot down unfamiliar words and look them up after they’ve finished their reading time.

The Patients with Stroke Assignment Example | Topics and Well Written Essays - 1250 words

The Patients with Stroke - Assignment Example It is a responsibility of a hard-headed nurse in assessing the religious and spiritual issues, family and social issues, and independence and activity issues in strict coherence with the physical symptoms and psychological distresses (Williams & Perry, 2010). Bearing it in mind, there comes a clear understanding of the link between the nursing interventions needful for stroke and Parkinson’s patients. ... To say more, it is a difficult process at a glance which needs a thorough look into blood tests, ECG, CT scans, and other medical interventions to be specifically assessed within a concrete time-limit. In this vein, a nurse should provide a set of practical treatments to make a patient go out of the depression caused by the neurological disorders discussed in the paper. One of the approaches is to pinpoint the exact source of anxiety among Parkinson’s multiple sclerosis patients (Lewis, Heitkemper, Dirksen, Goldsworthy, & Barry, 2006). It is a mandatory step for promoting efficacy through accuracy in nursing. On the other hand, what unites the three diseases in accordance with nursing intervention is the need for the â€Å"ask-tell-ask (also known as â€Å"Elicit-Provide-Elicit†) communication technique† (RNAO, 2010, p. 7). This is one of the general similarities in coping with the stroke, Parkinson’s, and multiple sclerosis patients. Needless to say, most clients with a chronic neurologic disorder will experience feelings of depression and hopelessness, and, therefore, a nurse’s care should be focused on this in the interpersonal dimension of care. Besides, to relieve the anxiety among Parkinson’s patients, a nurse is to have a set of procedures and implementations to be run during the whole process of intensive medical care.

Toxicology Research Paper Example | Topics and Well Written Essays - 250 words

Toxicology - Research Paper Example Methyl mercury can coordinate (bond) to more than one cysteine amino acid. Unlike ingested inorganic mercury, ingested methyl mercury is easily absorb by the gastrointestinal tract and found its way into the blood, where its forms bonds with the thio groups in cysteine of amino acids, peptides, and proteins. The methyl mercuric-cysteinyl compound or complex mimic another essential amino acid, known as methionine, and it is, unfortunately, recognized by amino acid transporting proteins in the body as methionine (Kerper, Ballatori, & Clarkson, 1992). Thus it is freely transported throughout the body to various parts including the brain and across the placenta, where it is absorbed by the developing fetus. It causes several health disorders in the body. Hence, methylation turns metal mercury into a toxic compound. Bibliography Kerper, L. E., Ballatori, N., & Clarkson, T. W. (1992). Methylmercury transport across the blood-brain barrier by an amino acid carrier. Am. J. Physiol. , 262 .

On Religious liberty Essay Example | Topics and Well Written Essays - 750 words

On Religious liberty - Essay Example The author argues that the demand for human freedom regards proper human spirit values. It also regards free exercise when it comes to society religion. Murray takes a careful note on these desires that met have put in their minds. He declares them to be in accord with justice and truth. To this point, the article seeks into the church doctrine and sacred traditionof which the current church keeps on bringing forth new aspects that are in accord and harmony with the old ones. There are two key points that the author has chosen to emphasize on. First, the author asserts that all human beings have the right of exercising free religion in their societies in accord with the dictates of their personal conscience. He claims that this is according to the right of nature. Essentially, this right belongs to the human being’s dignity as such. In the second point, the author asserts on the consequences that the judiciary has on this right. He asserts that obligations fall on other people in the society in order to acknowledge these personal rights, promote, and respect its free exercise. Generally, this is the center of all matters in this article. About the structure of the document, the author of the article presents two texts. The first text is Decree on Ecumenism (Chapter Five) â€Å"On Religious Freedom†. The second one is Bishop Emile De Smedt’s relation, of Bruges. This is the most important latter document, because it brings out a length decree rationale. The author therefore undertakes to state a briery the tenor and scope of the decree in relatio’slight. These two texts represent the entire issue and lengthy development concerning theological thought about the issue. The author uses theological concept and terms to support his opinion. For instance, he points out that the quest of man to God and his adhesion to God’s truth, must be free. He further asserts that, this is a divine law itself

MGM Journal Personal Statement Example | Topics and Well Written Essays - 250 words - 1

MGM Journal - Personal Statement Example In short, if we were to select two MGM tools as indispensible in the field, what would they be? With the ready help of information about a patient, the work of a physician gets much easier. And it does not only apply to a physician, but also to everyone working in the healthcare field. Access to important health information right on time will improve the efficiency and productivity, cutting down the average cost and nevertheless, make for a healthier world. Personal Health Record (PHR) guide is the just the tool for that purpose. The ultimate aim in medical profession is to achieve highest level of patient’s recovery, well being, and safety. Physician Practice Patient Safety Assessment (PPPSA) aims to increase the awareness and knowledge of the physician about the patient’s safety, thus creating a benchmark output for the physician. Better care and safety, lesser liability and better interaction is focused on to achieve higher level of performance and delivery on the part of the

HR Home Work 6 Assignment Example | Topics and Well Written Essays - 250 words

HR Home Work 6 - Assignment Example These areas of my education are very helpful to an aspiring CSA like me, as they will enable me to deal with clients of all walks of life and successfully close any transaction they might have with the company.† â€Å"I want to work for this company because not only is it reputed to have a good working environment that drives employees to excel, but it also has a record of fairness. This implies that the company strictly complies with existing labor laws and provides its workforce certain opportunities for growth. In addition, I want to work for this company because its mission-vision is very much in line with my personal goals.† The quoted paragraph above was my reply to this particular question during my job interview. I do not think any necessary revision should be made because the answer really captured the thoughts I intended to express at that time. I answered this question with by saying, â€Å"I believe I am the best person for the job because I am dedicated, devoted and armed with the right knowledge and skills. I will work to the best of my abilities.† â€Å"I believe I am the best person for this job because I am equipped with the knowledge and skills suitable to the position I have applied for. Such knowledge and skills are also honed by a high standard university with competent instructors. More than that, however, I am a person who is very much dedicated in almost every aspect of life. I am willing to sacrifice time, energy and resources just to get a work done. Giving up is also not in my vocabulary. Thus, if I am given my job, I will do my utmost to deliver the performance you seek.† â€Å"My strengths as an individual would stem from the drive to excel, sincere devotion to the responsibilities and tasks assigned to me, and the ability to cope up with pressures while delivering outputs on time. I am also

The Big Thirst Essay Example | Topics and Well Written Essays - 1250 words

The Big Thirst - Essay Example First, he claims that water is â€Å"unquestionably the most important substance in our lives... It is part of the â€Å"mystery of life and the routine of life† (2). This statement is true. The human body is composed of 50-60% of water, thus making water a mysterious substance that makes people survive for days even without food. Second, Fishman also enumerates the uses of water. According to him, people use water incessantly in their daily routine and important activities: to baptize children, digest food, quench thirst, feed animals, bathe, clean the dog, wash hands and dishes, cook, plant rice, fruits and vegetables, etc. These uses of water are commonly known. What is uncommon is the fact that water is also used to make bottled drinks, put up a concrete building, launch a spaceship, run electricity, make flat-screen TVs, set up MRI machines and Twitter accounts, produce iPhones and cars, etc. Meanwhile, five liters of water is also needed to produce two bottles of coke. As Fishman identifies these other important uses of water, his claims become more and more interesting and appealing to readers. Water has amazingly upheld the lives of people. It generally helps farmers sustain their farms and supply the need of people for food and beverages. Water in many parts of the world is accessible to farmers. However, in some countries like Australia, water seems to be scarce, thus there is great effort on the part of farmers to grow plants and harvest foods. Unfortunately, tons of water are required in some lands in order to turn a dry land into a fertile one. Often, people think that the secret of a farmer’s success is his ability to plant or his hi-tech farming tools and equipment but as Fishman points out, it is actually water that makes the harvest possible because without it or with very minimal water supply, the crops will not continue to grow. This thought resounds Fishman’s

HR Home Work 6 Assignment Example | Topics and Well Written Essays - 250 words

HR Home Work 6 - Assignment Example These areas of my education are very helpful to an aspiring CSA like me, as they will enable me to deal with clients of all walks of life and successfully close any transaction they might have with the company.† â€Å"I want to work for this company because not only is it reputed to have a good working environment that drives employees to excel, but it also has a record of fairness. This implies that the company strictly complies with existing labor laws and provides its workforce certain opportunities for growth. In addition, I want to work for this company because its mission-vision is very much in line with my personal goals.† The quoted paragraph above was my reply to this particular question during my job interview. I do not think any necessary revision should be made because the answer really captured the thoughts I intended to express at that time. I answered this question with by saying, â€Å"I believe I am the best person for the job because I am dedicated, devoted and armed with the right knowledge and skills. I will work to the best of my abilities.† â€Å"I believe I am the best person for this job because I am equipped with the knowledge and skills suitable to the position I have applied for. Such knowledge and skills are also honed by a high standard university with competent instructors. More than that, however, I am a person who is very much dedicated in almost every aspect of life. I am willing to sacrifice time, energy and resources just to get a work done. Giving up is also not in my vocabulary. Thus, if I am given my job, I will do my utmost to deliver the performance you seek.† â€Å"My strengths as an individual would stem from the drive to excel, sincere devotion to the responsibilities and tasks assigned to me, and the ability to cope up with pressures while delivering outputs on time. I am also

Piaget and Vygotsky Essay Example for Free

Piaget and Vygotsky Essay In this Essay I will compare and contrast the theories of Piaget and Vygotsky. They both were influential in forming a more scientific approach to analyzing the cognitive processes of the child active construction of knowledge. They both developed their own ideas of child development and they believed cognitive development in children took place in stages. However they were distinguished by different styles of thinking. Piaget thought that children actively construct their own cognitive worlds and they adapt their thinking to include new ideas because additional information furthers understanding. He stressed that to make sense of our world we organize our Schemata or experiences. We connect one idea to another. We also adopt new ideas. Adaptation is by assimilation, which occurs when individuals incorporate new information into their existing knowledge into an existing pattern of behavior of schemata (example). Piaget refers to Schemata or schemas to the way we organize our knowledge. We can think our knowledge as units and each of them related to aspects of the world including actions, objects etc. (referencing ) Accommodation occurs when individuals adjust to new information. Piaget thought that equilibrium occurs when is a balance between assimilation and accommodation. He believed equilibrium schema is both the category of knowledge as well as the process of acquiring that knowledge. As experiences happen and new information is presented, new schemas are developed and old schemas are changed or modified. An example is, say a child sees a crow and a pigeon in the sky, and is told that they are birds. The child then forms a bird schema defined as something that flies. The next day, he goes out and sees a seagull, which easily fits into his existing bird schema. This is called assimilation, when we take new experiences/knowledge and put them in our existing schemas (or categories). The next day, a child goes out and sees a plane in the sky. Whilst this fits the definition of something that flies, it seems to be quite different than the other birds he has seen, and he is told that this is not a bird. To explain this, the child forms one large category of flying things, with two sub-categories; birds and planes. This process is called accommodation, where we change our existing knowledge structures to account for new information that doesnt fit. Piaget also believed that we go thought four stages in understanding the world. Each stage is aged related and consist of a distinct way of thinking, a different way of understanding the world. This theory is known as Piaget’s Stage Theory because it deals with four stages of development, which are sensorimotor, preoperational, concrete operational and formal operational. ( referencing ) On the other hand, Vygotsky believed that children actively construct their knowledge. He gave social interaction and culture far more important roles in cognitive development than Piaget did. Vygotsky socio cultural cognitive theory emphasizes how cultural and social interactions guide cognitive development. He portrayed the child development as inseparable from social and cultural activities. Vygotsky argued, learning is a necessary and universal aspect of the process of developing culturally organized, specifically human psychological function (1978, p. 90). In other words, social learning tends to precede development. He believed that the development of memory, attention and reasoning involves learning to use the inventions of society, such as language, mathematical systems and memory strategies.( referencing) Piaget believed that development had to come before learning; Vygotsky believed that development and learning worked together though socialization and language. Vygotsky gave language a huge role in development. For vygotsky Language plays two critical roles in cognitive development. First language is the main means by which adults transmit information to children. Secondly, Language itself it is a very powerful tool of intellectual adaptation. Vygotsky believed that language develops from social interactions, for communication purposes. Later language ability becomes internalized as thought and â€Å"inner speech†. Thought is the result of language. Piaget thought that there was a connection between biological and cognitive development. Vygotsky believed that knowledge from social interactions spurred cognitive growth and development. Even they had really big differences; they both believed that social interactions played an irreplaceable role in cognitive development. Piaget thought that cognitive development is influenced by social transmission (learning from others). Vygotsky believed that social interactions were an instrument in development and that it heavily influenced thoughts and language. Piaget strongly considered that the developmental ages of students determined where they should be in the learning process. Vygotsky took that idea further by comparing the learner’s actual development to their potential development. He called this area of â€Å" zone of proximal development. ZPD is the range of tasks that one cannot yet perform independently, but can accomplish with the help of a more competent individual. For example, a child might not be able to walk across a balance beam on her own, but she can do so while holding her mothers hand. Since children are always learning new things, the ZPD changes as new skills are acquired. Piaget stages are hierarchical. Each of Piaget’s stages must be complete before moving to the next one. Vygotsky’s theory does not depend on time. Piaget stages imply that children cognitively develop on their own, without the help of someone or something. Vygotsky concentrates more on social interactions and aide given to a child when develops. Vygotsky Scaffolding is the kind of help, assistance and support that enables a child to do a task which they cannot quite manage yet alone and which it will help them in the future to be able to make that task or similar on their own. For example: In a school laboratory science class, a teacher might provide scaffolding by first giving students detailed guides to carrying out experiments, then giving them brief outlines that they might use to structure experiments, and finally asking them to set up experiments entirely on their own. ‘What the child can do with assistance today she will be able to do by herself tomorrow’ (Vygotsky, 1978, p.87). Both these educators contributed to the present day ideas of constructivist learning. Both offer some incredible insight into possible ways children learn and byusing there theories it is possible to create a more conductive learning environment for the child.

Report On Workplace Stress Management Essay

Report On Workplace Stress Management Essay Workplace stress can be defined as the mental trauma and distress that an employee has to go through when there is a disparity between the requirements at work and the capabilities, efficiency or the resources available. Workplace today has become a studio wherein scripts are written to overtake other studios and outperform every single instance of competition out in the middle. Hence the pressure put by employers on their â€Å"bulls† to plough their fields is immense. This pressure takes its toll and results in increased anxiety and tension levels among workers. This phenomenon is popularly called stress in the workplace. Overworking, repeated rebuttals can cause such a response in workplaces these days. Majorly, work related stress affects sleep causing insomnia and sleeplessness. It affects fitness adversely because of the reduced sleep. It can cause problems in the family of the affected individual like infighting, frequent arguments and fits of disagreement. This adverse ly affects the family life and also enhances the inefficiency at work. All of this lead to increased levels of frustration and hesitancy and directly affects the quality of work, thus further compounding the pressure on the individual. Also stress is related to the cause of various physical disorders like cardiovascular and others. Hence workplace stress is a potent problem faced by modern day offices and employees. It not only affects the individual, also the company is on the receiving end of poorer quality of work output. (Wikipedia) There has been much work going on in regard to increasing the level of comfort of an employee so that there are lesser and smaller chances of stress burnout. This includes increasing the number of employees taken in, or easier division of labour at the workplace, or better appreciation or acknowledgement of quality work. All of this is being done by companies to offer their employees an opportunity to a â€Å"healthy job†. A healthy job, as defined by the World Health Organization, is one where the pressure on an individual is proportional in measure to the individuals capability, the resources available at hand, the amount of work assigned to him and the people present to support him. All of these form important factors in deciding the stress levels of an individual at the workplace. Also, the WHO emphasises that a good working environment would be one wherein the individual feels not only the absence of stress inducing factors, but also the presence of health and goodwill pr omoting factors. (WHO official website) Statement of the problem: Our major concern in the undertaking of this project is to assess factors that may lead to a stress burnout in modern day work environments and a possible solution to mitigate their effects on employees. This study aims at studying the measures that have already been taken to counter the problem of work related stress and questions their effectiveness. We will look at measures suggested by various agencies like the WHO and people involved in research on this subject in order to provide the world with a workforce performing at its maxima. Purpose: Firstly, the study will focus on the causes and effects of increased stress levels, especially in or due to the workplace. The symptoms are evident. Increased levels of tension (hypertension), insomnia, loss of interest in work, apathy or indifference, increased frustration, fatigue, trouble concentrating; these are all symptoms that an individual is on the verge of a nervous breakdown due to highly exaggerated levels of stress or anguish, thus leading to a poor response at the workplace. At times, this heightened anxiety may also lead to the individual involving in the usage of dope or turning an alcoholic. Thus the symptoms indicate when a person is in need of guidance, help or assistance to cope with the psychological pressures of working overtime or not being able to match with the standards of his peers. Then our focus will be on measures to detract such situations from coming to the fore in a workplace. We will study methods that seek to improve the overall well being of the em ployee, whether it is changes in the sociological environment, or the use of a counsellor to help the individual emerge from his state of depression. Significance of the study: Its of immediate and absolute necessity that the problems of the office and the workplace be solved as soon as possible before they spill over into the personal lives of the concerned individuals. There are many problems affecting the corporate sector, problems related to publicity and HRM, but when the output coming out of an employee is sub standard, and if that happens on a mass scale, the company loses long standing clients and the reputation takes a steep decline, inhibiting further expansion and growth. Hence, employee satisfaction is one of the major concerns in todays corporate world. And one of the most important aspects in employee satisfaction remains burnout prevention. If the company can keep employees from exhausting their potential due to excessive workload, they will certainly excel in other aspects of growth. The feedback of an employee is essential to the expansion and the reputation of the company. Thus, employees form the backbone of the skeletal structure of any company. Hence the study of work related stress becomes of top priority of corporate honchos. If a company is unable to protect its employees from the disastrous outcomes of a burnout, the word about the companys exploitative policies gets out in the market and then there are hardly any people willing to join the company even on a bit elevated pay scale. The company loses reputation, and there is no way in which it can recruit quality professionals because of its lousy reputation. Also the company becomes a bed of controversies as people start criticising its policies of employee management. This adversely affects the stakeholders in the company. Hence, employee management and satisfaction form a primary priority of the companys policies. Chapter 2 Background: The problem we are looking at is the issue of employee burnout at the corporate level in todays cut throat environment where companies draw up plans of execution that require employees to exhaust themselves by repeated stints of overtime, incentive based overload, etc. Though in the short term the company ends up profiting from such misplaced dedication, in the long term, the company loses its energy and money on training professionals who are eventually going to burn themselves out in a particular instance. Hence the long term loss of the company is far more emphatic, and the company has to invest in order to set it right. Hence the company loses a lot of its money and time setting things right. Thus, the modern day corporate has woken up to an existing issue of workers suffering work induced stress. This problem needs to be addressed with a steel authority so that in the long term, employees dont end up leaving the company due to such reasons, and the company can retain most of its staff, thus putting good to all the investment it made on training and teaching the staff. The issue of employee burnout also has to be addressed to improve the output of a employee in a capacity. An increased output level of an employee can make wonders for a company looking for greater ventures. An employee holds the key to a companys ability to make it big in the corporate world. A grumpy and irritable employee only succeeds in turning the mood of an environment irritable, leading to an epidemic of grouchy workers, in turn leading to a horrible turnover for the company, failed attempts at meeting deadlines, angry clients. Thus an employee needs to be looked after if he does show signs of burnout. A pat on the back can do wonders to lift the morale of the worker. It can give him much needed assurance from the employers side. However, it is also rewarding to appreciate the quality of work a worker constantly turns in by rewarding him a pay rise. At times, a little counselling from experienced people can also help the individual climb out of his state of depression. Literature Review: A lot of literature has been published on the above topic to help companies with various techniques aimed at reducing stress at the workplace. The WHO has been actively involved in collaborating with researchers and the corporate world alike to enhance the methods taken to help individuals with their stress disorders. This is necessary for all companies throughout. The studies undertaken can be company specific, pertaining to the workplace of a particular company. The studies undertaken may be industry specific, pertaining generally to the kind of work involved in the industry of choice which will more or less be the same in most companies working within the domains of that industry. The studies could also be general, pertaining to some common features that all industries share. These measures can be adopted by all companies and are for global welfare of employees. Also the governments of various nations fund their own studies and researches to identify the key aspects that impact th e psychological functions of an employee. Thus even governments are actively involved in working for the welfare of their workforce. Many governments have set up centres or councils that work all the year around to study present day policies of companies towards its workers and give suggestions relevant and feasible to protect workers from an overdose of work. Also many nongovernmental organizations (NGOs) are also working for the same. Human rights activists are also actively voicing their concerns over the exploitative policies of certain companies and at times, also the governments. These add up to numerous research papers and literature on policies that a company should follow to save its employees from blowing off the lid off their heads. Definitions: An important definition is of a healthy job. As previously mentioned, a healthy job is one where the load on an individual is considering the capabilities of the individual, his resources, his knowledge of the topic, his work routine, so that he is not indirectly forced into putting in far too many extra hours, his support staff, whether everything in the personal life of the individual is fine and doesnt involve sizeable perturbations. Also the stress related hazards at work can be differentiated into 2 categories: work content and work context. Work content includes the amount of work handed to the individual, the quality of the job, also whether the individual is coped with enough resources to carry out the work, whether the work entails him to put in hours of extra effort, thereby affecting sleep. The work context includes the sociological factors in a workplace. These can be the competition at the workplace, the disappointments of failure, and the grumpiness due to malpractices at the workplace, the ignorance of the higher commands to the appreciable work done by the individual, the lack of motivation or disinterest in the kind of work allotted. Chapter 3 Causes of Workplace Stress: As many countries around the world spend billions of rupees on anti-depressants and stress-busters to relieve their people from stress, an analysis of the causes of stress provides a great deal of understanding of the problem. The research hence indicated some of the chief causes of stress, the major causes being explained as follows. The National Institute of Occupational Safety and Health, U.S., emphasises that the personal traits and characteristics of the workers play a chief role in determining the level of stress the person is likely to go through, given a fixed set of working conditions. (NIOSH, 2010). For instance, the stress level of one person may differ from another person based on their skills to cope and adjust, and the tendencies of their bodies to respond to the mental stress. Another increasingly popular notion which is gaining credence states that the working conditions, instead, play a greater and dominating role in causing stress to the people. Apart from these viewpoints, there are also other causes by various organizations of the world, which are cited as contributing factors in inducing stress. For example, the post of a person, his status in the organization can also alter the levels of stress he might be experiencing. In other words, people who have little influence and lower status in the organization are found to be more stressed out than other people, who at higher posts. Such arguments also state that even though people at powerful positions have higher workload, but there is no co-relation between workload and stress. In addition it must be mentioned, the Glob al Business and Round Table Conference on Addiction and Mental Health puts the overload factor, also called as â€Å"The Treadmill Syndrome† on the top of the list of the factors causing workplace stress. Moreover, there are popular arguments which have claimed to link the stress with economic factors. It can be best illustrated by an increasingly growing trend in the 21st century business world wherein companies are very quick to lay off workers or sack them stating some reasons, cutting down jobs and taking back benefits to the existing employees, so as to save on capital and adjust with the rapidly changing business environment. The solid emergence of the concept of â€Å"downsizing† leads to worrying employees, which in turn leads to a great deal of stress. Moreover, studies of the WHO reveal that the most significant cause of work stress can be attributed to the pressures and demands from the employees who are either not capable enough, or not qualified and equipp ed to the level which would enable them to do the required work. Such situations, clearly, lead to immense workplace stress. Another factor that adds to the stress of an average employee is the vagueness of his perception of his job and the goals of the organisation. When the employees are ambiguous about their jobs, their duties and what is expected of them, it leads to worries and anxiety. Furthermore, the lack of concrete and clear knowledge about the philosophy of the organisation and its objectives leads to a lack of awareness, commitment, interest and a sense of lessening confidence. In addition, many studies have revealed the inflexibility is also a major factor contributing to stress. Workplaces where the employees are required to work for long hours under a strict schedule, and particularly those where they are made to do so alone, and the environment is non-social, it leads to great stress. The mental pressure increases with the strictness, and this might also, in a way, d epend upon the characteristics of the supervisor (manager). Another aspect of stress which is usually found to be its cause is, as discussed, lack of control or participation. The reason behind why employees at lower positions feel stressed is actually this factor, by which the employee tends to feel that his contribution to the organisation is making no difference, since he holds no say in any sort of decision-making or policy-framing. Gradually a growing sense of alienation and frustration combine, thereby leading to stress. (Workstress.net) Effects of Stress: Stress in the working environment of a company directly affects the individuals, and in turn, affects the organizations and its many aspects to a great extent. Apart from the physical toll stress can take on an individual, leading to many problems like fatigue, blood pressure problems, the emotional and psychological effects of stress are the most severe. A distressed person may lose his spirit of dedication and commitment towards the organization totally, thereby putting in less and less amount of effort and creativity in the work he does, and contributing less to the organization. Stressed out employees may not be able to work with concentration which can affect the output of their work in a negative way. All this in turn affects the organization as a whole. For instance, increasing workplace stress may cause considerable absenteeism from work thereby pulling down efficiency and productivity. In addition, it may create many other problems like defaming the image of the company, and dissatisfaction among the public (customers). Stress among the employees also leads to objectionable trends like drug abuse, etc. It negatively impacts the procedure of recruiting new staff, as the image of the company has been harmed and damaged. In addition to this, stress can be very problematic on the personal side of the employee. Anxiety, mood swings, etc. may affect the personal life and the relationship of the employee with his family and loved ones, the negative impact of which may result into more and more stress. Hence, the effect of stress is multi-faceted. It is taxing to the company, to the individual and to other people not directly related to the organisation. The effects of the stress lead to symptoms of stress amongst the employees, which must be identified at a stable stage, so that the task of stress prevention is carried out effectively and successfully. (Workstress.info) Chapter 4 Summary: The problem of stress, its management, its causes and effects is one of the most important global problems of the current area. The ever-increasing concern about workplace stress and how to curb it is the key motivation behind the research. Furthermore, the primary aim of the research is to study the causes and effects of stress, and provided recommendations. There has been a genuine attempt in fulfilling the aim, beginning by reading a great amount of literature on the topic. Various studies and various sources have tried to provide a concrete notion of the causal of workplace stress, based on which many have provided recommendations. Those causes are studied in a practical environment, as part of this research, so as to genuinely assess their validity. The research also involves considerable study on workplace stress management. Preventive measures that have been implemented to reduce stress have been evaluated and looked into, and measures that include management of stressed out w orkers and their total recovery from stress have also been analysed. Discussion: It must be mentioned here that completely doing away with stress is an unprofitable concept. Psychological studies reveal that a small amount of stress can provide for just the right amount of drive needed to work effectively with genuine interest. Thus, a little stress is always good. But when stress assumes larger proportions, it can be destructive for the organisation. We have studied the factors leading to stress. The causes of workplace stress vary, as we have seen. Contrasting arguments also exist, for instance, some cases argue that the even though managers and executives of a company face a larger workload, there are less stressed out than other employees at lower positions. On the contrary, there are studies that list the overload factor as one of the primary factors leading to stress among the employees. The likelihood of the latter claim seems more intense, since it is more reasonable and plausible. Furthermore, stress is now increasingly believed to be arising out of a si tuation known as the Work Organisation Problem, which states that the stress among the employees is a consequence of improper, inefficient, problematic and inappropriate organisation of tasks and work amongst the employees. This is perhaps a result of various studies which point out and emphasize that the mismatch between qualification and work done by an employee is the root of all problems that arise in various forms within the organization. Moreover, the recommendation for the organisation to look for signs of stress amongst its employees stems out of the need for prevention of stress. Since stress management, i.e. management of stressed out workers involves many structural measures and a great deal of temporary effort, and is also time consuming, it is always imperative for the organisation to prevent stress in a proactive way. Managing stressed workers should always be recorded for further interpretation of the findings, and hence for effective human resource management of the organisation. The need for culture change within the body of employees is an area that must be taken care of. Having unions for the betterment of the employees is a notion that must be discussed with the employees first, and then implemented. Furthermore, it is quite clear and easily comprehendible that stress leads to the damage of the image of the organization. Such damage is usually both internal, i.e. within the perceptions of the employees, as well as in the eyes of the public. (Guide to Stress Management) Recommendations: Based on the findings, it can be concluded that stress arises out of not one factor, but many factors. Improper work organisation, economic factors like pressure from investors in the share-market, growing fear of being downsized, and so on can create workplace stress. In any case, an organization must follow certain fundamental steps whenever stress is discovered to threaten its efficiency. The risks involved with stress are huge, and affect the organisation in many direct and indirect ways. Hence, a concrete policy of risk-management must be followed. Such a policy includes various steps as shown by the following flowchart. Beginning from the assessment of risk, to planning and materialisation of the required action plan, all steps must be followed up with genuine concern for the stressed employees and the suffering organization. (Leka) Thus, to address the overload problem first and foremost, the primary concern of the managers should be proper distribution of work among the employees. Moreover, there can be also a regular training for all employees to teach them on how to prioritize work efficiently. Certain other factors that are also cited as causes of stress must be treated. For instance, random and abrupt disturbances for the employees can have a negative impact. Various experts have suggested measures such as effective management of workspace and time as a solution to this type of stress. In an organization, it is imperative for every employee to be treated equally and justly. Absence of such treatment can also leads to uncertainty and stress amongst the employees. Hence, it must be tended to that each employee is treated equally and at par with everybody else, and all his rights are guarded. Mistrust amongst employees should be taken care of, with an attempt to develop frank communication levels and healthy inter-personal relationships within the organization. It is strongly recommended that any kind of politics must be rejected and condemned, so as to create a healthy workspace. In addition, the aim of creating a healthy and productive workspace can be done through rewards and recognizing outstanding performances, and their appreciation. Such measures have been found to go a long way in creating a sense of loyalty, commitment and a positive attitude towards the company. Stress puts the whole organisation at the risk of survival. Hence, it must be addressed as soon it has been discovered. Apart from small measures, a need to take large steps within the organization to reduce the problems caused by work stress might also arise. Such steps may involve redesigning the whole structure of work, and reorganising it within the employees, and managing it. Work stress generally shows itself in little observations, hence regular and continual steps must be taken to assess the conditions of the w orkers, and to look for signs of stress. Such measures may include regular questionnaires, or talks with the employees and managers. Also, whenever the warning signs are discovered, immediate action must follow. Discussions should take place with the stressed out workers, and certain changes which will help remove stress must be implemented. Such discussions should encompass suggestions and measures that could be taken on the personal front of the employees, which could help in lowering the stress. Steps such as having a balanced diet, thinking positive and even incorporating ideas like organising regular workshops on how to psychologically manage stress and combat it could turn out to be of great help. It becomes all the more important in many situations whether these discussions take place or not, since they could greatly benefit and completely curb stress within the workplace. A sense of direction, in totality, needs to be provided to the staff at regular intervals. (Life positiv e official website) References: Wikipedia (n.d.) retrieved on 17/5/2010 from http://en.wikipedia.org/wiki/Workplace_stress WHO official website retrieved on 17/5/2010 from http://www.who.int/occupational_health/topics/stressatwp/en/ National Institute of Occupational Safety and Health official website (n.d.) data retrieved on 17/5/2010 from http://www.cdc.gov/niosh/programs/workorg/ Workstress.info official website (n.d.) retrieved on 17/5/2010 from http://www.workstress.info/the-health-effects-of-workplace- stress/ Workstress.net official website retrieved on 17/5/2010 from http://www.workstress.net/causes.htm Guide to stress management official website (n.d.) data retrieved on 17/5/2010 from http://www.guidetostressmanagement.com/workplace-stress/ Work Health and Organization Stavroula Leka and Amanda Griffiths UK 1-35 obtained on 17/5/2010 from www.who.int/occupational_health/publications/en/oehstress.pdf Life Positive official website retrieved on 17/5/2010 from http://www.lifepositive.com/mind/psychology/stress/stress-at-work.asp Appendix: Downsizing (cutting down or chopping the workforce in economically unfavourable times) Page 9. Flowchart on Risk Management Page 13. Flowchart on Stress Causal Mechanism Page 8. Global Business and Round Table Conference on Addiction and Mental Health (organised by the Centre of Mental Health and Addiction , Toronto) Page 9 National Institute of Occupational Safety and Health (NOISH) U.S. Page 8. Summary of the research Page 10. Treadmill Syndrome (disproportionately high amount of work with respect to time, space) Page 9. Work content Page 8. Work context Page 8. WHO—World Health Organisation Pages 4, 7, 9.

Sir Gawain and the Green Knight :: Sir Gawain and the Green Knight

Passage Analysis of Sir Gawain and the Green Knight In this passage, we find ourselves in King Arthur's court during a Christmas feast. A Green Knight has just proposed a challenge before the court, a game in which a blow for a blow shall be given. Seeing that no one is willing to accept this challenge, King Arthur himself steps up to the Green Knight, ready to defend his honor. Sir Gawain, being a noble knight, asks the court if he can replace King Arthur in the game. His wish is granted. The passage begins as King Arthur calls Sir Gawain to his side to give him his weapon and blessing. As Gawain kneels before his lord, King Arthur says: "Keep, cousin what you cut with this day, and if you rule it aright, then readily, I know, you shall stand the stroke it will strike after." (Norton p. 210) With these words King Arthur implies that since Sir Gawain has the first hit, he has nothing to worry about, since the Green Knight will be dead and unable to return the blow. The Green Knight asks Gawain to go over the terms of the game and asks to know his name. Gawain replies: "In good faith, Gawain am I whose buffet befalls you, what'er betide after, and at this time twelvemonth take from you another with what weapon you will, and with no man else alive." ( Norton p. 210 ) In this statement Gawain not only asserts himself but also makes sure that if he kills the Green Knight with his blow, no one shall take his place. Satisfied with that answer, the Green Knight reminds Sir Gawain that he must find him on his own, as promised before the court. However when Gawain asks the Green Knight where his home could be found, the Green Knight delays his answer, saying that Gawain will know soon enough after the blow where to find him. Not finding out the true identity of the Green Knight may be Gawain's first mistake. It is always important to know your enemies, especially when a very big, very green knight, who comes out of nowhere, presents one with a challenge. Having resolved the terms of the agreement, the Green Knight gets ready for the blow by kneeling down and moving his long green hair away from his neck. Gawain skillfully grips the ax and strikes the Green Knight with all his might, cutting through the flesh with such force that the blade ends up in the ground.

Shakespeares Macbeth - The Tragic Hero :: Macbeth essays

Macbeth: Macbeth The Tragic Hero The most recent meaning of the word Tragic Hero as defined by Microsoft Works dictionary is "A hero of noble stature whose fortunes are reversed as a result of weakness." Many characters in the play were affected by tragedy for a number of reasons, but without argue, Macbeth and his reverse of fortunes are due to his own actions, and the rest of the cast were merely victims of this. Macbeth's action's lead to his very nemises. From the beginning of the play this tragedy of his was manifested through forces beyond human; the supernatural if you will. These forces were that of the witches. The next factor in determining his fate was his own decision's and action's. Lady Macbeth is the second reason for Macbeth's tragedy; without her support in aiding his decision, Macbeth would have never had the strength to lie, scheme, and destroy to such extremes. The last, and most devastating to Macbeth, was his cripled conscious which made him act out of selfeshness and lust. The sequence of these factors were most defenitely provoked by the evilness and twisted nature of the witches, for if it weren't for their influence, then Macbeth would have never turned his desires into reality. At the very beginning of the play Macbeth is nothing but a general fighting for his country. His fellow fighter's admire Macbeth, for in their eyes, and even in the eyes of the highest of authority, his nobility and couragousness is looked up to. His success for his acheivement is rewarded, and his confidence is made stronger because of this. But this is only the beginning, and soon these good fortunes will come to a tragic end. The audience is then introduced to a group of witches. Three witches who appear as wicked and repulsive. They seem to signify all that is wrong and corrupt. Macbeth's over- confident attitude is the first characteristic the witches detect, and they take advantage of this trait to make his life as miserable as they possibly can. He encounters the witches in Act1, scene1, and from this point he is now a step closer to realising what his future holds... so he thinks. The witches first address Macbeth as king, and Banguo as one "Lesser than Macbeth."(1.2.65) Infact, Macbeth isn't king, never the less, the witches insist in prophecising that he is and will be. The witches are already planting seeds of persuation into his head which are made to bloom into tragedy. These destructive and manipulative forces the witches have power over alter his viewpoints about his values and

Company law ans

Bristol is a substantial shareholder in Chester-Perry Industries Ltd. A business competitor, Gun and Fames Pity Ltd, is selling in great volume a cookbook similar to one in respect of which Chester-Perry Industries holds the copyright. Bristol believes his company has incurred a substantial loss and his own shares have been reduced In value by $150,000. HIS solicitors believe an Infringement of copyright has occurred. Cycles and Pollock are the directors of Chester-Perry Industries Ltd. They state that they have decided not to litigate because they believe hat to take legal action for infringement of copyright is too expensive and risky.Bristol is unsure whether the directors of Chester-Perry Industries have any interest in Gun and Fames Pity Ltd. On the general principles laid down Salmon's case, can Bristol sue Gun & Fames? Issue: Can Bristol sue Gun & Fames on behalf of Chester-Perry as a shareholder in Chester-Perry? Relevant law: Salomon. Application: The House of Lords in Salom on held that upon incorporation, a company beneficially becomes a separate legal entity even though its issued shares are owned by the same person Like In Salomon.Similarly In this question, Chester-Perry Is a company that has been incorporated and therefore, is a separate legal entity from all its shareholders. In this case, according to Salomon, Bristol who is a shareholder of Chester- Perry cannot sue Gun & Fames on behalf of Chester-Perry as a company is separate from its shareholders. Conclusion: Bristol cannot sue Gun & Fames on behalf of Chester Perry due to the principle laid down in Salomon where upon incorporation Chester Perry is considered as a separate legal entity from all its shareholders, including Tutorial 2 Bristol.Q(a). The Constitution of Big Hopes Pity. Ltd. Includes the following provisions: Rule XSL: On any Increase In capital the new shares must be offered to members In proportion to their excellent shares. John (an existing shareholder) is distressed when an allotment of a new issue is Issue: of What action can John take against Big Hopes for failing to allot new issue shares to him according to Rule xi of the Constitution? Relevant law: CA 2001. Application: s. 140(1)(a) states that a constitution of a company is a contract between the company and its company and its shareholders.In this essence, both the shareholders are bind by the constitution. Must Big In this instance, Rule xi of Big Hopes' constitution states that new shares be offered to existing shareholders as per their existing shares. However, Hopes failed to allot new shares to John as according to his existing shares and have therefore breached its contractual obligation in the constitution under Conclusion: John can take an action against Big Hope under s. 140(1)(a) for breaching its to contractual obligation in its constitution for failing to allot the new shares John as per his existing shares.Tutorial 3 Q. John, Ring, George and Paul incorporate Big Hopes Pity Ltd for their property development business. Big Hopes Pity Ltd was empowered under a provision in its constitution to appoint a managing director. However, the company did not appoint managing director, executed a contract with Vincent for the purchase of a certain property. The market price for the property subsequently collapsed. The board of Big Hopes Pity Ltd, learning of the contract, expressed their disapproval to Paul and claimed that the company was not bound by the contract.Vincent seeks your advice as to his legal position. Issue: Is the company bound by the contract with Vincent? Relevant law: Constructive notice, Turned, and s. 129(2)(a) and (b), s. 29(5) (6) CA 2001 , Actual authority and Apparent authority. Application: Under the old principle of constructive notice, the constitution of public companies are made available for public inspection and therefore, the public are deemed well aware of the limitations on the authority of the companies' principle will not apply here a s Big Hopes is a private officers. This old company.Furthermore, under the common law Turnaround's case, any outsiders with companies can assume that the persons with whom they are with have the authority to contract on behalf of the companies and all proceedings have been complied with. Dealing internal In this case, the constitution of Big Hopes states that a MD should be appointed but did not state that Paul has been properly appointed as the MD. Vincent can argue that he assume that Paul has been appointed as the as per the Turnaround's case and therefore, has the authority to contract on behalf of the company.He also has no actual knowledge or suspicion that Vincent has not been properly appointed (Note: In test/exam, if there are any circumstances that arouse suspicion, argue using the case of Nonresident Developments). The principle of constructive notice has also been abolished by s. 130(1) of CA 2001. In dealing with companies, outsiders are entitled to make certain assumpt ions contained in s. 129 of ACACIA as per s. 128(1) of ACACIA. In this instance, Vincent can argue that he has been empowered by s. 128(1) to make certain s. 129 assumptions when contracting with Paul from Big Hopes. Reticular, he can assume under and (b) that Paul has been properly appointed as the MD of Big Hopes and can therefore exercise all the customary duties of a MD which include entering into contracts on behalf of Hopes. In this essence, Vincent can assume that Paul has actual implied authority to enter into contracts on behalf of Big Hopes. Note: In test/exam, if question requires arguing on apparent/ostensible authority, use the case of Freeman Locker to support your argument). Vincent can also argue either s. 129(5) or (6) depending on whether Big Hopes execute contracts by way of seal or without seal.Either way, Vincent can argue that Paul has complied with all the internal proceedings when executing the contract with/without seal (e. G. Proper meeting, quorum, fixatio n of seal, witnessing of fixation et cetera) under either of these two sections. The exceptions under s. 128(4) CA 2001 will not apply to Vincent as he has ever known or suspected that Paul has not been properly appointed and the contract has not been properly executed. Conclusion:Big Hopes is bound by the contract with Vincent under both common law (as per Turnaround's case whereby entitled to make certain s. 29 assumptions again, there is no evidence suggesting any when dealing with Big Hopes and exceptions under s. 128(4) that will rebut the s. 129 assumptions made by Vincent. Tutorial 4 Q. Maria is keen to purchase shares in Action Ltd. , but is unable to raise sufficient funds to do so. It is suggested that the company lend Maria the sum of $50,000 to enable her to complete the purchase. The directors of Action Ltd. Seek your advice as to this proposal. Issue: Can Action Ltd lend Maria the sum of $50,000? Is this considered as financial assistance?Relevant law: s. AAA(1) CA 200 1, ASIA v Adler. Application: Under s. AAA(1), a company may only financially assist a person if it (a) does not materially prejudice the interests of its shareholders and affect its ability to pay its creditors, (b) must be approved by all shareholders, and (c) exempted by s. CHIC. Therefore, before Action Ltd lends the $50,000 to Maria, it must ensure that it has comply with all the requirements in s. AAA(1). Otherwise, Action Ltd will be breaching s. AAA(1) as per the case of ASIA v Adler. In ASIA v Adler, Mr..Adler the director in HI has utilized the money of HI to financially assist his personal company PEE to purchase the shares in HI when HI was already in financial difficulty and without the approval of the shareholders. The court deemed this to be a contravention of s. AAA(1). Requirements in s. AAA(1). Conclusion:Action Ltd can only financially assist Maria to purchase the shares of Action Ltd if it satisfied all the requirements in s. AAA(1). Otherwise, Action Ltd will be deemed to have contravened s. AAA(1) as per the case of ASIA v Adler.Tutorial 5 Q. An opportunity has arisen to purchase land for development at Christmas Hills. The shareholders of Central Developments Ltd. Passed a resolution that the company purchases the land. However, the directors have ignored the resolution and refuse to act on it. Are the directors bound to implement the shareholders' resolution? Issue: Are the directors of Central Developments bound by the shareholders' resolution to purchase the land at Christmas Hills? Relevant law: Separation of ownership and management powers, Automatic Self- Cleansing, John Shaw.Application: Under the principle of separation of ownership and management powers, the management of the company is vested fully in the board of directors despite the shareholders owning the company. Therefore, the shareholders cannot pass resolutions instructing the directors on how to manage the company. According to the cases of Automatic Self-cleansing and John Shaw, the directors as long as acting within the management powers bequeathed on them by the company's constitution have absolute power in managing the company and the shareholders have no rights to interfere in this as per the company's constitution.In this event, the directors of Central Developments can ignore the resolution of the shareholders to purchase the land at Christmas Hills because purchasing of land can be considered as a type of management power and only the Conclusion: The directors of Central Developments can ignore the resolution of the shareholders to purchase the land at Christmas Hills because the directors have absolute power to manage the company including whether to purchase the land as per the principle of separation of ownership and management powers and the cases of Automatic Self-cleansing and John Shaw.Tutorial 6 IQ. Seven Dwarves Ltd operates nursing homes. Its directors are Sleepy, Grumpy and Dopey. They hold 30% of the shares in the company. The directors allocate 1 million new shares to certain business associates. This has upset certain shareholders who claim that the placement was made with a view to preventing a future takeover offer being made. The directors claim that the allotment was made to raise cash required for the company's future needs. Advise the shareholders.Issue: Advise the shareholders whether the directors have breached any of their director's duties by allocating 1 million new shares to certain business associates? Relevant law: s. 181 CA 2001 â€Å"proper purpose† (but for test), Whitehorse v Carlton, Howard Smith. Application: Under s. 181 CA 2001, directors must act in good faith, in the best interest of the shareholders and for a proper purpose. The shareholders in claimed that the directors have issued 1 million new shares to Seven Dwarves certain business associates to defeat a takeover and therefore, the issuing of these new shares is for an improper purpose.To determine whether the issui ng of new shares is for an improper purpose (I. E. To defeat a takeover), the but for test will be applied. But for to defeat a future takeover, will the directors issue the 1 million new shares? † (Note: Students must reason and argue on this question to reach an answer, either Yes/No). If the but for test reveals that no, if not to defeat a takeover, the directors will not issue the new shares, then obviously the reason for issuing shares is to defeat a takeover. He to prevent the wife from having majority control over the business and in the case of Howard Smith, whereby new shares were issued to prevent future takeover, the court ruled that the issuing of new shares in these cases was for improper purpose. Therefore, the directors have breached s. 181 because their purpose in issuing the 1 million new shares to certain business associates is to defeat a future takeover which is considered as improper as per the two cases discussed above. Conclusion: The directors of Seven Dwarves have breached s. 81 because they have issued cases new shares for an improper purpose (I. E. To defeat a takeover) as per the of Whitehorse v Carlton and Howard Smith. Tutorial 7 (This question is not taken out from the tutorial questions but you can still use it as a reference for answering questions from this tutorial) Sam and Pete are the erectors in BBC Pity Ltd. They have decided to use the 1 million dollars in the company's bank account to invest in the shares of DEAF Ltd after doing all the necessary research and making all the necessary inquiries by themselves from the Internet and financial Journals and magazines.Six months after the investment, the World Financial Crisis occurs and DEAF Ltd goes into liquidation causing BBC Pity Ltd to lose its 1 million dollars investment. Do the shareholders of BBC Pity Ltd have a course of action against Sam and Pete? Issue: Do the shareholders of BBC have a course of action against Sam and Pete for asking an investment that cau sed the company to lose 1 million dollars? Relevant law: Old subjective common law standard, Re Cardiff Bank, Re City Equitable Fire Insurance, Daniels v Anderson (objective standard), s. 80(1) and s. 180(2) CA 2001. Application: Under the old common law, a subjective standard is applied to directors when exercising their duty of care towards their companies. In both the case of Re Cardiff Bank and Re City Equitable Fire Insurance, the subjective standard is applied whereby directors were only required to exercise duty of care as per their personal level f skill and experience. However, this approach has been overruled by the modern objective standard landmarks in the case of Daniels v Anderson.In this case, all directors are expected to exercise a duty of care that any other reasonable directors will apply in the same position and circumstance and not according to their personal level of skill and experience. This standard is further illustrated in 180(1) CA 2001 which states that directors must exercise their power with degree of care that any reasonable directors would exercise in the same circumstances, position and responsibilities. In this event, if the shareholders of BBC are able to establish that any other Sam and Pete would be breaching their duty of care towards BBC under 180(1).However, Sam and Pete will be able to raise the Business Judgment Rule Defense (BBC) in s. 180(2) CA 2001. In order for them to raise the BBC, they must satisfy four elements; (1) They have made the business Judgment in good faith and for a proper purpose – there is no evidence that Sam and Pete have ill intentions when making the investment, (2) They have no material personal interest in the business Judgment – again, there is no evidence that Sam andPete have gained any benefits financial or non-financial wise from the investment, (3) They have informed themselves of the subject matter of the business Judgment – there is evidence that Sam and Pete have done all the necessary research including online and from Journals and magazines, and (4) Any other reasonable person in the same position and circumstances would have made the same investment as they did after doing all the research – Sam and Pete must be able to prove so. If Sam and Pete are able to establish all the elements in s. 180(2), then they will be able to use the BBC to defend themselves from breaching s. 0(1). Conclusion: The shareholders of BBC will have a course of action against Sam and Pete if they can prove that no reasonable director will invest the 1 million dollars in DEAF and therefore, in doing so, Sam and Pete have breached their duty of care to the company under s. 180(1). However, if Sam and Pete can establish all the elements under s. 180(2), then they will be able to use the BBC to defend themselves from breaching s. 180(1). Tutorial 8 (These questions are not taken out from the tutorial questions but you can a shareholder in EX. Pity Ltd.