Equitable rights to a property - Free Essay Example

Sample details Pages: 9 Words: 2675 Downloads: 6 Date added: 2017/06/26 Category Law Essay Type Analytical essay Did you like this example? A) After considering the concern you have raised during our meeting I have prepared a summary of the law and advice. Although there is not any reference to notice or restriction on the property there are equitable rights which can bind the purchaser of a property even if there is not any reference to them on the register. Martin has stated that he has paid half the purchase price of the property when he and Penelope purchased the property. Don’t waste time! Our writers will create an original "Equitable rights to a property" essay for you Create order When an individual has paid towards the acquisition of the property they will acquire a resulting trust in the property. A beneficial interest awarded via a resulting is normally restricted to the actual amount invested by the individual. If Martin can prove that he did indeed pay more than half of the purchase price at the initial acquisition of Bylands It is likely that he has acquired a beneficial interest in the property by way of a resulting trust. As it is possible that Martin owns an equitable interest in the property he could therefore claim that his interest will bind the purchaser of the property. This will depend if Martin is deemed in actual occupation of Bylands under schedule 3 Paragraph 2 of the Land Registration Act 2002. A wife and husband occupation will be viewed as separate as expressed in William Glynà ¢Ã¢â€š ¬Ã¢â€ž ¢s Bank Ltd v Boland. The wife has acquired a beneficial interest by way of a resulting trust her husband had remortgaged the property which was in his sole name. He fell behind on the payment and the bank sought to repossess. The wife claimed that her occupation an interest was seperate and would override the bank interest, the House of Lords held that her occupation could be distinguished from her husbands and her interest did in fact override that of the bank. At the time that the property was viewed Martin was on a two month tour with his modern jazz band. In the case Chhokar v Chhokar[1] a husband tried to deprive his wife of her equitable interest buy selling the property which was in his sole name while she was in hospital. On her return from hospital she was excluded from the property buy the purchaser the court of appeal held that she had an overriding interest. A persons belongings on their own will not suffice as occupation on their own Strand Securities v Caswell [2]. The case law therefore dose not exclude person who are on a temporary break if there has been belonging in are still in the and there has been p revious occupation with the intention to return after the break. The court will consider if the occupation would be obvious after a reasonably careful inspection. The opening of drawers and cupboard would beyond reasonable inspection but making further inquires would not be as illustrated by Kingsnorth Finance Co Ltd v Tizard[3]. However, the occupation is required to be discoverable. It would depend on how obvious it would on a reasonable careful inspection and the availability of making additional inquires. For example if the presence of Martinà ¢Ã¢â€š ¬Ã¢â€ž ¢s belongings were obvious or his occupation would have been obvious by speaking g to the neighbours or estate agent. It is normal practice for the mortgage company to secure waver of all people living in the property, it is therefore worth checking with the mortgage company if you have a mortgage on the property. It is possible for Martin share to be overridden but the purchaser if there are two trustee but as is appears that the property was only in Penelopeà ¢Ã¢â€š ¬Ã¢â€ž ¢s name it is apparent that there was only one trustee in this case and therefore it would not be possible. It is imperative that Penelopeà ¢Ã¢â€š ¬Ã¢â€ž ¢s details are forward for communication to be established in order to recover the purchase price or for the correct proportion of the price paid is given to Martin depending on the establishing on further facts relating to Martinà ¢Ã¢â€š ¬Ã¢â€ž ¢s occupation. Declan states that he has a three year lease for the studio flat at the top of Bylands but he does not have any written evidence of the lease. A legal lease which is over three years must be made by deed section 52(1) of the Law of Property Act 1925 but a legal lease for term of three years or less there is no requirements of a deed. As Martin lease is for a term of three years or less there is no requirement for a deed and can validly be made orally. Lease are known as the second legal estate under section 1(1) of the Law of Property Act 1925 and are further defined in section 205 (1) of the Law of Property Act 1925 as an estate in land for a fixed maximum period. In addition there are certain requirements for a lease to arise these are defined by Lord Templeman in the Case Street v Mountford[4] as exclusive possession for a fixed period or periodic term certain in consideration of a premium or periodic payments. Rent or premium must be fixed amount that does not fluctuate from month to month .In addition the lease must be have a fix maximum term. In order for there to be exclusive possession the tenant must have control over the premises occupied and the area must be the exclusion of the landlord from the area lived by the tenant of the. The flat is self contained and People and Martin were excluded from the are further enquires to ascertain Martinà ¢Ã¢â€š ¬Ã¢â€ž ¢s lease is also for a fixed term of three years. Further details is relation to the amount and regularity of rent paid wou ld need to be clarified. Based on the facts before me it would appear that the requirement of a lease has been fulfilled. As Declan lease is for three years it is not necessary for any registration or to be evidenced by a formal written document. In the event of Martinà ¢Ã¢â€š ¬Ã¢â€ž ¢s lease was over three years it would be required to be in writing. If Martinà ¢Ã¢â€š ¬Ã¢â€ž ¢s lease was an equitable lease it should be entered as a notice on the lessorà ¢Ã¢â€š ¬Ã¢â€ž ¢s title to be binding, however , if the tenant is in actual occupation the lease will bind the purchaser of the property under paragraph 2 of schedules 1 and 3 of the Land Registration Act 2002. In addition Leases of less than seven years are also binding on the purchaser of the legal estate under schedules 1 and 3 of the Land Registration Act 2002. Therefore the purchaser of Bylands will be subject to Declanà ¢Ã¢â€š ¬Ã¢â€ž ¢s lease for the self contained studio flat on the top floor of the house. Declan has al so asserted that he has paid  £15,0000 for the option to buy Bylands within the next three years for  £700,000. He has a written contract signed by Penelope and Martin. It appears that the document is a valid option to buy, but in order for the option to be bind the purchaser it must be registered. An option to buy is classed as an estate contract class C iv land charge which must be registered on the title before the purchase takes place as expressed in Philips v Mobil Oil Co Ltd[5]. If the charge is not registered it will be void against the purchaser for money or money worth under section 4(6) of the Land Charges Act 1972. The option will be void if unregistered even if the purchaser had actual knowledge of the option existing as illustrated in the case Midland Bank Trust Co v Green[6] Lord Wilberforce stated it is not fraud to rely on legal rights conferred by statutenotice and good faith are irrelevant. As there is not any sign of registration of the option to buy in favour of Declan therefore the purchaser of Bylands will not be bound by the option. It is likely that Martins has an equitable interest in Bylands by way of a resulting trust which may be binding on the purchaser of Bylands. In additional the purchaser will be subject to Declanà ¢Ã¢â€š ¬Ã¢â€ž ¢s lease. In order to terminate the lease the landlord will need to pursue the provision under the Protection from Eviction Act 1977. As the option to purchase in Declanà ¢Ã¢â€š ¬Ã¢â€ž ¢s favour is not registered the purchaser of Bylands will not be subject to the option. B) When a lease is created there are covenants contained in the lease. These are promises by which one party undertakes to do or not to do something these can be implied or express covenants. The tenants implied obligation are keeping property in a tenant-like manner Warren v Keen[7], allowing the landlord to enter the property to inspect Mint v Good[8] and to pay rent and taxes. The landlords implied obligations are to permit the tenant quiet enjoyment of the premises and keep the property fit for human habitation under section 8 of the Landlord Tenant Act 1985. There are many types of express covenants which will be written in to the contract the most common is not to sub-let the property. The enforcement of covenants were dramatically different before the Landlords and Tenants (Covenants) Act 1995. The contractual relationship arising from the covenant will continue even after the tenant has assigned the lease or the reversion of the freehold has been sold by the landlord. Therefore the original tenant would have only covenanted for there own conduct but that of those who are assigned the lease. The previous landlord will also be liable for a breach of a covenant when they are no longer the owner of the freehold. Even if it is not expressed that the covenant related not only to themselves but there successor of the title it will be implied through virtue of section 79 of the Law of Pro perty Act 1925. Therefore if the assigned tenant breaches a covenant the original tenant will still be liable to be sued by the landlord for their successor breach Thursby v Plant[9]. Likewise the landlord who has sold the freehold will be liable to be sued by the tenant for a breach of a covenant by the new landlord. The tenant would be liable for the term of the lease for any breach of covenants by their successor. The burden of most covenants will also pass to the new tenant under the assignment of the lease and they will be personally liable for the breach. This means a choice of who to sue was provided the original tenant under privity of contract or the new tenant under the assignment of the lease. It is usually more convenient to sue the new tenant who has caused the breach, but if the new tenant disappears or not worth suing the landlord can recover his loss from the original tenant. As mentioned previous the same rules apply to the liability of a landlord who has sold th e property. If the original tenant or landlord had been sued it is possible they could recover their losses. The original tenant or landlord can directly sue the person who committed the regardless of the number of times it has been assigned through the rule in Moule v Garret[10]. This is that where one person is compelled to pay damages by the legal default of another, he is entitled to recover from that person the sum paid. He may also who will then recover their loss from their assignee as so on until the loss is recovered from the person who has committed the breach. The fact that the original tenant or landlord remained liable for any breach of covenant by their successors throughout the whole term of the lease had produced unfair results main due to the fact tenant and landlords were not always a ware of the true nature of the provisions. During economic difficulties in the 80à ¢Ã¢â€š ¬Ã¢â€ž ¢s the hardship was intensified for original landlords and tenants which led to pressure for a change in the legislation. Many found themselves in the position of being sued as the current tenant could not afford to pay in many cases the lease had passed several times and the original tenant knew nothing of the current tenant or landlord. The 1995 Landlord and Tenant Act provides for the release from covenant except personal ones for the original landlord and tenant. For the tenant the release is automatic section 5 of the 1995 Act provides that from the assignment of the lease the tenant is released from the burden of the covenants. The section relates to any assignment of the lease and will cover all assignment not just the one from the original tenant. Although the original tenant will be freed automatically from the burden of the covenants the landlord may requires him to entre in to an authorised guarantee agreement by which he guarantee the assigneeà ¢Ã¢â€š ¬Ã¢â€ž ¢s conduct. The landlord is permitted to offer such agreement when either it is a condi tion that his permission is required at the assignment of the lease or when it is a condition to consenting to the assignment of the lease. Although the 1995 Act provides that landlords are released from the burden of the covenants the release is not automatic on the reversion of the lease. The Act provides a procedure under section 8 by which the landlord is required to give notice of the intended or actual assignment of the reversion and request release from the covenants. When tenant doses not respond or consent the landlord can apply to the court for an order that it is reasonable that he is released from the covenant. The tenant has the right to oppose the assignment and release from the covenants. Under section 11 of the Act the burden can still continue for the original landlord or tenant when an assignment has taken place contrary to a covenant forbidding the assignment or assignment by law through bankruptcy or death. Only covenants which are not truly personal will p ass. An example of a personal covenant is in BHP Petroleum Ltd v Chesterfield Ltd[11], in this case the original landlord had promised to undertake certain remedial work to the property and it was clear that this was to be a personal obligation that could not be enforced against the landlordà ¢Ã¢â€š ¬Ã¢â€ž ¢s successors. The court held the nature of the covenant was did not fall under the scope of landlordà ¢Ã¢â€š ¬Ã¢â€ž ¢s covenants and therefore was not subject to the Act. The benefits of the Act for original tenant is that section 17 provides that the landlord cannot recover arrears of rent or other fixed sum from a former tenant unless within six months of the money falling duje the landlord has served a notice of the intention to recover. This prevent landlords from allowing rent arrears accumulating and then pursuing the original tenant where they have not been released from their obligation .Section 18 negates the rule in Centrovincial Estates Plc v Bulk Storage Ltd[12] that the original tenant will be liability can increase with variation of the lease after the assignment. An original tenant also has the right under section 19 to grant an overriding lease in which will take effect as a concurrent lease or a lease of the reversion. This will have the effect of investing the landlordà ¢Ã¢â€š ¬Ã¢â€ž ¢s powers of enforcement in the original tenant allowing him to limit his liability. The limitation of the landlords and tenants id not yet absolutely resolved but the Act has made huge improvement. Despite the fact it can be undoubtedly unjust that the original tenant or landlord can be liable In some cases it may be unjust that there no other recourse when the original landlord or tenant has knowingly re-assigned the reversion or the lease knowingly to an unscrupulous tenant or landlord. Bibliography Burn, EH Cartwright J Cheshire and Burnà ¢Ã¢â€š ¬Ã¢â€ž ¢s Modern Law of Real Property (17th edition, 2006) Oxford: OUP BLACKSTONEà ¢Ã¢â€š ¬Ã¢â €ž ¢S STATUTES ON PROPERTY LAW 2007-2008 OXFORD 14TH Edition April Stroud, Making Sense of Land Law (2nd edition, 2008) Palgrave Macmillan Judith-Anne Mackenzie Mary Philips Textbook on Land Law 12TH Edition OXFORD 1 Footnotes [1] 1984 FLR 313 [2] 1965 Ch 958 [3] 1986 1 WLR 783 [4] 1985 AC 809 [5] 1989 1 WLR 888 [6] 1981 AC 513 [7] 1954 1 QB 15 [8] 1951 1 KB 517 [9] 1 Saund 230 [10] 1872 LR 7 Ex 101 [11] 2002 Ch 194 [12] 1983 46 P R 393

Criminal Justice System A System Of Law Enforcement

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Blood Diamond Outline free essay sample

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The Reconstruction Essays - Reconstruction Era, Black Codes

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Scholarship Essay

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Case Collection Study - Essay Example The interrelationships between what used to be an indicator of health or illness in the economy have changed dramatically and analytics must be changed to reflect those facts. An example of one of the ways that the world is very different is the health of the stock market as a reflective device about the wealth of the nation. While the stock market has been showing better numbers in recent months, the nation on the whole is not thriving at the same level with unemployment still high. As well, the level of CEO salaries are over 300% that of the average worker. It used to be that the level of salary of a CEO reflected the health of the salaries of the employees. In 1980 the ratio between the CEO and the worker was 42-1 (Carroll & Buchholtz, 2010. What this reflects is the continuing disparity of wealth in the United States. And while this existed in 2007, the economic downturn of 2008 established the destruction of the Middle class, creating a whole new way in which consumer prediction s needed to be approached. The cost of living has gone up and working class people and the remnants of the middle class have very little disposable income. Davenport, Harris, and Morison (2010) discuss some of the reasons to not use analytics. One of these reasons is when history misleads the results of the analytics. Because of the changes that have occurred in the last six years, the historic interconnections of different indicators are not necessarily still meaningful. The example of the stock market and how it no longer indicates overall wealth is an example of how predictors can now be misleading for the future from today. Willis (2011) writes that in the last century the stock market has always been an indicator of overall wealth, but since the economic downturn that has changed. This example shows how a number of factors have changed in the new economy and in order to create a predictive analysis, these factors must be taken into consideration. What has not changed, however, is the power of distinction. People are still finding ways to buy items and distinction has created enough power for many companies to thrive in this stifled economy. One example of this is the iPad which launched in 2009 and sold over 25 million of the units in a few short years. Distinction has created the market for the iPad and its competitors have not come near to duplicating that success (Bell, 2011). It is the one that comes out first that will get the attention and this is how distinction is still a powerful factor. This can also be seen in the iPhone which has decent competitors, but all one has to do is watch the commercials to see that the competition is doing its best to diminish the cult status of the Apple phones. Through trying to insinuate that they are at the end of their life-cycle competitors like Galaxy and Microsoft are using a thin stick to strike a mighty mountain. In order to gain the power of predictive analytics, then, it is important to recognize what has changed in the last six years, but to realize that the most important part of business has not changed. When a new idea is good and has a great deal of consumer value the idea will succeed. Demand can be predicted through distinction, but where there is no distinction and an idea is being recycled or improved upon, the predictive analytics will have to take into consideration the real status of the

Uprising of Syria Research Paper Example | Topics and Well Written Essays - 2500 words

Uprising of Syria - Research Paper Example The questions, which arise from the crisis in Syria, are the nature of the Syrian conflicts, the relationship between a civil war and a revolution and whether the crisis in Syria overshadows a revolution (hill). Nature of conflicts in Syria The crisis in Syria cannot be classified as purely sectarian as the international and the local media try to classify it. This classification of the Syrian conflicts as sectarian is as a result of the failure of the media personalities to understand Syrians or generally Arabs in other terms, which do not identify them as sectarian. A sectarian conflict can only be described as one that lies outside a country's history and does not depend on any social and economic factors. Sectarian conflicts are often referred to as religious conflicts and are static. The Syrian situation is similar to the case of Spanish civil war, Yemen civil war and the revolution that occurred in Libya. The main cause of the Syrian civil war is as a result of the uprising of the Syrian citizens against a class of individuals whose main goal is to enslave others. According to McMahon in his article on crisis in Syria, he describes the cause of the continued crisis is mainly as a result of disunity among different religious and ethnic group. This makes it more difficult to find a concrete solution to these crises (Macmahon). US president is quoted in solidarity magazine saying, â€Å"The crisis in Syria should be solved through a meditation led by international community†. This implies that international communities like the United Nations should initiate the process of mediation in order to find long term solutions to the...Moghadam in her article on Syria crisis and prospects quotes the UN secretary general saying, â€Å"We need to come up with an immediate solution to these uprisings†. On this has seen some of the nations like the United States of America and Britain argue that it is crucial to intervene in the crisis in Syria, while othe r nations like Russia and France arguing otherwise (Moghadam). The Syrian uprising has attracted attention from every nation across the world given the fact that Syria was once considered as the most peaceful and stable Arab country in the world. Different leaders across the world have varying opinions on the crisis in Syria. Some view it as a civil war while others view it as a revolution which involves political forces. The Syrian crisis should so far be classified as civil war since the government is fighting against a well organized rebel gang â€Å"Sunnis† which was possibly established during the initial uprisings. Most revolutions bare some aspects of civil war; however some aspects of civil war cannot be overlooked during a civil war as in the case of the Syrian revolution which has turned out to be a civil war. In conclusion, the crises in Syria originate mainly from the internal factors and forces. The major internal cause of the crisis is the government of Syria, which triggered the initial demonstration through infringing the rights of its citizen.

Creativity report Coursework Example | Topics and Well Written Essays - 1250 words

Creativity report - Coursework Example Creativity and innovation have become valuable features of leading companies. Schirrmacher (1988) defines creativity as one’s ability to see things in novel ways; it is breaking boundaries and going beyond the known facts. It is also developing something new, different and original and combining things which do not seem to be related to each other but eventually makes sense when put together. This is closely related to innovation which is sparked by a new idea. The idea can be a new technology such as a gadget that can provide more convenience to consumers, a new service like an alternative form of relaxation, a new product, or even a new administrative procedure. Such ideas are driven by needs that are seen by the innovators. Innovation requires creativity. In organizations, innovation becomes the growth of a new idea from its initial state into its actualized form as a full-blown innovation (Roberts, 2006). Thus, creativity is at work when one innovates. The ongoing global recession has caused the shutdown of several companies, leading to massive unemployment. Epic Events Management Company is a small company that has likewise suffered the blow, with many of their clients opting to forgo their special events as a way of cutting down expenses. To keep the company afloat, they had to let go of a large part of their office space which occupied the whole floor of a prominent building downtown. The CEO decided to just keep his office for entertaining clients, the team room with a few office tables and the reception area. Because of this drastic move, they have significantly saved on rental expenses. The problem now lies on how they would rearrange the office so that all the staff can fit in and still be productive. On top of that, they need to think up of other alternative income-generating ideas that will augment the losses incurred from the lack of projects. For the problem of lack of office space for the

Comparison The Lovely Bones and The Liars Club

Comparison The Lovely Bones and The Liars Club In this term paper I will compare two books that I really liked: The lovely bones and The liars club. I decided to write about them, because I believe that both stories are very similar and very well written. I also think that the authors of these books are admirable women who have struggled with life, society and family. For this reason, I consider important to compare the two books. I will start to write about the lovely bones. At the beginning, I did not want to finish reading the book, because it is a hard story that talks about the raping of a little girl. Therefore, I felt so angry and frustrating. But then I understood that I had to continue reading the book if I wanted to know the meaning of it. The point of view of the lovely bones is first person and it is narrated by Susie Salmon, the girl that was horribly raped and murdered by her neighbor. The entire story is about the grief that the Salmon family is experimenting after Susies death. However, there was a member of the family who suffered the most: Susies father, Jack Salmon. This man loved her daughter so much that when he knew that she was killed, life became a hell for him. As a result, his marriage was very affected and his wife cheated on him. I found a quote that explains the relationship between Susie and her father: His own father had taught him how to build ships in bottles. They were something my mother, sister, and brother couldnt care less about. It was something I adored. The den was full of them. He would call me in whenever he was ready (Sebold, Alice p, 45) Unlike her siblings, Susie enjoyed her fathers hobby. This man loved to build ships in bottles, because his father taught him how to do them. So, he shared this hobby with their children, but the only one who liked and care about it was Susie because she had a very strong relationship with her father. Therefore, when she passed away his father Jack wanted to die. On the other hand, Mary Karr in her book The liars club showed that her relationship with her father was very special and unique. For example, she mentioned that he used to be a very lovely father with her and her sister and that even though he was many years in the war, when he came back home he always wanted to spend time with his family. However, Marys father did not have a good relationship with the rest of the family, because his mother in law did not like him and as a result, his marriage was falling apart. This quote explains the situation he was living: Mother threatened divorce a lot of times, and Daddys response to it was usually a kind of patient eye-rolling. He never spoke of divorce as a n option. If I asked him worried questions about a particularly nasty fight, hed just say I shouldnt talk bad about my mother, as if even suggesting they might split up insulted her somehow (Karr, Mary pa, 35) As we can see, Marys father did not want to get divorce maybe because he wanted to be with her two children. Moreover, he said to Mary that even though he had conflicts with his wife, she had to love her mother no matter what. I think this man showed that he was a good husband and a good father since he always asked Mary to respect her mother. This case is very similar to the conflict that Susies parents had in the book The lovely bones. As we know, when Susie died, all the family struggled with the fact that she was not longer with them. Each of them faced Susies death differently. The father, for example, was obsessed to find the killer, the sister Lindsay did not want to talk about it, the brother was very innocent to realize that her sister had passed away and the mother decided to cheat on her husband to relieve the pain. I said before that Susies father and Marys were similar because both men were married with women whot, from my point of view, did not care about their children . Marys mother cared only about herself. She just wanted to have fun and get another husband that is why she went on a trip with his Latin-American boyfriend and left her children. Susies mother did the same thing when she decided to move to another state in order to be alone and deal with her daughters death. THE RELATIONSHIP BETWEEN SIBLINGS I believe that in the two books that I decided to compare, the relationship between siblings is one of the most important topics. In this part of my term paper, I will compare Susies relationship with her brother and sister and Mary Karr relationship with her sister Lecia. Susie Salmon had one brother called Buckley and one sister called Lindsay. The tree of them were very closed and cared very much about each other. There is a quote in the book The lovely bones where Susie says that once she saved her brothers life. a three-year-old Buckley had swallowed it. Buckley was choking, his body bucking, and I carried him with Nate trailing into the garage, where my fathers precious Mustang sat. I put Buckley in the back and grabbed and grabbed the keys from the unused terra-cotta pots where my father hid them. I sped all the way to the hospital. if the hadnt been there, the doctor later told my mother you would have lost your little boy (Sebold, Alice p, 93,94) As the quote explains, Susie saved her brother because she loved him very much. She also had the courage to do it since many people would not dare to do what Susie did. Susie loved Buckley so much that she did not think about anything but to safe her little brother. Later in the book, this strong connection is demonstrated when in one of the chapters, Buckley said to his dad that Susie touched his cheek and that he felt that Susie was seeing them from heaven. Susie also got along well with her sister Lindsay. Both girls enjoyed being together, not only because they were sisters but also because they were the same age. As a result, when Lindsay knew that her sister was dead, she did not want to talk about this tragic event to anybody. For me, it is very understandable the way that Lindsay felt. Some people like her deal with death by being quite and reserved. Some others share their feelings in order to release their pain. But what really cares is to remember the people who we love. Now, the author of The liars club also had a good relationship with her sister Lecia. These two girls suffered a lot not only because they had many problems in their home, but also because they have an alcoholic mother and a hysterical grandmother. I found a quote that explains their relationship: Lecia and I both behaved like savages at any opportunity. When she was only twelve, Lecia could beat the dogshit out of any neighbor boy up to the age of fifteen. For my part, I can remember standing behind the drainage ditch in our yard cussing Carol Sharp for bloodying my nose (Karr, Mary pa, 40) In this quote, Mary Karr explains that she used to play pranks with her sister and that thought she had problems in home, she tried to forget them by playing with Lecia. From my point of view, it is very difficult to live you life normally when you know that your family is hurting each other. For this reason, I admired Mary Karr very much, because she tried to forget all her problems. Unfortunately, when you are a child, all these family conflicts affect you and the only thing that you can do about it is to move on with your life just as Mary Karr did. On the other hand, I also believe that she was conscious about her family problems, but she could not do anything about it. I can not imagine what it feels like to live with a family that is full of traumas and that does not care about you. For example, Mary Karrs grand mother was a bitter woman who did not love their grand children and who lived in the past. That is why Mary Karr did not suffer when her grand mother passed away. Inste ad, she felt relieved and free. Susie Salmon also had a special grand mother, but unlike Marys she was a good person who loved their grand children very much. This woman was an alcoholic but she took cared of their grand children while her daughter Abigail decided to move to another state. These two women were so different, but as any human being they have many flaws. Now, in the next pages of my paper I will talk about the role of the mothers in the two books The lovely bones and The liars club THE ROLE OF A MOTHER IN A FAMILY It is well known that a mother represents many important things in a family. She is the one who takes care of her children, because she has a protective instinct that a father does not have. For this reason, it is unbelievable for me to understand why Susies mother abandoned their children in order to forget her dead daughter. I can understand that it is very painful to lose your daughter, but by abandoning your other children you are not going to resolve anything. Now, I also comprehend that as human beings we need to have our space, because is our right. But when you have a family like Susies mother you also have to think about them. Another thing that also surprised me was that Susies mother cheated on her husband. Even now I can not understand what she did that. There is a very good quote that explains Abigails attitude according to Susies point of view: Len kissed her forehead hard and closed his eyes. She took his hand and placed it on her breast. She whispered in his ear. I knew what was happening. Her rage, her loss, her despair. The whole life lost tumbling out in an arc on that roof, clogging up her being. She needed Len to drive the dead daughter out (Sebold, Alice p, 152) This woman desired to forget her daughters death by cheating on her husband. She thought that her pain was going to disappear if she transferred all his sorrow in another person, but I think that is not the correct way to resolve our problems. She could have gone to a therapist or talking to her husband about Susies death. Infidelity is something that I can not comprehend. Unfortunately, Abigails infidelity did not bring Susie back. Instead, this deception caused Abigail more pain and more remorse to her life. At the end of the book, we know that Abigail returned with her family because Jack had a heart attack, but we never knew if she stayed again with them or if she decided to be brave enough in order to tell her husband that she had cheated on him with Len Fenerman. In the book The liars club Mary Karr explained that her mother was always worried about herself, just exactly like Susies mother. You might think that I am judging these women very hard, but I just can not understand why they behaved that way with their children. I mean, when you decide to have children is because you know that you have to take care of them, yet there are some mothers that do the opposite thing. Mary Karrs mother for example, tried to be a good mother, but I feel that she had a very hard background that did not allow her to live her life peacefully. Even Mary Karr recognized that when she finished her book, it was very hard for her mother to read it. At the same time, Mary said that she was very supportive when the book was done. Another thing that it was hard to assimilate for Mary and her sister Lecia was to live with their stepfather Hector. He constantly had arguments with Marys mother and they did not have a good relationship. There is a quote that explains this situation: Other nights were occupied with Mother and Hector fighting. The litany of his innate low-lifedness got seared into skull during this time. Hector was a pussy, was her main gripe. Also, he lacked gainful employment, which meant Mother accused him of sponging off her all the time. As this quote explains, Marys stepfather did not support his wife economically. Therefore, Marys mother argued with him and had many conflicts. Plus, he was an alcoholic who was worried more about drinking than about taking care of his wife, his house and his stepdaughters. When I think about the problems that Mary had to deal with, I really felt sorry for her. She was only a child when her parents got divorce and when he had to accept a new father figure. I can see Marys life like a quest. During her childhood, she lived so many bad things that made her stronger, but at the same time made her more vulnerable. In order to conclude this term paper in the next to pages, I will talk about the most difficult topic in both books: raping. The reason why I decided to write about it at the end, was because I want to reflect about how raping can change your life. TWO GIRLS WHO LOST THEIR INNOCENCE The books that I decided to compare in this term paper talk about a very hard topic: raping. In the lovely bones, the main character Susie Salmon was horribly raped and killed by her neighbor Mr. Harvey. This story is fiction, but the author of it was raped in real life. For that reason, she wrote this book. As we know, Susie Salmon was a fourteen year old girl who had a normal life and who wanted to fell in love for the first time. Unfortunately, all of her dreams were destroyed by a disgusting and despicable man named Mr. Harvey. He took away Susies innocence when he raped her. After this, he decided to kill her so she could not accuse him of anything. But Susie was not dead in a one hundred percent, because her spirit went to heaven. She saw her family and her killer from there. She saw all the pain that Mr. Harvey had caused after he killed her. But she also saw that her family got over her death and moved on. Here is a quote in which Susie explains her raping: Mr. Harvey made me lie still underneath him and listen to the beating of his heart and the beating of mine. How mine skipped like a rabbit, and how thudded, a hammer against cloth. We lay there with our bodies touching, and, as I shook, a powerful knowledge took hold. He had done this thing to me and I had lived. (Sebold, Alice p, 14) The only thing that I can say about this quote is that I can not imagine what this girl felt in that moment. For me, it is very difficult to understand how these criminals can exist. I mean, this man took advantage of a child who was not big or strong enough to defend herself. Killing a person is horrible, but killing a kid who is weak and innocent is the most despicable act in the world. From my point of view, Mr. Harvey was a scum of the earth who did not deserve to be alive, because she also killed other children. All of them were girls that had a life, dreams and hopes for the future. But this killer ruined their lives and left sorrow in their families. Finally, in the book The Liars club Mary Karr narrates that she was raped, when she was a little girl. This event changed her life and her perspective about the world. The quote says: He pulled me off my shorts and underwear and threw them in the corner in a ball, over where I knew there could be spiders. He pushed down his pants and put my hand on his thing, which was unlike any of the boys joke about hot dogs and garden hoses. It was hard as wood and felt big around and felt big around as my arm. He wrapped both my hands around it, and showed me how to slide them up and down (Karr, Mary p, 66) When I read this fragment of the book, I really felt so angry and frustrated. I can to imagine the desperation that Mary Karr experimented. She as Alice Sebold experienced how it felt to be raped and humiliated by a man. But at the same time this horrible experience made them successful and brave. So, my conclusion for this term paper is the following: every person forms his character based on his personal experiences. As a consequence, in life we can follow two paths: the one that is related with hate, vengeance and sadness and the one that is connected with love, success and hopes. I believe that the authors of the books that I compared followed the second path, because they decided to heal their emotional wounds in order to move on. That is a lesson that all human beings should learn. Nobody said that life is easy. Nobody said that life is pink color. However, god made us strong to achieve any objective that we have. He made us intelligent to understand that life is something that is full of bad and good moments. For this reason, these two authors, Alice Sebold and Mary Karr succeed when they decided to tell their stories to the world. They had a lot of pain in their lives, but they also decided to cure their traumas to move on and have a good life.

Important Qualities in the Life of Jesus :: Religion

Important Qualities in the Life of Jesus Ever since Jesus was born, he has always been perfect. There have never been any flaws that had to do with him. He had many different characteristics and qualities that were unique about him including holiness, purity, faithfulness, mercifulness, grace, righteousness, love, integrity, divinity, and courageousness. There is nothing that is more powerful than that of the triunity, which consists of God the Father, God the Holy Spirit, and God the Son. This report deals mostly with God the Son, which is Jesus. Jesus has all these qualities and we are supposed to be following in His footsteps. Most Christians try as hard to have these great characteristics, but there is no possible way that we could achieve such a goal. It is impossible for humans to reach that goal. It says in the Bible "For everyone falls short of the glory of God.". That right there is enough proof to show that we are not worthy of his presence. God is of the Spirit. He is not made of matter and mind, and he does not possess a physical nature. Some think that God is that of a human. There is no possible way that this could be, because in John 4:24 Jesus speaks "God is spirit, and those who worship him just worship in spirit and truth.". Even though Jesus had flesh was of the Spirit he still did have matter. He had flesh which is matter. In this flesh was very important qualities. God still possesses all of these qualities even though He does not have flesh. These characteristics would fit for either God the Father, God the Son, or God the Holy Spirit. They all work in the triunity and have these qualities even though one might display it in a different manner than the other. In the thirty-three years of Jesus' life, He had three very important characteristics that are something we all should try and follow: Loveliness, Faithfulness, and Forgiveness. Very often when people think of Love, they think of Jesus. In John 4:8,16 it says that God is love. This is a paraphrase but it is still stating something that is very important. That verse shows that Jesus had (and still does) mercy and compassion for us. Another verse that shows that God's love as apparent is John 3:16, "For God so loved the world that he

Respectable Citizens: Gender, Family and Unemployment

Respectable Citizens: Gender, Family and Unemployment in Ontario’s Great Depression By Lara Campbell – A Review Lara Campbell’s, professor of history at Simon Frasier University, book Respectable Citizens: Gender, Family and Unemployment in Ontario’s Great Depression (published in 2009) provides a thoroughly researched look at an often looked over topic in regards to the Great Depression; gender. Her beginning introductory chapter sets the focus of this book and she takes time to consider the strengths and weaknesses of her thoroughly used sources.This overview of the book provides the reader with a well formatted look into her topics of discussion; namely the aspects of the welfare state, labour, and gender identity and understanding. Campbell divides her book into five primary chapters; each of which discuss a variety of issues and themes supplemented thoroughly with examples of accounts. Chapter one demonstrates the vital role which women, particularly as mothers, played within the home in order to ensure economic survival. Additionally, this chapter discusses the influence and importance of society’s view of just what a â€Å"good wife/mother† was including class differences.Survival through domestic work (e. g. nutrition, clothing, keeping house, budgeting) and informal labour (e. g. taking in laundry, sewing, prostitution, taking boarders) served as staples for women and mothers alike during this era. Campbell also discusses and provides insights on the matters of single motherhood, employed married women – who were largely subject to public ire for taking the jobs of men especially if their husband also had a job– and women deserting their families. This chapter, much like the second focuses on the roles, duties and expectations placed upon women and men in regards to their families.Chapter two continues on such topic with its focus being on men. This particular chapter demonstrates the stresses pla ced upon the family as men — the quinticental â€Å"bread-winners† — were increasingly unable to fill their role and were forced to endure searches for work and resulted in demands of social entitlement. Campbell spends particular attention to the humiliation of men in accepting relief money and as well as the concept of being unable to provide and fill their role as husbands and fathers leading to suicide.Chapter three canvases the contributions and involvements of the youth with their families through, primarily, informal and formal labour along with theft and black market dealings. It can be seen in this chapter the weighting of school against economic need; many for going schooling due to lack of clothing, supplies and duty to the family. As the chapter progresses Campbell demonstrates the requirements placed upon the sons and daughters even as they reached adulthood and the conflicts it generated between parent and child through the various acts employed by the state (e. . Parents Maintenance Act). The subject of illegitimate children and abortions is also discussed as Campbell portrays the effect the Depression had upon marriage rates. Chapters four and five, much like chapters one and two, share similarities in their subject matter; both chapters discuss protect, state policy and provision at length. In chapter four Campbell focuses on the stresses and their effects on both men and women in the home, including domestic abuse, and towards the state (e. g. eviction protests, meetings and political mobilization).Chapter five builds on the themes of protests toward the state and the variables of such things as gender (largely traditional in nature), ethnicity and class that shaped such matters like child welfare and rightful claims. By large Campbell explores the identity of Canadians during the Great Depression through gender and family. She depicts and discusses the traditional notions of the â€Å"Bread-Winner† husband and the â€Å"Good† wife and mother; both characters that provide and sustain the families in vital ways and the reflection the trials of the era presented such â€Å"Respectable Citizens† with.The main method of asserting these notions being through her extensive use of accounts from government documents, court records, newspapers, memoirs, plays, and interviews with women and men who lived in Ontario during the 1930s. Campbell’s focus on the hardships faced during the economic crisis allows for one to neatly achieve insight into the gendered dynamics that took place within the families of Ontario’s lives. She draws less so on the notion of Canadian â€Å"Britishness† but more so on how such a foundation influenced the actions of the people in what was to be perceived as the fundamental aspects of the man and women of the house.Campbell’s focus on the family-sphere demonstrates not only aspects of class structure and gender norms but the stateâ₠¬â„¢s view on them. She reports that often mothers were the unsung heads of house that not only fed, cleaned, clothed and nurtured but took stock of every item and ensured that every penny eared or received was used to its full capacity (this aspect being the chief discussion topic in chapter one). Additionally, she presents the societal view of class standards of women as the consumers of society.Poor or low class women often lectured on the supposed simplicities of keeping house and, perhaps famously, â€Å"making do†, while the middle to high class women were reportedly encouraged to spend what money was available to them for the purpose of keeping the Canadian market going as opposed to their counterparts who praised for â€Å"making a dollar do the work of five† (as praised by the father of Mary Cleevson about his wife on page 26 of Campbell’s book). Campbell also goes into detail of the effectiveness of the various acts put in place during the 1930s to sup plement earnings and the survivability of a family.These entitlements, while for a number of men were seen as humiliating to receive as it was a show against their ability to provide , served to identify that which adult (primarily parents) were entitled too by virtue of some nature of service. The Parent’s Maintenance Act is a good example of this; a parent or set of parents were able to call upon the court and demand payment due to them from their adult children under the basis that their sons and daughters owed a debt to them simply for being their parents.There were of course, as Campbell does not fail to provide examples for, cases in which the adult children were unable to pay due to personal circumstance or out of refusal by way of seeing their parent (particular the father) as lazy—such as the mentioned case of 52 year old Harry Bartram in June of 1937 who was denied by one of his three sons the five dollar weekly payment under such a claim (as seen on page 98 of Respectable Citizens). Finally, Campbell’s demonstrates the somewhat charming penchant Canadians appear to have for complaining.Within the chapters of Respectable Citizens one is shown various instances in which wives and mothers of all sorts take the community’s moral fiber into their own hands through acts such as calling the police on those suspected of prostitution, theft and selling on the black market and sending letters to the Primers of Ontario of the time George Henry (1930-34) and Mitchell Hepburn (1934-42) of the hardships that must face. It is this activism that becomes a part of the identity that builds into eviction protests, meetings and committees and political mobilization.Lara Campbell’s book contributes to the understanding of Canadian history and identity of the affectionately named â€Å"Dirty Thirties† by taking the opportunity to look past the issues of hunger and job loss alone and onto the people more specifically. While she do es take time to emphasize the job loss and economic crisis of the decade, she applies those factors in making an effort to comprehend society’s reaction and how that reaction reflects upon gender roles and family.This analysis clearly reveals aspects of the Canadian welfare state through well-developed topics and examples, providing a comfortable read for any who should chose to read this book. The discussion of state policy, relief efforts, labour and social movements as well as they altered family dynamic of the era allows for a clear understanding on a human level. Bibliography Campbell, Lara. Respectable Citzens: Gender, Family and Unemployment in Ontario’s Great Depression. (University of Toronto Press: 2009).

Engaging Religions To Shape Worldviews Example

Engaging Religions To Shape Worldviews Example Engaging Religions To Shape Worldviews – Article Example Engaging Religions to Shape Worldviews Religion remains an integral part and a critical aspect in the lives of many today; despite the fact, no all people are religious by nature. Contrary to common opinions that religion is important only for the religious, current trends have ideally changed such a perception as it currently plays a substantive role in the shaping of worldviews. Many have believed that religion only entail matters of personal, private belief and as such, never plays any significant role in either public life or in the contemporary world. Religion has a critical role it plays in creating sustainable cultures. Based on such an approach, it is evident that climate change remains a global challenge today. Different religious groups are currently in plans of addressing such challenges, through the formation of partnerships with concerned organizations such as United Nations, where religious groups work towards greening of activities aimed towards reducing aspects such a s climate change, deforestation, and water scarcity (Gardener 23). Previous studies have revealed an increased potential in faith communities becoming potentially influential as gateways to discussions pertaining to environmental protection (Gardener 24). Such a perspective is in addition to the aspect religious gathering becoming education forums for network building, cooperation towards initiating peace and engagements in the communities. The major drivers of environmental impact such as technology and populations have ideally increased elements of consumerism. Even though religion has not taken a strong stand on matters pertaining to consumerism, which contribute significantly to environmental degradation, religion has advocated simple living and such elements that have little impact on the environmental degradation (Gardener 26). Based on the aspects addressed above, it is clear that indeed religion has played a significant role in shaping worldviews, contrary to common opinion that religion only involves matters of personal, private belief and does not play a significant role in public life or the contemporary world.Work CitedGardener Gary. State of the World. Engaging Religions to Shaping Worldviews, Transforming Cultures: From Consumerism to Sustainability. The world Watch Institute, 2010.

Into the Breach!

Into the Breach! Into the Breach! Into the Breach! By Maeve Maddox A reader experienced a moment of doubt when he came across an online essay ending with this line: So, no cry of victory yet. Rather, â€Å"Once more unto the breach, dear friends!† I forget.  Is it supposed to be breach, as in the gap in a broken wall, or breech, as in the part of the gun where you load the projectile, unless the gun is loaded down the muzzle, of course. I guess King Harrys famous speech isnt as famous as it used to be. To the reader who knows his Henry V, the second line answers the question: Once more unto the breach, dear friends, once more; Or close the wall up with our English dead. Act Three begins with Henry and his troops surging onto the stage. The men, carrying scaling ladders, are exhausted. Henry is encouraging them to make another assault on the walls of Harfleur. The â€Å"breach† is a gap in the city wall. Where Shakespeare says â€Å"unto,† we now say â€Å"into.† The two words, breach and breech, both derive from a word meaning break. The English word breeches meaning trousers derives from the plural of broc, garment for the legs and trunk. From this plural comes the word breech meaning the part of the body covered by breeches. By extension the word came to be used in other contexts. A breech birth for example, is one in which the child emerges rear-end first. (Or in some manner other than headfirst.) In gunnery the breech is 1. the hindermost part of a piece of ordnance. 2. the part of a cannon behind the bore 3. the corresponding part in a musket or rifle Breech-loading cannon were used during the Hundred Years War. One of Joan of Arcs military skills was the ability to judge their range. The breech-loading rifle came along in the nineteenth century. You can read King Henrys entire rousing speech here. Sad P.S. As an afterthought I did a search to see if anyone was writing into the breech. Oh dear. Its all over the place. Theres even a band that calls itself that. As the professor in The Lion, the Witch and the Wardrobe asks himself frequently, What do they teach in schools these days? Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Misused Words category, check our popular posts, or choose a related post below:The Royal Order of Adjectives On Behalf Of vs. In Behalf OfConversational Email

Case study on Google.com Essay Example | Topics and Well Written Essays - 2000 words

Case study on Google.com - Essay Example The company also serves corporate clients, including advertisers, content publishers and site managers with cost-effective advertising and a wide range of revenue generating search services. Google's breakthrough technology and continued innovation serve the company's mission of "organizing the world's information and making it universally accessible and useful.""( http://www.google.com.au/profile.html) As a company Google holds the reputation of the pioneer company in website maintenance, and maintains a website which is one of the most popular in demand. It serves the need of a five year old as well as fifty year old. The search engine has attracted interest of great number of internet users because of its simple design and user-friendly interface. Google has been able to achieve this by maintaining an index of more than 8 million web pages on the web. The versatility of the search engine has appeal to wide range of customers and any one with an Internet connection can use this website to search for information. Google has achieved the status of brand name search engine because of its popularity, ease of use and the wide indexing of categories. The user interface is user-friendly and has versatility and appeal to hundreds of languages worldwide. It is also a very popular advertising medium for other sources, and this is the main source of revenue. "The company generates revenue t hrough the advertising programs. The advertising program consists of advertisers advertising with Google and then Google uses its search technology selecting which web page should host the ad. Every time someone clicks the ad revenue is shared between Google and the publisher of page where the ad is being hosted." (http://www.19.5degs.com/element/19344.php) Revenue is also accumulated through Google Search Appliance, which is hardware and software solution that companies can use to implement Google search technology to their internal and external information. Google maintains a very efficient network of support in 14 countries with 25 sales offices spread out in major locations.. Apart from providing support to existing users there exists direct sales teams. These teams target advertisers with large advertising budgets and are more in a role of relationship building than one off sales. (http://www.19.5degs.com/element/19344.php) Google has been primarily recognized as company with primary interest and focus in the area of web content. Google had made attempts to diversify its umbrella with experimenting interest in other markets like radio and print publications. This is confirmed by the fact that in 2006, Google announced its first purchase of a radio advertising company "dMarc", which provides an automated system that allows companies to advertise on radio. (Levingston, 2006) Google is making strides to combine tow niche advertising media-the internet and radio. This strategic union of the two synergistic media streams combined with Google's ability to penetrate and focus on the tastes of the consumers, is an invincible attribute of the company. In the process of diversification Google has also focused on selling advertisements from his advertisers in offline newspapers and magazines. They have been filling unsold space in the newspaper that would normally have been used in for

Do Consumers Really Make Rational Decisions Essay

Do Consumers Really Make Rational Decisions - Essay Example To be able to answer the question regarding the rationality of the choices made by the consumers, it is important to explore the issues related to the decision-making process of the consumers. There are different internal and external factors that can affect the choices of the consumers. The internal factors of a consumer include factors in his or her psychological core such as motivation, ability, and opportunity; exposure, attention, and perception; knowledge and understanding; attitude formation and change, memory and retrieval. These factors comprise the core values of a consumer which can affect the decisions that he or she makes. In addition to these factors, the external aspects or the consumer’s culture also contributes to the choices made. The external parameters are composed of the consumer diversity, the social class and household influences, the psychographics or the values, personality, and lifestyles, and the social influences. Through the interaction of the internal and external factors, the decision-making process can be completed.... The problem can be equated to the need of a consumer which can only be answered by a particular product or service. This need also dictates the possible outcome of the decision-making process. The needs of a consumer can be defined by the necessities of the daily existence (Mullen and Johnson, 1990, p. 91). One paradigm that presents the basis of a consumer’s needs is the Maslow’s hierarchy of needs which defines the consumer behavior as an effect of the human needs. The said needs then are considered as â€Å"underlying factor of consumption† which are classified into physiological and psychological needs. Physiological needs are for survival thus considered basic and found at the lowest level of hierarchy. This is followed by another physiological need which is the safety needs such as shelter and insurance. The next levels consecutively comprise the psychological needs such as belongingness and love needs; need for esteem; and self-actualization needs (Jansson -Boyd, 2009, p. 119). By tapping any of the said needs different companies and business can generate profits. Although this is one of the basic factors, the consumers’ needs are only considered as one of the many factors that contribute to the complicated web of interaction to come up with the client’s choice. Actual Process of Decision-Making It is important to consider that the said needs are the stimuli that can lead to the decision of the client to buy a particular product or avail a particular service offered. Once the need of the client had been recognized, it leads to the second level of the decision-making process which is deciding whether to buy a product or not. It is important to consider that the act

Week one Discussion Assignment Example | Topics and Well Written Essays - 250 words

Week one Discussion - Assignment Example 7). Likewise, these people were revealed to be alert and interested to indulge in various activities such as: â€Å"using the Internet for shopping, keeping in touch with family members, and learning about all sorts of topics. Theyre attending college classes, taking art lessons, and scheduling trips to Prague, Alaska, and Scandinavia† (Misconceptions About Aging, 2013, par. 10). 2. Research the aging theories discussed. Which one makes the most sense to you-why? Research a study on one aspect of aging and tell the class about it-be brief and cite your source. Do you agree with the study conclusions? There were two major categories of aging theories: biological and social theories (Lecture Notes: Topic 3: Theoretical Perspectives on Aging, 2013, p. 3). One believes that biological theories make most sense because physical changes naturally occur out of biological process which could not be prevented. One modern biological theory was the programmed theory which reportedly implies that â€Å"aging follows a biological timetable, perhaps a continuation of the one that regulates childhood growth and development. This regulation would depend on changes in gene expression that affect the systems responsible for maintenance, repair and defense responses† (Jin, 2010, par. 3). As such, Jin(2010) expounded that there are three sub-categories of the programmed theory which included: (1) programmed longevity, where the life span depends on apparent switching on and off of genes; (2) endoctrine theory, where homones were noted to control aging; and (3) immunological theory, where the immune system contributes to alleged propensities to contract illnesses that eventually shortens the life span. With the extensiveness and comprehensiveness of the study, one thereby agrees with the study and the author’s

Online Marketing Essay Example for Free

Online Marketing Essay In today’s world, marketing research has begun to use the Internet and popular social networking sites such as, Facebook and Twitter, to gather personal information of all users. It’s becoming a lot easier for companies to connect directly with customers and collect individual information that goes into a computer database. This information can also be matched to other websites and share data collected during unrelated transactions. There are ethical and technical considerations that need to be addressed on how companies conduct its market research. Two major examples of ethical considerations of online marketing are privacy and confidentiality. Many online consumers try to avoid anything that will result in invading their privacy, but many companies tend to do that without the consumer’s knowledge. A company can easily have the ability to collect and store information relating to a consumer that can violate their right to privacy. The companies use this information to target certain advertising to that consumer, but the constant targeting can put a strain on the privacy of the consumer and start to result in a breach of confidentiality. Businesses are constantly sharing consumer’s information with partners or other affiliates to precisely target them with certain services or products they offer. Some companies sell the information to outside companies to make extra money that will lead to more strain on your privacy or even worse, identity theft. The most important example of technical consideration of online marketing is security. Security is the number one issue in a consumer’s mind when they need to use personal information to purchase or do anything online that requires that information. Hackers and viruses can lead to personal information on any database to be sold and used to wreak havoc on innocent consumers. Viruses can be used through E-mail or websites to hack into the businesses or consumer’s computer and track or steal sensitive information that can be given to a hacker at any time. Hackers can then sell that information to anyone or use it for their own benefit to ruin the reputation of that consumer. For example, hackers can use the personal information of the consumer to steal their identity and purchase things without the knowledge of the consumer and the consumer will be at fault for anything the hacker does. This continues to be an ongoing problem in the online world and something that businesses need to be very cautious about when dealing with personal information that was given from a consumer through trust in the company’s integrity online. As online marketing is becoming more popular daily around the world, companies need to realize the ethical and technical considerations that play a role on the abundance of consumer’s personal information they have. Businesses rely on precise online marketing to make the most profit with as little effort as possible, but they also need to focus on the consumer’s personal needs. Privacy, confidentiality, and security are the most important topics when it comes to personal information being stored and shared online. Without taking the time to address and resolve these issues, companies can scare away consumers from revealing certain information that helps their business grow and become successful. References Masters, T. (n.d.). Ethical Considerations of Marketing Research. Retrieved from http://smallbusiness.chron.com/ethical-considerations-marketing-research-43621.html. Sullivan, B. (Dec 6). Online privacy fears are real. Retrieved from http://www.nbcnews.com/id/3078835/t/online-privacy-fears-are-real/#.UZl358qE72o

B Cell Activation in HIV Infection

B Cell Activation in HIV Infection During HIV infection, B cells can be activated by HIV virions, plasmacytoid dendritic cells, infected macrophages and CD40 ligands. Mannose binding lectin (MBL), a C-type lectin, is in a complex with the MASP (MBL-associated serine proteases) enzyme and is involved in recognising and binding carbohydrates on pathogens (e.g. HIV envelope protein gp120 is highly glycosylated). When the carbohydrates are recognised, MBL activates the enzyme activity of MASP which causes the activation of the complement system by cleaving C2 and C4 complements resulting in the formation of C3 convertase. This activation and formation of C3 convertase is known as the alternative pathway of the complement system. C3 complement is cleaved by the C3 convertase enzyme and C3 fragments (C3d/C3dg, iC3b) are formed from this breakdown. These fragments are deposited onto the HIV virion surface. HIV IC (immune complexes) interact with CD21 (complement receptor) on B cells and C3 fragments acts as a mediator in the IC-CD21 interaction. CD21 is involved in the activation of B cells and a constant IC-CD21 activation could trigger the polyclonal a ctivation of B cells in HIV viremia. (1-4) Plasma dendritic cells (pDCs) express TLR9, TLR7, CD4, CCR5, CXCR4 and MCLR receptors. TLR7 receptor is stimulated by its interaction with viral ssRNA and TLR9 by its interaction with unmethylated DNA motifs of the viral genome. Stimulation of these receptors leads to the activation of intracellular pathways both of which involves the activation of the adaptor protein, MyD88. The MyD88-IRF7 pathway involves the activation of IRF7 by MyD88 which goes on to regulate the gene transcription of Type I IFN, leading to Type I IFN production by pDCs. NF-kB is also activated by MyD88 and causes the production of pro-inflammatory cytokines such as TNF-ÃŽ ± and IL-6 by upregulating their gene transcription in pDCs. IFN-ÃŽ ± (a Type l IFN) induces the activation and differentiation of B cells into plasmablasts. The presence of IL-6 causes differentiation of plasmablasts into antibody secreting plasma cells. TNF-ÃŽ ± is involved in the polyclonal activation of B cells. The production of Type I IFN upregulates the mRNA expression of two cytokines involved in stimulating B cells in pDCs. These cytokines cause the activation, proliferation and survival of B cells, immunoglobulin class- switching and are known as BAFF (B cell activating factor) and APRIL (a proliferation-inducing ligand). Both cytokines belong to the tumour necrosis factor (TNF) ligand family. BAFF interacts with B cells by binding to the BAFF receptor (BAFFR) located on the surface of B cells. Plasmacytoid dendritic cells also activate B cells through the interaction of their CD70 ligand with the CD27 receptor on B cells, causing proliferation and differentiation of memory cells into plasma cells. HIV infected macrophages, activate B cells by Nef protein indirectly when it is taken up and expressed de novo by infected macrophages. HIV Nef induces the production of ferritin through the NF-ÃŽ ºB pathway causing gene transcription and releasing ferritin from the infected macrophages. Adequate production of ferritin induces proliferation of resting B cells into antibody secreting plasma cells by upregulating the expression of B cell gene. This activation of B cells can lead to hypergammaglobulinemia the increase in the level of gamma globulins (immunoglobulins) in the blood. (1,20) Figure 1 shows adequate levels of ferritin can lead to increase in immunoglobulin (Ig) levels in the plasma (hypergammaglobulinemia). To determine whether there is a correlation between hypergammaglobulinemia (B cell dysfunction) and plasma ferritin level in HIV infection. Plasma Ig levels were compare to plasma ferritin levels of 83 infected HIV infected people. The results obtained show that there is a positive correlation between plasma ferritin levels and plasma levels of IgA, IgG and IgM in the HIV infected individuals studied. As plasma ferritin levels increased, plasma IgA, IgG and IgM levels also increased generally. (20) The outer layer (envelope) of HIV virions contains viral protein, gp120, which can directly bind to receptors on B cells. Activation of B cells by gp120 causes polyclonal immunoglobulin class switching. This occurs in the presence of BAFF which binds to its receptor on B cells, BAFFR and gp120 binds to MCLRs (mannose-binding C-type lectin receptors) on B cells. The interaction causes IgM to switch to IgG and IgA through the upregulation in the expression of the activation-induced cytidine deaminase, an enzyme involved in class-switch DNA recombination. The HIV gp120 has also been found to inhibit the production of IFN-ÃŽ ± by pDCs by affecting the activation of the TL9 pathway involved in its production. The protein, gp120 binds to CD4, CCR5, CRCR4 and MCLR receptors on pDCs and its binding to CD4 and MCLR has been found to not produce IFN-ÃŽ ± by the TLR9 pathway. This prevents the activation of B cells by the TLR9 pathway through the release of IFN-ÃŽ ±. (7,9,10,21) B cells can also be activated by the interaction between CD40 receptors on B cells and CD40 ligands on T cells in the presence of cytokines (e.g. IL-10). This interaction activates the B cells to differentiate and undergo immunoglobulin class switching by causing class-switch recombination. Class-switch recombination is induced by the activation of NF-kB transcription factor which induces the gene expression of activation-induced cytidine deaminase (AID). However, during HIV infection CD4+ T cells are targets for the HIV virus so number of CD4+ T cells are depleted suppressing this activation of B cells. (22,23) References: Moir, S., Malaspina, A., Li, Y., Chun, T., Lowe, T., Adelsberger, J., Baseler, M., Ehler, L., Liu, S., Davey Jr., R., Mican, J. and Fauci, A. (2000) ‘B Cells of HIV-1–infected Patients Bind Virions through CD21–Complement Interactions and Transmit Infectious Virus to Activated T Cells’, The Journal of Experimental Medicine, 192 (5), pp.637-645. Jakubik, J., Saifuddin, M., Takefman, D. and Spear, G. (2000) ‘Immune Complexes Containing Human Immunodeficiency Virus Type 1 Primary Isolates Bind to Lymphoid Tissue B Lymphocytes and Are Infectious for T Lymphocytes’, Journal Of Virology, 74(1), pp.552-555. Eisen, S., Dzwonek, A. and Klein, NJ. (2008) Mannose-binding lectin in HIV infection, Future Virol., 3(3), pp.225-233 Haurum , JS., Thiel, S., Jones, IM., Fischer, PB., Laursen, SB. and Jensenius, JC. (1993) ‘Complement activation upon binding of mannan-binding protein to HIV envelope glycoproteins.’, AIDS, 7(10), pp.1307-1313 Muraguchi, A., Hirano, T., Tang, B., Matsuda, T., Horii, Y, Nakajima, K. and Kishimoto, T. (1998) ‘ The Essential Role Of B Cell Stimulatory Factor 2 (Bsf-2/Il-6) For The Terminal Differentiation Of B Cells’, J Exp Med, 167, pp.332-344. Jego, G., Palucka, A., Blanck, J., Chalouni, C., Pascual, V. and Banchereau, J. (2003) ‘Plasmacytoid Dendritic Cells Induce Plasma Cell Differentiation through Type I Interferon and Interleukin 6’, Immunity, 19, pp.225-234. Chung, N., Matthews, K., Klasse, P., Sanders, R. and Moore, J. (2012) ‘HIV-1 gp120 impairs the induction of B cell responses by TLR9-activated plasmacytoid dendritic cells’, J Immunol, 189(11), pp. 5257- 5265. Shaw, J., Wang, Y., Ito, T., Arima, K. and Liu, Y. (2010) ‘Plasmacytoid dendritic cells regulate B-cell growth and differentiation via CD70.’, Blood, 115, pp.3051–3057. He, B., Qiao, X., Klasse, P., Chiu, A., Chadburn, A., Knowles, D., Moore, J. and Cerutti, A. (2006) ‘HIV-1 envelope triggers polyclonal Ig class switch recombination through a CD40-independent mechanism involving BAFF and C-type lectin receptors.’ J. Immunol, 176, pp.3931–3941. Martinelli, E., Cicala, C., Van Ryk, D., Goode, D., Macleod, K., Arthos, J. and Fauci, A. (2007) ‘HIV-1 gp120 inhibits TLR9-mediated activation and IFN-ÃŽ ± secretion in plasmacytoid dendritic cells.’ Proc Natl Acad Sci USA, 104, pp.3396–3401. Kadowaki, N., Ho, S., Antonenko, S., Malefyt, RW., Kastelein, RA., Bazan, F. and Liu, YJ. (2001) ‘Subsets of human dendritic cell precursors express different toll-like receptors and respond to different microbial antigens.’, J Exp Med, 194 (6), pp.863-870 Lund, J., Sato, A., Akira, S., Medzhitov, R. and Iwasaki, A. (2003) ‘Toll-like receptor 9-mediated recognition of Herpes simplex virus-2 by plasmacytoid dendritic cells.’, J Exp Med., 198 (3), pp. 513-520 Lund, JM., Alexopoulou, L., Sato, A., Karow, M., Adams, NC., Gale, NW., Iwasaki, A. and Flavell, RA. (2004) ‘Recognition of single-stranded RNA viruses by Toll-like receptor 7.’, Proc Natl Acad Sci USA, 101 (15), pp 5598-5603 Lambert, AA., Gilbert, C., Richard, M., Beaulieu, AD. and Tremblay, MJ. (2008) ‘The C-type lectin surface receptor DCIR acts as a new attachment factor for HIV-1 in dendritic cells and contributes to trans- and cis- infection pathways.’, Blood, 112(4), pp.1299-1307 Jego, G., Palucka, AK., Blanck, JP., Chalouni, C., Pascual, V. and Banchereau, J. (2003) ‘Plasmacytoid dendritic cells induce plasma cell differentiation through type I interferon and interleukin 6.’, Immunity, 19(2), pp.225-234 Litinskiy, MB., Nardelli, B., Hilbert, DM., He, B., Schaffer, A., Casali, P. and Cerutti, A.(2002) ‘DCs induce CD40-independent immunoglobulin class switching through BLyS and APRIL.’, Nat Immunol., 3(9), pp. 822-829 Tezuka, H., Abe, Y., Asano, J., Sato, T., Liu, J., Iwata, M. and Ohteki T. (2011) ‘Prominent role for plasmacytoid dendritic cells in mucosal T cell-independent IgA induction.’, Immunity, 34(2), pp.247-257 Dai, J., Megjugorac, NJ., Amrute, SB. and Fitzgerald-Bocarsly, P. (2004) ‘Regulation of IFN regulatory factor-7 and IFN-alpha production by enveloped virus and lipopolysaccharide in human plasmacytoid dendritic cells.’, J Immunol., 173(3), pp.1535-48 Cerutti A., Qiao, X. and H, B. (2005) ‘Plasmacytoid dendritic cells and the regulation of immunoglobulin heavy chain class switching.’, Immunol Cell Biol., 83(5), pp.554-562 Swingler, S., Zhou, J., Swingler, C., Dauphin,A., Greenough, T., Jolicoeur, P. and Stevenson, M. (2008) ‘Evidence for a pathogenic determinant in HIV-1 Nef involved in B cell dysfunction in HIV/AIDS’, Cell Host Microbe, 4(1), pp. 63-76. Geijtenbeek, TB., Kwon, DS., Torensma, R., van Vliet, SJ., van Duijnhoven, GC., Middel, J., Cornelissen, IL., Nottet, HS., KewalRamani, VN., Littman, DR., Figdor, CG. and van Kooyk ,Y. (2000) ‘DC-SIGN, a dendritic cell-specific HIV-1-binding protein that enhances trans-infection of T cells.’, Cell, 100 (5), pp.587-597. Dedeoglu, F., Horwitz, B., Chaudhuri, J., Alt, FW. and S. Geha, RS. (2004) ‘Induction of activation-induced cytidine deaminase gene expression by IL-4 and CD40 ligation is dependent on STAT6 and NFkB.’, International Immunology, 16(3), pp.395-404 Qiao, X., He, B., Chiu, A., Knowles, DM., Chadburn, A. and Cerutti, A. (2006) ‘Human immunodeficiency virus 1 Nef suppresses CD40-dependent immunoglobulin class switching in bystander B cells.’, Nature Immunology, 7, pp.302-310 JESSIE FLORENCE GHANSAH