Advantages & Disadvantages of E-Learning

E-learning is an expansive term that for the most part alludes to any sort of learning finished with a PC and Internet association or CD-ROM. It is utilized by people, instructive foundations and organizations. Similarly as with a learning, it works preferred for some over others. The nature of e-learning has improved as of late, as instructors and understudies have gotten increasingly alright with the innovation. 1. Contemplations * E-learning is a brilliant alternative in training, especially when there are impediments to customary learning situations.For model, a few people wish to proceed with their instructions however don't live inside driving separation of a school or college and don't think that its plausible to migrate. E-learning is a reasonable option for these understudies. Another deterrent to conventional learning, particularly in grades K through 12, is the â€Å"one size fits all† mindset it grasps. Numerous understudies simply don't learn well in a conventiona l learning condition, yet flourish in an increasingly adaptable setting. To address this issue, guardians are going to e-learning open doors for their children.Some pick full-time enlistment in a virtual school, while others use e-figuring out how to enhance a self-teach educational plan. In the business world, e-learning gives an approach to organizations to prepare and educate workers without expecting them to head out to a focal area. Points of interest * Convenience is one of the significant focal points of e-learning. It permits understudies to work and learn at their own pace without the resolute time limitations of customary learning. Since e-learning gives access to learning materials whenever, understudies have the adaptability to plan around families, employments and other activities.Another significant advantage of e-learning is the availability it gives. Understudies can gain from anyplace on the planet. This is a particularly significant thought for understudies who wis h to concentrate in an alternate nation. Also, in light of the fact that e-taking in should be possible from home, understudies have less apparel and driving costs than with conventional learning. Inconveniences * A significant detriment to e-learning is the self-control it requires. While having the option to work at your own pace can be a preferred position, it can likewise be a disadvantage.This is particularly valid for understudies who experience issues with time the executives and lingering. These understudies will in general be progressively fruitful with the structure of conventional learning. Another detriment to e-learning is the innovation in question. A few people don't have prepared access to a PC and Internet association. Also, some who do have the necessary hardware feel sick prepared to utilize it. Absence of cooperation among educator and understudy is another downside to e-learning. A few understudies need the prompt criticism that communication gives. Types * Ther e are a few kinds of e-learning situations.The most normal incorporate taking a solitary course on the web, full-time enlistment in an online secondary school or school, separation taking in through satellite and gaining from data on a CD-ROM. Numerous organizations and associations offer preparing for their workers utilizing different e-learning techniques. Cautioning * E-adapting enormously expands the accessibility of instructive chances. Sadly, it additionally builds the quantity of tricks identified with online instruction. People considering e-learning prospects ought to be aware of such tricks and altogether explore any program before making a responsibility.

Social Media Advertising Free Essays

Web Advertising: Social Networking First Name Last Name BUS 123 Introduction To Advertising Dr. First name and last name September 26, 2010 Internet Advertising Now like never before, private ventures can advance themselves online by focusing on clients and extending their systems, regularly for practically no expense. Organizations can advance themselves through an assortment of strategies, for example, focusing on clients by socioeconomics, adding to online conversations and causing to notice new administrations. We will compose a custom paper test on Web-based social networking Advertising or on the other hand any comparative subject just for you Request Now Publicizing in the 21st century has become flexible as a result of different online social sites like Facebook and Twitter, alongside other blog environment sites like Pinterest and Craigslist. In the most recent decade, the blast of mechanical advances has delivered exceptional occasions throughout the entire existence of humankind. One of them is the Internet and its change into another vehicle for promoting and the utilization of social correspondence in publicizing. Unavoidably, the web has completely changed us. Inâ traditional media, papers, radioâ and televisionâ can cause data overloadâ and change the perceptionâ of the crowd (Janoschka, 2004). The Internet is notâ exempt from thisâ danger, butâ has the potential toâ do something different,â becauseâ it can legitimately reachâ the target audienceâ and connect with it. An element of memory is to overlook, particularly data that isn't critical. The test of publicizing is to cause you to recollect the advertisements. The design is to sell. The great exposure persuades the watcher to purchase the item. This requires making an alluring brand picture and fortifying it with every advertisement. Publicizing utilizes both verbal and nonverbal components that are created to occupy explicit existence positions controlled by the support. Promoting contacts individuals through a channel of correspondence alluded to as a medium. Today, innovation empowers promoting to reach its’ target crowd proficiently through the Internet. In the 1990’s, the Internet turned into a significant piece of American culture and is the quickest developing kind of publicizing. Its something other than standard promotions, it implies enormous arrangement intelligent advertisements, internet searcher showcasing, making uncommon promotion recordings for web download and supporting TV advertisements with online destinations. Correspondence among individuals everywhere throughout the world is easy, and data on practically any theme is only a couple of keystrokes away. As an open worldwide stage open to a wide range of data, amusement, and correspondence, one of which is web based publicizing, it has become the most recent mass medium. † (Janoschka, 2004). Web innovation permits conveying the correct message to the ideal indiv idual at the opportune time while helping promoters to contact their crowd. Fromâ the second theâ surferâ entersâ the web to look for data, pop ups show up permitting the crowd to buy in toâ mailing records thatâ will sendâ continuousâ news, advancements, articles, and so on , relying upon  their inclinations. This permits theâ sellerâ to betterâ reach its targetâ and maintainâ continuousâ communicationâ in the shortestâ time conceivable. .Most online promotions don't come to you as an individual, however by your inclinations in different subjects, your area or, when all is said in done, by your conduct during web route. In many nations, it is conceivable to isolate the crowd by geographic territory dependent on IP address, which encourages publicizing organizations that offer items and administrations in those zones. Sites utilize segment information to learn more their crowd. While enlisting with a gateway or site, you regularly give certain individual data, for example, your age, sexual orientation, leisure activities, and so forth. With this data, sites offer significant substance and promotions dependent on the data gave. A few organizations spend significant time in an information assortment process known as conduct promoting which matches advertisements to the interests of clients dependent on their riding propensities. As clients peruse, publicists gather information on their online movement: locales visited, time spent on every promotion appeared, advertisements that were clicked, when and how frequently you click on the flags. Today, treats are apparatuses that permit publicists to target publicizing to explicit crowds and portions. Comparedâ with conventional mediaâ the cost ofâ internet publicizing isâ extremely low, andâ because of its effectivenessâ and its high potential for development, it isâ idealâ for smallâ and medium organizations thatâ do not have largeâ resources to investâ in other media. At that point the questionsâ arise: howâ to advertiseâ online? What is theâ correct wayâ to? There is noâ magic formulaâ that a media organizer would you be able to utilize however here are a few proposals. Because of the web being worldwide, the system gives the likelihood to contact all crowds on the planet. With web promoting one mustâ include,â email,â search engineâ registration, and standards which areâ ads withâ motion designs whichâ are situated in differentâ sitesâ of the networkâ as a gatewayâ inputâ to a site. Utilizing email as a type of notice is simple and free. All that is required is to pursue email with your internetâ service providerâ or aâ freeâ mailâ serverâ such as Yahooâ mail or Gmail and send messages toâ the potentialâ customers withâ offersâ or informationâ on items. As indicated by Arens, â€Å"Google is the most well known goal on the web arriving at a shocking 40 percent of all Web clients each day† (pg 337). Web indexes are just liable for enrolling entryway sites and their substance and afterward conveyance the outcomes to the clients who made solicitations for data. Coming up next is a case of how a web crawler functions. A client utilizes the inquiry engineâ of their decision andâ asks to findâ companiesâ that exportâ tomatoes. The web crawler willâ sendâ in responseâ with a rundown of sites of companiesâ that fulfillâ the demand andâ then the client canâ enterâ the diverse sitesâ to seeâ what they need and select the organization thatâ meetsâ their prerequisites. Theâ banner systemâ isâ one meansâ of web advertisingâ that is increasingly powerful: You can chooseâ the categoriesâ to be shown andâ include enlightening wordsâ to detectâ if the client isâ looking for that specific item. Theâ bannersâ are like theâ rotatingâ bannerâ butâ the distinction is thatâ the client can interactâ with them. As in anyâ project,â internet advertisingâ should beginâ byâ makingâ a vital arrangement. The outcome will beâ better arranging ofâ a site andâ the capacity to maintainâ the user’s attentionâ and client reliability. The nearness of web promoting will be a superb supplement to customary media publicizing and may wind up getting one of the needs of sponsors. For the time being, an ever increasing number of promotions in the media show the heading taken by publicists alongside client care and different administrations of intrigue. Client gatherings, blogsâ andâ social networkingâ sites like Facebook and Twitterâ are priceless resourcesâ for monitoringâ companies’ reputationsâ and interests ofâ consumers of administrations andâ products. Facebook is the biggest informal community on the planet with in excess of 500 million individuals associated with one another. Facebook has not outperformed Yahoo! o be the second most famous webpage on the web behind Google. Facebook’s prevalence has expanded because of the capacity to associate people without land hindrances. The uniqueness of Facebook permits individuals to meet for all intents and purposes to talk about and share their in clinations with one another (Arens, Schaefer, Weigold, 2011). There are 60 million notices posted each day in more than 65 dialects. Facebook’s crowd is far better than some other mass medium like TV channels, radio or press Facebook has changed publicizing by the size of its crowd, yet in addition by the designing behind its activity. It permits a logical and shrewd promoting to arrive at the exact objective crowd through market division as per sex, age, geographic area, nation, city and territory, instructive level, likes, premiums, item inclinations, most loved exercises, most loved projects and language. For instance, it is currently conceivable to know without broad statistical surveying which nations have the biggest number of youth somewhere in the range of 18 and 35 years and who love exciting music, football and a specific brand of brew. Having a nearness in web based life is an absolute necessity have for most brands. Facebook made Pages for organizations to post data about their administrations or items. When utilizing a web search tool, your Facebook Page will be one of the primary consequences of your inquiry. Buyers have huge force and impact on a brand and trust suggestions of different shoppers they don’t know. As indicated by Barefoot, â€Å"Groups and applications gain ubiquity one companion of a companion of a companion at a time† (Barefoot, pg 174). The outcome is companions turning out to be fans or joining bunches urging them to buy an item or administration that is being talked about or promoted. Twitter is as yet a mainstream internet based life organizing webpage, in spite of the fact that selection is declining. Contrasted with Facebook, Twitter has 50 million tweets made every day and the normal Twitter account has a normal of 300 supporters. Long range interpersonal communication is critical to advertisers since it offers them the chance to show clients that they are tuning in to what they need to state about a brand or item and react in like manner. The conceivable outcomes are huge. It is basic forâ organizations to give direct consumerâ messagesâ dailyâ on Twitter, maintainâ a Facebook page, or depending?

Unconscionability as the Basis of Rendering a Contract - Free Essay Example

ASSIGNMENT à ¢Ã¢â€š ¬Ã…“Discuss whether the doctrine of unconscionability is appropriate to form the underlying basis for a claim of voidable contract on the ground of undue influenceà ¢Ã¢â€š ¬Ã‚  TABLE OF CONTENT Introduction Common Law Countriesà ¢Ã¢â€š ¬Ã¢â€ž ¢ Position England Australia Canada Malaysiaà ¢Ã¢â€š ¬Ã¢â€ž ¢s position Conclusion Bibliography Introduction According to the Contract Act[1], in section 16(3) when a person entered into a contract with a person who has the position to dominate the will of another, and the transaction appears to be unconscionable, the burden to prove that the contract is not by undue influence lie on the person who has the will to dominate another. Here, it seems that the act was saying the unconscionability is an element of undue influence. However, do the doctrine of unconsionability can be regarded as an underlying basis of the Undue Influence? Doctrine of unconscionability is application of consent based obligations, where someoneà ¢Ã¢â€š ¬Ã¢â€ž ¢s consent to bargain was only procured through external pressure that another person exploited. Basically, unconscionable contract is held unenforceable because no reasonable person would agree otherwise to it. The perpetrator is not allow to benefit, as the consideration is lacking, and to enforce the contract will be unfair. For the defe nce of unconscionability to apply, contract has to have been unconscionable, that later, the circumstances make the contract irrelevant Unconscionability is understood by jurists as a doctrine used by the court of equity to correct menà ¢Ã¢â€š ¬Ã¢â€ž ¢s conscience against unconscionable. Until now, inspiring writings and discussions have been made concerning the supposed or probable definition, description, criteria and application of the doctrine Undue influence is the use of power or influence by one person over another in such a way that the stronger party acquires a benefit, either for himself or for some other person.[2] The equitable construct of fiduciary relationships is associated with the doctrine of undue influence, which is distinguished from duress, the threat or use of excessive force. Cases of undue influence are founded upon the principle that one party is in a stronger bargaining position,[3] or has superior knowledge, or superior mental capacity than the other, weaker party who, as a result, relies on the stronger party. Common Law Countriesà ¢Ã¢â€š ¬Ã¢â€ž ¢ Position For the purpose of this assignment, I will firstly discuss the position of the Common Law countries, which are England, Canada and Australia on the use of doctrine of unconscionability as the basis of undue influence. England In cases of undue influence, a relationship exists where one party owes the other an obligation of candor and protection, where the former acquires over the latter a measure of influence, of which the ascendant person then takes unfair advantage. Allcard v. Skinner,[4] took place in the religious climate of nineteenth century England.Back then courts themselves had only recently been reformed then, the case highlighted the growth of undue influence in the nineteenth century as a factor which could spoil a contract. In the case, Miss Allcard gave virtually all her money to a religious sisterhood who devoted themselves to works of charity. Mis s Allcard became a sister and left the sisterhood and waited six years before she initiated action for the return of her money. After the trial judge held for the defendant, the case was appealed by raising two questions: (1) whether the gifts were revocable; and (2) if so, whether revocation was competent years after leaving the religious order. Although the majority of the Court of Appeal dismissed the appeal, the enunciation of the equitable rule of undue influence became a vital doctrine. In another case, Earl of Chesterfield v. Janssen[5] involved an unfair agreement for the sale of an inheritance expectancy by an improvident young heir. à ¢Ã¢â€š ¬Ã…“no man in his senses and not under delusion would make on the one hand, and as no honest and fair man would accept on the other.à ¢Ã¢â€š ¬Ã‚  That view has been echoed in England.à ¢Ã¢â€š ¬Ã‚ Thus here, it can be conclude that England does agrees that the doctrine of unconscionability is the requirements of Undue Influenc e. Australia The Australian position commencing with the established High Court decision of Commercial Bank of Australia Ltd v Amadio[6]. Amadio involved two plaintiffs who were elderly migrants with limited knowledge of English and lack of understanding of guarantee documents proffered by the bank, a circumstance that court described as a à ¢Ã¢â€š ¬Ã…“special disability.à ¢Ã¢â€š ¬Ã‚  Amadio has been accepted as stating the law on unconscionability in Australia, as the court in Gregg v Tasmanian Trustees Ltd had held, à ¢Ã¢â€š ¬Ã…“at least, the emergence from the shadows of this ground of equitable relief has relegated the doctrine of undue influence to a position of relative unimportance.à ¢Ã¢â€š ¬Ã‚  The reasons given by the House of Lords for rejecting the case based on undue influence in National Westminster Bank Plc. v. Morgan that unconscionability as an independent ground of relief does not appear large on the English scene[7]. Unconscionability and undue infl uence overlap, the latter being more limited in scope, concerned as it is with the exercise by the contracting party of an independent and voluntary will.[8]While undue influence has been demoted to a position of relative unimportance in Australia, has an unmistakably defined doctrine of unconscionability. Thus, it may be concluded that in Australia, doctrine of Unconscionability is not the basis of Undue Influence as it stands alone. Canada In Canada, an evolved doctrine of unconscionability ought to identify material distinctions and similarities with the doctrine of undue influence. Otherwise, a blurred distinction might have a deterring effect. For example, one difference is the obligation of a party to refute undue influence where that incident exists by inference or presumption, as opposed to the evidentiary burden on a party pleading unconscionability to show there has been an improper use of power on the facts. The influential case on unconscionability was Fry v. La ne[9] and, although it was decided in 1888, over a year after Allcard v. Skinner,[10] Fry did not mention Skinner in the law report. Fry v. Lane considered future interests, setting set aside a deed taken from a poor and ignorant man at a considerable under value, the vendor having no independent advice. In the case of the equitable doctrines of undue influence and unconscionability, both are said to be à ¢Ã¢â€š ¬Ã…“separate and distinct doctrines with closely related principles,à ¢Ã¢â€š ¬Ã‚ [11] both are separate causes of action, leading to the equitable remedy of rescission. Cases of unconscionability, however, often contain elements of undue influence[12] and the doctrinal distinction is blurred. In Canada, undue influence remains universal compared to unconscionability, but the distinction is unclear. For example, it was stated in MacKay v. Bank of Nova Scotia, that à ¢Ã¢â€š ¬Ã…“unequal bargaining power, together with an unfair contract, create a presumption of un due influence.à ¢Ã¢â€š ¬Ã‚ [13]This statement is at odds with the earlier statement in Norberg v. Wynrib that the à ¢Ã¢â€š ¬Ã…“doctrine of unconscionability and the related principle of inequality of bargaining power are evolving.à ¢Ã¢â€š ¬Ã‚ [14] In conclusion, the boundaries between undue influence and unconscionability have been shifting or evolving, arguably affecting the standard of judicial decision making. While successful cases of unconscionability appear less frequently, the doctrine appears broader in scope than does undue influence. However, for now, the distinction remains unclear, resulting to a very wide interpretation of the doctrines. Malaysianà ¢Ã¢â€š ¬Ã¢â€ž ¢s Position In Malaysia, the doctrine of unconscionability is considered as still at its infancy but the awareness of the existence of this doctrine seems to be gaining ground. Section 16(3) of the Contract Act placed unconscionable as a mere part of proving undue influence. The Privy Council de cision in an Indian case of Poosathurai v Kannappa Chettiar,[15] observed that an agreement is considered `unconscionable when the lender is in a position to dominate the will of the borrower, and the bargain was `unconscionable within the meaning of s 16(3).. The decision in Poosathurai was further reaffirmed by Visu Sinnadurai J in Polygram Records Sdn Bhd v The Search Anor[16]. Malaysian courts are grappling with arguments based on inequality of bargaining power amidst the statutory provision on undue influence in the Contracts Act 1950. In Saad Marw[17]is case, the Court of Appeal had adopted a different approach. Gopal Sri Ram JCA started his judgment as follows: This is an important case. It has to do with whether our jurisprudence recognises a doctrine of inequality of bargaining power independent of the well-established doctrine of undue influence. This is the first time, at least as far as I am aware, that this issue has come up for decision at the appellate level. T he appellant, a farmer, had rented some land from the respondents (the leased land) from which he harvested coconuts. The appellant also held two pieces of land (the property) by prescriptive rights under the land law in force in Penang at the material time. This meant that the appellants title was defeasible and this defeasibility was confirmed by an indorsement on the title Then, he entered into agreement with responded, but the agreement is in English, and had deceived him. The appellant purported to terminate the agreement with the respondents. The appellant defended the action on a ground that the agreement was vitiated by undue influence.The trial judge rejected and the appellant appealed against the order of the trial judge. On appeal, the appellant argued that while the trial judge was entitled to reject the defence of undue influence, he ought to have held that the appellant had established a case of unfair advantage under section 21(2)(a) of the Specific Relief Act 1950 [18].According to the Court, this brought to focus the doctrine of inequality of bargaining power falling short of the proof of undue influence under section 16 of the Contracts Act. With this, the Court went on to consider whether Malaysian law recognises a general doctrine of inequality of bargaining . The Courts reference to both the doctrine of inequality of bargaining power and the doctrine of unconscionability in Saad Marwis case, read literally, would mean that the Malaysian position is wider than the English position where Lord Dennings attempt to invoke the principle of inequality of bargaining power to set aside transactions in Lloyds Bank Ltd v Bundy[19] was clearly rejected by the House of Lords in Westminster Bank Plc. However, in Canada, Lord Dennings principle of inequality of bargaining power has remained an important element in the development of unconscionability even after its rejection in the United Kingdom This has resulted in the Canadian doctrine being a fl uid and flexible one, and as described by Gopal Sri Ram JCA in Saad Marwis case, one which achieves practical justice.Some legal commentators suggest that à ¢Ã¢â€š ¬Ã…“the doctrine of undue influence is about impaired consent, not about wicked exploitation.à ¢Ã¢â€š ¬Ã‚ [20] A blurred distinction between undue influence and unconscionability exists, however, to the extent that recent cases on unconscionability restate the doctrine with a à ¢Ã¢â€š ¬Ã…“kind of legal shorthand expression.à ¢Ã¢â€š ¬Ã‚ [21] Whether it is possible for unconscionable bargain or transaction to exist separately from the doctrine of undue influence? Apparently, there are several Malaysian cases that provide this answer in positive. The early case of Chait Singh v Budin b Abdullah[22], showed how court was willing to justify the existence of unconscionable bargain on the basis of the position of the parties, without the need to prove the requirement under section 16(1). This case apparently suggest s the independency of the doctrine of unconscionable bargain from the doctrine of undue influence in s 16. Gopal Sri Ram JCA suggests in Saad Marwi v Chan Hwan Hwa Anor that it is possible for Malaysia to import the wider doctrine of unconscionability independent of the doctrine of undue influence into the Malaysian contract law. The proposed wider doctrine is according to the English doctrine but tailored to the broad and liberal Canadian way because of the vulnerability of many Malaysians in matters of commerce and of the insufficiency of statutory protection afforded to Malaysian consumers. It is worth to point that Saad Marwi is held in Koh Yen Bee to be correctly decided based on the merits of the case. There is the possibility that Saad Marwi and Koh Yen Bee have looked at the doctrine of unconscionability from a narrow perspective. However, towver, Hbnusshe Court of Appeals decision in Saad Marwi v Chan Hwan Hua Anor [2001] 3 CLJ 98 has brought Malaysia nearer to this front in its recognition of a wider doctrine of inequality of bargaining power and the adoption of the English doctrine [of unconscionability] but apply it in a broad and liberal way as in Canada. Conclusion Unconscionability as an independent doctrine or as a doctrine of wider application is still at its infancy despite the historical evidence that it had been used to correct mens conscience in cases involving equitable frauds. There were several setbacks in its growth, which was hindered particularly by the common laws adherence to the doctrine of freedom of contract and the will theory. Even though the purpose of the doctrine is different from freedom of contract, it contributes towards ensuring security of the contract. 1The fact that the word unconscionable itself is in the Contract Act showed that the legislative wanted it to be a part of the doctrine of Undue Influence, either as a basis or as an element. However, based on the decision by the cases, Doctrine of unco scionability can also be a separate element from undue influence, being an independent equity itself. It is up to the court to interpret the law in section 16(3), and to really draw a line between unconscionability and undue influence. However, for now, the doctrine of unconscionability is appropriate to form the base for a claim of voidable contract (according to section 20 of the Contract Act) on the ground of undue influence but, it is still open for wider interpretation and alteration. BIBLIOGRAPHY TEXT BOOKS Cheong May Fong, Contract Law in Malaysia (Malaysia, Singapore, Hong Kong: Sweet Maxwell, 2010) Sinnadurai, Visu, Law of Contract, 4th ed (Butterworths: Lexis Nexis, 2011) Guest, AG (ed), Chitty on Contracts, Volume 1, General Principles, 31st ed (London: Sweet Maxwell, 2004) JOURNALS Sykes, N. A. Deakin University.à ¢Ã¢â€š ¬Ã‹Å"Unfairà ¢Ã¢â€š ¬Ã¢â€ž ¢ results and unfair doctrines: Structuring the application of the equitable doctrines of undue influence and unconscionable dealing. Retrieved on 28th March 2014 Low Hang Yen, Malayan Law Journals Article. Unconscionability As A Ground For Withholding Payment In Demand Guarantees: Should The Exception Be Extended To Letters Of Credit?(2008) Retrieved on 28th March 2014 Black. J. A.Undue Influence And Unconscionability In Contracts And The Equitable Remedy Of Rescission In Canada. Retrieved on 28th Match 2014 Cheong May Foong, Malayan Law Journal Article; A Malaysian Doctrine of Inequality of Bargaining Power and Unconscionability after Saad Marwi. (2005) Retrieved on 30 April 2014 ACTS Act 137 Act 136 [1] Act 136 [2] Blackà ¢Ã¢â€š ¬Ã¢â€ž ¢s Law Dictionary 743 (3d ed. 2006). [3] Business Dictionary, Inequality of bargaining power, ://www.businessdictionary.com/definition/inequality-of-bargaining-power.html [4] [1887] 36 Ch.D. 145 (Eng.). [5] 28 Eng. Rep. 82 (Ch. 1750). [6] (1983) 151 CLR 447 [7] [1985] AC 686 [8] Gregg v Tasmanian Trustees Ltd., (1997) 73 F.C.R. 91 (Austl.) (citing Sir Anthony Mason, The Place of Equity, 110 L. Q. Rev. 248, 248 à ¢Ã¢â€š ¬Ã¢â‚¬Å" 9 (1994)). Sir Anthony authored this article long after his judgement in Amadio, but before he retired in 1995 as Chief Justice of the High Court of Australia. [9] [1888] 40 Ch. D. 312 (Eng.). [10] [1887] 36 Ch. D. 145 (Eng.). [11] Morrison v. Coast Finance Ltd., [1965] 54 W.W.R. 257 (Can.). [12] Floyd v. Couture, [2004] A.J. No. 377, n.98 (Can. Alta.). [13] 1994] O.J. No. 2498 (Can.). [14] [1992] 2 S.C.R. 226 (Can.). [15] (1919) L.R. 47 Ind. App. [16] [1994]3 MLJ 127 [1 7] [2001] 3 CLJ 98 [18] Act 137 [19] [1975] QB 326 [20] Birks and Chin, On the Nature of Undue Influence Good Faith and Fault in Contract Law (Beatson Friedmann eds. 1995). [21] Smyth v. Szep, [1992] 2 W.W.R. 673, 681 à ¢Ã¢â€š ¬Ã¢â‚¬Å" 2 (B.C.C.A.) (Can.). [22] (1918) 1 FMSLR 348

College Selection Paradox Of Prestige

Getting a gleaming letter of acceptance to an Ivy League is a tremendous boost of self-esteem and sign of validation for practically any high school student; years of polishing your resume and dreadful weeks spent trying to craft a flawless essay payed off. Its as if anyone accepted to a distinguished university is guaranteed prosperity and triumph.   Ã‚  Ã‚  Ã‚   However the mindset that in order to be successful in life you must go to a prestigious college is being even more frequently questioned in the past several years. The idealized image of a top tier college as a ravishing center of learning and innovation is diluted in an ocean of student debt and suspicious admission decisions favoring the wealthy applicants (despite calling themselves ‘need-blind’).   Ã‚  Ã‚  Ã‚   Racial minorities, like Native Americans and Pacific Islanders, have a significant advantage in admissions; an equally qualified Caucasian applicant would be rejected because colleges wan t to promote an image of diversity. Similarly, out of state students are favored at universities with high in-state percentages; for instance at UCLA the acceptance rate for OOS students is almost 10% higher than for California residents. At what point will an applicant be judged based purely on merit, and not on uncontrollable factors like race, geographic location, and social class? The issue is especially prominent in the most well-known institutions because they have to maintain a an impeccable image to ensure high ranking.   Ã‚  Ã‚  Ã‚   I had the privilege of spending the past week at a summer program at Stanford University – living in the dorms, attending journalism classes and experiencing a college lifestyle. Luckily, I got three very likable roommates and had plenty of spare time after classes to explore the vast campus which completely re-shaped my perceptions of my â€Å"dream college†. Alluring autumn trees with endless beams of sunlight glaring thro ugh the branches, proud students flaunting ‘Stanford’ t-shirts and carelessly racing   their bikes through the blossoming parks - at first glance it might even seem as if college isn’t as stressful as my parents led me to believe. However behind the welcoming smiles and polished appearances are people who spend restless hours studying every night, participating in a multitude of clubs and athletics and burying themselves in test prep books to ensure a high SAT/ACT score. Many were forced to give up the classes they enjoyed to replace them with what they believe colleges are looking for and prioritize subjects they fundamentally disliked to increase their grade point average, knowing that in the future they won’t be pursuing a career in that field.   Ã‚  Ã‚  Ã‚   If I learned anything that week, it’s that going to a prestigious college isn’t about the bragging rights, and not even about impressing your future employer, but rather about surrounding yourself with other ambitious, intelligent, committed students - those who will challenge you and, at times even make you feel like you are under accomplished, but most importantly push you to become a more independent and empowered individual. A top ranked college might be full of ambitious students, but also people who were admitted based on their financial standing, legacy status, or the fact that they came from an underrepresented region of the country. There are countless Ivy League graduates who, after finishing post-secondary education, have difficulty finding employment or putting their skills to practice. Abraham Lincoln was just one of the nine US presidents who never went to college, yet can you imagine how vastly different the country would’ve been if, instead of pursuing his wildly successful career in politics, he spent four years being forced to study subjects he has no interest in.   Ã‚  Ã‚  Ã‚   The popularity of the college you go to doesn ’t at all define you, and no one should be putting their self-esteem into the hands of an admissions officer who flips through dozens of applications on a weekly basis, often forgetting to acknowledge that there are real people behind the unadorned folders whose faith is being determined. Likewise, picking a college purely based on its high ranking to impress your peers is an enormous (though unfortunately frequent) mistake.   Ã‚  Ã‚  Ã‚   Graduates of reputable colleges are inherently looked up upon, thus defying expectations when they don’t achieve the level of success expected from such a diligent student. Excelling academically has little to do with the impact one will make on their community and the planet, and more to do with how well they can follow the strictly defined academic system. Everyone has their own preferences when it comes to education, and not one college would fit every passion and aspiration; so it shouldn’t be a surprise when a valed ictorian and student body president announces she’s turning down an offer from Princeton to go to a state school, just like it shouldn’t be a surprise when a Harvard alum finds themselves broke and unemployed.

Womens Roles in Hiean Court of Medieval Japan - 506 Words

The Heian court of medieval Japan was a progressive and dynamic society where women commanded a fair amount of power and respect. In many ways it seemed to be the basis of the rank n file, material culture of today’s society. The social structure of society throughout the court was set up in three different ranks. In chapter two, Genji’s friend, To no Chujo explained the three roles and how they determined the role of women in court. Women of high rank would be the wife of a high ranking elite, thus responsible for raising the future heirs, women of lower rank were concubines and often had better relationships with the man than his wife. did It was this complicated ranking system that led to the abundance of accepted promiscuity, however the two roles kept a bit of stability and normalcy throughout the court. Social rank was a main factor in determining women’s role in court and from the first chapter of â€Å"The Tale of Genji† author Maruabu Shikabu stressed the importance of social role. Genji’s mother, often the brunt of slanderous abuse from the Emperors wife, withdrew from court and took Genji away from court to live with her family. Social importance was best explained though in chapter two by Genji’s friend, To-no-Chujo. Chujo defines the different ranks to Genji while discussing the women they have slept with. To suggests that the three different ranks among women were; â€Å"High rank, Middle Rank, and No Rank (Commoners). Genji’s mother was a lower (Middle) rank

Learn About Where Polar Bears Live

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

An Elderly With Congestive Heart Failure - 1429 Words

An elderly male with congestive heart failure was brought to a clinic because he was experiencing atrial fibrillation and had a ventricular response of 110 beats/min with palpitations and shortness of breath1. Medications that he was taking includes angiotensin-converting enzyme inhibitor, Lisinopril, Carvediol, Digoxin, and Furosemide1. His left ventricular ejection fraction has been reduced to 25%1. Further examinations showed that he had edema in his legs and crackles at the base of his lungs1. He was then told to increase the dosage of Furosemide by taking the drug twice daily instead of once, and doubling the dose per administration1. One week later, the electrocardiogram revealed that he had ventricular arrhythmias such as premature†¦show more content†¦Stroke volume is the volume of blood the ventricle ejects per heartbeat, and factors such as preload, afterload, and contractility of the heart all have implications in stroke volume2. Preload describes the extent to wh ich the myocardial fiber stretches at the end of diastole, and afterload is the resistance the heart must overcome for the ventricle to eject blood2. Heart failure describes a syndrome in which the patient has a dysfunctional heart incapable of sustaining an adequate cardiac output, and this syndrome is responsible for a large portion of cardiovascular-related deaths2. There are two types of left ventricular dysfunction, one is systolic dysfunction which has implications in defective ventricular ejection and contraction, and the other is diastolic dysfunction which has implications in dysfunctional ventricular relaxation and filling2. Heart failure patients with systolic dysfunction have an ejection fraction of less than 40%, and heart failure patients with diastolic dysfunction have an ejection fraction of greater than 40%. In the case study, the patient has a left ventricular ejection fraction of 25% which means that he is suffering from systolic dysfunction. Consequences of left ventricular systolic dysfunction include ischemic diseases, atrial fibrillation, increased ventricular response, and myocardial infarctions2. Some of these symptoms were seen in the patient from the case study. Factors leading to left