Tuesday, December 24, 2019
Effects Of Nutrition Interventions On The Food Choices Of...
Impact of Nutrition Interventions on the Food Choices of High School 9th Grade Classes Introduction Due to the high rates of youth obesity in the United States, more than one third of children and adolescents were overweight or obese in 2012, School nutrition has become an increasingly important factor in the health of all students (1). School nutrition officials are constantly evolving with changing laws, regulations and preferences in order to influence student physical health and practices in a positive way. In order to support these efforts, research must be done to determine if nutrition interventions in school classrooms do indeed have a positive effect on student choices. If changes in student health are to be achieved, then the†¦show more content†¦Limitations Although as many factors as possible were controlled during the time of this study, some limitations could not be manipulated by the researcher. These limitations included each student’s choice to focus on and learn from the provided lesson, the time of the day at which the lesson was presented and th e nutrition habits of students before the lesson. Background/Review of Literature As the research for this area of study grows, it is becoming increasingly apparent that School nutrition interventions are crucial tools to improve student health. There are numerous articles that have completed research into the efficacy and impact of nutrition interventions on students in all levels of school. According to one article, between the years of 1991 and 2010 over 43 studies were published and showed a pooled reduction of 17% in the BMI of tested students (2). As seen in multiple sources of literature, most nutrition interventions do seem to have a lasting effect on those involved (3,4,5,6). On web-based intervention, for example, provided health and nutrition information to 336 students. Upon completion of this study, it was found that BMI decreased significantly for those who demonstrated BMIs above the 85th% and did not change significantly for those at a normal weight (4). Overall according to recent research, nutrition interventions a re definitely improving the
Sunday, December 15, 2019
The Chinese Culture Free Essays
The dictionary defines â€Å"culture†as â€Å"the behavior and beliefs characteristics of a particular social, ethnic, or age group†China has about five thousand years history which is a very long period of time. Also, the Chinese civilization was growing with these periods of time and it will continues greater than ever. Many wars and unhappinesses were happening during this period. We will write a custom essay sample on The Chinese Culture or any similar topic only for you Order Now The Chinese culture has many special characteristics which are very interesting for people to learn. The family life is very important for every Chinese. Chinese families are very close-knit. Children tend to stay with their parents even after they get married and have children of their own, so that you often see three or four generations living under the same roof. Each member of the family help each other when there is any problem The Chinese culture has many special characteristics which are  very interesting for people to learn, and delicious food to try. Some types of common Chinese food are rice, noodles, soup. The  Chinese people are known for their unusual eating method using â€Å"two chopsticks†. The tradition of chopsticks was introduced to many other countries in the world such as  Vietnam, North Korea, and South Korea. As for many Asian families , Chinese people eat dinner all together at one table, They try to put the meal in the centre of the table and other serving stuff informt of the people. If this is an official dinner with guests, all the places on the table can be fulled with plates. If this a dinner with the family guys, only the minimum part of the table is used. Their most popular food is white rice and they mostly like fish and sea foods. The people also like eggs, fish, fruit, and shellfish.. Vegetables, especially cabbage and Tofu rank second in Chinese diet. Roasted sweet potatoes are a popular snack Tea is the traditional Chinese beverage. Breakfast in China may be rice porridge, chicken noodle soup, or deep fried pastries that taste like donuts. In China the people’s favorite lunch time foods include eggrolls, and dumplings filled with meat or shrimps. A typical Chinese dinner includes vegetables with bits of meat or seafood, soup, and rice and noodles. In China most Chinese dishes are served in a boiling soup to keep the contents hot for longer, Chinese cuisine and culturel behaving can be very very intresting chapter for us. That’s why people are trying to visit China and feel the difference of their cultures.. This is a very short time to summerize a very old culture in 1 hour but these Chinese different foods must have been tasted by everybody once in a life. That’s why Chinese restaurants are always crowded all over the World. How to cite The Chinese Culture, Papers
Saturday, December 7, 2019
Mice and Men is a story written by John Steinbeck mainly about two friends, George and Lennie Essay Example For Students
Mice and Men is a story written by John Steinbeck mainly about two friends, George and Lennie Essay Mice and Men is a story written by John Steinbeck mainly about two friends, George and Lennie. George is described as Small, Quick, Dark of face with restless eyes and sharp strong features. Lennie is totally the opposite, and is described as huge man, shapeless of face with large pale eyes and sloping shoulders. John Steinbeck shows that George is the small clever guy whereas Lennie is the big dumb guy. George and Lennie travel together everywhere in the search for a job. Lennie keeps on messing up and so George and Lennie have to move elsewhere. This brings them to a ranch in California. George describes people working on the ranch as the loneliest guys in the world. They have no family and dont belong no place. Theyre working in the ranch to build up a stake to have their own place. The bosss son Curley has a wife who likes to flirt around with the guys and one day she is flirting around with Lennie whilst everyone else is playing a game. She tells Lennie to touch her hair, but this was a grave mistake because Lennie doesnt let go. Curleys wife starts to scream and try to get Lennie hands of her hair. But this result in Lennie holding her hair even tighter, and because of Lennies brute strength, her neck was broken and she died. Seeing this Curley set out for revenge for his wife and his broken hand. He goes with all the ranch workers set on killing Lennie. George knows where Lennie had gone and he also goes there. George does not want Lennie to be brutally killed and for the sake of friendship he kills Lennie himself so Lennie can be spared from being killed by others. There are many themes to the play but the main one is friendship between George and Lennie. Unlike any other worker on the ranch George and Lennie have each other. Steinbeck reiterates this point by saying I got you and you got me. In Mice and Men every ranch worker desires to come together in a way that would allow them to be like brothers. Each ranch worker would like to know that there is someone in the world dedicated to protecting them. The Boss asks George Say-what you sellin? He was suggesting why he always looked out for Lennie and if he wanted the money Lennie earned. The Boss could not understand the fact that George and Lennie were friends and looked out for each other unlike the other ranch workers. Another theme would be the Human existence and during the story at one point or another nearly all the characters, including George, Lennie, Candy, Crooks and Curleys wife admit to having a profound sense of loneliness and isolation. Curleys wife admits to Candy, Crooks, and Lennie that she is unhappily married and Crooks tells Lennie that life is no good without a companion to turn to in times of confusion and need. The characters are rendered helpless by their isolation, and yet, even at their weakest, they seek to destroy those who are even weaker than they. Perhaps the most powerful example of this cruel tendency is when Crooks criticizes Lennies dream of the farm and his dependence on George. Having just admitted his own vulnerabilitiesà ¢Ã¢â€š ¬Ã¢â‚¬ he is a black man with a crooked back who longs for companionship, Crooks zeroes in on Lennies own weaknesses. It seems that each person gets strength when criticising someones weakness. Crooks seems at his strongest when he has nearly reduced Lennie to tears for fear that something bad has happened to George, just as Curleys wife feels most powerful when she threatens to have Crooks lynched. The novel suggests that the most visible kind of strength, that used to oppress others, is itself born of weakness. Probably the main reason why Lennie and George were together was because they fear loneliness. Another theme is the Impossibility of the American Dream where every character reveals that they wish to live another life. Curleys wife confesses her desire to be a movie star. Crooks, bitter as he is, allows himself the pleasant fantasy of hoeing a patch of garden on Lennies farm one day, and Candy latches on desperately to Georges vision of owning a couple of acres. All the characters have to resign themselves to something that they dont want to be. The theme is that no-one ever is getting to fulfil their dreams especially during the depression period. During the 1930s there was depression when the American economy was low and out and out of business with no money or jobs. So everyone was going to the land of dreams. It was California that everyone wanted to go to, as the soil was good for growing crops. But even California was being called a Dust Bowl which meant that the drought made it impossible to farm on the land. On the contrary people had wear masks not to inhale the sand otherwise they might not even live. For migrant workers it was really hard to earn money and was really lonely. If a migrant worker was too old they would fire him because he cant work properly. In the novel, Candy has a similar situation. The moment he cant swamp out bunk-houses theyll can him purty soon. This suggests that people who work at the ranch have to be able to work. This is why Candy wanted to lend George and Lennie the money so he would have a stake and a place to live when he was too old. Only the strongest survived in the world. Theyre lifestyle was very poor and had to work really for little money. When George and Lennie arrive in the bunkhouse they have few comforts in their quarters. The men have to sleep on rough burlap mattresses. Life was not so clean in the ranch, but Candy talks to George about the person who had earlier the bed that George had. Whitey was a very clean person and used to wash his hands even after he ate. This suggests that the rest might not have washed their hands after meals. This shows that theyre lifestyle was of a low class. Just Like That by Michael Richards EssayThe language that Steinbeck uses for Curleys wife when talking to the ranch workers is persuasive to make them understand her situation and possibly feels sympathetic for her. Also she talks in a sweet way trying to seduce them. Perhaps the time of depression resulted in women not being treated fairly and this resulted in loneliness. The culture was to try to earn as much money as they could this resulted in men forgetting about their wives. In Mice and Men there is only one black person in the whole ranch. At the time there was a lot of racism by white people to black people. Black people were being segregated by white people in everything. White people wanted to show that they are superior in every way to black people. John Steinbeck shows this as well in the book in the form of Crooks. He gets racially abused all the time because he was a black. He never spoke to anyone and he had his own room separate from everyone else so he never had chance to speak to anyone. No-one ever talked to him apart from sometimes Slim. The workers were embarrassed to talk to Crooks just like Candy is when he enters Crooks room. They called him a black negro or nigger which is a foul word to say especially if its not black man to black man. Curleys wife is very racist to Crooks saying I could get you strung up a tree so easy it aint even funny. She could get Crooks lynched through no fault of his. When Lennie tries to come into Crooks room and talk to him as the rest have gone out, Crooks says You got no right coming into my room. Crooks tell Lennie that he isnt invited to the bunkhouse because hes black and that he stinks. He was implying that he couldnt do things that other people did because he was a different race colour. When he talks, no-one gives him importance because its only a nigger talking. But finally the aspiration of talking to someone overcomes him and he allows Lennie to come in. Crooks views everyone as racist depicting his character as someone who keeps to himself and doesnt try to interact with anyone else. The culture at the time was very similar to South Africa where also this type of racism and possibly even worse racism happened to black people. The American dream was a dream everyone wanted to strive for. The poor ranch hands wish to be their own bosses, and actually have stability. George, Lennie, Candy and Crooks are all chasing the dream. George and Lennie have the dream even before they arrive at their new job on the ranch, to make enough money to live off the fat of the land and be their own bosses. They plan to have their own little place with some cows and pigs. Also they want a big vegetable patch and a rabbit hutch and chickens. Candy upon hearing about the dream, wanted to join them so he would not be left alone, especially after his dog was killed. He would have been out of a job and living place soon enough because he was getting old and so if he had his own place no-one could kick him out. Crooks wanted to join them so he wouldnt be alone. He felt that if he lived with George, Lennie and Candy, he may not be racially abused and can talk to someone. George has to let go of his dream and financial security when he kills Lennie so he would escape a brutal death. In the novel, Steinbeck mocks the dreams of the characters because of the impossibility of a better life for them. Killing Lennie meant that he wouldnt have enough money and also a person to live with so therefore he would spend his whole life alone working in the ranches. This is also dramatic irony because at the start he keeps telling Lennie that he would have done better if he was alone. But now when he is alone he cant live this way. One other aspect of the American dream portrayed in the book is the dream of Hollywood for Curleyquot;s Wife. This is the feminine version of the dream of owning land. However, she also envisions escaping the world she lives in and moving to a perfect one like the male dream. She says, whilst talking to Lennie, a show came through and I met one of the actors. He says I could go with that show. But my olquot; lady wouldnquot;t let me. She says because I was onquot;y fifteen. But the guy says I coulda. If Iquot;d went, I wouldnquot;t be livinquot; like this you bet. This quote shows how she has convinced herself that there is a better life that she could have had, and maybe still hope for in the movies. This dream is seemingly all that keeps her going in her unhappy marriage to Curley, showing once again how dreams are needed to be held onto. This has been an appropriate to study novel because it is a good way of learning about the life in America and the culture in the 1930s. The novel shows the different aspects of culture in America during the 1930s. You can learn about friendship at the time, living style, how woman were treated, racism and the dream of owning land. The most favourite part of this novel is the role of Curleys wife and how she treated by other people and how she reacts to it. This is what probably told me the most about the culture of America during the 1930s. The way that Steinbeck has depicted each character really demonstrates the life during the 1930s. This is why I feel that this has been an appropriate novel to study.
Saturday, November 30, 2019
Lab Report Food Testing free essay sample
Food Tests Carbohydrates (Sugars and Starches) Reducing Sugars. The reducing sugars include all monosaccharides, Such as glucose and fructose, and some disaccharides, such as maltose. Use 0. 1 – 1% sugar solutions. Test for reducing sugar: Benedicts test: Add 2 cm3 of a solution of the reducing sugar to a test tube. Add an equal volume of benedicts solution. Shake and bring gently to the boil, shaking continuously to minimise spitting. Observation: The initial blue coloration of the mixture turns green, then yellowish and may finally form a brick red precipitate. Basis of test: Benedicts solution contains copper sulphate. Reducing sugars reduce soluble blue copper sulphate containing copper (II) ions (Cu2+) to insoluble red brown copper oxide containing copper (I). The latter is seen as a precipitate. Non- Reducing sugars. Non reducing sugars, the most common non reducing sugars is sucrose, a disacchriade. If reducing sugars have been shown to be absent (negative result in a above test) a brick red precipitate in the test below indicates the presence of a non reducing sugar. We will write a custom essay sample on Lab Report: Food Testing or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page If reducing sugars have been shown to be present, a heavier precipitate will be observed in the following test than with the reducing test if non reducing sugar is also present. Tests for non reducing sugar: Add 2 cm3 of sucrose solution to a test tube. Add 1 cm3 dilute Hydrochloric acid. Boil for 1 minute. Carefully neutralise with sodium hydrogencarbonate (Check with pH paper) Care is required because effervescence occurs. Carry out benedicts test. Observation: As benedicts test. Basis of test: Disaccharide can be hydrolysed to it’s monosaccharade constituents by boiling with dilute hydrochloric acid. Sucrose is hydrolysed to glucose and fructose, both of which are reducing sugars and give the reducing sugar result with the benedicts test. Test for starch: Iodine/potassium iodide test. Add 2cm3 of 1%starch solution to a test tube. Add a few drops of iodine potassium solution. Alternatively add the latter to the solid for of starch. Observation: A blue-black colouration. Basis of test: A polyiodide complex is formed with starch. Test for a lipid: Emulsion test: Add 2cm3 fat or oil to a test tube containing 2cm3 of absolute ethanol. Dissolve the lipid by shaking vigorously. Add an equal amount of cold water. Observation: A cloudy white suspension. Basis of test: Lipids are immiscible with water. Adding water to a solution of the lipid in alcohol results in emulsion of tiny droplets in the water which reflect light and give a white , opalescent appearance. Test for a protein: Biuret test: Add 2cm3 protein solution to a test tube. Add an equal volume of 5% potassium hydroxide solution and mix. Add 2 drops of 1% copper sulphate solution and mix. No heating is required. Observation: A mauve or purple colour develops slowly. Basis of test: A test for peptide bonds. In the presence of dilute copper sulphate in alkaline solution, nitrogen atoms in the peptide chain for a purple complex with copper(II) ions (Cu2+). Buiret is a compound derived from urea which also contains the –COHN- group and gives positive results.
Tuesday, November 26, 2019
18 Best Love Flowers A Practical Guide to Romantic Flowers
18 Best Love Flowers A Practical Guide to Romantic Flowers SAT / ACT Prep Online Guides and Tips Buying flowers for a significant other can be a nerve-wracking experience. You want to choose a bouquet that’s in your budget, pretty, and will send the right message. Luckily, we’re here to help you craft the perfect bouquet of love flowers. In this article, we’ll first discuss what factors are important to consider when crafting romantic bouquets and Valentine’s flowers. Then, we’ll provide suggestions for the most appropriate flowers for the early phases of a new relationship, an established relationship, weddings, and anniversaries. We’ll wrap up with some flowers to avoid for romantic purposes. 4 Key Considerations When Creating a Romantic Bouquet There are several factors to consider as you try to choose the best flowers for love and romance purposes. Some are more practical, like cost and availability. But you should also consider the flower’s symbolic message and the personality of the recipient. Cost There are a couple of facets to cost: how much you can actually afford, and what cost level is appropriate for the occasion and relationship. Only you can really determine how much you can afford. But there are romantic flowers at pretty much all price points, and we’ve provided a helpful price index for all the flowers listed in this article: $ = 3 dollars per stem $$ = 8 dollars per stem $$$ = 8+ dollars per stem In terms of what is appropriate, in the early stages of a relationship, spending hundreds of dollars on an elaborate arrangement may come across as too much. You want to charm the recipient, not alarm them! However, it’s quite appropriate to be more extravagant in the context of a longer, more established relationship to mark significant milestones or occasions, if your finances allow it. For events like weddings, you might spend quite a lot on flowers. The Knot advises that you can expect to spend around 8% of your total wedding budget on all the flowers. For the budget-conscious, the Huffington Post has some sage tips on keeping wedding flower costs down. Buckets of wedding flowers could cost buckets of money! Seasonality/Availability/Climate Consider what love flowers are in season at any given point in time. Flowers that are in season locally will almost invariably be cheaper than something that has to be flown in from a thousand miles away. And some rarer flowers may simply not be available at particular points in the year. Seasonality is listed in this guide, but if you want further guidance as to what’s available at a given point in the year, consult with a florist. Additionally, flowers that do well in your particular climate will last longer and look better over time. This is especially true for any situation where the flowers will be outside and/or out of water for a long time. (Read: weddings). Symbolic Message After you’ve considered the practical parameters of your flower-buying endeavor, consider what the flowers you’re sending mean. Some meanings are obvious and well-known: red roses signify passionate love. Others, like the sweet pea, have less obvious meanings. (The sweet pea signifies lasting pleasure and bliss, FYI). However, the most meaningful bouquet will carry some symbolic significance beyond just â€Å"these flowers are pretty and I like/love you.†(That is a fine message to be sending! Just not the most thoughtful). There are also a few flowers you may want to avoid gifting due to their symbolic significance as specifically un-romantic flowers. See the last section of this article for a note on those. Ranunculus and white roses: means "you are charming," new beginnings, and soul deep love. Personality of the Recipient Unless someone actively dislikes flowers (which is possible and something you should try to find out before you give them to someone), most people will be happy to receive flowers of love from anyone they care about. However, for the most meaningful bouquet, consider the personality of the recipient. Are they a traditional romantic who would be happiest to get a bouquet of roses or lilies? Do they have subtle and subdued tastes better suited for lilac, aster, gladiolus, or sweet pea? Or maybe they are bold and unconventional and would appreciate bird-of-paradise or a potted orchid. Try your best to choose flowers that match the tastes of the recipient. Courtship and Early Romance Flowers When you’re trying to first express romantic feelings for someone or are in the earliest stages of a relationship, overly showy or intense flowers can come across as too much, too soon. However, subtler flowers with a more discreet message is a sweet and appropriate way to express romantic admiration. The following romantic flowers are excellent choices for the early stages of a new relationship. Aster Also called: Starwort, Michaelmas Daisy Cost Range (Per Stem): $ Seasonal Availability: Year-round; fall peak About This Love Flower The name â€Å"Aster†comes from the Greek and Latin words for â€Å"star.†Ancient Greek legend says the goddess Astraea looked down on earth from the sky and wept when she saw that there were no stars on earth. Her tears became the Aster flower. This flower represents daintiness, elegance, and small beginnings. It’s also a love talisman. These qualities make it an appropriate choice for the early stages of romance. The blooms are small and dainty and the flower comes in delicate, soothing colors of pink, white, purple, and blue. The aster expresses romantic admiration in a subtle and not overbearing way. Gerbera Daisy Also Called: Gerber Daisy, African Daisy, Transvaal Daisy Cost Range (Per Stem): $ Seasonal Availability: Year-round About This Love Flower The Gerbera daisy is a bright and cheerful flower that blooms in a huge variety of bright colors. They symbolize cheerfulness, joy, and innocence. Because they are fairly hardy and last well over a week when cut, they are a common bouquet flower at all times of the year. They are readily available for purchase and fairly affordable. Gerbera daisies will bring cheer in the early stage of a relationship as an early flower for love. Hyacinth Also Called: Hyacinthus Cost Range (Per Stem): $ Seasonal Availability: Winter, spring About This Love Flower The hyacinth flower gets its name from a Greek myth. Hyacinth was the young lover of Apollo, but Zephyr also admired Hyacinth. In his jealousy, he caused Apollo’s discus to strike Hyacinth, killing him. In his grief, Apollo transformed Hyacinth’s spilled blood into the hyacinth flower. As such, the hyacinth was dedicated to Apollo. Perhaps due to this myth, the hyacinth symbolizes young love. In 19th-century France, the flower communicated a kind of desperate, all-consuming love. The English connotation was more flirtatious and playful. In Victorian flower language, the different colors of purple, blue and white communicated different messages. Now, the message of young love remains, making hyacinth an ideal flower for a new courtship. Lilac Also Called: Syringa Cost Range (Per Stem): $ Seasonal Availability: Spring, summer About This Love Flower With its heady scent and clusters of tiny blooms, lilacs are a welcome sign of the coming summer. To the Victorians, this flower represented the first emotions of love. This symbolism still holds today, as the lilac represents the earliest blush of love and the beginning of summer. The lilac also represents the bittersweet sadness of new lovers when they are forced to part for even a moment. Lilac is not as commonly available for purchase as some of the other flowers described here. You probably won’t find it in the grocery store. However, it’s in many cutting gardens and you may be able to buy it through a dedicated florist. If you are lucky enough to have access to lilacs for cutting, a bouquet of fresh-cut lilac is a stunning gift for a new paramour. Ranunculus Also Called: Buttercup (some species in the genus) Cost Range (per stem): $-$$ Seasonal Availability: Year-round (winter-spring peak) About This Love Flower Small but lush ranunculus comes in many colors and makes a sweet bouquet. It sends the message that the recipient is charming and attractive- the perfect message for an early-romance gift! The message is the same regardless of the color, so pick whatever color your paramour will like best. These flowers can last up to a week in a vase. Valentine's Flowers and Romantic Flowers For a more established relationship, you may want to go with more opulent love flowers. Valentine’s day is a key occasion where your partner may want (or even expect!) beautiful flowers. We offer several floral options for a range of personalities and tastes that are appropriate for romantic occasions. Bird of Paradise Also Called: Strelitzia, crane flower Cost Range (Per Stem): $$ Seasonal Availability: Winter, spring (tropical climates) About This Love Flower The exotic and striking Bird of Paradise is named for the tropical bird that it resembles. This showy flower signifies the wonderfully unexpected, magnificence, paradise, royalty, and joyfulness. For a lover who is bold and unconventional, an arrangement with bird of paradise captures an exuberant, opulent spirit. This makes it a perfect romantic flower for the right personality. This flower of lovesis native to South Africa. As the Bird of Paradise thrives in heat and humidity, they can be somewhat expensive outside of those climes. However, this flower is worth springing for to commemorate a truly special occasion! Carnations (Red) Also Called: Dianthus Caryophyllus, Clove Pink Cost Range (Per Stem): $ Seasonal Availability: Year-round About This Love Flower The hardy carnation is thought to be native to the Mediterranean region. The carnation has historically been associated with love and marriage. Renaissance portraits often depicted betrothed couples holding a carnation. Red carnations in particular send a message of intense love and admiration. Red carnations are an affordable Valentine bouquet option when other Valentine’s day flowers are out of reach of your budget. They are a good option for affordable love flowers and romantic bouquets in general. They can last up to three weeks when cut and communicate passionate love without breaking the bank. Gladiolus Also Called: Gladiola, Sword Lily Cost Range (Per Stem): $ Seasonal Availability: Year-round, summer peak About This Love Flower With its blade-like sheaf of blooms, the gladiolus indicated to the Victorians that the receiver had pierced the sender’s heart. Now the flower symbolizes grace, fidelity, honor, and a strong character. Gladiolus is an excellent flower to express deep admiration for a significant other. It is especially appropriate for a more subtle personality- the type of person who might be overwhelmed by an enormous bouquet of oriental lilies or two dozen red roses. Lily Also Called: Lilium Cost Range (Per Stem): $$-$$$ Seasonal Availability: Year-round About This Love Flower The lily is known for its notably sizable blooms. The genus has incredible variation in color and pattern. The lily has been a sacred flower since ancient times. In the ancient near east it was associated with Ishtar, the goddess of love and fertility. Similarly, in Rome, the lily was a symbol of Venus; in Greece, a symbol of Hera. As Christianity overtook older traditions, the lily came to be associated with the Virgin Mary. In the Victorian era, it was the highest flattery to compare a woman to the Virgin Mary. As such, comparing a woman to a lily, Mary’s emblem, was to pay her high honor indeed. The white lily in particular symbolized purity, chastity, innocence, and modesty. The connotations of purity still persist somewhat, particularly with the white lily. However, lilies have also come to signify perfection, majesty, and excellence. Thus, it is a high compliment to gift someone lilies. Many consider lilies to be an incredibly romantic flower. As a showy and even bombastic floral option, lilies are one of the most striking and magnificent flowers of love. For a Valentine’s bouquet or other romantic occasion, lilies are an excellent choice. However, note that lilies are very poisonous to cats. So only give in a cat-free household! Or if your significant other has a cat, consider sending the flowers to their workplace if you know they won’t mind. Orchid Also Called: Orchidaceae Cost Range (Per Stem): $$-$$$ Seasonal Availability: Year-round About This Love Flower The tropical orchid family includes some of the most prized and exquisite of flowers. There are over 28,000 orchid species, displaying an astonishing variety of color, shape, size, and scent. The orchid symbolizes the exotic, the ecstatic, and the luxurious. It also signifies mature elegance, beauty, and refinement. However, orchids are not particularly common as a cut flower. This is because the actual flower stems are short, making the flowers incredibly hard to maintain in a bouquet. It’s more common to give an orchid as a potted houseplant. If your significant other has an interest in horticulture and would actually enjoy taking care of a plant, the orchid can be a romantic choice. The orchid is a meaningful romantic flower for love that sends the message that the receiver is highly prized and valued. But again- make sure your partner won’t be irritated that they need to take care of a plant! Roses (Red, Purple, or Orange) Also Called: Rosa Cost Range (Per Stem): $-$$$ Seasonal Availability: Year-round About This Love Flower Roses are associated with love and romance and have been for centuries. In ancient Greece, the red rose was associated with Aphrodite, goddess of love. It was also an emblem of her Roman counterpart, Venus. To the Victorians, the rose signified love, and the deeper the love, the deeper the color. Red roses meant passionate love. Today, the rose is still primarily associated with love and beauty. Red roses in particular carry the signal of passion, desire, and romantic love. Today, red Valentine roses have become so ubiquitous as to be almost cliche. However, while red roses are undeniably love flowers, Valentine’s day may not actually be the best occasion to gift them. The flowers will be dramatically more expensive (think up to 400% increase in cost). The blooms themselves may also be of lower quality. So for Valentine’s flowers, consider expressing your flower-love some other way. Say, with one of the other blooms in this section! If you must do Valentine’s day roses, consider opting for another color. Purple and orange roses also have romantic messages, and can make truly striking arrangements. Purple roses send a message of enchantment. Lavender roses connote love at first sight. A deeper purple speaks of majesty, fascination, and adoration. That’s a romantic message for sure! Purple roses are especially appropriate for a significant other with a mystical turn of mind. Orange roses mean fascination, desire, passion, and energy. It’s a supercharged, zingy romantic flower. Coral roses convey an intense desire. Sweet Pea Also Called: Lathyrus odoratus Cost Range (Per Stem): $ Seasonal Availability: Winter, spring About This Love Flower The sweet pea is native to the Mediterranean. This climbing flower emits a sweet honeyed scent when it blooms. With its profusion of blooms, it’s a well-loved choice for cutting gardens. It’s a little more difficult to find for purchase, but a specialty florist should be able to point you in the right direction. These blooms come in many colors, most commonly whites, pinks, blues and purples. The sweet pea was a hugely popular flower during the Victorian era, when it symbolized lasting pleasure and easy luxury. The sweet pea still symbolizes pleasure and bliss. If you’re looking for unique and sweet flowers for Valentine’s day or another romantic occasion, sweet peas fit the bill. Tulips (Red or Purple) Also Called: Tulipa Cost Range (Per Stem): $-$$ Seasonal Availability: Winter, spring About This Love Flower Originally native to the mountains and steppes of central Asia, the perennial tulip has become one of the most popular flowers worldwide for both gardens and bouquets. The tulip is a romantic flower, whose strongest symbolic associations are with love and creativity. However, red and purple are the most romantic tulip colors by far. Red tulips signal a declaration of love. This symbolism comes from Persia. There, it’s said that the red of the petals represent the fire of the suitor’s love. The black center is the suitor’s heart, burned to coal by the strength and heat of their love. Purple tulips signify royalty. For an extra-special bouquet, consider mixing red and purple tulips. If you’re looking for an alternative to Valentine roses, tulips are a great choice. Tulips make great love flowers because of their vibrant blooms and meaningful symbolism. They also last a decent amount of time- about ten days- when cut. The Best Wedding Flowers Pretty much all of the flowers already mentioned would be appropriate for wedding bouquets, boutonnieres, centerpieces, etc. However, several additional flowers are particularly well-suited to weddings. Calla Lily Also Called: Zantedeschia aethiopica, arum lily, trumpet lily Cost Range (per stem): $$-$$$ Seasonal Availability: Year-round (summer peak) About This Love Flower The calla lily is named for the Greek word for â€Å"beautiful.†Interestingly, the calla lily does not actually have a bloom. The part we think of as the flower is actually a leaf. They come in many colors, including bright orange and striking purple. However, they are most commonly used for weddings in their white incarnation. Calla lilies symbolize majestic beauty. White calla lilies represent purity, modesty, marital bliss and devotion. Purple calla lilies would also be appropriate, as they symbolize royalty and passion. Calla lilies come in both large and small varieties, making them ideal for both bouquets and boutonnieres. Lily of the Valley Also Called: Convallaria majalis, May bells Cost Range (Per Stem): $$ Seasonal Availability: Year-round, spring peak About This Love Flower The humble but striking lily of the valley was the emblem of the Norse goddess of the dawn, Ostara. In Christian lore, it’s said that the lily of the valley sprang from the tears of Mary as she wept at the cross. The lily of the valley represents purity, sweetness, and a renewal of happiness. This makes it a great choice for a wedding bouquet- especially one that’s not too neat or fussy. It’s fairly expensive on a per-stem basis. But only a few are necessary to make a beautiful bouquet. It can also be accented nicely with other flowers. Orange Blossom Also Called: Citrus Sinensis Cost Range (Per Stem): Not a typical bouquet flower; discuss with a florist Seasonal Availability: Spring About This Love Flower When the orange tree blooms- usually in April- it bears beautiful, fragrant white flowers. These flowers are closely associated with weddings in many cultures. It’s said that the crusaders brought the practice back to Europe from the Middle East, where Saracen brides wore the blossoms as a symbol of fecundity. In Victorian England the blossoms came to signify a bride’s purity. In Japan, orange blossoms symbolize chastity and eternal love. The blossoms have remained symbolic of a fruitful marriage, loveliness, and innocence. For a traditional (and pleasantly fragrant) wedding flower experience, use orange blossoms in the bridal headpiece or bouquet. Roses (White) Also Called: Rosa Cost Range (Per Stem): $-$$$ Seasonal Availability: Year-round About This Love Flower The white rose bears many different shades of meaning. It’s said that white roses accompanied the birth of Aphrodite from the sea. In the Christian era the white rose was associated with the Virgin Mary. To the Victorians, it signified chastity and innocence. The white rose most traditionally symbolizes purity. However, it also symbolizes new beginnings, loyalty, and soul-deep love. This make it a very appropriate wedding flower. Cream roses in particular are considered very bridal flowers. Stephanotis Also Called: Madagascar jasmine, bridal flower Cost Range (per stem): $ Seasonal Availability: Year-round About This Love Flower White, trumpet-shaped Stephanotis is native to Africa and heavily perfumed. Its also the quintessential wedding flower, as it symbolizes marital happiness. Its delicate blooms, sweet scent, and symbolic meaning make it an extremely popular flower for wedding bouquets and boutonnieres. It can be a filler in an arrangement with larger blooms, or clusters of stephanotis can be the focal point. Wedding Anniversary Flowers When you’re picking flowers for a wedding anniversary, first ask yourself: Do I want to give the traditional flower associated with the anniversary, or do I want to branch out? If your spouse doesn’t even know that there are specific anniversary flowers, you’re probably better off choosing something you know s/he will appreciate. Any of the romantic flower choices could be good choices for anniversary flowers. If, however, your think your spouse would appreciate receiving the traditional anniversary bouquet for your designated year of marriage, here’s a chart with the breakdown. (Note that past the fifteenth year, there aren’t flowers for every year anymore!) Chart Anniversary Flower 1st Carnation 2nd Lily of the valley 3rd Sunflower 4th Hydrangea 5th Daisy 6th Calla lily 7th Freesia 8th Lilac 9th Bird of paradise 10th Daffodil th Tulip 12th Peony 13th Chrysanthemum 14th Orchid 15th Roses 20th Aster 25th Iris 30th Lily 40th Gladiolus 50th Yellow roses and violets This could be a beautiful anniversary bouquet. Love Flowers To Avoid You have a lot of options for flowers of love. But what about flowers you should avoid? Here are a few types of flowers you may want to leave out of your romantic bouquets. Yellow Flowers Yellow flowers typically symbolize one of two things: platonic friendship or jealousy. Neither of these are particularly auspicious messages for romance. I’m not saying you can never send yellow flowers to someone you're in a relationship with: if yellow is their favorite color, or you have an established relationship and you want to send some cheer, yellow might be appropriate. But early in a relationship, you may want to avoid yellow’s ambiguous symbolism. Flowers With Un-romantic Symbolism In addition to yellow flowers, there are several other plant varieties that don't lend themselves to very romantic messages: A gift of narcissus indicates that the recipient is self-obsessed and egotistical. Not the most heartfelt and romantic message! Lavender signifies distrust, perhaps because it was frequently used to conceal unpleasant odors. A striped carnation signifies refusal of love. Snapdragons signify both graciousness and deception, so this is another flower that may be fraught with romantic peril. You might want to avoid these blooms. Flowers That Will Poison Your Pets or Children Nothing kills romance faster than a dead puppy. If your beloved has pets (or children) at home, avoid giving flowers that are poisonous to the household denizens! Some of the biggest poison culprits are lilies and calla lilies. You can look up other plants poisonous to children here and other plants poisonous to pets here. Remember, roses are edible- making them pretty much non-toxic to all! So they're generally a safe bet. Flowers That Trigger Allergies Does your beloved get hay fever? Then there are a few flowers you should avoid, unless you want them to sneeze whenever they get too close to your bouquet! The asteraceae family may trigger allergies. This family includes asters, dahlias, daisies, Gerbera daisies, and chrysanthemums. Lilies also have pollen, but you can trim off the stamens before gifting the flower, eliminating the problem. In general, flowers with smaller blooms produce more pollen than larger flowers, making them more of an issue for allergy sufferers. Definitely not a great flower for love! So definitely don't pick poisonous yellow flowers with lots of pollen! Key Takeaways: Finding the Perfect Love Flowers When it comes to buying romantic flowers, not all blooms are created equal! When choosing the best bouquet for a loved one, you’ll need to consider: Price: What can you afford, and what’s appropriate to spend? Seasonality/availability: what flowers are available? Symbolism: What flowers send the most appropriate symbolic message? Personality of the recipient: What flowers match the recipient’s style, taste, and personality? Different flowers are potentially appropriate for different points in a relationship. Flowers particularly appropriate for early in a courtship include the aster, the gerbera daisy, the hyacinth, the lilac, and the ranunculus. Blooms well-suited to romantic occasions and Valentine’s bouquets include the bird-of-paradise, red carnations, gladiolus, lilies, orchids, roses (orange, red, or purple), the sweet pea, and red or purple tulips. The most appropriate wedding flowers include the calla lily, the lily of the valley, orange blossoms, white roses, and stephanotis. For wedding anniversaries, you can give your significant other either the designated anniversary flower for your years of marriage or an appropriately romantic bouquet of your choosing. Here’s what you should avoid when crafting a romantic bouquet: Yellow flowers- they mean either platonic friendship or infidelity Flowers with negative or ambiguous symbolism, like narcissus, lavender, striped carnations, and snapdragons. Flowers poisonous to any pets or children that live at the recipient’s home Blooms that will trigger allergies, if the recipient has them Armed with this info, you’re ready to craft the most romantic bouquet the world (or at least your paramour) has ever seen!
Friday, November 22, 2019
Adverse effects of the PPT rule
Adverse effects of the PPT rule In the EU context, the ECJ case law cannot be ignored to interpret anti-abuse provisions such as the PPT rule. Apart from settle case law, I considered the recent decisions on French and German anti-abuse rules confirming the ECJ’s adherence to the familiar wholly artificial arrangement test. Abuse is considered to exist if the setting up of an intermediate or other holding company qualifies as wholly artificial arrangements. This is the case if the facts show that setting up or maintaining the holding company does not correspond to the freedom of establishment’s intended aim of promoting economic integration. For this to exist, a company must pursue genuine activities for an indefinite period through a fixed establishment in another Member State. This in turns requires the existence of premises, staff and equipment to carry out economic activities. The question of what facilities can be considered to constitute a sufficient physical presence depends on the nature of th e activities pursued. These facilities must in any event be proportionate for the activities that are to be carried out. Instead, passive activities, such as certain holding company activities, generally require few facilities. The further requirement is for the entity to perform genuine economic activities. Passive activities can in principle satisfy this requirement, unless the activities are so marginal that they can no longer be regarded as bearing any relationship to economic reality. It could potentially be concluded from the ECJ case law that pursuing passive activities without any accompanying provision of services does not constitute a genuine economic activity. The absence, therefore, of any services provided by the intermediate or other holding company to a group company or third party could suggest the lack of a link to economic reality. If arrangements are to qualify as abuse – and, therefore, as lacking an establishment – it also has to be determined whether the parent company was objectively seeking to obtain a tax advantage by setting up the secondary establishment. This will be the case if the facts demonstrate that the arrangements could not have any purpose other than a wish to escape tax. An aspect of critical importance is the link that a company has with the host Member State through its pursuit of genuine economic activities, whereby the term ‘genuine economic activities’ has to be interpreted widely. Even activities of a more passive nature, such as certain holding company activities, can in principle be covered by this term, providing the intermediate or other holding company has sufficient physical presence to perform the activities and the arrangements have not been put in place solely for the purposes of avoiding tax. Finally, I tried to exemplify the adverse effects that the PPT may generate in practice by simulating the application of the rule to an equity wall structure. I showed the reasons why the PPT rule may represent a stronger weapon in the hands of tax authorities.
Wednesday, November 20, 2019
Exercise is now known to benefit cognitive function in people of all Essay
Exercise is now known to benefit cognitive function in people of all ages. Describe the evidence that supports this statement - Essay Example Along with VO2max and brain oxygenation, the adults who participated in the study showed an improvement in their cognitive function after they finished the exercise program that was designed for them for four months (â€Å"Exercise Improves†& â€Å"Exercise makes†). Another research was conducted for people with mild cognitive problems such as those diagnosed with about an average of ten times the risk of having dementia. During the intervention of an aerobic exercise to the adult participants with mild cognitive impairment, the result of the study found that there was an improvement on the cognitive function of the participants. For the women, there was an observed change in the physical and chemical reaction that includes â€Å"better disposal of glucose, decreased fasting plasma levels of insulin, cortisol, and brain –derived neurotrophic, while men showed an increase in their plasma level of insulin-like growth factor (Bankhead n.d).†Similarly, Kramer, Erickson, and Colcombe (2006) obtained a result showing an improvement of people, this time with anemia, found to have a positive effect of exercising to those who are already affected by dementia. Specifically, the controlled studies conducted by Baker, et al (n.d.), the effect of high-intensity aerobic exercise though geared towards the improvement of cognitive function, specifically identified the specific effects of exercise to men and women. While men’s plasma levels of insulin-like growth is increased, women’s disposal during the metabolic clamp is increased and the function of fasting plasma levels of insulin is decreased (Baker et al,
Tuesday, November 19, 2019
Casestudy Essay Example | Topics and Well Written Essays - 1750 words
Casestudy - Essay Example This aspect is very subjective and the expectations and objectives along with their ever changing nature make them very ambiguous and prone to conflicts and misinterpretations (Petersitzke, 2009, p.26). This has made the concept of psychological contract the root cause of mistrust between employers and the employees. Psychological contract is a phenomenon that induces at the very onset of a relationship between an employer and an employee. Psychological contract often forms the basis of employee associations and emergence of faiths and beliefs of an individual (Wilton, 2010, p.37). Figure 1: Psychological Contract and the effect on Organization (Source: Wilton, 2010, p.37) The figure above clearly shows the components as well as the influence on the areas of organization with regards to the aspect of psychological contracts. ... The aspect of psychological contract and its linkage with economic and monetary aspects including rewards and compensation has been a matter of debate for academic and other circles. Authors like Schein state that psychological contracts and its effects are only prominent in case of non tangible aspects and hence rewards and monetary compensation do not influence the aspect of psychological contract in an organization and vice versa. However certain authors often refute this claim and state a direct linkage with aspect like compensation and psychological contracts (Makin, Cooper & Cox, 1996, p.5). The case study in the present analysis reveals a case of psychological contracts and its influence. On one hand it is seen that the initial reception to the trainees was good and it induced a lot of motivation on the part of the employees. This include the corporate sponsored lunch and dining at various plush hotels, blackberry set for office work etc. Moreover the rigorous and tough recrui tment process was also motivating to the extent that employees started to believe of a path breaking successful stint at the organization and were hopeful of getting a profile that would add value to their careers. They also hoped that the rigorous process and the following events would essentially mean a tenure that would provide them with considerable responsibility that would add to their learning curve and would enrich the value addition process. In this case the process of psychological contract can be seen to have evolved much before the actual stint at the organization. It also reveals that these aspects were essentially not a part of the formal contract between the employee and the employer. However these aspects had a crucial linkage with the morale and
Saturday, November 16, 2019
Investigating the Possibility of a Developmental Trend in the Way That Children Describe Themselves Essay Example for Free
Investigating the Possibility of a Developmental Trend in the Way That Children Describe Themselves Essay This version of Rosenberg’s research into children’s self-descriptions analysed data from semi-structured interviews with two children; Annie (8) and Kirsty (16). The data was interpreted to ascertain whether, as in Rosenberg’s research, children’s self-descriptions show evidence of a developmental progression and whether locus of self-knowledge shifts from other to self as children get older. Substantial support was found for Rosenberg’s theory that children’s self-descriptions become more complex with age and demonstrate a developmental trend. Some support was found for the idea that the locus of self-knowledge shifts from other to self with age but some of the children’s responses ran counter to expectation. Introduction A child’s sense of identity begins to form at a young age and develops throughout childhood. Eleanor Macoby (1980) pointed out that a sense of self emerges gradually as a child develops more complex understandings. Research shows that children differ in the way that they describe themselves at different ages. Bannister and Agnew (1977) and Harter (1983) found that as children get older they use more complex descriptions and include more references to emotions and attitudes. Younger children rely more on physical attributes, activities and preferences. Bannister and Agnew (1977) proposed that as children get older they become better able to ‘distinguish themselves psychologically’ from others (The Open University, 2009, p.20). Harter (1983) proposed that the way children describe themselves follows a developmental sequence which reflects the notion that identity develops in increments throughout childhood. Rosenberg (1979) focused part of his research into the self-concept on investigating this idea of a developmental trend in children’s sense of identity. He interviewed a sample of 8-18 year olds and created categories in which to sort the children’s responses. In keeping with the findings of Bannister and Agnew and Harter, Rosenberg found that younger children used mostly physical descriptions of themselves while older children relied more on character traits. As a result he concluded that ‘the self becomes less and less a perceptual object and more and more a conceptual trait system’ (Murphy (1947), as cited in The Open University, 2009, p.21). He found that, as children get older, they focus more on interpersonal traits and refer more frequently to relationships and inner qualities. Rosenberg also investigated what he called the ‘locus of self-knowledge’ – the extent to which children develop an ‘independent, self-reflective sense of self’ (The Open University, 2009, p.22). This was measured by asking children who knew them best, themselves or someone else. He found that younger children were more likely to claim that another, usually a parent, knew them better. Older children were more self-reliant when it came to judging themselves. Therefore, Rosenberg concluded that the locus of self-knowledge shifts with age from another to the self. Increased self-knowledge would result in more psychological self-descriptions so this relates to the idea of developmental progression being demonstrated in children’s self-descriptions. This study is based on Rosenberg’s research and is an analysis and interpretation of interview data. Children’s responses are allocated to Rosenberg’s categories in order to answer the research question: Do children’s self-descriptions show evidence of a developmental trend? This study will focus on answers to the ‘Who Am I?’ statements but will also pay attention to further interview responses to understand differences in the way children of different ages self-evaluate, view themselves and others and conceptualise an ideal self. This study also examines the concept of a locus of self-knowledge and asks: Does a child’s locus of self-knowledge shift from other to self with age? Method Design Rosenberg’s research design is employed in this study the responses from a semi-structured interview are compared. Participants The participants are Annie (8) and Kirsty (16), pupils from schools in the Milton Keynes area. They were recruited by the ED209 course team who asked school teachers for help in identifying willing participants. Materials A microphone and a video-recorder were used to amplify and record the interviews. Rosenberg’s semi-structured interview, with questions on self-description, self-evaluation, self and others, ideal self and locus-of self-knowledge was used. A sheet of A4 with the words ‘Who Am I?’ printed at the top and ten numbered lines beginning with ‘I’ was provided to enable participants to complete the written exercise. Adaptations of Rosenberg’s categories were used to analyse the responses to the Who Am I? exercise. The analysis of the ‘Who Am I?’ statements was presented on category analysis forms (appendix 1). A consent form was provided for the parents of the children to sign. Procedure The interviews took place in May 2005 during the day. Both children were interviewed by members of the ED209 course team in familiar rooms used by the schools. Annie was accompanied by a classroom assistant. The participants were told that they could stop the interviews at any time and were briefed as to the purpose of the research. A sound recordist and producer were present but efforts were made to ensure that neither they nor the equipment used inhibited the participants. Background noise was occasionally intrusive and recording halted. The final recording of the interviews was edited to ensure a smooth flow. The recorded interviews were listened to several times. The ‘Who Am I?’ statements were identified and transferred onto a pre-prepared category analysis form (appendix 1). The categories, Physical, Character, Relationships and Inner, were adapted from Rosenberg’s (see appendix 2). Each sentence read out by the interviewer was taken to constitute one statement. The statements were then coded. To ensure coding consistency, each statement was reviewed against the criteria for the inner category, then relationships, then character and then physical. Only if there was no way it could be said to fit within the ‘higher’ category was it pushed down. Even if it may have fitted within two categories, the fact that an order of review was applied meant that it would not be considered for a second category if it had already been allocated. Once the categories had been applied, the responses in each column were added up and the percentages calculated so that the results could be compared with Rosenberg’s findings. Next the detailed responses to the interview questions, including the locus of self-knowledge questions, were analysed in the context of Rosenberg’s research findings. The responses of the children were analysed to see if the same patterns were present. Ethics The data collected by the Open University ED209 course team was intended to comply with the BPS ethical code and principles. The children agreed to take part and their parents signed consent forms on their behalf. At the start of each interview the children were informed of their right to withdraw from the research and were told that they could ask for the recording to be stopped at any time. The purpose of the research and they way in which the data would be used was explained to them before the interviews began. Results The first research question was: Do children’s self-descriptions show evidence of a developmental trend? The second research question was: Does a child’s locus of self-knowledge shift from other to self with age? Table 1 shows a comparison between Annie and Kirsty’s self-descriptions. It shows that the majority (60%) of descriptors used by the younger child are about physical characteristics and activities and the remainder are character descriptors. She makes no reference to relationships or inner qualities. The majority of the older child’s responses relate to inner qualities (50%). She spreads the remainder of her descriptions across the physical, character and relationship categories. Self Evaluation When discussing their strengths and weaknesses, Kirsty focused far more on character and relationship descriptions than Annie, who focused on physical attributes, particularly for her weak points (‘my ears my legs’). However, Annie counted her friends as a strength and the fact that she likes ‘being myself’. Self and Others Annie’s awareness of similarity to others in her age group was centred on having the same likes and dislikes. She also identified differences between herself and others in this way. Kirsty talked about having the same experiences as others her own age but identified character and inner traits as distinguishing her from others. Ideal Self Annie’s notion of herself in later life was focused upon what job she might do and how else her time may be spent. Kirsty focused on the character traits that she hoped to have developed. Locus of Self-Knowledge The locus of self-knowledge responses were not straightforward as both participants gave ambiguous answers at times. Annie conceded that in some ways her mother would know her better than she knew herself and Kirsty insisted that her mother knew her just as well as she did herself. Discussion In the ‘Who Am I?’ data, it can be seen that, in accordance with Rosenberg’s findings, the majority (60%) of descriptors used by the younger child are about physical characteristics and activities. Rosenberg found that older children are more likely to use character traits to define the self. In this analysis, Kirsty actually uses a lower percentage of character descriptors than Annie, but this is influenced by the large percentage of inner descriptors used. The data in this study supports Rosenberg’s finding that older children referred more frequently to relationships. He also noticed that older children were more likely to reference inner qualities, which can be seen by the high percentage of Kirsty’s inner descriptors (50%). For the main part, the analysis of the self-description data supports Rosenberg’s findings. Rosenberg found that older children focused on interpersonal traits when describing their strengths and weaknesses. Kirsty’s responses follow this pattern but Annie also mentioned the large number of friends she has as a strength. She also said that ‘being myself’ was a strength which was interesting. The interviewer explored this a little more and she seemed to revert back to describing preferred activities. Further prompting, however, may have ascertained that by ‘being myself’ she meant that she was confident about who she was, which would be a character description. It is difficult to tell at this point if Annie lacks the ability to explain what she means which may affect the results. Rosenberg found that only 36% of 8 year olds mentioned interpersonal traits when talking about the person they would like to become, compared with 69% of 14-16 year olds. Annie and Kirsty’s responses fall into the majority pattern for their age group. Analysis of the data provides a positive answer to the research question, Do children’s self-descriptions show evidence of a developmental trend? The developmental trend as identified by Bannister and Agnew, Harter and Rosenberg, is characterised by younger children relying on physical attributes when describing themselves and older children being able to use more sophisticated and complex descriptions that focus more on psychological characteristics. The data in this study largely supports this theory. The evidence for the locus-of-self-knowledge shifting from other to self with age (as Rosenberg found) is less obvious. When asked about who knows her best at school Annie identifies teachers and parents as being the best judge of her performance, which supports the idea that the locus of self-knowledge in young children rests with another. However, when questioned further about who would be right if they had different answers about Annie’s maths performance, Annie’s responses indicate that she is the best judge of her ability. However, when questioned about her behaviour at home she places the locus of self-knowledge with her mother. Kirsty, somewhat surprisingly given her high percentage of references to inner qualities (indicating high self- knowledge), believes that her mother would know her just as well as she knows herself and explains that her mum has ‘pretty much figured me out’. She decides that any differences in answers about how she would behave at home would be a matter of different interpretations. It is possible that Kirsty is unsure about what is being asked and a reformulation of the questions might provoke different responses. Although Kirsty does not exactly place the locus of self-knowledge within herself, she does not place it with someone else either, and so the data does not, in itself, contradict Rosenberg’s theory. The analysis of the locus of self-knowledge responses produces some support for Rosenberg’s findings but it is not conclusive. However, it is important to remember that this is a sample of only two participants and so the data is not enough to prove or disprove his theory. Another limitation of this study is that the coding reliability was not checked. Coding was applied according to one person’s interpretation. Had the coding of the data been interpreted differently results may have been different for the self-descriptions data (see appendix 3 for alternative coding of Kirsty’s responses. In this instance the evidence in favour of a developmental trend in self-descriptions is present but less compelling). Another consideration lies with the ethics of the research. The issue of informed consent is often difficult in research with children. In the case of a young child, such as Annie, it is not clear that she fully understands the nature of the research, despite the fact that it is described in simpler terms than those used to explain it to Kirsty. It is also possible that the power-imbalance between the interviewers and the participants may prevent them from withdrawing from the interview, even if they are told that they can. Conclusion The results of this study provide support for the idea of a developmental progression in the way that children describe themselves, particularly the analysis of the ‘Who Am I?’ data. Qualitative analysis of the other interview questions, however, while showing some support for Rosenberg’s theory, also presents some deviation from expectations.
Thursday, November 14, 2019
Youth Representation in movies Ten Things I Hate About You compared to Stand By Me :: Papers
Youth Representation in movies Ten Things I Hate About You compared to Stand By Me From the very beginning of both films we can see there is going to be a big difference. At the very beginning of "10 things I hate about you" we see a big town, which I think is Seattle because in the background I can see the "CN Tower", and also there is a sort of modern U.S.A. high school rock being played which is kind of upbeat. Unlike "Stand By Me" which starts off with an adult sitting in a car, in a field, in the middle of nowhere, and there is slow old music being played in the background as the adult is reading a newspaper article about an attorney being killed (later on we realise that the attorney was once a very close friend). Also from the very beginning "10 Thing'sà ¢Ã¢â€š ¬Ã‚ ¦." starts with very bright colours which shows us that its is going to be a cheerful, interesting and happy film, we can say this because that's the kind of feelings people get from bright colours. However "Stand by me" starts off with a quite dull colour scheme, because of the dull colour scheme we can say that it is going to be a sad film, as well as an emotional film. Also the youths in "10 Thing'sà ¢Ã¢â€š ¬Ã‚ ¦." lifestyles are basically going to school which we can relate to and also, they date, get drunk and have lots of friends which we can also relate to. However the youths in "10 Thing'sà ¢Ã¢â€š ¬Ã‚ ¦." are very privileged and we know this by all the places they can go and hang out, for example paint balling boating and all the sports that they are offered from school in which they can take part. Unlike "Stand By Me" which must be during the holidays because although the children mention school, we never see them in school, there lifestyle is completely different to the youths in "10 Thing'sà ¢Ã¢â€š ¬Ã‚ ¦.", for example Chris, Verne, Gordie and Teddy usually lounge
Monday, November 11, 2019
A Brief History of Drama Essay
The time period from about 1650 to 1920 was ever changing in the world of drama. Neo-classicism sprung up from Greek and Roman models in Europe during the Enlightenment, Romanticism struck the Globe in the 1800’s based on principles like emotion, intuition and seeking God. During and after the 1800’s naturalism and realism began to play major roles in the area of drama. Naturalists such as August Strindberg and realists such as Henrik Ibsen demonstrate an entirely different view of what drama is all about. During the time period known universally as the Enlightenment, an artistic movement came about in Europe that reflected in many ways the Greek and Roman tradition. Ancient Greeks and Romans focused their art on harmony, symmetry, and balance, while keeping an equal emphasis on logic and aesthetic. During the enlightenment there was a major importance placed upon science, reason and thought. These human, but multifaceted functions are displayed in many neo-classicism plays. Plays such as Racine’s Phaedra clearly demonstrate the notion of common sense and the idea that if you have a problem or cause a problem you will be punished. This play is very typical of the neo-classics because it is based on the ancient Greek play Hippolyths written by Euripidies in ancient Greece. Hippolyths is very closely related to its modern version Phaedra. All neo-classic era plays were in some way based on the French Academy’s rules for drama which involved a concrete moral, no monologues and truth along with few other qualifications. Most plays that possess some or all of these qualities are from the neo-classicism era. After the 1700’s a new way of thinking developed that didn’t involve as much truth or structure. Free flowing emotionally based romanticism paved the way for drama in the 19th century. The 1800’s were a time of innovation and industrial revolution. In America, thousands of people were migrating to cities to find work in large factories powered by new, innovative technologies. New thinking developed through the likes of Charles Darwin and the Origin of the Species, and Karl Marx and the Communist Manifesto. Romanticism deals with three main ideas, emotion, intuition, and seeking God, while grasping the audience with thick plots and poetic language. All of these qualities are displayed in most romantic plays of the 19th century. Throughout the late 1800’s and early 20th century, naturalist and realist took charge of the drama scene with a new outlook of what could be done on stage. With Naturalism comes plays which display daily life and street language with real settings meant to display a message or cause. With realism comes real language, strong plots, realistic settings and social critique. In realistic plays such as Henrik Ibsen’s A Doll House, a very common situation involving an everyday married couple is reviewed and critiqued. In the naturalistic play Miss Julie by Swedish playwright August Strindberg, a naturalistic tragedy develops as the characters find themselves trapped in an odd love triangle. Both Naturalism and Realism were monumental to drama because they explored many social issues very critically while challenging the neo-classicism view of what is allowed on stage. It seems obvious that both naturalism and realism attempted to overstep the boundaries of what was acceptable onstage and it is very apparent that it was a success because many naturalism and realism era plays are still popular today. Unlike the strict ruled neo-classicism or the emotionally based romanticism, naturalism and realism display real events, real people and real stories that can be related to by real people. Television shows today are very realistic. With the new wave of reality T.V. hitting every station, it is obvious that the realist and naturalist took a step in the right direction when they looked beyond restriction and let what is real come to life. It is obvious that very monumental changes occurred in drama from 1650-1920. All over the world new ideas and innovations were being explored and challenged on stage.
Saturday, November 9, 2019
Alan Greenspan’s misunderstand of the causes of the consequences and causes
Today's policymakers must see past Alan Greenspan's misunderstand of the causes of the consequences and causes of the extraordinary grown of the U. S. ‘s account deficit. According to Greenspan, high rates of saving abroad led to increased consumption in the U. S. An alternative view to the cause of the growth in the deficit is that increased globilization made trade between richer countries and poor countries possible. Rich countries began to buy cheaper goods in poor countries, and poor countries continued to buy their own domestic goods because they were cheaper than those abroad.As a result, the U. S. deficit, which was balanced in 1991, rose to $850 billion in 2006. With the increased trade effects of globilization taking place, the central banks of countries which had a surplus prevented their currencies from appreciating by printing their own currencies and buying thousands of billions of dollars to sustain their competitive advantage. Greenspan argues that no real harm believe that no real harm has been done by these trade imbalances, and that rising debt and progress go hand-in-hand. It seems more likely that the rise of the U. S.Deficit and the paper money creation have generated an economic bubble around the world that is close to imploding. In order to stave off a complete systemic meltdown, the central banks of Europe, the U. S. , and the U. K. have injected billions into the credit markets. The Federal Reserve has been prompted to issue a round of aggressive rate cuts. U. S. lenders have expanded their balance sheets at an unprecedented pace, and the U. S. government is currently rushing through a $150 billion emergency stimulus package in an effort to prevent a world recession. Overall, it seems that Greenspan has confused cause with effect.
Thursday, November 7, 2019
Shift in Architecture essays
Shift in Architecture essays What made the shift, from the modern machine culture of Corbusier to the new brutalism order of Team 10. Every phase of architecture has to have an anti-phase, where its ideals are opposed. The young architects who grew up with old masters ideals soon became disenchanted with his visions. It can be harsh because a singular vision of utopia can never be achieved. The birth of Team-X is due to these reasons. CIAM, Congres Internationaux d'Architecture Moderne was started in 1928 as a declaration, signed by 24 architects in Europe. Its agenda emphasizes building rather than architecture as the elementary activity of man intimately linked with evolution and the development of human life. It was primary dominated by the idea of individualism at the first three meetings with topics that focused on the ideal, efficient spaces for individuals and the minimum living standards. At the 4th CIAM in 1933, the ideals of Corbusier took over. His visions of the utopian, modernist Machine City thus spread its influence throughout Europe. City planning became the main focal point of the meetings. This in fact would shape social orders throughout the continents. And during his reign as the main idealist of CIAM, it became the custom of architectural students to flock to CIAM, to re-establish contact with the international Modern Movement, to sit at the feet of its great masters and to acquire those non-parochial standards of architectural values. This consequently lead to the birth of Team 10, the younger generation of architects who were involved with CIAM. They wrote We of the younger generation received a shock at the Aix in seeing how far the wonder of the ville radieuse had faded from CIAM. The members of Team 10, Bakema, Candilis, Gutmann, Howell, van Eyck, Voelcker and the Smithsons were tied together by their ideals of reform the old visions of the original members of CIAM, and also th ...
Monday, November 4, 2019
Strategic Management Essay Example | Topics and Well Written Essays - 2750 words - 3
Strategic Management - Essay Example Specially mentioning, strategic management assists modern business organisations to take effective decisions and conduct activities for attaining success, resulting in attaining superior competitive position and sustaining in the long run (Wells, 2003). In this essay, the views of two different authors of strategic management will be elaborately discussed in order to gain a proper understanding of strategy. The essay intends to explore and compare the views of Mintzberg’s ten schools of thoughts along with Whittington’s four strategic lenses. A proper analysis will be conducted in order to gain insights about the different levels of strategy. According to the views of Michael Porter, strategy is a decision, which includes a conscious approach of performing activities in a different manner from that of the competitors in order to accomplish a viable long-term competitive advantage. Porter states that it is important for the organisations to focus not only on the operational perspectives but also on the strategic activities that tends to be effective in performing effectively in the business markets (Sage Publication, n.d.). Moreover, as per the views of Strickland and Thompson (2003), strategy is described as a managerial process, which is used to form strategic visions, objectives and approaches that are considered to be appropriate in order to accomplish long-term success. It is reflected that a strategy is said to be ineffective without the implementation of proper strategic management. It is often observed that there are various strategies that reflect as quite useful for developing overall business performance, but d oes not succeed in the long-run due to the lack of strategic management initiative. It is noticeable that the success of the organisations is dependable on various factors and thus there exists various levels of strategy for fulfilling the
Saturday, November 2, 2019
Trade and labour standards Thesis Example | Topics and Well Written Essays - 500 words
Trade and labour standards - Thesis Example Bringing about this issue within the framework of WTO would indicate the enhancement of working conditions around the world. The proposed working group would be responsible for studying the trade and core labour standards. Many developing as well as some developed countries however argue against this proposition because such core labour standards should technically not be a part of the WTO. Developing countries’ representatives argue that such policies might subjugate the comparative advantage of the lower wage in developing nations. In fact the improved working conditions according to the essential labour standards require high scale improvements in the infrastructure of the workplace which is often not conducive to a developing nation. In a developing nation with relatively lower economic growth such enforcements of standards would bring about poverty and some lapse of time in improving working standards. The compulsion to stick to the labour standards and the need towards l abour market flexibility work together to bring out protests and non-cooperative approach of the workers especially in nations where political structures favored some voice to the workers.
Thursday, October 31, 2019
Comparison of two poems Essay Example | Topics and Well Written Essays - 500 words
Comparison of two poems - Essay Example As a result the child misses the father even after he is dead. The child remembers her father at the time when she is thirty nine years old. This is a prime age in the life of a woman as at this time in her life she is about to enter menopause. It is at this time that the woman has lived a larger part of her life as she is increasingly becoming wiser. She becomes more understanding to her actions when she was younger as well as their consequences both to her and her loved ones. In this case she remembers how tired her father was when she was young due to his hard work. In the first poem Spike (2003, p. 15) the child that is betrayed is both defenseless and in much more need for love and care than in the second poem. However in the second poem, contrary to the lack of love in the first one there is a lot of love and understanding from the parent. This is evidence by the phrase ‘He taught me how’. This phrase explains that the child had a lot of time with the parent who took the initiative of teaching the child the virtue of honesty. The language in the first poem shows the evidence of human brutality and cruelty against the child. The actions taken by the parent killing the child who is unborn and does not even know that it exists is the evidence. On the other hand we look at the second poem which has a smooth tone evident by the care and love portrayed by the parent. From the phrase, ‘had a savings account.’ it portrays the dedication and care of the father to the future of the child. The final stance of the poem is evidence of the lack of virtue by the parents Spike (2003, p. 15) . According to the context of the society parents are supposed to be the ones to protect and give care to the children. Unfortunately the parents in the poem even celebrate on the death of the unborn baby; this shows the failure of the society in actual sense. In the second poem Walkers (2005, p. 25) there is evidence of the society being
Tuesday, October 29, 2019
Bonjour Tristesse by Francoise Sagan Essay Example | Topics and Well Written Essays - 3000 words
Bonjour Tristesse by Francoise Sagan - Essay Example He was young for his age, full of vitality and possibilities, and when I left school two years before, I soon noticed that he lived with a woman. It took me rather longer to realise that it was a different one every six months. But gradually his charm, my new easy life, and my own disposition led me to accept it.....It was easy to love him, for he was kind, generous, gay, and full of affection for me.' Sagan (p9) Cecile repeats his assertion that fidelity and commitment are 'arbitrary and sterile' Sagan (p13). That he is shallow and superficial, and will behave so, is expressed in her statement: 'Although I did not share my father's aversion to ugliness, which often led us to associate with stupid people, I felt vaguely uncomfortable with anyone devoid of physical charms.' Sagan (p11) In fact, she is more like him than she thinks, for having met Cyril, she is very taken with his looks, though touches on his character as an afterthought. Here too are the signs of an awakening sexuality. 'He looked typically Latin, was very dark and sunburnt. There was something reliable and protective about him which I liked at once.....He was tall and sometimes beautiful, with the sort of good looks that immediately inspired one with confidence.' Sagan (p11) Such values inherent in both Cecile and Raymond suggest that how they behave will be driven 3 by these. This, despite her slight criticism of Raymond as follows: 'His only fault was to imbue me with a cynical attitude towards love which, considering my age and experience, should have meant happiness and not only a transitory sensation.' Sagan (p21) The suggestion is that Cecile is already corrupted and that the later behaviours she displays are evidence of that corruption.... That Cecile is the narrator helps to give immediate insight into the themes and characters of the people, describing what they are and how their behaviours make things happen in line with any particular theme at the time. The opening lines are brilliantly expressive of a rather selfish young girl whose thoughts are ambivalent. The reader is made aware that for Cecile, the love from and for her father, together with the life they lead, is her greatest happiness. With the explanation of how they live, Raymond's immorality and character are exposed: In fact, she is more like him than she thinks, for having met Cyril, she is very taken with his looks, though touches on his character as an afterthought. Here too are the signs of an awakening sexuality. The suggestion is that Cecile is already corrupted and that the later behaviours she displays are evidence of that corruption. That he and she will selfishly seek sexual gratification, with little concern for fidelity is only a short time away. The catalyst is Anne's arrival, a woman who, unable to hide her feelings and character, puts in motion the jealousy and self-protection which overwhelm Cecile. motivated by love and perhaps self-importance, Raymond's by lust and love, they cause the manipulative, distressed and confused teenager to em
Sunday, October 27, 2019
A Trade Mark
A Trade Mark Introduction A trade mark is a way for one party to distinguish themselves from another. In business, a trade mark provides a product or organization with an identity which cannot be imitated by its competitors. According to section 1(1) of the 1994 Act, a trademark is ‘any sign capable of being represented graphically which is capable of distinguishing goods or services of one undertaking from those of another’. In Sigla SA v OHIM (Office of Harmonization for the Internal Market) the Court of First Instance (CFI) stated that a trade mark does also convey other messages concerning the qualities or particular characteristics of the goods or services which it covers, such as luxury, lifestyle, exclusivity, adventure, youth. A mark has then an inherent economic value which is independent of and separate from that of the goods and services for which it is registered. The CFI held that ‘these messages are conveyed, by trademarks with reputation and confer on it significant value which deserves protection because the reputation of a mark is the result of considerable effort and investment on the part of its proprietor’. However, how far the UK courts and the European Court of Justice (ECJ) have recognised this â€Å"inherent economic value†of registered trade marks? Relative Grounds for Refusal Marks which conflict with earlier marks or signs may not be registered. The grounds for refusal of the registration of a trade mark are found in section 5 of the Trade Marks Act 1994 and Article 8 of the Community Trade Mark Regulation (CTMR): Identical marks on identical goods and services: section 5(1)/Article 8(1) (a); Identical marks on similar goods and services that there exists a likelihood of confusion on the part of the public which includes the likelihood of association with the earlier mark: section 5(2) (a)/Article 8(1) (b); Similar marks on similar goods and services and there is a likelihood of confusion which includes the likelihood of association, between the marks: section 5(2) (b)/Article 8(1) (b); Identical or similar marks on goods or services which would take unfair advantage of, or be detrimental to, the distinctive character of the earlier mark, without due cause: section 5(3)/Article 8(5). UK incorporated Articles 4(4) (a) of the EC Trademark Directive and 8(5) of the Community Regulation 40/94 into domestic law under section 5(3) of its Trade Marks Act 1994. According to section 6, Earlier Marks cover UK and Community Trade Marks with an earlier registration date and Community Trade Marks with seniority derived from an earlier UK mark. They can also be marks registered under the Madrid Protocol and â€Å"well known†trademarks protected under Article 6bis of the Paris Convention. Article 4(4)(a) of the EC Trademark Directive allows any Member State to provide that ‘a trade mark shall not be registered where, the trade mark is identical with, or similar to, an earlier national trade mark and is to be registered for goods or services which are not similar to those for which the earlier trade mark is registered, where the earlier trade mark has a reputation in the Member State concerned and where the use of the later trade mark without due cause would take unfair advantage of, or be detrimental to, the distinctive character or the repute of the earlier trade mark’. There are four main grounds for infringement, which are set out in section 10 of the Trade Mark Act 1994. They are the same grounds for refusal of registration, as contained in section 5. Any act of infringement is not required to of held any previous knowledge or intention to carry out the act. To infringe, a mark must be used ‘in the course of trade’. Any use which is liable to put at risk the guarantee of origin may be prevented, because this guarantee constitutes the essential function of the mark. Identical and Similar Marks under Section 10(1) If the marks are identical or similar, and the goods and services are identical or similar, confusion must be shown. A mark is considered similar if in the mind of the average consumer the likelihood of confusion for the goods/services is at issue. The marks must be compared as wholes because the average consumer generally recognizes marks as a whole. Section 10(1) prohibits the use of an identical mark to the registered mark upon goods or services for which the mark is registered. In Reed executive v Reed Business Information Ltd it was held that the marks were similar, not identical. The claimant alleged that the defendants had infringed its trade mark. The defendant had used ‘Reed’ as part of the composites ‘Reed Elsevier’ and ‘Reed Business information’. Jacob LJ did not think that ‘Reed Business information’ was identical to ‘Reed’ and he noted that the additional words would not ignored by the average consumer. The ECJ in SA Societe LTJ Diffusion v SA Sadas stated that the criterion ‘must be interpreted strictly. The definition of identity implies that the two elements should be the same in all aspects’. The level of identity between the marks must be high. In Origins Natural Resources Inc v Origin Clothing Ltd the marks ‘Origin’ and ‘Origins’, were held to be similar but not identical. Likelihood of Confusion Likelihood of confusion is arising from similarity with an earlier mark and goods and services for which that earlier mark is registered. If exists a likelihood of confusion on the part of the public, the trade mark will not be registered under section 5(2). Jacob J recommended in British Sugar plc v James Robertson Sons Ltd, that to apply section 5(2) is to ask first whether the marks are the same or similar and then whether the goods are the same or similar. Finally, ask whether the proviso applies and whether there is a likelihood of confusion, including a likelihood of association between the marks. If the answer to all three questions is positive, then there will be a conflict. In Sabel v Puma the ECJ held, that the likelihood of confusion must be appreciated globally, taking into account factors including the recognition of the trade mark on the market, the association which can be made between the registered mark, the sign and the degree of similarity between the mark, the goods and the services. The Court considered that there is a greater likelihood of confusion where the earlier trade mark has a highly distinctive character. It was noted in Ruiz-Picasso v OHIM, that attention would be particularly high as regards goods which are expensive, and highly technological in character. The ECJ said in Canon Kabushiki Kaisha v Metro-Goldwyn-Mayer Inc that, if the association between the marks causes the public to believe that the respective goods come from the same or economically linked undertakings, there is a likelihood of confusion. In Marca Mode CV v Adidas AG it was held that ‘the reputation of a mark does not give grounds for presuming a likelihood of confusion simply because of a likelihood of association in the strict sense’. Protection for Marks with Reputation Article 8(5) of the Trade Mark Directive and Article 4(4) the Community Trade Mark Regulation offer protection for marks ‘with a reputation’, recognising that trade marks do more than simply signify origin. In Bristol Myers Squibb v. Paranova the â€Å"essential function†of the trade mark was held to be to guarantee origin to the consumer without any risk of confusion. Some marks because of their reputation have obtained a value not confined to the basic distinguishing function of a mark, so that they should be entitled to protection. The CFI give guidance in Sigla on the distinction between the notion of the likelihood of confusion and the risk of unfair advantage. The Court noted that a likelihood of confusion occurs where a consumer is attracted to a product or service covered by the applied for mark because of a misunderstanding that it comes from the same origin as that covered by an earlier mark which is identical or similar. However, the risk of unfair advantage might happen where the consumer is attracted to the mark itself, without confusing the origin of the good or service. The Court in Sigla held that: ‘Article 8(5), ensures that a mark with a reputation is protected with regard to any application for an identical or similar mark which might affect its image, even if the goods or services covered by the mark applied for are not similar to those for which the earlier mark with a reputation has been registered’. Being able to prove that the trade mark ‘has a reputation’ is a key to a trade mark owner’s ability to benefit. Dilution Section 5(3) of the Trade Marks Act 1994 offers the means for an earlier trade mark holder to prevent registration of a later trade mark which dilutes the distinctiveness and exclusivity of his trade mark. The dilution claim it appears as section 10(3) of the Act: A person infringes a registered trade mark if he uses in the course of trade a sign which is identical with or similar to the trade mark, and is used in relation to goods or services which are not similar to those for which the trade mark is registered. The trade mark must have a reputation in the UK, namely the use of the sign must be without due cause and must either take ‘unfair advantage of’ or be ‘detrimental to’ the distinctive character or repute of the trade mark. In Adidas-Salomon AG and Adidas Benelux BV v Fitnessworld Jacobs found that the concept of detriment encapsulates dilution, which is often referred to as ‘blurring’ and means that the mark is no longer capable of arousing an immediate association with the goods for which it is registered or used. This concept of detriment is sometimes referred to as ‘tarnishment,’ and means that the goods for which the infringing sign is used, appeals to the public’s senses which accordingly affects the mark’s power of attraction. Reputation The justification for the laws protecting trade marks focuses on the recognition and their quality. Kur stated that reputation could be claimed by ‘a trademark with a relatively low degree of renown, yet which possesses an attractive, strongly associative image’. The question of the reputation needed by a trade mark to qualify for protection was decided by the ECJ in General Motors Corporation v Yplon . It was stated in this case that the stronger the earlier mark’s distinctive character and reputation, the easier it will be to find that detriment has been caused to it. The ECJ held that the words has a reputation in Section 5(3) of the Trade Marks Act, Article (4)(4)(a) of the 89/104 directive and Article 8(5) of regulation 40/94 require the mark known only by a significant part of the public concerned by the products or services covered by it. To oppose a trade mark under Article 8(5) a challenger must prove in the case of an earlier Community trade mark the trade mark has a reputation in the Community and, in the case of an earlier national trade mark, the trade mark has a reputation in the Member State concerned. The Court held that a national Court when is deciding whether a mark had a reputation has to take into account facts like ‘the market share held by the trade mark, the intensity, geographical extent, and duration of its use, and the size of the investment made by the undertaking in promoting it’. In Hag II the Advocate General stated that trade marks found their justification ‘in a harmonious dove-tailing between public and private interests’, the right purpose of the law being to protect the ‘clarity of the signal transmitted by the mark’. The CFI in Spa Monopole v OHIM-Spa finders , held in that the reputation for certain goods or services can not be extended to other goods and services. The Court held that the reputation for mineral waters could not constitute the evidence of reputation for goods in class 3 (namely soaps, perfumery and cosmetics) and that ‘the proprietor of the earlier mark is not required to demonstrate actual and present harm to his mark. He must adduce prima facie evidence of a future risk, which is not hypothetical, of unfair advantage or detriment’. Marks with Reputation on Similar or Dissimilar Goods Section 5(3) of the 1994 Act has been amended to mirror section 10(3) which is relevant to goods and services that are dissimilar to those of the relevant registration. There is no need for there to be any ‘likelihood of confusion’ for an infringement under section 10(3). It was considered in Davidoff Cie SA and Zino Davidoff SA v Gofkid Ltd that a well known mark should receive the same protection where the goods are similar as it receives where the goods are dissimilar. The Court held that member states were entitled to provide specific protection for registered trade marks with a reputation in cases where a later mark or sign, which is identical with or similar to the registered mark, is intended to be used or is used for goods or services identical with or similar to those covered by the registered mark. In Adidas v Fitnessworld the ECJ held that ‘it is sufficient for the degree of similarity between the mark with a reputation and the sign to have the effect that the relevant section of the public establishes a link between the sign and the mark’. It was considered that where a member state exercises the option under Article 4(4) (a) of the directive it is bound to grant the protection in question in cases of use by a third party of a later mark or sign which is identical with or similar to the registered mark with a reputation, in relation to goods or services which are not similar and to goods or services which are identical with or similar to those covered by that mark. In this case the Court stated that ‘Article 5(2) of the directive establishes, for the benefit of trade marks with reputation, a form of protection whose implementation does not require the existence of likelihood of confusion’. The ECJ considered that Article 5(2) of the Directive must be interpreted in the sense that, where the sign is used for identical goods or services, a mark with a reputation must benefit from protection which as extensive as where a sign is used for non-similar goods or services. Unfair Advantage or Detriment A trade mark will not be registered where the use of the later mark must either take unfair advantage of, or be detrimental to, the distinctive character or the repute of the earlier trade mark. The Court held in Spa-Finders that ‘Unfair advantage encompasses cases of clear exploitation and free-riding on the coat-tails of a famous mark or an attempt to trade upon its reputation, unfairly drawing on and profiting from an earlier mark owner’s goodwill and investment in promotion’. Detriment could take the form of tarnishing or blurring. The association between two marks and between the goods or services to which they relate could be detrimental to the strength and reputation of the earlier mark if it tarnished it by association or made it less distinctive. Evidence of reputation can go a long way toward proving unfair advantage or detriment. Unfair Advantage of the Earlier Mark Advocate General Jacobs in the Adidas case considered that the concept of ‘unfair advantage of distinctive character or repute’, as found in Article 5(2) of the EC Trademark Directive was ‘intended to encompass instances where there is clear exploitation and free-riding on the coattails of a famous mark or an attempt to train upon its reputation’. The CFI in Sigla, stated that the unfair advantage of the repute takes place where there is a risk that the image of the mark with a reputation or the characteristics which it projects are transferred to the goods covered by the second mark, with the result that the marketing of those goods is made easier by that association with the earlier mark with a reputation. Sir Thomas Bingham, in Taittinger SA v Allbev, stated that it would be unfair to allow others to ‘cash in on the reputation that they had done nothing to establish’. In L’Oreal SA v Bellure NV , the defendants were a cosmetic company who were trying to pass off their brand as that of L’Oreal’s. The L’Oreal trade mark is very popular. Jacob LJ looked at the importance of unfair advantage and stated that the relation between the defendants’ packaging and the registered marks, if established, would give an advantage on the defendants. He gave as an example of unfair advantage, where a well known mark in one field is used by another in a same field and therefore excludes the chance for the owner of the registered mark to move into that field in the future. In Akteselkabet af 21 November 2001 v OHIM, the earlier mark benefited from a reputation for ‘apparatus for recording transmission or reproduction of sound or images’ and evidence has been given of its use in sporting events, while the other trade mark was applied for clothing. It was considered by the CFI that as the public was familiarized to seeing the TDK mark on clothing related to sporting events, the use of the second sign on clothing could make the public to believe that such clothing was manufactured by, or under licence from, the owner of the TDK mark. Detrimental to the Distinctive character of the earlier mark It was held in Spa-Finders that there is detriment where the earlier mark is no longer able of beginning direct association with the goods for which it is registered and used. The CFI held that the existence of a link between the marks Spa and Spa-Finders in the mind of the relevant public is not enough to show the risk of detriment to the distinctive character. The Court in Intel Corporation Inc v CPM United Kingdom Ltd said that article 4(4)(a) of the Directive was to be interpreted as meaning that whether there was a link between the earlier mark with a reputation and the later mark was to be assessed globally, taking into account all the relevant factors which included the fact that, for the average consumer, who was reasonably well informed, observant and circumspect, the later mark called the earlier mark with a reputation to mind was tantamount to the existence of such a link between the conflicting marks. It was held in Intel that ‘the fact that the earlier mark had a reputation for certain types of goods or services, and those goods or services and the goods or services for which the later mark was registered were dissimilar or dissimilar to a substantial degree, and the earlier mark was unique in respect of any goods or services, did not necessarily imply that there was a link between the marks’. Jacob LJ thought that there should be more than a ‘mere calling to mind’ of the earlier mark by the average consumer when confronted with the later mark on dissimilar goods. Any detriment should be to the distinctiveness of the earlier mark in relation to the goods and services it covers, no to its attractiveness more generally. The more unique the earlier mark appeared, the greater the likelihood that the use of a later identical or similar mark would be detrimental to its distinctive character. Detriment to the Repute In Claeryn v Klarein the Court considered that the concept of detriment to the repute of a trade mark, often referred to as degradation or tarnishment of the mark, describes the situation where the goods for which the infringing sign is used, appeal to the publics senses in such a way that the trade marks power of attraction is affected. The case of Sigla SA v OHIM, explained that the detriment to the repute occurs where the goods or services, for which the reputed trademark is unjustifiably used, have a quality or a value which may have a negative influence on the image of the earlier mark with reputation. The CFI held in Spa-Finders that there is no ‘antagonism’ between the goods and services covered by the marks which might be detrimental to the repute of Spa mineral waters. The Court notes that it is unlikely that the mark Spa-Finders will tarnish the image of the Spa mark. These marks designate different goods consisting, in mineral waters and, on the other hand, in publications and travel agency services. The Court find that it is unlikely that the goods and services covered by the mark Spa-Finders, even if they turn out to be of lower quality, would diminish the power of attraction of the mark Spa. The closer the goods are the easier to prove a detriment to the repute will be. Without Due Cause When an opponent has established that its earlier trade mark has a reputation, and that use of the applicant’s mark will take unfair advantage of, or to be detrimental to, the earlier mark, the obligation then falls upon the applicant to show that the use would not be without due cause. Jacob LJ noted in L’Oreal v Bellure that the onus of establishing due cause lies with the defendant. In the Nasdaq Stock Market Inc case the CFI held that Nasdaq was distinctive and conveyed an image of modernity which was attractive and relevant to the stock market and to other goods such as the applicant’s. It was considered that the applicant had not established that its use of the trade mark would be founded on due cause within the meaning of Article 8(5), and the Court held that there was no due cause for the applicants use of the sign. The Court in Premier Brands UK v Typhoon Europe, applied the criterion from found that Typhoo was an established brand of tea with a reputation and that the defendant used its mark without due cause. It was held that there would be no likelihood of confusion but proceedings commenced in relation to section 10(3), on the idea that the goods in subject were dissimilar. Neuberger J held that the phrase ‘without due cause’ required an applicant to show some reasonable grounds for using its sign in relation to its goods even this was unfair or detrimental to the earlier mark. Good faith would not justify the registration of a mark. In Hollywood SAS v Souza Cruz SA it was held that ‘the condition of due cause is not fulfilled merely by the fact that the sign is suitable for identifying the products for it is used, the applicant has already used this sign for these or similar products within and outside the territory of the community or the applicant invokes a right ensuring from a filing over which the filing by the proprietor of the opposing trade mark takes precedence’. These factors are guidelines which may the Court use in balancing the competing interests present in dilution cases. Conclusion A trademark is a powerful right. For many businesses, a Trade Mark is a valuable asset which plays a key role in the commercial success of the business. Reputation can improve the distinctiveness of the mark and increase its scope of protection. Trade marks act as a motivation to sustain quality since they act as a guarantee to the consumer. The ECJ has treated the requirement that the trade mark must have a reputation as a threshold that can be included into a global appreciation. As the ECJ has interpreted it, the additional zone identifies that the economic value of a trade mark can reflect ability for doing something more than presenting its important meaning and that this ability can require certain legal protection.
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