Tuesday, November 26, 2019

The Original Jurisdiction of the U.S. Supreme Court

The Original Jurisdiction of the U.S. Supreme Court While the vast majority of cases considered by the U.S. Supreme Court come to it in the form of an appeal to a decision by one of the lower federal or state appeals courts, a few but important categories of cases can be taken directly to the Supreme Court under its â€Å"original jurisdiction.† Original jurisdiction is the power of a court to hear and decide a case before it has been heard and decided by any lower court. In other words, it is a court’s power to hear and decide a case before any appellate review. The Fastest Track to the Supreme Court As originally defined in Article III, Section 2 of the U.S. Constitution, and now codified in federal law at 28 U.S.C.  § 1251. Section 1251(a), the Supreme Court has original jurisdiction over four categories of cases, meaning parties involved in these types of cases can take them directly to the Supreme Court, thus bypassing the usually lengthy appeals court process. In the Judiciary Act of 1789, Congress made the Supreme Courts original jurisdiction exclusive in suits between two or more states, between a state and a foreign government, and in suits against ambassadors and other public ministers. Today, it is assumed that the Supreme Courts jurisdiction over other types of suits involving the states was to be concurrent or shared, with the state courts. The categories of cases falling under the Supreme Court’s original jurisdiction are: Controversies between two or more states;All actions or proceedings to which ambassadors, other public ministers, consuls, or vice consuls of foreign states are parties;All controversies between the United States and a state; andAll actions or proceedings by a state against the citizens of another state or against aliens. In cases involving controversies between states, federal law gives the Supreme Court both original- and â€Å"exclusive†- jurisdiction, meaning such cases may be heard only by the Supreme Court.   In its 1794 decision in the case of Chisholm v. Georgia, the Supreme Court stirred controversy when it ruled that Article III granted it original jurisdiction over suits against a state by a citizen of another state. Both Congress and the states immediately saw this as a threat to the sovereignty of the states and reacted by adopting the Eleventh Amendment, which states: â€Å"The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.†Ã‚   Marbury v. Madison: An Early Test An important aspect of the Supreme Court’s original jurisdiction is that its Congress cannot expand its scope. This was established in the bizarre â€Å"Midnight Judges† incident, which led to the Court’s ruling in the landmark 1803 case of Marbury v. Madison. In February 1801, newly elected President, Thomas Jefferson - an Anti-Federalist - ordered his acting Secretary of State James Madison not to deliver commissions for appointments for 16 new federal judges who had been made by his Federalist Party predecessor, President John Adams. One of the snubbed appointees, William Marbury, filed a petition for a writ of mandamus directly in the Supreme Court, on the jurisdictional grounds that the Judiciary Act of 1789 stated that the Supreme Court shall have power to issue †¦ writs of mandamus ... to any courts appointed, or persons holding office, under the authority of the United States.† In its first use of its power of judicial review over acts of Congress, the Supreme Court ruled that by expanding the scope of the Court’s original jurisdiction to include cases involving presidential appointments to the federal courts, Congress had exceeded its constitutional authority.  Ã‚   Few, but Important Cases Of the three ways in which cases may reach the Supreme Court (appeals from lower courts, appeals from state supreme courts, and original jurisdiction), by far the fewest cases are considered under the Court’s original jurisdiction. On average, only two to three of the nearly 100 cases heard annually by the Supreme Court are considered under original jurisdiction. However, many are still important cases. Most original jurisdiction cases involve border or water rights disputes between two or more states, meaning they can only be resolved by the Supreme Court. For example, the now famous original jurisdiction case of Kansas v. Nebraska and Colorado involving the rights of the three states to use the waters of the Republican River was first placed on the Court’s docket in 1998 and was not decided until 2015.   Other major original jurisdiction might involve lawsuits filed by a state government against a citizen of another state. In the landmark 1966 case of South Carolina v. Katzenbach, for example, South Carolina challenged the constitutionality of the federal Voting Rights Act of 1965 by suing U.S. Attorney General Nicholas Katzenbach, a citizen of another state at the time. In its majority opinion written by revered Chief Justice Earl Warren, the Supreme Court rejected South Carolina’s challenge finding that the Voting Rights Act was a valid exercise of Congress power under the enforcement clause of the Fifteenth Amendment to the Constitution. Original Jurisdiction Cases and Special Masters’ The Supreme Court deals differently with cases considered under its original jurisdiction than those reaching it through its more traditional â€Å"appellate jurisdiction.† In original jurisdiction cases dealing with disputed interpretations of the law or the U.S. Constitution, the Court itself will usually hear traditional oral arguments by attorneys on the case. However, in cases dealing with disputed physical facts or actions, as often happens because they have not been heard by a trial court, the Supreme Court usually appoints a â€Å"special master† to the case. The special master- usually an attorney retained by the Court- conducts what amounts to a trial by gathering evidence, taking sworn testimony and making a ruling. The special master then submits a Special Master Report to the Supreme Court. The Supreme Court then considers the special master’s ruling in the same manner as a regular federal appeals court would, rather than conducting its own trial. Next, the Supreme Court decides whether to accept the special master’s report or to hear arguments over the disagreements with the special master’s report. Finally, the Supreme Court decides the case by voting in its traditional manner, along with written statements of concurrence and dissent. Original Jurisdiction Cases Can Take Years to Decide While most cases that reach the Supreme Court on appeal from lower courts are heard and ruled on within a year after being accepted, original jurisdiction cases assigned to a special master can take months, even years to settle. The special master must basically â€Å"start from scratch† in handling the case. Volumes of pre-existing briefs and legal pleadings by both parties must be read and considered by the master. The master may also need to hold hearings in which arguments by the lawyers, evidence, and witness testimony may be presented. This process results in thousands of pages of records and transcripts that must be compiled, prepared and weighed by the special master. For example, the original jurisdiction case of Kansas v. Nebraska and Colorado involving disputed rights to water from the Republican River was accepted by the Supreme Court in 1999. Four reports from two different special masters later, the Supreme Court finally ruled on the case 16 years later in 2015. Thankfully, the people of Kansas, Nebraska, and Colorado had other sources of water.

Friday, November 22, 2019

Learn About Where Polar Bears Live

Learn About Where Polar Bears Live Polar bears are the largest bear species. They can grow to from 8 feet to 11 feet tall and about 8 feet long, and they can weigh in anywhere from 500 pounds to 1,700 pounds. They are easy to recognize due to their white coat and dark eyes and nose. You may have seen polar bears in zoos, but do you know where these iconic marine mammals live in the wild? Knowing can help us help this threatened species survive. There are 19 different populations of polar bears, and all live in the Arctic region. This is the area that is north of the Arctic Circle, which lies at 66 degrees, 32 minutes North latitude. Where to Go If Youre Hoping to See a Polar Bear in the Wild United States (Alaska)Canada, including the provinces and territories of Manitoba, Newfoundland, Labrador, Quebec, Ontario, Nunavut, Northwest Territories, and Yukon Territory)Greenland/DenmarkNorwayRussian Federation Polar bears are native to the countries above and occasionally are found in Iceland. A polar bear range map from the IUCN can be seen to view populations. You can see live footage of polar bears in Manitoba. If you want to see a polar bear in a completely non-native region, you can check out the polar bear camera from the San Diego Zoo. Why Polar Bears Live in Such Cold Areas Polar bears are suited to cold areas because they have thick fur and a layer of fat that is 2 inches to 4 inches thick that keeps them warm despite the frigid temperatures. But the main reason they live in these cold areas is that that is where their  prey  resides. Polar bears feed on ice-loving species, such as seals (ringed and bearded seals are their favorites), and sometimes walruses and whales. They stalk their prey by waiting patiently near holes in the ice. This is where the seals surface, and therefore where the polar bears can hunt. Sometimes they swim below the ice to hunt, directly in the freezing water. They can spend time on land and not just on ice banks, so long as there is access to food. They can also sniff out where seal dens are for another means to find food. They need the fat from the seals to survive and prefer these types of high-fat creatures. The range of polar bears is limited by the southern extent of sea ice. This is why we commonly hear about their habitats being threatened; less ice, fewer places to thrive. Ice is essential for the survival of polar bears. They are a species that is threatened by global warming. You can help polar bears in small ways by reducing your carbon footprint with activities such as walking, riding a bike or using public transportation instead of driving; combining errands so that you use your car less; conserving energy and water, and buying items locally to cut down on the environmental impacts of transportation.

Thursday, November 21, 2019

Health Economics by Bolnick Essay Example | Topics and Well Written Essays - 1000 words

Health Economics by Bolnick - Essay Example It shall also discuss the personal, political, and ethical drivers of these two chosen health care systems. Bolnick emphasizes that there can be no ideal model for the health care system to apply. He also points out that pigeon-holing the health care system into a model is not a prudent move because the health system has unique peculiarities based on personal, social, and political factors. According to Bolnick (2003), the wants and needs of the health care system is driven by ethical and political considerations. The politics of nations differ from each other. For instance, the public health care system of the United Kingdom was adapted in response to the turmoil and chaos that the Second World War created (Bolnick, 2003). After the war, its people were also in a favourable state of mind to accept a socialised and public health care system, hence, the conditions were favourable in the UK for the introduction of such system. And, it proved to be beneficial for the people. In fact, â €Å"since the implementation of the NHS, the United Kingdom has experienced longer life expectancy rates and concomitant change sin disease patterns† (McCarthy and Schafermeyer, 2007, p. 525). Tulchinsky & Varavikova (2000) also describe the United Kingdom as a unitary state; as such, its health system is rooted at the local authority level. They further point out that UK’s national health system slowly developed since the 19th century and evolved to the comprehensive system it is today.

Tuesday, November 19, 2019

Save Money Britains Macroenvironment Coursework

Save Money Britains Macroenvironment - Coursework Example Social Save Britain Money achievement have also been as the result of social aspects that the company has adopted. For example, the NES surveyors visit the customers in their homes and advise them on the various improvement strategies that can be done on services provided by the company (Gentle, 2012). Additionally, the company maintains an active work force whose majority are less than 34 years. In this way, the staffs are energetic to undertake the company activities. As compared to other organizations, the employees are fairly treated including high compensation. The strong relationship between the employees and the management has also contributed to the success of the company (Li and Bernoff, 2008). For example, through the â€Å"tell the CEO† initiative, the employees can freely intermingle with the chief executive officer and provide their views on the company operations (Lardi and Fuchs, 2013). The staffs are also provided with opportunities where they practice their skills th us developing themselves. The social contact between the company and the 15,000 households has also contributed to the high demand for the company products resulting in increasing the customer savings (Mary, 2010). Technology SBM emulates technology in order to provide services that meet the needs of its customers. For example, in 2013, the company launched Green Deal, an innovation that allows the householders to make energy savings or improvement of the company services without upfront costs (Teich, 2008).

Sunday, November 17, 2019

World War I Essay Example for Free

World War I Essay Introduction   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The war began in the mid of May, year 1914. A Bosnian Serb student, Gavrilo Princip, fired shots from his revolver under an oak tree, aiming to murder Archduke Franz Ferdinand, the sole heir to the Habsburg throne, the Austria-Hungary supremacy. This happened as he and his wife visited Sarajevo, the Bosnian capital. The plot to murder the archduke is a part of Princip’s training and it was directed by Colonel Dragutin Dimitrijevic, otherwise known as the â€Å"Apis†, or â€Å"The Bull†. Colonel Dragutin Dimitrijevic is the head of the Serbian military intelligence during the time of assasination.   Bosnia-Hercegovina, then, was under the rule of Austria-Hungary, that which Archduke Franz Ferdinand is scheduled to succeed. Princip did not only successfully accomplish the murder of the archduke. He did fire a shot that killed his wife, Sofie, as well. She passed away in few minutes with his husband (Strachan 1998).   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   This single instance of this assassination triggered the First World War, which is further referred to as â€Å"The War to End All Wars†. It was in July 28 of the same year that Austria-Hungary declared war against Serbia. At first, this was supposed to be the third Balkan war, but it did eventually become the World War I. Initially, the Austrian government would like to Serbia to take responsibility of what had happened and to fully allow Austrian investigators to take part in the case investigation and proceedings. At this point, Austria-Hungary was already assured of an exclusive, unconditional support by the Germans, should the war break out. The Serbian government, on the other hand, has been able to solicit the support of Russia, which is already considered as a big powerful nation then. Serbia agreed to all terms subjected to them, except to the one that allows the involvement of the Austrian agents in the case. Serbia believed that this is another issue of violation of their already marred sovereignty by the same nation (Strachan 1998).   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Both Russia and Austria-Hungary mobilized their armies during the long stand-off. Germany, however, set an ultimatum to Russia to stop their army mobilization in no less than 12 hours. After the ultimatum has expired and Russia did not respond, Germany then declared war on Russia. Germany started with the occupation of Luxembourg, aiming to get Belgium as well.   The German wanted a free passage from Belgium into France, but the former disagreed to it. During this point in time, Belgium, France, and Britain are all on neutral position with regards to the war. But by August 3, Germany declared war on France and invaded Belgium because their free passage was not granted (Strachan 1998). This then triggered Britain to declare war against Germany. Thus, the formation of the Allied Powers, led by Britain, France, and Russia came about. Later on, they are joined in by Italy and the United States army. They all unite in full force against the Central Powers, which, on the other hand, were composed of Germany, Austria-Hungary, and the Ottoman Empire. The Ottoman Empire, which can also be regarded as the Turkish Empire, joined the First World War as a result of a secret Ottoman-German Alliance that is signed in August 1914. Russia was a long-time enemy of the Ottoman Empire, and this is the main reason why they chose to be on the Central Power’s side, even if there have been several parties in their side who are in favor of alliance with the Allied powers instead (Strachan 1998). America’s Position in World War I   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Prior to 1917, the American position on the First World War was neutral and impartial, just like that of Britain’s before the declaration of war with France. The then president, President Woodrow Wilson, reflects the public mood of remaining that way and instructed the Congress to do and maintain so. The Washingtonians and the whole nation in general, fully supported this stance. America upheld its position of insisting on unbiased rights. They are also aiming to successfully negotiate peace in all other places that has acquired stress due to the tensions brought about the war boiling in Europe. But America has one stand which is based from its own stateliness and pride. And that is not to tolerate unrestricted submarine warfare. The American nation believes that viola infringement of this would result in the violation of their respective national dignity (Goldstein and Maihafer 2004).   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   At first, Germany agreed to this sole provision. They stopped unrestricted submarine warfare, but only for the time being. It is by January that they publicly announced that they would continue to do so. It was in this year that Britain dominated the seas, and they have done so for many centuries preceding the war.   This caused the State of America to entirely eradicate its neutrality and join the forces of the Allied Powers, as an associate. To counter America’s response, Germany even commissioned Mexico to join the war beside them and be their ally against the United States. This instance fueled and further angered the American population and opinion. By April 16, 1917, the United States declared war against the Germans, as requested by President Wilson. The U.S. House of Representatives accordingly approved the resolution to join the First World War with a high margin of pro-war votes at 373-50. The US Senate followed suit with an 82-6 stand also in favor of the nation’s approval to join the now much celebrated war (Goldstein and Maihafer 2004).   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The American initial position on the war, in reality, seems to make its decision to enter it relatively less likely. America is on a neutral stand, and would likely to remain neutral had the Germans did not took the first step to severe that otherwise peaceful position (Goldstein and Maihafer 2004). Even prior to America’s involvement in this war, the whole governing body, including all its people, continually follows the judicious guidance of its previous president, President George Washington in his farewell address, as delivered on September 17, 1796. And that is to steer clear of any permanent alliance in any portion of the foreign world. The people and the government of America remained true to this statement, until after its own dignity was trampled upon and was forced to join the First World War. And that single instance made it easy for the entire nation to take part in a coalition against the very people who attempted to take pride out of the whole country (Klose and Lader 2001). But following the events of the First World War, the German people did seem to intentionally go against the United States’ declaration of no unrestricted submarine warfare. That is the only stance that the American nation requested with the conflicting forces, but that simple request was not granted. Germany, in their own defensive and offensive tactics, found it fitting to continue their attack, for reasons they alone know (Klose and Lader 2001). Given this scenario, it seems as if that that whole circumstances was planned and mitigated, with the aim to drag the Americans into the war. The Germans, at that point, believe that they could walk over America and their whole army. But they were painfully wrong. They had underestimated the military offense of the American force and they actually seem to have requested for their defeat even more, after they had decided to involve the Americans (Klose and Lader 2001). The American artillery joined forces with the British and the French, and the American troops are not scattered or broken up to reinforce the British or the French army. They fought as one group, one nation, against one cause. The Effects of American Involvement on the Home Front   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   America’s participation and victory in the First World War has its share of advantageous and disadvantageous points. First and foremost, right after the war, the United States, as well as her other allies, namely Britain and Italy, experienced an increase in their respective Gross Domestic Product or GDP. While statistics tell that that is seen to have decreased in allies France and Russia, the American nations have surely gained from the boost. However, on the Central Power’s side, there was an astounding shrinkage of as much as 30% to 40% in their respective GDP’s (Hibbard 1919). It is also believed that the greatest and the most important thing that the war ever contributed to the American nation is in the form of loans and supplies that are given and are sent to the Allies. As a proof, a lot of money was raised by bond sales, which is much as compared to those raised by taxes. The cost of the war was estimated to be US $35 billion, and about $10 billion of that went to the Allies in the form of loans. The whole American Nation gained from this, as the British and the rest of the forces began to repay their loans back to the United States (Hibbard 1919). The First World War also resulted in the expansion of the military powers of the then underestimated American nation. America was not even remotely compared to the British Empire or the other powerful countries before. But because of their support and victory of the First World War, the American people and government became aware of what they can do with their military powers. This is the birth of America being a super power, in terms of weaponry attack and tactical offense. Indeed, America was reborn to that of a giant, a giant in terms of its national stability, force and power (Hibbard 1919). The First World War also brought about American apparent domination of the world. As a country that never affiliated itself with other foreign entities, it is perceived to be just a stand-alone race, ready to respond to its internal needs and requirements. But because of the World War I, the American nation has become a domineering force in the economical, political and the social aspects (Bagby 1999). As a negative effect the First World War actually resulted in the shortage of laborers and farm workers. Military men and soldiers were sent over to the war. And common men were even drafted to join in, to add to the number of military soldiers and privates. America, even though it is engaged in the war, inevitably, still has to produce for the rest of the nation. The need to be economically stable amidst the war is very much important (Bagby 1999). Because it was the women who are left on the American soil, they stood up and participated accordingly. These women, who then, do not have any social powers and abilities to call their own, came out and worked in the absence of their male counterparts. If before, they were merely persons of the house, the war drastically changed that. They worked and did their husbands, their son’s, or the brother’s job (Bagby 1999). And in line with this, it is also the First World War that sparked women’s right to suffrage. This originally started in the British soil, but actually found its way towards America. American women suddenly found their voices and demanded to be heard in the society, as well as in politics through the electoral process. And the woman did succeed in this endeavor. She was given the right to vote in the 19th amendment of the United States Constitution in the year 1920. The rest of the nations, including Canada and Britain, followed (Mead 2004). American radicals proposed a â€Å"live for the day† attitude in response to the World War I. This attitude was introduced so as to inculcate to other people that American nation has to stop in meddling with other nation’s concerns and start living on its own, for its own. But this isolation idea can be referred to be in vain, if data up to the current day is taken into consideration (Mead 2004). Conclusion   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The First World War has taken its toll towards other nations as well as America. Any war, big or small would create an impact in all the aspects of a nation. A war is not for the poor, because it would just consume its resources even more. The war maybe for the rich nations, but even them, would feel the impacts of the war, even if the lose or win in it. Either the case, there is no real winner in a war. Every nation, everyone, is left on the losing end.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   United States has been wise to join the war. Because through it, it has successfully unleashed its military powers and social dominance that it otherwise would not have discovered. The potential to become powerful, to uphold the whole world’s rights, to protect every nation’s privileges, have become so moving in the part of the Americans. The American has become the stronghold for leadership, equality, power, and justice. This is the image that American has acquired because it has joined the very First World War. And this image is too life-size and too real. The rest of the nations began to be looking up to the American power and pride. American has indeed become a super power.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   But America could have been wrong to join the war too, because it has exposed the whole nation into unnecessary grief and hardships. The United States of America has long been self-sufficient. It participated in economic trade and relations, if only to develop itself and its people. It has not affiliated nor allied itself to other foreign entities, no matter how big and strong they may seem, simply because it do not want to subject its people to the implications a certain international treaty would bring; a treaty that, in the face of difficulties and international strain, would definitely place the entire nation in a very inconvenient stature. And this is a stature that the great men in the history of the United States have foreseen.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   And because America has proved that it is strong and capable, over time, it has lived up to its own self-acclaimed title of being the world’s alleviator, as the world’s protector against injustice and violations. Since the World War I, the American nation has processed laws and statues that have involved its own self in the Second World War, in the Cold War, the Vietnam War, the Gulf War, and more recently, the attack on Iraq.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The then stand alone and sufficient nation has seen itself suddenly amidst turmoil and conflict against other countries, in reasons directly, and even indirectly applicable to them. They are involved in situations they have to decide for themselves and the other nation. They require themselves to help who they perceive as the much weaker country.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The effects of the World War I on the United States of America is indeed, very big. Its once neutral stand against disagreeing countries that was seen prior to World War I was never seen again after it. The nation has assumed a role on its own, and it is not necessarily a productive idea, because it does affect it overall processes as a nation, and as an entity.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   America’s international relations have changed since the First World War. Some diplomatic relations have severed. A lot of economical embargo was positioned. But there are also international relations that are nurtured and stabilized. Since the First World War, America’s alliance with Britain was enhanced and has become noticeable stronger, no matter which President or which Prime Minister has replaced their respective predecessors.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The war, in general, brought out in to open the men who are in abnormal need of power and those who are philanthropists of goodwill and equality.   There are times that war is good when it is viewed from a different angle. But in general, and in essence the avoidance of war should still be primary. The effects of war to the people of today and the future generation should not be overlooked just to serve personal and selfish reasons. In times of war, we needed people who are humanitarian advocates, and not those who have an uncharacteristic clamor of authority and control.    Works Cited Mead, Rebecca J. How the Vote Was Won: Woman Suffrage in the Western United States, 1868-1914. New York: New York University Press. 2004. 1-10. Goldstein, Donald M and Maihafer, Harry J. America in World War I: The Story and Photographs. Virginia: Brassey’s Inc. 2-6.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Strachan, Hew, ed. The Oxford Illustrated History of the First World War: A History. New York: Oxford University Press. 1998. 52-59   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Klose, Nelson and Lader, Curt. United States History Since 1865. New York: Barrons Educational Series. 2001. 6-12. Bagby, Wesley Marvin. Americas International Relations Since World War I. New York: Oxford University Press. 2001. 5-9 Hibbard ,Benjamin Horace. Effects of the Great War Upon Agriculture in the United States and Great Britain. New York: Oxford University Press.1919. 65-69

Thursday, November 14, 2019

Seventeenth Century Natural Acting Essay -- European History Essays

Seventeenth Century Natural Acting As we read through the standard accounts of seventeenth-century acting, observers display the same desire to believe in the fictions of the actors as their twentieth-century counterparts. Webster said of "An Excellent Actor" that "what we see him personate, we think truly done before us" ("An Excellent Actor," 1615, in Overbury's The Wife) An anonymous elegy on the death of the famous actor Richard Burbage (d.1619) recalls, Oft have I seen him leap into a grave Suiting the person (which he seemed to have) Of a sad lover, with so true an eye That then I would have sworn he meant to die: So lively, the spectators, and the rest Of his sad crew, while he but seemed to bleed, Amazed thought that he had died indeed. Like spectators today, the Jacobean spectators had strong ideas about what constituted "good acting." Thomas Heywood notes that good looks, combined with type casting, are important: "actors should be men pick'd out personable, according to the parts they present" (An Apology for Actors 1612). In the fictional acting lesson in The Return from Parnassus, Part II (c. 1601-03), the Burbage character remarks to his student, "I like your face, and the proportion of your body for Richard the Third ... let me see you act a little of it." Shakespeare's Peter Quince and Holofernes go in for similar methods of casting in their amateur theatricals. Rhetoric and vocal virtuosity were also admired. Hamlet advises that the players speak "trippingly on the tongue" (Hamlet, III.2, c. 1603), and Heywood adds that the actor should observe the structure of his texts, "and with judgment to observe his commas, colons, and full points; his parentheses, his breathing spaces, and distin... ...n the men's companies seem to have learned more from examples that from a curriculum. In The Return from Parnassus, Part II, both Burbage and Will Kemp are shown teaching by imitation: BURBAGE: I think your voice would serve for Hieronimo; observe how I act it, and then imitate me. Here we run up against the bugbear of historically informed performance. So many of the treatises (in music and dance as well as in acting) depend on the student's imitation of an admired master, and a gradual perfection of "good taste" as his society constructed that elusive quality. We cannot recreate those apprenticeships, those saturations in a period aesthetic. However, by constructing exercises along the lines of a Renaissance aesthetic, we may expose some of the differences between what the Shakespearean audience saw, and what the North American audience sees today.

Tuesday, November 12, 2019

The Ohio Gang

Hilary Barrett April 13, 2009 Ohio History Dr. Patrick Thieving Their Way into History In 1919 World War I had come to an end. Ten years later the stock market crashed throwing the United States into a Great Depression. The time period in between was a time that was classified by a boom in the economy and prohibition legalized by the eighteenth amendment. This amendment had lead to an increase of organized crime nationwide. In that time span of these two prominent moments in American history was one of the most scandalous presidencies in American history. It came from no other than Ohioan Warren G.Harding. Harding can be considered one of the worst presidents of all time. He won the Presidential election of 1920 which made him officially the President in January of 1921. Once he became president, he immediately made up his cabinet. Three members of his cabinet included his attorney general Harry Daugherty, his secretary of the navy Edwin Denby, and his secretary of the interior Alber t Fall. These three men along with Charles Forbes, Thomas Miller and Jess Smith were coined ‘The Ohio Gang’. ‘The Ohio Gang’ was a group of men either in Harding’s cabinet or they directly knew Harding.Although some of the members are not from Ohio, they were coined this name due to their relation to Harding. In fact a majority of the members were not from Ohio. Harding let these men do as they pleased. These men single handily put together some of the biggest scams of the 1920’s. The scandals they pulled off were neither elaborate or spectacular but they made a ton of money off of them. Daugherty was Harding’s first appointed cabinet member. The beginnings of ‘The Ohio Gang’ surfaced while Daugherty was in office. He was accused of selling his vote for five thousand dollars.From that point on any kind of scandal relating to Daugherty and had an affiliation with President Harding went simultaneously with ‘The Ohio Gan g’. In a nutshell, as soon as Daugherty was appointed by Harding, the gang began their scandals. Not only that, Daugherty was the single backing of all of the scandals that occurred during Harding’s presidency. For all tense and purposes Daugherty was the backbone of ‘The Ohio Gang’. The Department of Justice at the time had two desks with the names Jess Smith and Howard Mannington on them. Jess Smith was a long time friend of Daugherty. Daugherty and his brother actually set Smith up in business.Mannington was a long time political companion of Smith. They had both worked in Columbus together. Both Smith and Mannington were brought to Washington to help the attorney general. Mannington was released from his office though. Harding believed that Mannington was becoming too reckless for his administration and sent him to Cuba. He had slight affiliations with the gang but never really lived them out the affilations as much as the other members did. He went th ere on behalf of the largest banking company in the United States and was then no longer officially associated with ‘The Ohio Gang’.The 1920’s was a time of prohibition and having someone who was considered an alcoholic as a President only lead to scandal. The only part of ‘The Ohio Gang’ that related to Mannington was the embezzlement of alcohol to New York. John Gorini, Bill Orr, and Mannington would illegally sell permits. The money for these permits was given to Gorini, then to Orr, then to Mannington. Then if you would actually want to buy liquor you could at an extra cost. Every member of the chain of sales got a little kickback. Gorini alone made over two hundred thousand dollars in a matter of four months.Orr and Mannington also got cuts that big and sometimes bigger. Also, Manningtons right hand man, Jess Smith, also got a cut. The rest of the money made on the selling of alcohol and permits was not known by Gorini where it ended up. This wa s the only relation that Mannington had to the gang. Since he was gone before anything major had happened, he was the only one who got away without repercussion. He became rich and went on to have a very successful life. ‘The Ohio Gang’ even went and had their scandals go international. A Japanese man had a connection with Mitsui and Company.The bankers of this company handed one hundred one thousand dollar bills to the Japanese man. He in turn gave the bills to Gaston B. Means. Means originally worked for the Bureau of Investigation in Ohio. Means then handed over all of the money to Jess Smith. That was a grand total of 100,000 dollars made with just this one company. Harry Daugherty never seemed to be out of the action in all of the scandals that ‘The Ohio Gang’ was a part of. It started with alien property custodian Thomas Miller. He had accepted bribes by Smith to illegally transfer a German-owned American subsidiary to the American firm.John King also had a part in this scandal. He manipulated the alien property custodian’s office to his own benefit. He died right after he was indicted for this case. It was found that he left his widow fifty thousand dollars in American Metals bonds. Daugherty is connected because all three of these men were indicted for this case. It was the case that eventually leads to the demise of the head of ‘The Ohio Gang’. The biggest scandal that ‘The Ohio Gang’ pulled off was the Teapot Dome Scandal. The Teapot Dome is an area of oil bearing land in Wyoming and Elks Hills in California.The land had been set aside for the Navy in order to provide them with petroleum. Edwin Denby was the Navy Secretary at the time. He had almost complete control of what happened to this area. Albert Fall, who was the secretary of interior, was illegally leasing the land to two oil companies; the Mammoth Oil Company and the pan American Petroleum Company. In return, Fall would receive pers onal loans or gifts from the two different oil companies. Once the scandal came to a close, Fall had made over four hundred thousand dollars in loans or gifts.Fall resigned his position once authorities found out what exactly was going on in Wyoming and California. During the U. S. investigation, Denby was called to the stand. Since he was the one who was supposed to be watching the area one would think that he would have known exactly what was going on. Yet, he was another pawn of Daugherty and came to the stand and basically pleaded the fifth. It was clear that during his confession that he was too stupid to be crooked like the rest and just went along with what Daugherty or Harding wanted him to do.Due to the way he acted during the interrogation, he is known as Harding’s best employee since he did not confess to anything. During the Senate hearing, it came to the court that Fall used the money to pay off ten years of backed taxes. Two people also came to the stand and adm itted that they had leased land from Fall. They were Harry Sinclair and Edward Dohney. They both admitted to giving Fall large loans in order to lease off the land. Fall pleaded the fifth on these two accusations. Fall was found guilty on accepting money for oil leases. He was fined one hundred thousand dollars and sent to a year in jail.All of the oilfields were returned to the U. S. Navy. Charles Forbes was appointed by President Harding as the director of the Bureau of Veteran’s affairs. It was created by President Harding in order to help out veterans of World War One and future veterans of other possible wars. It has been since renamed and still holds some status today. Forbes did serve in WWI in the marines and had a reputation as being a deserter. Once Forbes received his rank from Harding, he immediately gave himself the honor of being a colonel in the United States Army.Also, the biggest scandal of the Bureau of Veteran’s affairs was that Forbes embezzled two hundred and fifty million dollars. This money was collected to help out various veterans and Forbes kept it for himself and the gang. As quickly as ‘The Ohio Gang’ came to power, they fell just as hard. Harding died on August 2, 1923. It has been said that he died from pneumonia yet it also could have been a heart attack. With this Calvin Coolidge came into office since he was Harding’s Vice-President. Once Coolidge took the oath of the oval office, ‘The Ohio Gang’ and their dominance in scandalous political events was over.The gang had put most of their funds that they received in a bank that Daugherty’s son burned to the ground. All of the embezzled money was mostly now gone. A perfectly good reason for this was so the authorities would not see the bank books of the gang. This way they could not arrest them on charges of tax invasion as well as the ones that they were facing already. Another place that the money ended up was in Means backyar d. Means had back gate that was opened with a special key. It was in some ways almost as good as a bank vault. It was camouflaged with vines so the average person would not see it.It was a small steel box that was lowered into the ground by a strong rope. Means kept the money that Smith had bought to him. He always kept a detailed account on how much money was coming in and how much was going out. At times, Means had as little as fifty thousand dollars and as much as five hundred thousand dollars in his backyard. Smith would usually make withdrawals and go right to Daugherty’s house. Jess Smith always had a key role in the gangs constant thieving. Smith was Daugherty’s right hand man. He helped Daugherty get much of his money. Smith had brought a revolver in Columbus the night before he committed suicide.Daugherty was with Smith the night he had bought the gun. Daugherty had gone to sleep and was awakened to Smith rolling around with a revolver in his hand. Smith was n ot dead yet, but he was on the point of going crazy and shooting himself. The next night he had been rooming with a friend of Daugherty. This person was awakened by a crash and saw Smith with his head in a waste basket and a revolver in his right hand. One of the main members was now dead and Daugherty was coming up on indictment. Not much is known why Smith killed himself but much can be assumed. The main theory is that Smith knew way too much.If Daugherty and Harding were the master minds, Smith was their associate handing out tasks to all of their little pawns; he knew everything. Most historians think that he killed himself because he did not want to go through the agony of trial along with spilling the inner most workings of the gang. Charles Forbes was the next one to go. He was brought to trial on a conviction of embezzlement. Yet, he stood no chance. Once his actions went public, he was immediately convicted of embezzlement. He received a one hundred thousand dollar fine and two years in jail.His actions brought attention to the American public. It showed just how distrustful government officials are among the American people. Ironically Daugherty was forced to investigate most of the stuff that was going on during Harding’s presidency. Congress, at the time, said that Daugherty was doing a poor job investigating these cases. Once Daugherty backed Smith for his suicide, which he claimed it was just illness; the Senate launched an investigation on him. Daugherty was not directly linked to anything that the gang did. Yet, Daugherty still resigned his post as attorney general.It was a sketchy move that a lot of people still question. It was not until Hoover’s administration that all of the members of ‘The Ohio Gang’ were out of office. They were a modern day mob, who had all of the resources to get what they wanted. Harding’s presidency is solidified with their actions and should rightfully so. He headed the most scandalo us cabinets in presidential history. All of the members were not the brightest in the bunch but they got what they wanted. Although they paid the price for their actions, they will go down as the biggest bunch of crooks to ever step into such high authority as they did.

Saturday, November 9, 2019

Children’s Literature †an Autobiographical Narrative Essay Essay

Books have been a major part of my life for as long as I can remember. I was taught to read both at home and at school, and was given the freedom to choose whatever genre I decided on. My experiences with books were always positive, which allowed me to develop a love for literature. The reading that I did throughout my childhood helped to shape both the genres I enjoy and the amount I read today. The earliest memory I have containing books involves my mother reading me bedtime stories. She would read to me before bed each night, and I quickly developed favourites. One Fish, Two Fish, Red Fish, Blue Fish by Dr. Seuss was at the top of my list, and I would request this book more often than any other. I loved how the words flowed off the pages and the rhymes stuck in my head, as well as how vibrant the images on the pages were. At this age, primary colors definitely appealed to me. After reading this book to me for what seemed to be the hundredth time, my mother thought she would trick me by skipping pages in the book in order to get through it faster. Unfortunately for her, by this time I had memorized the entire book, word for word. I would throw a fit and refuse to go to bed until she went back and reread the book properly. Throughout kindergarten, grade one, and grade two, my school had a reading program. It was used to positively reinforce books in a child’s life. Each day at the end of class, children had to sign out at least one book to take home and read it with their parents. There were five levels of books, ranging from easy to difficult, and points that were given according to what level of book the child chose. Parents had to sign off that their child had read these books, and both the book and parental signature would be returned the following day. When the points were totaled at the end of each week, the child with the highest amount of points was allowed to choose a prize from a range of small toys or stuffed animals. I would strive to have the most points at the end of each and every week, and was usually able to succeed in doing so. I would sometimes try to take home four or five books a night, just to earn extra points. What I loved most about the reading program was the fact that children were able to choose their own books to take home, rather than being assigned a book. By choosing my own books, IÂ  was able to determine what genres I preferred, and which I would rather not read at all. Another major influence on my reading as a child was my older sister. She was five years older than me, and the books she was reading fascinated me. They involved stories of girls with boyfriends, and girls having their own adventures. I would always ask her to tell me about the newest book she was reading, and would sometimes steal it and pretend I was reading the same book, even if I couldn’t understand the majority of the words. I would push myself to read outside of my own reading level, always asking my parents to explain the meanings of new words. I did this until I too could read The Babysitters Club and Nancy Drew. When my sister started reading books about children with fatal diseases, by the author Lauren McDaniel, I wanted to read these books as well. Their illnesses became my own, their thoughts became my thoughts, and their world became my world. This continued throughout my life, until I reached the age where our reading levels were the same. Today, my sister and I have very similar tastes in books. If I finish a book that I know my sister will enjoy, I will mail it to her home in Ontario so she is able to get the same amount of pleasure out of it as I did, and she always returns the favor. Today, I enjoy reading fantasy, classic literature, and various works of fiction. I was able to develop my specific tastes by experimenting with different genres while I was growing up. By having the freedom to choose what genres I enjoyed both at home and at school, I acquired a love for books. I have read hundreds of titles, and will continue to do so for the rest of my life.

Thursday, November 7, 2019

films&tv increase violence essays

films&tv increase violence essays We are all influenced by things that happen to us. Watching films and television programmes are one of the main activities of human beings, so we cannot help but be influenced by them. Whether we are influenced adversely or beneficially depends on what we watch. Films and television programmes of today are filled with violence. There is never a shortage of violent shows. we get shows on crime, war, martial arts, psychopaths, murders, the occult and all manner of human degradation. The public seem to love these shows. They get a thrill out of someone kicking another to death, or see a man shoot another in cold blood, or watch a psychopath slice someone to shreds. If they enjoy seeing such shows I do not see how they can avoid being influenced. My personal experience is that after seeing a show that I enjoy, I find myself wanting to emulate the hero. At one stage of my young life, I imagine myself being James Bond. At other times I fantasize about being Rambo, Dirty Harry, Bruce Lee and other celluloid heroes. Of course I know I cannot be like them, but the influence these shows have on me is obvious. Unconsciously I imitate them. How do we get to use terms like no sweat, man, cool it, baby and others? They are all straight out of the movies. We are all influenced, whether we admit it or not. There have been cases where armed robberies copy the methods shown on popular films. The police admit this. This shows the direct influence of film on crime. Also recently there were cases of people being attacked by person wielding Samurai swords. Would these not be the influence of violent Japanese and martial arts films? They certainly look so. I have seen my friends taking up martial arts after watching one of Bruce Lees films. It is all right if they do not go out and pick a fight with someone. But who can tell? Given the opportunity they might just become another crime statistic. ...

Tuesday, November 5, 2019

Major General Alexander Hayes in the Civil War

Major General Alexander Hayes in the Civil War Alexander Hays - Early Life Career: Born July 8, 1819 at Franklin, PA, Alexander Hays was the son state Representative Samuel Hays.   Raised in northwestern Pennsylvania, Hays attended school locally and became a skilled marksman and horseman.   Entering Allegheny College in 1836, he left the school in his senior year to accept an appointment to West Point.   Arriving at the academy, Hays classmates included Winfield S. Hancock, Simon B. Buckner, and Alfred Pleasonton.   One of the best horsemen at West Point, Hays became close personal friends with Hancock and Ulysses S. Grant who was a year ahead.   Graduating in 1844 ranked 20th in a class of 25, he was commissioned as a second lieutenant in the 8th US Infantry. Alexander Hays - Mexican-American War: As tensions with Mexico increased following the annexation of Texas, Hays joined Brigadier General Zachary Taylors Army of Occupation along the border.   In early May 1846, following the Thornton Affair and beginning of the Siege of Fort Texas, Taylor moved to engage Mexican forces led by General Mariano Arista.   Engaging at the Battle of Palo Alto on May 8, the Americans won a clear victory. This was followed the next day by a second triumph at the Battle of Resaca de la Palma.   Active in both fights, Hays received a brevet promotion to first lieutenant for his performance.   As the Mexican-American War ensued, he remained in northern Mexico and took part in the campaign against Monterrey later that year. Transferred south in 1847 to Major General Winfield Scotts army, Hays took part in the campaign against Mexico City and later aided Brigadier General Joseph Lanes efforts during the Siege of Puebla.   With the end of the war in 1848, Hays elected to resign his commission and returned to Pennsylvania.   After working in the iron industry for two years, he traveled west to California in the hopes of making his fortune in the gold rush.   This proved unsuccessful and he soon returned to western Pennsylvania where he found work as an engineer for local railroads.   In 1854, Hays moved to Pittsburgh to commence employment as a civil engineer.    Alexander Hays - The Civil War Begins: With the beginning of the Civil War in April 1861, Hays applied to return to the US Army.   Commissioned as a captain in the 16th US Infantry, he left this unit in October to become colonel of the 63rd Pennsylvania Infantry.   Joining Major General George B. McClellans Army of the Potomac, Hays regiment traveled to the Peninsula the following spring for operations against Richmond.   During the Peninsula Campaign and Seven Days Battles, Hays men were predominantly assigned to Brigadier General John C. Robinsons brigade of Brigadier General Philip Kearnys division in III Corps.   Moving up the Peninsula, Hays took part in the Siege of Yorktown and the fighting at Williamsburg and Seven Pines.            After participating in the Battle of Oak Grove on June 25, Hays men repeatedly saw action during the Seven Days Battles as General Robert E. Lee launched a series of attacks against McClellan.   At the Battle of Glendale on June 30, he earned high praise when he led a bayonet charge to cover the retreat of a Union artillery battery.   In action again the next day, Hays helped repel Confederate attacks at the Battle of Malvern Hill.   With the end of the campaign a short time later, he departed for a month of sick leave due to partial blindness and paralysis of his left arm caused by combat service. Alexander Hays - Ascent to Division Command: With the failure of the campaign on the Peninsula, III Corps moved north to join Major General John Popes Army of Virginia.   As part of this force, Hays returned to action in late August at the Second Battle of Manassas.   On August 29, his regiment spearheaded an assault by Kearnys division on Major General Thomas Stonewell Jacksons lines.   In the fighting, Hays received a severe wound in his leg.   Taken from the field, he received a promotion to brigadier general on September 29.   Recovering from his wound, Hays resumed active duty in early 1863.   Leading a brigade in the Washington, DC defenses, he remained there until late spring when his brigade was assigned to Major General William Frenchs 3rd Division of the Army of the Potomacs II Corps.   On June 28, French was transferred to another assignment, and Hays, as the senior brigade commander, took command of the division. Serving under his old friend Hancock, Hays division arrived at the Battle of Gettysburg late on July 1 and assumed a position towards the northern end of Cemetery Ridge.   Largely inactive on July 2, it played a key role in repelling Picketts Charge the next day.   Shattering the left side of the enemy assault, Hays also pushed part of his command out to flank the Confederates.   In the course of the fighting, he lost two horses but remained uninjured.   As the enemy retreated, Hays flamboyantly seized a captured Confederate battle flag and rode before his lines dragging it in the dirt.   Following the Union victory, he retained command of the division and led it during the Bristoe and Mine Run Campaigns that fall.    Alexander Hays - Final Campaigns In early February, Hays division took part in the abortive Battle of Mortons Ford which saw it sustain over 250 casualties.   Following the engagement, members of the 14th Connecticut Infantry, which had sustained the bulk of the losses, accused Hays of being drunk during the fighting.   Though no evidence to this was produced or immediate action taken, when the Army of the Potomac was reorganized by Grant in March, Hays was reduced to brigade command.   Though unhappy with this change in circumstances, he accepted it as it permitted him to serve under his friend Major General David Birney.   When Grant commenced his Overland Campaign in early May, Hays immediately saw action at the Battle of the Wilderness.   In the fighting on May 5, Hays led his brigade forward and was killed by Confederate bullet to the head.   When informed of his friends death, Grant commented, â€Å"He was a noble man and a gallant officer.   I am not surprised that he met his death at the head of his troops.   He was a man that would never follow, but would always lead in battle.† Hays remains were returned to Pittsburgh where they were interred in the citys Allegheny Cemetery.   Ã‚     Ã‚   Selected Sources Major General Alexander HaysHistory Central - Alexander HaysUnion Generals: Alexander Hays

Sunday, November 3, 2019

Brand Management and Research Coursework Example | Topics and Well Written Essays - 1750 words

Brand Management and Research - Coursework Example However, brand image becomes important both in the context of the marketer and the consumer (Holt, 2002) In the case of the laptop brands like Apple, HP and Acer, the brands are influential and potentially capable of shaping up the market trends. An evaluative approach would analyse the laptop brands not only on the basis of product quality but also on the basis of the very brand image. Apple is perhaps a very strong brand in the world of laptop market. It is an innovative and capable market leader. The brand image of Apple is based on a lot of anticipation from the customers. The Apple brand actually raises expectations. Apple has been such a strong brand that the corporation ventured to make the year 2003 the year of laptops. This was stated by Steve Jobs, Apple’s CEO, in his speech at the Macworld conference, San Francisco. Aptly, the brand image of Apple inspires â€Å"technolust† and creates a stir in the market with every new release in the array of its quality pr oducts (Albritton, 2003). From the perspective of critical reflection, evaluating the laptop brand from the customer’s point of view is worthy. Apple laptops would smoothly connect on the go. The Apple laptop is compact and elegantly designed. Using it in a meeting or conference is likely to create a good impression. It has a large Multi-Touch glass trackpad on its aluminium body. The built-in iSight video camera is a technological beauty (Reinhold, 2009). Moreover, customer experience tells that it has a large display and respectable battery life (Allbritton, 2003). Overall, the brand image of Apple is innovative and adventurous. HP, on the other hand, is a brand that has an influential image as an organisation. It has a worldwide presence and a strong customer relationship management system. HP offers great after-sales support as a strong and powerful organisation. The brand has top level support and formidable investment of resources. As a laptop brand, it is backed with a mechanism of design and redesign which is apt to adjust in the rapidly changing laptop markets. The group dynamics at HP are productive and help it to survive as an organisation in fierce competition (Zell, 1997). The brand image of HP is rather dependable and the company is always ready to assist its customers. It can be rightly called an international giant in the world of information technology. With a wide range of other electronic products, HP has a reliable brand image in the laptop markets too. The company has shown phenomenal growth throughout its history. It is relatively an older international brand that started its operations in the year 1938. The brand image of HP offers a blend of strong organisation, considerable business experience and competent customer support (Pham-Gia, 2009). Companies like BenQ and Acer are known for designing and making several ICT products for other companies. The brand image of Acer is thus not as impressive as that of Apple and HP. Still, Ac er is a known name in the laptop markets. It has established a respectable brand image and it is one of the largest brands of monitors and laptops in Europe (Martin, 2006). Acer, however, depends on low cost manufacturing bases to maintain the economy of its production lines. The company has outsourced many of its manufacturing processes to Eastern Asia. As a brand, it has to depend largely on the cost-effectiveness of its products (Yu, 2007). By means of relevant