Old Life in Hangzhuo China and the Modern Life in New York City Essay

Old Life in Hangzhuo China and the Modern Life in New York City - Essay Example Similar to the modern day New York City, Huangzhuo is one of the most important cities in China in the 13th century. Huangzhuo is the capital of the Southern Song dynasty making it a major cultural and political center. The account of Marco Polo describes this city as "magnificent" and "beyond dispute the finest and the noblest in the world" (Yule 185). Being surrounded by bodies of water, the city is surrounded by twelve thousand bridges in order to facilitate travel to and from it. This physical structure is also present in the modern day New York even though the number of bridges is far smaller. The Staten Island is connected to Brooklyn by the Verrazano-Narrows Bridge (New York City). Being the capital of a dynasty, Huangzhuo has also been a seat of entertainment which is performed in what Marco Polo describes as "a rich, beautiful and spacious edifice, furnished in such style as to seem fit for a palace of an Emperor (Yule 186)" in one of the city's island. Within this structure, important celebrations and occasions are held. In the modern day New York City, this can be likened to the Coney Island which is one of the earliest amusement ground in the US, the Madison Square Garden, and the Broadway theatre district (New York City). The economic significance of the two cities is also comparable

Banking and Finance Essay Example for Free

Banking and Finance Essay Introduction The automated teller machine (ATM) is a machine that acts as a teller in an institution by receiving and issuing money to and from the ATM account holder or user. The growth and evolution of at ATMs was not only due to, but rather as a result of general global concentration in the technological revolution. This came due to challenges of multiple bulk of daily complex information that arise from existing difficulties like; increase in competition, increase in customer’s demand for both services provision as well as efficiency , expansion due to increase in demand and all the likes just to name a few. The ATM system used by micro financial institutions today is an inherited system from banking system therefore brought in efficiency in different micro financial institutions in terms of speed, data processing and storage. Thus, it brought in enormous improvement in queuing in institutions in use of the ATMs. Despite all the merits of ATMs, customers still bring up complains on the demerits of the system such as; breakdown of ATMs, long queues at the ATM service point, retention of customers cards. In this light, this research entails to find out why all these cries after all the goods incurred in the system. 1.1 Background of the study. 1.1.1 Historical background. The history of micro financial institutions can be trace as far back as the 1880s when the theorist Lysander Spooner was writing over the benefits of from small credits to entrepreneurs and farmers as a way of getting people out of poverty. Today, the use of the expression ‘’micro financing’’ has its root in the 1970s when organisatons were sarting and shaping the modern industry.At that time,many microfinance ini tiatives introduced many new innovations into the sector.Many entreprises began experimenting with loaning to the under served people. The main reason why micro financing is been traced back to the 1970s is that, the programme could show that people can be relied on to pay their loans and that it’s possible to provide financing services to poor people through market based enterprises without subsidies.

Mexico in South Phoenix :: Arizona Mexican Culture Essays Papers

Mexico in South Phoenix â€Å"It’s like going to Mexico without ever leaving Phoenix.† This was a quote by Mr. Virgil, the Manager of the Ranch Market. A tour of the Ranch Market showed his statement to be true, hence the title of this paper. The following will discuss the Ranch Market and Mexico in South Phoenix. To begin, the tour was absolutely intriguing. The class was introduced to Mr. Virgil. Then we proceeded to get a really in-depth insight into what was up with the Ranch Market. While the Ranch Market is really just another store to purchase canned food, fruit, personal hygiene products, and even a meat department, the real attraction is the food service department. The class and I learned about the revenue intake of the entire Ranch Market; and as things go, the food service department accounted for over 40% of the income. I thought the food was awesome, as did the several hundred patrons. The food service department consists of several components. The most prosperous of the components is the Mexican food deli, followed only shortly by the bakery. The Mexican food that is prepared right in front of you consists of tacos, burritos, tostadas, quesadillas, nachos, and about any other type of Mexican food one could think of. The bakery is awesome. The prices are very appealing to the frugal, but the availability of all types of bread (donuts, to loafs, to cakes and pies) is appealing to basically everyone. However, the whole Ranch Market seemed to be focused on appealing to the Mexican culture. This type of environment reminded me of a reading that was assigned; it was titled American Apartheid, Segregation and the Making of the Underclass. This reading addressed the segregated society. A few sentences really interested me, such as â€Å"†¦extreme racial segregation did not just happen; it was manufactured by whites through a series of self-conscious actions and purposeful institutional arrangements that continue today.† This reminded me of how South Phoenix has been shunned by the Valley of the Sun and a haven for illegal immigrants who do not speak English. Another reference from American Apartheid is â€Å"Although poor black neighborhoods still contain many people who lead conventional, productive lives, their example has been overshadowed in recent years by a growing concentration of poor, welfare-dependent families that is an inevitable result of residential segregation.

Super Project

The Super Project Case Study FIN 3717 Braden Eddy, Lauren Gear and Dakota Conravey The Super Project Case Study FIN 3717 Braden Eddy, Lauren Gear and Dakota Conravey Statement of Facts General Foods is a large corporation organized by product lines. They are evaluating Super Project, the manufacture of a new powdered dessert. Crosby Sanberg, a financial analysis manager, must determine the value in accepting the proposal, along with J. C. Kresslin, the Corporate Controller. The Super Project will increase profit with a payback period of less than ten years.The proposed capital investment for the project is $200,000 ($80,000 for building modifications and $120,000 for machinery and equipment) and production would take place in an already existing building in which Jell-O is manufactured using the available capacity of a pre-existing Jell-O agglomerator. Sandberg has analyzed the different investment proposals based on three different capital allocation techniques. The three different cash flow evaluation alternatives (Incremental, Facilities-Used, and Fully Allocated) differ in the way that the cost of existing facilities and future increases in overhead are allocated.The acceptance or rejection of the project relies on the project’s costs. As Sanberg looks to compare Super Project with current profit criteria, recent discussion has brought about what the proper evaluation technique is for their cash flows; specifically, in concern to the relevancy of sunk costs. The problem for General Foods is to decide what the best method for evaluating the Super Project was since each method produced drastically different returns. Issues General Foods has quite a few factors to consider when determining relevant cash flows in their analysis of the project.Multiple factors for consideration are whether or not to account for test market expense, the allocation of overhead expense, the allocation of charges for agglomerator and capacity use, and erosion of Jell-O sales. Under the analysis of an incremental basis, management included the incremental fixed capital of $200,000, which included packaging equipment. Sanberg also advocates that Super should be charged with the â€Å"opportunity loss† of agglomerating capacity and building space that could be used for future production of Jell-O or other products.Management also analyzed the project based on the amount of facilities-used. Recognizing that Super will use half of an exisiting agglomerator and two thirds of an existing building, Sanberg added Super’s pro rata shares of these facilities to the incremental capital. Overhead costs directly related to these existing facilities were also subtracted from incremental revenue on a shared basis. Sanberg felt this analysis was a useful was of putting various projects on a common ground for purposes of relative evaluation.Lastly, management included a fully allocated basis of the project in their projections. They recognized that individu al decisions to expand inevitably add to a higher overhead base and therefore an increase to the costs and investment base were added. Overhead expenses included manufacturing costs plus selling and general and administrative costs on a per unit basis equivalent to Jell-O. Overhead capital also included a share of the distribution system assets. AnalysisUpon review of management’s case, we broke down the relevant cash flows separately according to test-market expenses, overhead expenses, erosion of Jell-O contribution margin and allocation of charges for the use of excess agglomerator capacity. The four capital budgeting techniques appropriate for review are NPV, IRR, ARR and payback period. The accounting for test-market expense yielded the following results: Exhibit 1| Net Present Value| $671. 98 | Internal Rate of Return| 24. 73%| Average Rate of Return| 216. 34%| Payback Period. | 5. 4 years| The accounting for overhead expense yielded the following results: Exhibit 2| Ne t Present Value| $704. 30| Internal Rate of Return| 28. 83%| Average Rate of Return| 207. 70%| Payback Period. | 4. 55 years| The accounting for erosion of Jell-O sales yielded the following results: Exhibit 3| Net Present Value| $182. 33| Internal Rate of Return| 14. 63%| Average Rate of Return| 125. 62%| Payback Period. | 6. 39 years| The accounting for including the excess capacity expense yields the following results: Exhibit 4| Net Present Value| $375. 5| Internal Rate of Return| 16. 11%| Average Rate of Return| 71. 55%| Payback Period. | 5. 80 years| After review of the independent costs, we found that each one produces a positive NPV, an IRR above the discount rate and a payback period within the required ten years. However, it is unrealistic to consider these on an independent basis. For our realistic case, we included overhead expenses and the excess cost of capacity for the agglomerator. We did not include the erosion of Jell-O sales and the test market expense, as this is a sunk cost.Under these circumstances we produced the following results: Exhibit 6| Net Present Value| $350. 32| Internal Rate of Return| 15. 98%| Average Rate of Return| 58. 91%| Payback Period. | 5. 74 years| In this analysis, we included the overhead expense for 1972-1977 because as the project begins to gain a foothold in the market it will acquire a larger market share and will become a larger portion of General Foods’ overall dessert sales. Also, the agglomerator and excess capacity was charged as an incremental investment, which brought the initial investment to $653,000.Since 70% of the initial $200,000 was depreciated over the 10-year period, we applied the straight-line depreciation method to compute 70% of $453,000 that added an extra $32,000 of depreciation to each year. We did not include the erosion of Jell-O sales because an external competitor could easily acquire the 20% of market share currently held by Jell-O in the future. This would take away profit that would hinder Jell-O regardless of whether it is internal or external. Since we also believe this a mature market, it is a cost that seems to be irrelevant in this analysis.We did not include the test market expense as well since this was a sunk cost. It did not seem logical to include, because it was almost double the value of the initial investment of $200,000 and roughly half of our adjusted initial investment of $653,000. Since General Foods has a limited amount of product lines in the dessert market, the test market expense should not be accounted for. Conclusion Under our assumptions, we conclude that General Foods should accept the project due to its positive NPV, IRR above discount rate and the attractive payback period within six years (exhibit 6).When compared to Crosby Sanberg’s view (exhibit 5), which resulted in a negative NPV of -$575. 32, IRR of . 28% and a payback period of just about 10 years, our assumptions lead to a more accurate portrayal of the Super Pro ject. Although we do recommend that General Foods take on the Project, they must be cognizant of increasing test expenses and the initial impact that the addition of Super will have on Jell-O sales. The benefits will be an increase in overall sales for the company, and the chance for General Foods to become a leading producer in the dessert market.

Moving to Another Country Essay

Tradition is existing knowledge. A tradition is a group of related ideas that have lasted for a long time. In some cases people have spent that time trying to improve the ideas. We’ll call that a dynamic tradition because it changes over time. In other cases, the focus has been on keeping the tradition exactly the same over time. We’ll call that a static tradition because it does not change. Although these approaches are contradictory, some traditions are mixed. Dynamic traditions are important because they contain some of our best knowledge. Today, they contain only the best ideas any participants have thought of in the whole history of the tradition. I don’t mean they are perfect, but if they missed a good idea, it was despite people’s efforts, not intentional. They do a pretty good job of gathering the best ideas, and keeping those around, and discarding ideas that are discovered to be mistaken. The reason dynamic traditions are especially valuable is the sheer amount of thought, criticism and error correction that has gone into them from many people. Just because traditions contain valuable knowledge doesn’t mean they are always right. Sometimes they aren’t. I shouldn’t defer to traditions just because a lot of smart people didn’t see any way to improve them further. I should defer if I don’t see any way to improve them further. If I make up a new idea, and I don’t see any way to improve it further (in 20 minutes of thought), then it’s not particularly reliable. I could easily have missed something. With a tradition, perhaps thousands of people put in twenty minutes of thought, and some others put in years, so even if I don’t see any way to improve things, and even if I don’t know much about the subject, it has an advantage over just making something up myself. All the knowledge in traditions can be intimidating . And no one has time to carefully and critically go through all the details of all the traditional knowledge they use. That’s OK. But one should bear in mind two things. First, if something goes wrong — if there seems to be a problem — then relying on tradition isn’t good enough. It’s not working, and you’ll need to tweak something or find another tradition. And second, a thoughtful person should critically evaluate some traditions. It’s your choice which, but everyone ought to be good at something and have the experience of trying to improve some knowledge. Everyone should put some serious thought into some area. There isn’t much point to life if I don’t seriously think about some parts of it. In the case of a disagreement, an  appeal to tradition is invalid. The tradition might be wrong and someone thinks it is. To address that disagreement, I have to consider their criticism of the tradition, any alternative ideas they have, and any arguments in favor of the traditional idea, and then try to work out what is true. Traditions containing people’s best ideas of the past won’t always be the best ideas anyone thinks of in the future. The biggest value of traditions is they can often give useful ideas that are not controversial, or starting points which partially solve problems. In a disagreement, although we can’t say, â€Å"This is true because a lot of smart people didn’t see anything wrong with it, and who are you to say they missed something?† the fact that something is a tradition is not irrelevant either. Dynamic traditions have, over the years, faced a lot of criticism. They often already include explanations of why common criticisms of the tradition are mistaken. Major traditions have existing literature that provides arguments and ideas on the subject. This literature can answer many disagreements, which are often made in ignorance. When we find something wrong with a tradition, if at all possible we should improve the tradition, not abandon it. We should seek a way to modify the tradition but also retain existing knowledge. To keep the most existing knowledge, our change should be as small as possible to solve the problem. If we were to start over from scratch, we may avoid the flaw we found, but we’re not perfect and our new ideas will contain other flaws. And new ideas won’t have the benefit of decades or centuries of people trying to find and correct flaws. We should consequently be respectful of tradition even as we find errors in it, and try to improve it with new ideas of our own. Static traditions are different. Although they’ve been around a long time, no one has been trying to find mistakes in them, so they aren’t very useful. Nor are they innocuous. Consider: why does the static tradition still exist? Why didn’t it disappear after its original advocates died? With a dynamic tradition, it’s passed on to the next generation because people find it useful, and teach it. A static tradition, too, must have some mechanism for being passed on. But it canâ€⠄¢t be that people voluntarily learn it due to its usefulness. Because it never changes, and never corrects errors, it’s not very useful. Instead, people must in some way be tricked or fooled into it, or indoctrinated, or forced, or brainwashed. Often they are pressured, and made  to feel bad, sinful or guilty if they do not follow the tradition. But controlling people’s emotions is difficult. Because people are creative and will try to defend themselves, it takes a lot of knowledge to reliably control or manipulate them. Where does that knowledge come from? Static traditions are not actually entirely static. The main ideas, doctrine or dogma is kept constant. But the way of passing it on changes. The more people try to preserve the tradition unchanged, and make sure it will last forever, the more creativity they put into mechanisms for transmitting the tradition to the next generation. All traditions face a selection effect. For a tradition to last, it has to be passed on from older people to younger people. But only so many ideas can be taught to the next generation. Children are only in school, and in their parents’ home, for so many years. The amount of ideas is large, but it’s limited. Only a certain amount of tradition can fit. Only the ones that are better at being passed on will make the cutoff. D ynamic traditions compete by being as useful as possible. Thus the selection effect pushes them to be better and better. They try to be true, and people like the truest ones so much that they teach them to children. Static traditions compete differently. They can’t compete with good ideas directly, so they use other approaches such as manipulating or controlling people. In short, in some way they disable the person’s creativity so he doesn’t realize the tradition is low on useful truth content, and doesn’t think of alternative ideas against which a static tradition can’t compete. The selection effect for static traditions makes them worse, not better. Any static tradition that fails to create a permanent blind spot in the person runs a serious risk that one day he’ll realize it’s not a great tradition and doesn’t have a lot of useful knowledge. And if he realizes that, whether he ever changes his mind or improves himself, what he won’t want to do is teach it to his kids. There will never come a time when his children have some problem or qu estion, and he thinks if he teaches them this tradition it will help them, since he knows it is not useful. Traditions are important because they contain our best knowledge collected over the years. But they can also be dangerous. Static traditions that induce blind spots in people and are useless at everything except getting themselves taught to children. It is up to us to consider which traditions are which.

Spanish Verbs Meaning to Begin

Spanish Verbs Meaning to Begin Spanish has two everyday verbs that can be used for to begin or to start: empezar and comenzar. They usually can be used interchangeably. Although empezar is more common than comenzar, comenzar doesnt come across as conspicuously formal like its English cognate, commence. Both empezar and comenzar are conjugated irregularly. Correct Way to Use Empezar and Comenzar To say to begin to do something, you can use either of the verbs followed by the preposition a and an infinitive: El web empieza a generar dinero. The website is beginning to generate money. ¿A quà © hora empezà ³ a nevar? At what time did it begin to snow?Cuando llegamos a Quito, comenzaba a llover. When we arrived at Quito, it was beginning to rain.Uruguay comienza a estudiar la produccià ³n de energà ­a nuclear. Uruguay is beginning to study the production of nuclear energy.Empiezo a pensar por ti mismo. I am beginning to think just like you.La inflacià ³n va a empezar muy pronto a bajar. Inflation is going to begin to drop very soon. Each verb can stand by itself without an object: La lluvia empieza a caer ms y ms fuerte. The rain is beginning to fall harder and harder.El mitin comenzà ³ finalmente a las 10 de la noche. The meeting finally began at 10 p.m.Bueno, pues sà ­, empezamos con esto. Good, then, lets get started with it. (Literally, with this.)La boda comenzar a las 12:30 hora local. The wedding will begin at 12:30 local time. When either verb is followed by a gerund, it often has the meaning of to begin by or to start out: Empezà ³ estudiando en el taller del escultor famoso. She started out studying in the famous sculptors studio.Comencà © trabajando 10 horas por dà ­a como limpiadora de casa. I started out working 10 hours per day as a housecleaner.Empezamos corriendo juntos el primer kilà ³metro. We begin by running the first kilometer together. Although probably not as common as in English, the two verbs can also take direct objects to indicate what is getting started: Tiene muchos consejillos para comenzar un negocio. He has many tips for starting a business.La ciudad empezà ³ la reparacià ³n de la calles en abril. The city began the street repairs in April. Other Verbs for To Begin As just shown, you often can use the verbs to refer to beginning an activity with the activity as the object of the verb. But it is also common to use the verb emprender for that purpose. Emprender is especially common when referring to the beginning of travel. No quiere emprender la tarea sin ayuda. He doesnt want to do the task without help.Dentro de unos minutos emprendo el viaje. Within a few minutes I begin the trip.Emprendieron el reto de construir un proyecto conjunto. They began the challenge of building a project together.Emprendà ­ el vuelo en direccià ³n hacia donde el sol se pone. I began the flight in the direction of the sunset. The verb originarse often translates to begin when it is used to mean to originate: El problema se originaba cuando navegaba ciertas pginas web. The problem started when I was going to certain web pages.La crisis econà ³mica mundial se originà ³ en EEUU. The world economic crisis began in the U.S. Use of Verb Tense To Indicate Beginning Often, when speaking of events in the past, the preterite tense is used in preference to the imperfect to indicate that an activity began. A form of begin isnt necessarily used in translation, however. A common example is the verb conocer, which often means to know a person. The difference between Conocà ­a a Katrina and Conocà ­ a Katrina is roughly the difference between I knew Katrina and I began to know Katrina. Typically, the second sentence would be translated as I met Katrina. Other examples: Yo tenà ­a calor. (I was warm.) Tuve calor. (I began to be warm. I got warm.)Ella sabà ­a la verdad. (She knew the truth.) Supo la verdad. (She began knowing the truth. She found out the truth.) This concept is further explained in the lesson on using the past tense with certain verbs.

SAT Subject Test Dates 2018-2019

SAT Subject Test Dates 2018-2019 SAT / ACT Prep Online Guides and Tips At PrepScholar, we pride ourselves on using the best data to keep you posted about upcoming test schedules and registration deadlines. It's essential to plan ahead and choose wisely when selecting Subject Tests and test dates. You can see the SAT test dates for previous years. Refer to this information to get a general idea of when College Board has its test dates for the SAT and how long after the test you can view your scores. In this article, I’ll give you the SAT Subject Test dates for 2018-2019 and explain what you should consider when choosing your test date and Subject Tests. Test Dates for the 2018-2019 School Year SAT Subject Tests are given on the same dates and in the same locations as the SAT, but there’s an additional test date in March for the SAT that isn’t offered for the SAT Subject Tests. Subject Test Dates The College Board lists these dates on its website, but they’re still subject to change. Not every test is offered on every date. For example, the language with listening tests are only offered in November. Subject Test Aug 25, 2018 Oct 6, 2018 Nov 3, 2018 Dec 1, 2018 May 4, 2019 Jun 1, 2019 Literature X X X X X X US History X X X X X X World History X X Mathematics Level 1 X X X X X X Mathematics Level 2 X X X X X X Biology E/M X X X X X X Chemistry X X X X X X Physics X X X X X X French X X X X X German X Spanish X X X X X Modern Hebrew X Italian X Latin X X French with Listening X German with Listening X Spanish with Listening X Chinese with Listening X Japanese with Listening X Korean with Listening X You can take chemistry on each testing date. Registration Dates The registration deadlines and score release dates are projected by PrepScholar. Test Date Normal Registration Late Registration Score Release Aug 25, 2018 Jul 27, 2018 Aug 10, 2018 Sept 13, 2018 Oct 6, 2018 Sep 7, 2018 Sep 21, 2018 Oct 25, 2018 Nov 3, 2018 Oct 5, 2018 Oct 19, 2018 Nov 22, 2018 Dec 1, 2018 Nov 2, 2018 Nov 16, 2018 Dec 20, 2018 May 4, 2019 Apr 5, 2019 Apr 19, 2019 May 23, 2019 Jun 1, 2019 May 3, 2019 May 17, 2019 Jun 20, 2019 How Accurate Are the Tables Above? The test dates are the anticipated dates provided by the College Board, and the registration and score release dates are our estimations. Even though all the dates are likely to be correct, because the test dates are provided by the College Board, those dates may be somewhat more reliable. The test dates won’t be confirmed until within a year of the test. If any of the dates change, they’ll probably be a week earlier or later than the anticipated date. You can use these dates to help determine when you'll take your SAT Subject Tests. If you know your available options, you can select the date that works best with your schedule. Also, you can factor in the specific tests you're taking and the time you need to prepare for them. The tables are pretty accurate. How to Choose Your Subject Tests? Here’s what you should consider when selecting your Subject Tests: What Do Your Colleges Require? Know the requirements of the schools you're considering applying to. Do they require Subject Tests? If so, how many and which ones? Are you applying to a school or program that requires you to take science and math? Do you have to take Math II? Are you applying to colleges that want to see your skill level in a variety of subjects? Furthermore, are you applying to test optional or flexible colleges that allow you to use Subject Tests in place of the SAT or ACT? Call the admissions office if you have any questions about a school's policies. What Are Your Best Subjects in School? Typically, you'll do the best on the tests related to your best subjects in school. If you thoroughly enjoy US History and you're excelling in your AP US History class, you'll probably do well on the US History Subject Test. Are You Fluent in Another Language? Many non-native English speakers take the Subject Test in their native tongue, even if they’re not taking a class in that language. Often, they're able to get a high score and show off their language prowess. However, make sure you review the content for the Subject Test even if you're fluent. I scored higher on my Spanish Subject Test than some of my friends who are native Spanish speakers because I was more comfortable with Spanish grammar rules and written Spanish even though they were much more adept at conversational Spanish. For more guidance and study resources, read our articles on SAT Subject Tests. How to Choose Your Test Dates Review this article on how to select SAT Subject Test dates. When picking your test date, remember that you can take one, two, or three Subject Tests on a single test date. Here are the most important factors to consider. When Your Skills Are at Their Best Generally, you want to take your Subject Test in a particular subject when you’re studying the highest level of that subject. If you're taking AP Chemistry in your junior year, you may want to take the Chemistry Subject Test in May or June of that year right after you've spent a full year studying chemistry and preparing for the AP test. When Are Your College Deadlines? For most schools, the December test of your senior year will be the last time you can take the Subject Tests, and if you're applying early, the October test may be the last possible date for you. Make sure you have enough time to retake the tests, if necessary, and know your deadlines. Check Your Personal Schedule Give yourself ample time to study, and try to avoid taking the test when you have possible conflicts. If your'e particularly preoccupied with school and extracurricular activities in a certain month, you may want to avoid taking your Subject Tests then. What's Next? Find out how to register for SAT Subject Tests and send your scores. Also, learn more about how SAT Subject Tests are scored. Finally, if you're deciding between taking Math I and Math II, check out this article. Need a little extra help prepping for your Subject Tests? We have the industry's leading SAT Subject Test prep programs (for all non-language Subject Tests). Built by Harvard grads and SAT Subject Test full or 99th %ile scorers, the program learns your strengths and weaknesses through advanced statistics, then customizes your prep program to you so that you get the most effective prep possible. Learn more about our Subject Test products below:

How to Change Your Habits and Improve Your Grades

How to Change Your Habits and Improve Your Grades Its disappointing to receive low scores on a big test or a homework assignment, but you dont need to let small setbacks get you down. There is always time to make things better. Steps to Take If It Isnt Over Yet If youve received a few low grades on assignments throughout the year and youre facing a big final, then you still have time to bring up your final grade.   Sometimes, a good grade on the final project or exam can increase your final grade dramatically. Especially if the teacher knows youre really trying. Gather all your work assignments to determine exactly how and why you earned the low grades. Identify your weak points. Did your grades suffer because of careless grammar or poor writing habits? If so, be more mindful of grammar and structure during the final.Visit the teacher and ask her to go over your assignments with you. Ask her what you could have done differently.Ask what can you do for extra credit. By trying to take charge of your destiny, you are showing responsibility. Teachers will appreciate this.Ask for advice from the teacher. Teachers can direct you to resources that are topic-specific.Put all your energy into the final test or project. Find a tutor to help you. Ask the teacher to explain the format of the test. Will it be an essay exam or a multiple choice test? Target your study accordingly.Join a study group. Discuss the final exam with other students. They may have notes that you missed or they may have better insight into the teachers preferences when it comes to test questions and answers. Improve memory skills. There are many techniques to improve your memory. Find one that is best for you and the material youre studying.Get serious. Dont be late to class. Get some sleep. Turn off the TV. Talk to your Parents If you know a bad grade is imminent, then it might be wise to talk to your parents first. Let them know that you are trying to make a change and improve your performance. Get them involved. You may want to discuss creating a homework contract with your parents. The contract should address time commitments, homework help, supplies, and other issues that affect grades. Looking Toward the Future If you have just received your end-of-year grades and youre looking forward to improving your performance next year, there are plenty of things you can do. Get organized. Keep a journal of assignments to identify strengths and weaknesses. Organize your supplies and establish a good study space.Try to use color-coded supplies to stay organized.Identify your personal learning style. This is critical to improving your study habits. Dont waste valuable study time using ineffective study methods.Talk to your counselor about your schedule or your diploma program. You may be enrolled in a program that isnt right for you. Are you taking courses that are too difficult because your diploma program requires it?Review your schedule. Cut out extracurricular activities that dont help you reach your true goals. If youre involved with that team or club just for fun- then you may need to make some tough decisions.Improve your writing skills. Students sometimes complain because they are penalized for poor writing in courses other than English. Teachers dont have much patience for this complaint! Good writing skills are critical for every class.Join a stu dy group. Be Realistic If you are stressing out about a possible B grade, you should know that perfect grades arent everything, and expecting them isnt very realistic, either. While it is true that some colleges place a lot of value in grades, it is also true that they are interested in recruiting humans, not machines.If you are hoping to get into a specific, highly competitive college and you are worried about getting a B, then you are smart enough to make yourself stand out in another way. For instance, you could use your creativity to craft an essay that stands out.Give yourself credit if youre doing your best. If you have tried everything, but you just cant become the perfect student you want to be, perhaps you should give yourself a break. Identify your own strong points and make the best of them.Dont give yourself a bad reputation. If you arent happy with a grade or a report card, you can discuss this with a teacher. However, if you make a habit out of visiting your teacher to complain, then you may be making a pest of yourself.

Exploring the major Sociological theme of Suicide Essay

Exploring the major Sociological theme of Suicide - Essay Example In the Lettres Persanes he speaks of "the misery of the human condition". Speaking of the suicide of Brutus and Cassius, this is what Montesquieu writes: In France, the end of the eighteenth century had seen the beginning of a shift from a moral discourse on suicide to a growing concern with suicide rates. By 1842, Quetelet was investigating the extent to which moral phenomena of suicide could be said to resemble physical phenomena, his answer being that large numbers served to cancel out individual peculiarities and to reveal the institutional and general features of society in the figure of the 'social man', a fictitious being conforming to the median results of statistical analysis. In France, Bertillon's statistical experimentation inspired Durkheim's later adoption of replicative analysis. By the 1850s, French social commentators linked industrialization and the expansion of urban, commercial life to the development of 'gosme' and 'odieux individualisme', both defined in terms Durkheim later applied to anomie, as consequences of moral paralysis. On one hand, pathological individualism was taken to be at the root of social disord er, apathy and exploitation; on both sides of the political spectrum, there was talk of a 'general malaise', of the possibility of social dissolution, and of a 'national decadence', one sign of which was taken to be a falling birth rate and it is interesting to note, as Lukes does, that Durkheim authored a paper on birth rates and suicide in 1888. There was a felt sense that the decline of those traditional moral controls associated with pre-revolutionary social formations had left a vacuum. If one were anticlerical, this vacuum was to be filled by a new, secular morality, answerable in the abstract to reason and in practice to a science of normalcy or health. If one were a Catholic traditionalist, it would be addressed by a revival of Christian moral education and the social authority of the Church. On the other hand, social anarchy, and political anarchism, was likened to forms of 'hysteria' arising from excessive individualism on one hand and the formation of 'crowds' on the other. The mass popularity of romantic literature was blamed for a degenerate aestheticism leading to a suicide 'mania' escorting the types designated social conditions affecting suicide rates, not motivations for individual acts. But it is worth noting that Durkheim's more specific images of the types of suicide are often couched in subjectively

Discussion Questions Essay Example | Topics and Well Written Essays - 500 words

Discussion Questions - Essay Example In this way, firms of different sizes could be compared on an equal footing. For example, COGS of firm A may be greater than that of firm B. But its sales may be higher too. Q6. The dates on financial statements are important because they indicate the period in which profits or losses accrue and cash flows occur, as well as the financial status of the company as at a date. Q7. The income statement presents the incomes or revenues and expenses or costs of the firm incurred during a period, regardless of paid or not, to arrive at the profit or loss. On the other hand, the cash flow statement of the firm presents the revenues or costs received or paid during a period, regardless of incurred or not, to arrive at the cash outflow or cash inflow. The balance sheet captures the financial snapshot of the firm as at a particular point in time. The profit or loss on the income statement enters the retained earnings account, which is under shareholder's equity in the balance sheet. The cash inflow or cash outflow from the cash flow statement is added to or subtracted from the beginning cash balance to arrive at the ending cash balance, which is under current assets in the balance sheet. Q5.

Seven Oaks Shopping Centre Essay Example | Topics and Well Written Essays - 750 words

Seven Oaks Shopping Centre - Essay Example With a number of food outlets and other service stores, the mall provides a stop point shop for all class of people. At least the mall has something to offer for the visiting customers. The available shops offer customers what they need and when they need it. It is a perfect place to relax, grab something to eat and meet for special occasions. The diverse portfolio in the mall is more than $8.7 billion of retail, industrial, office and other offices.  ¬1Located in Abbotsford, Seven oaks shopping centre neighbors a number of super built structures offering different services to the people. It borders Mill Lake Park on the south. The park is one 1.  Ross, Ian. "Housing Starts Build Banner Year under a Blue Sky."   March 1, 2005.of the attracting sites in Abbotsford. A number of people usually take time to relax in the park. Before visiting the park, at least visitors can visit the mall to buy snacks. The mill Lake Road offers a good connection to the shopping mall. The mall is al so close to the Abbotsford’s senior secondary school on Southwest and also Abbotsford Arts centre. There is also the Ravine Park that is connected to the mall by Bourquin crescent. The George Ferguson way connecting two main countries is also a plus to the mall since people travelling from the United States. The mall is also borders Real Canadian superstore, which is a source of some products being used in the mall.   Abbotsford is known for its unpredictable climatic conditions, it is however known for its cool climatic conditions.

Physiology Essay Example | Topics and Well Written Essays - 1000 words

Physiology - Essay Example While osteoblasts are bone-forming cells, osteocytes are mature bone cells and osteoclasts break down and reabsorb bone (†Bone Growth and Development†). Ossification is basically of 2 types, intramembranous and endochondral. In both these, the formation of bone tissue is similar. First, there is increase in the number of cells and collagen fibers. Then, the cells differentiate into osteoblasts. These cells form an organic matrix called the osteoid in which the bone salts are deposited. Some of these osteoblasts remain in the matrix and transform into osteocytes (Gardner, 856-862). The replacement of sheet-like connective tissue membranes with bony tissue is known as intramembranous ossification and bones formed by this method are known as intramembranous bones. Some of the flat bones of the skull and irregular bones fall into this category. These bones are initially formed as connective tissues membranes, later on the osteoblasts migrate to the membranes and deposit bony matrix around themselves and change into osteocytes. Replacement of hyaline cartilage with bony tissue is known as endochondral ossification. Most of the bones in our body are formed in this manner and hence these bones are known as endochondral bones. The bones are first formed as hyaline cartilage models as early as in the 3rd month of gestation. This is surrounded by a membrane called the perichondrium. Later, this becomes infiltrated with blood vessels and osteoblasts and then is called the periosteum (†Bone Growth and Development†). Primary center of ossification is the region in the bone in which the process of ossification starts first and this is indicated by an increase in the cells and fibers. Ossification continues from this center toward the ends of the bones. The time at which the primary center appears depends on the bone. The parietal and frontal bones, maxilla, and mandible appear during the embryonic period. In the long bones, the primary center of ossification

Journal research Essay Example | Topics and Well Written Essays - 500 words

Journal research - Essay Example The introduction gave a brief description of body mass index ( BMI) as a measure for obesity.The historical background of the research is focused on the increased cardiovascular risk for obese children. The importance of measuring BMI and its validity in establishing obesity was a good platform in establishing a good hypothesis. The study was conducted no less than one of the authors ( Pietrobeli) with another group of researchers. Studies citing complications that arose from obese children in a 40 yr follow-up study by Jacques et al in was presented. Accordingly, the study by Jacques revealed that childhood obesity did not only result to diabetes but led to increased mortality due to coronary artery disease as well. The present study hypothesized that early childhood obesity along with a sedentary lifestyle increases the risk for diseases such as type 2 diabetes and cardiovascular diseases. This translates to higher incidence of mortality when these children become adults. For the methods section, a comparative survey that compares the BMI across teens in the US was used. The cited study was done by Lissau et al published in 2003. The method engaged was a cross-comparison of incidence of obesity in teens in US against teens in Europe. The comparison resulted to the conclusion that occurrence of obesity in US teens is three times higher than European counterparts. Unfortunately, much cannot be said about statistical data since the study was just referenced in the journal Much of the given conclusions were summaries of compiled studies. In fact, the journal is more like of an informative and persuasive article that warns the public of the dangers of childhood obesity. The journal also comments on what directions , programs and policies that European Commission must do so that European teens would not experience same situation as American teens. The suggestions posed by the researchers were interventions

WORKING WITH AND LEADING PEOPLE Essay Example | Topics and Well Written Essays - 2750 words

WORKING WITH AND LEADING PEOPLE - Essay Example In that case, the retention, selection, as well as the recruitment process is imperative for every firm. In recruiting a new member, there is a need to have a different document, the firm must obey the statutory laws, and go beyond the sequential procedure of selecting (Bell 2012).The human resource department has the mandate to select the right people and prepare a document that details various rules as well as regulations. The management of the restaurant needs to prepare a document detailing various aspects such as the approval of recruitment. The concerned departments who require a new worker then send a draft, which has a description of the position and the necessary education as well as skills that are required. Subsequently, the draft is approved and sent to the HR department. The selection as well as recruitment process commences after the management gives an approval with regard to the request. The approval should have an electronic copy that has the advertisement as well as the copy of the draft. In the document, there is also the description of the position for which the restaurant needs to recruit new trainees. This is imperative for every firm since it cannot change the position after the advertisement of the post. It is also to be understood that the post needs to be approved by the management and should include the responsibility of the new staff (Dessler 2011). After the position description there is the advertising section, which needs to be approved by the director. Through the advertisement, the firm will get the right candidates and can be done using various channels such as the use of print media, open advertisement, or electronic means. The advertisement will also include announcement on the vacancy, the required competencies, and payment among others. The HR department will need to obey the legal procedures of advertisement (Bell 2012). In selecting an applicant, I would

Journal research Essay Example | Topics and Well Written Essays - 500 words

Journal research - Essay Example The introduction gave a brief description of body mass index ( BMI) as a measure for obesity.The historical background of the research is focused on the increased cardiovascular risk for obese children. The importance of measuring BMI and its validity in establishing obesity was a good platform in establishing a good hypothesis. The study was conducted no less than one of the authors ( Pietrobeli) with another group of researchers. Studies citing complications that arose from obese children in a 40 yr follow-up study by Jacques et al in was presented. Accordingly, the study by Jacques revealed that childhood obesity did not only result to diabetes but led to increased mortality due to coronary artery disease as well. The present study hypothesized that early childhood obesity along with a sedentary lifestyle increases the risk for diseases such as type 2 diabetes and cardiovascular diseases. This translates to higher incidence of mortality when these children become adults. For the methods section, a comparative survey that compares the BMI across teens in the US was used. The cited study was done by Lissau et al published in 2003. The method engaged was a cross-comparison of incidence of obesity in teens in US against teens in Europe. The comparison resulted to the conclusion that occurrence of obesity in US teens is three times higher than European counterparts. Unfortunately, much cannot be said about statistical data since the study was just referenced in the journal Much of the given conclusions were summaries of compiled studies. In fact, the journal is more like of an informative and persuasive article that warns the public of the dangers of childhood obesity. The journal also comments on what directions , programs and policies that European Commission must do so that European teens would not experience same situation as American teens. The suggestions posed by the researchers were interventions

Leadership Challenges in Organization Assignment

Leadership Challenges in Organization - Assignment Example As leadership challenges become more complex, leaders should also develop approaches to track the market requirements and evaluate the workers capacity to satisfy the market needs (Gill, 2011). Leaders’ awareness about the market needs and organizations’ capacity is of the essence because it will assist them to influence their teams in order to utilize the organizations’ capacity to satisfy the market requirements. Leaders in the 21st century have to take an active role in the overall organization activities and to act as ceremonial figures they used to be in the early time. Effective leadership is essential in all aspects of the organization and must establish a strong relationship between the workers, the organization and the market (Morse et. al., 2007). The organization leadership in the 21st century requires establishment of focused workforce, effective and well-coordinated market activities as well as ability to build personal leadership capacity to meet th e changing market needs. In the 21st century, leaders must help and encourage workers and the stakeholders to determine their interests and potential for growth. Leaders cannot force workers or stakeholders to pursue things that are outside their interests (Palestini, 2009). In the present time, workers and stakeholders in the organization have personal interests which they expect to be satisfied as they pursue organizations goals. They want to grow alongside the organization and they will be encouraged to engage in activities that have no likelihood to promote personal growth. Employees and the stakeholders at the present time have personal ambitions if they are not satisfied the success of the organization is put at stake (Gill, 2011).

Stories by Flannery OConnor Essay Example for Free

Stories by Flannery OConnor Essay Flannery OConnors two narratives, Everything That Rises Must Converge and Good Country People, are different stories presenting different characters, different plots, and different themes; however, both stories revolve around a mother and her child and their relationship. Everything That Rises Must Converge concerns Julian and his mother, and Good Country People concerns Hulga and her mother. As the two stories unfold, the similarities between Julian and Hulga, two seemingly different individuals, become apparent. The two, who appears unlike at first, turn out to have characteristics similar to one another. Both Julian and Hulga exhibit an educated and a proud character. They both use other people to validate their beliefs, and they both face a situation where they learn a lesson that they have to recognize for themselves. At the beginning of each story, OConnor presents each character as learned, conceited, and self-righteous. Julian has just graduated from college, which is a big achievement, considering that her mother did it all by herself. Julian is an aspiring writer who, for now, sells typewriters and lives with his mother. He thinks of himself as very intelligent. In fact, he often draws himself into the inner compartment of his mind . . . the only place where he [feels] free of the general idiocy of his fellows. In the same way, Hulga is a 32-year old woman who holds a Ph.D. in Philosophy and currently lives with her mother. She, like Julian, also thinks of herself as superior to others. She thinks  that if she only can, [s]he would be in a university lecturing to people who know what she [is] talking about. She also thinks to herself, [A] true genius can get an idea across even to an inferior mind. The two characters think too highly of themselves that they belittle other people, even their mothers who support them until now. In the course of each story, Julian and Hulga both use other people to prove to themselves and to others their beliefs. Julian uses black people to prove to his mother that the society has changed. He tries to make friends with  black people not because he likes them and sees them as coequals, but because he wants to irritate his mother and to show everyone that he is not narrow-minded like most white people are. Likewise, Hulga tries to seduce Manley Pointer into withdrawing his faith and into believing that there is no God. She wishes to teach him the deeper meaning of life. She imagines that she [takes] his remorse in hand and change[s] it into a deeper understanding of life. Hulga wants to convert Manley. Julian and Hulga both wish to change others into accepting what they believe are true and correct. As each story concludes, the two characters face messages whose meanings they have to make use of. Right after the confrontation of Julians mother with the black woman, Julians mother collapses unexpectedly and dies while Julian knowingly lectures her. Julian says to his mother, From now on youve got to live a new world and face a few realities for a change. Buck up, it wont kill you. Then the mother falls to the pavement. Now, the mother that Julian despised before is gone, and he is left in a world of guilt and sorrow. Similarly, Hulga loses her wooden leg over a mediocre country boy. In irritation, Hulga says to Manley, Youre a fine Christian! Youre just like them  allsay one thing and do another. Manley simply says before leaving, [Y]ou aint so smart. I been believing in nothing ever since I was born! Now, Hulga is left legless, helpless, and Godless. Both Julian and Hulga try to change other people when it is them who need to change. Julian and Hulga are both learned and proud. They both use other people for personal validation, and they both face lessons, which they have to figure out for themselves. OConnor characterizes Julian and Hulga in a way that they seem odd and far from what most people are, but as the characters evolve, they turn out to be ordinary people in all walks of life. They turn out to be where most people areliving in a delusion that their way is better than the way of the others.

Gals vs. Women :: Creative Writing Journalism Essays

Gals vs. Women This article is about gals. It's not an article about women. There are way too many books about women, and most of them are way too serious. Women itself is a serious word, not to mention womanhood and womanly. While being female is a serious activity, there is a lighter side which is rarely examined or written about. But women tend to attach too much significance to womanhood. This results in certain characteristically feminine, by which I mean over exaggerated self-important, behavioral patterns that can produce unfortunate results. These things include, but are not limited to, women being viewed as ruthless bitches who will step on anyone to get the best of a man. These things have given females a bad name. And the "Woman's Movement," which is supposed to give women more rights, seems to be densely populated with masculine looking para-military types. (These "females" require an entirely different category, but I will leave that discussion for a later time. For now I will write about those females which I believe fit into "normal parameters.") So I'm saying that there's another way to look at females: not as aggressive career hungry ego-maniacs; not as sensitive, Suzy Homemaker; but as gals. And what, exactly, do I mean by "gals"? I don't know. I haven't thought that much about it. Females whether women or gals do spend a lot of time pondering about our deepest feelings, but women think a lot about what it means to be a woman, and gals just are. But although I can't define exactly what it means to be a gal, I can describe certain gal characteristics, such as: Gals Do Not Have A Rigid And Well-Defined Code Of What It Takes To Be A Woman This is not the same as saying that gals do not consider themselves women, or do not think about being a woman, but gals do not get hung up thinking about it. Gals have never really grasped the Basic Code Of What It Takes To Be A Woman, such as matching their handbag, shoes, and belt, or only wearing white shoes between Memorial Day and Labor Day. Or is it Labor Day and Memorial Day? (A Woman, would know and have these dates marked and memorized.) Take my two dogs as examples, Blue, a neurotic dog who can only be categorized as a guy, and Katie, a gal dog.

Transitions Of Reptiles To Mammals Essays -- essays research papers

Transitions of Reptiles to Mammals A long long time ago, in a galaxy not too far away, was a little blue planet called Earth, and on this world not a single mammal lived. However a lot of time has past since then and we now have lots of furry creatures that are collectively called mammals. How did they get their? Where did they come from? These are the kinds of questions that led me to my subject of choice. I will endeavor to provide examples, using specific transitional fossils, to show that mammals have evolved from a group of reptiles and were simply not placed here by unknown forces. Before I begin, I would like to define some terms so that nobody gets left in the dust. The term transitional fossil can be used in conjunction with the term general lineage, together they help explain the how one species became another. "General lineage": This is a sequence of similar genera or families, linking an older to a very different younger group. Each step in the sequence consists of some fossils that represent certain genus or family, and the whole sequence often covers a span of tens of millions of years. A lineage like this shows obvious intermediates for every major structural change, and the fossils occur roughly (but often not exactly) in the expected order. However, usually there are still gaps between each of the groups. Sometimes the individual specimens are not thought to be directly ancestral to the next-youngest fossils (e.g. they may be "cousins"" or "uncles" rather than "parents"). However they are assumed to be closely related to the actual ancestor, since the have similar intermediate characteristics. Where Does It All Begin ? Mammals were derived during the Triassic Period ((from 245 to 208 million years ago) It began with relatively warm and wet conditions, but as it progressed conditions became increasingly hot and dry.) from members of the reptilian order Therapsida. The therapsids, members of the subclass Synapsida (sometimes called the mammal-like reptiles),generally were unimpressive in relation to other reptiles of their time. Synapsids were present in the Carboniferous Period (about 280 to 345 million years ago) and are one of the earliest known reptilian groups. Although therapsids were primarily p... ...ng the origin of major new adaptive types. To simplify definitions and to allow the strict delimitation of the Mammalia, some authors have suggested basing the boundary on a single character, the articulation of the jaw between the dentary and squamosal bones and the attendent movement of accessory jaw bones to the middle ear as auditory ossicles. The use of a single character allows the placement in a logical classification of numerous fossil species, other mammalian. characters of which, such as the degree of endothermy and nursing of young and the condition of the internal organs, probably never will be evaluated. It must be recognized, however, that if the advanced therapsids were alive today, taxonomists would be hard-put to decide which to place in the Reptilia and which in the Mammalia. References Carroll, R. 1988. Vertebrate Paleontology and Evolution. W.H. Freeman and Co., New York Gingerich, P.D. 1977. Patterns of Evolution in the Mammalian Fossil Record. Elsevier Scientific Pub. Co. Gingerich, P.D. 1985. Species in the Fossil Record: Concepts, Trends, and Transitions. Paleobiology. Rowe, T. 1988. Definition, Diagnosis, and Origin of Mammalia. J. Vert. Paleontology.

Performance Appraisal Essay

Performance appraisal is a universal phenomenon with the organization is making judgement about one is working with and about oneself. It serves as a basic element of effective work performance. Performance appraisal is essential for the effective management and evaluation of staff. It aims to improve the organizational performance as well as individual development. Performance is an employee’s accomplishment of assigned work as specified in the critical and as measured against standards of the employee’s position. The term â€Å"Performance Appraisal† is concerned with the process of valuing person’s worth to an organisation with a view to increasing it. EXERCISE : STEP 1: Divide participant in group of 3. STEP 2 : Let them to select upon themselves a manager, an employee and an observer. STEP 3 : Assign each group with one scenario to begin with. STEP 4 : Each scenario will take approximately 5 min to play. STEP 5 : manager and employee has to take part in play and observer has to write down the Observations. STEP 6 : Observer has to focus on following questions – †¢ What worked? †¢ What didn’t? †¢ How did the â€Å"manager† shows caring during the play? †¢ How did the â€Å"employee† react to a caring approach? †¢ Was the manager candid with the employee? How? †¢ How did the employee react to the candid approach? †¢ Did a collaborative effort surface? Describe it? Different scenarios are : Scenario 1 : Was it that important? Manager : You’ve missed the three of those meetings during the last two quarter. Employee : But I thought they were optional. I’ve been missing meetings all week†¦. I never realise it as a problem Manager : Well I am telling you now your attendance is mandatory. But that’s not the only reason you scored low in this category†¦.. You also been consistently coming to work late. Employee : But I am always here by 8:15. The switchboard doesn’t even open until 8:30. Manager : ( Ad lib from here, and see where it takes you! ) Employee : ( Ad lib from here, and see where it takes you! ) Scenario 2 : Are you done yet? Manager : I know you are working hard on this report I assigned, but you keep getting them to me late. I can’t prepare next year’s budget unless I know exactly how much money each contract brought in this year. So you are going to have to get them into me by tomorrow afternoon, Okay? Employee : Sorry, sometime I have trouble prioritizing†¦.. I didn’t realised they were that important. Manager : Well, they are important, and I need your report on time from now on. Okay? Employee : ( Ad lib from here, and see where it takes you! ) Manager : ( Ad lib from here, and see where it takes you! ) In that manner we can assign different scenario to different groups. STEP 7 : Now the manager and employee are going to provide with a paper and they were asked to write down the behaviour of one other in role play. ( In this way manager appraise their employees performance and employee appraise their managers performance. ) STEP 8 : Finally observer has to share his observation with others.

Atticus Finch Character From To Kill a Mockingbird Essay

In the final courtroom scene in the movie â€Å"To Kill a Mockingbird†, Atticus Finch is given the case of a lifetime when he gets the chance to defend Tom Robinson, a black man who is being falsely accused of raping a white woman in the 1930’s when inequality and racism was very prevalent during that time in the deep South. The odds he faces are terrible because he is defending an African American which during that time would always be an uphill battle and very few had the audacity to even try. Atticus Finch is delivering a speech trying to encourage and persuade a court who is biased against Robinson to believe that the crime he had been charged with never even took place. Despite the fact that Tom is soon going to be found guilty for a crime he didn’t do, the speech appealed to all of the audience and jury in the courtroom logically, emotionally, and in justice using the appeals of Pathos, Logos, and Ethos (To Kill a Mockingbird). Atticus Finch’s speech displays pathos by provoking the thoughts and emotion of the jury and audience through persuasive and appealing statements. He stated many important points all while his voice was full of trust; trust in the jury to make the right decision, which had the courtroom stirring and this created favorable emotions. Finch creates a feeling of guilt when he states, â€Å"I have nothing but pity in my heart for the chief witness for the state, but my pity does not extend so far as to her putting a man’s life at stake, which she has done in an effort to get rid of her own guilt† (To Kill a Mockingbird). Another emotion brought into play by Atticus was empathy when he says, â€Å"There is not a person in this courtroom who has never told a lie, who has never looked upon a women without desire† (To Kill a Mockingbird). With the use of empathy he establishes a relationship between Tom and the audience because they were able to put themselves in T om Robinsons’ shoes and feel the same pain. Atticus’s use of the rhetorical appeal pathos was very powerful in creating feelings within the courtroom in an attempt to get the audience to believe in what he is saying and ultimately see past their prejudice ways. This piece of rhetoric also gives a logical appeal through logos which makes the speech a solid logical argument; facts are used in Atticus Finchs’ closing argument to portray a more logical appeal. He starts his speech out by saying there isn’t enough medical evidence to prove that the crime even took place. Finch has a very solid point and statement when he proceeds to say, â€Å"Now there is circumstantial evidence to indicate that Mayella Ewell was beaten savagely by someone who led, almost exclusively, with his left hand. And Tom Robinson now sits before you, having taken â€Å"The Oath† with his only good hand he possesses, his right† (To Kill a Mockingbird). Atticus Finch backs this up in the first sentence of his speech when he says, â€Å"It has relied instead upon the testimony of two witnesses† (To Kill a Mockingbird), stating that this is the only solid evidence that they have in place. Atticus Finch does a good job of presenting a logic al argument while backing up everything he says. Atticus Finch also displays ethos in his speech through his tone and style which also has a major impact on his audience. Atticus Finch having lived in this culture during this time of segregation also gives him a sense of what Tom Robinson and his audience was feeling. By using ethos, he makes a statement that shows how society looks at a white women kissing a colored man, â€Å"Now what did she do? She tempted a Negro. She was white and she tempted a Negro. She did something that in our society is unspeakable† (To Kill a Mockingbird). All throughout the speech Atticus sounds very professional and knowledgeable on the information he is talking about, he seems as if he invested much of his time to that one case and is determined to free Tom Robinson. During the court case, Atticus Finch states, â€Å"Now, gentlemen, in this country, the courts are the great levelers. In our courts, all men are created equal† (To Kill a Mockingbird). Atticus uses this very statement in order to elevate the importance of maintaining equality and unbiased opinions to the jury and show his understanding of the court system. Atticus Finch, by using ethos; has proven himself to his audience. I feel that if I was in the audience during the time that Atticus Finch was giving his closing argument I would be utterly and totally convinced because in the speech he uses the rhetorical appeals pathos, logos, and ethos very well which made his speech fit and connect together. Atticus knew just exactly how to appeal to his audience through logic, emotion, and in justice so that an innocent black man isn’t falsely accused. Works Cited To Kill a Mockingbird. Dir. Robert Mulligan. Perf. Gregory Peck, Mary Bedham, and Phillip Alford. Universal Pictures, 1962. Film.

Case Briefing and Problem Solving

Issue Spotters Delta Tools, Inc. , markets a product that under some circumstances is capable of seriously injuring consumers. Does Delta owe an ethical duty to remove this product from the market, even if the injuries result only from misuse? Why or why not? I think Delta Tools, Inc. doesn't owe an ethical duty to remove the product from the market unless the company doesn't warn its customers of the danger they can meet upon misuse of the product. If the company takes all the measures to warn their customers of the danger of the product once it's misused, customers have knowledge of the risk and voluntarily assume it.For example, the use of any antibiotics with the alcohol can lead to many harmful processes and activities. Nevertheless, pharmaceutical companies don't remove these products from the market because of that. It's a customer's responsibility to use the product properly. Case problems 8–1 Business Ethics. Jason Trevor owns a commercial bakery in Blakely, Georgia, that produces a variety of goods sold in grocery stores. Trevor is required by law to perform internal tests on food produced at his plant to check for contamination.Three times in 2008, the tests of food products that contained peanut butter were positive for salmonella contamination. Trevor was not required to report the results to U. S. Food and Drug Administration officials, however, so he did not. Instead, Trevor instructed his employees to simply repeat the tests until the outcome was negative. Therefore, the products that had originally tested positive for salmonella were eventually shipped out to retailers. Five people who ate Trevor's baked goods in 2008 became seriously ill, and one person died from salmonella.Even though Trevor's conduct was legal, was it unethical for him to sell goods that had once tested positive for salmonella? If Trevor had followed the six basic guidelines for making ethical business decisions, would he still have sold the contaminated goods? Why or why not? The issue in this case problem is whether Trevor's actions were unethical. In my opinion it was unethical for Jason Trevor to sell goods that had once tested positive for salmonella. Salmonella is a bacterium that can cause many illnesses.Two basic ethical approaches can be applied to this case. Firstly, Trevor should've thought about his customers from the religious position. He could've foreseen that products positive tested on salmonella would harm people inevitably. Secondly, he had to consider the outcome of this sale. He didn't think about the consequences that can follow. He acted negligent by letting his employees ship the products to the retailers. If Trevor followed the six basic guidelines for making ethical business decisions he would not have sold the contaminated goods to the public.Having five people seriously ill and one person died because of the contaminated products harms the name of the brand associated with this incident. Thus, company loses its custom ers and, as a result, part of the revenues. I think Trevor also should feel guilty about what happened to those people meaning that on the Conscience step, which is the 4th guideline, he would've reconsidered his actions and probably changed his mind. I guess he would've not been happy to be interviewed about the actions he was about to take.And the next step, which is Promises to his customers, would've made him doubt his decisions because of the trust of the customers that he held in his hands. And I am sure Trevor's hero would not have acted the way that can harm people. Thus, Trevor would not have sold the contaminated goods had he followed the basic guidelines for making ethical business decisions. Brody v. Transitional Hospitals Corporation United States Court of Appeals, Ninth Circuit, 280 F. 3d 997 (9th Cir. 2002). http://caselaw. findlaw. com/us-9th-circuit/1019105. html FACTS Jules Brody and Joyce T.Crawford filed a class action complaint against Transitional Hospitals Cor poration (THC) and its officers on August 28, 1997 accusing THC of unlawful insider trading after THC bought 800,000 shares of its stock between February 26 and February 28 without first disclosing that Vencor and other parties had expressed interest in THC. In addition, Brody and Crawford claimed that THC, in its March 19 and April 24 press releases, materially misled them about THC's intention to sell the company. The district court granted the defendant's motion to dismiss the claims. The plaintiffs appealed to the US Court of Appeal, Ninth Circuit.ISSUE Are Brody and Crawford the proper plaintiffs to sue THC for damages for violation of the statute and rule? regarding the insider trading? DECISION No. US Court of Appeal, Ninth circuit, affirmed the district court's decision to dismiss Brody and Crawford's complaint for failure to state a claim upon which relief can be granted. REASON The Court noted that plaintiffs did not meet a contemporaneous trading requirement, a judicially -created standing requirement, which specified in Section 14(e) and Rule 14e-3 that the plaintiffs must have traded in a company's stock at about the same time as the alleged insider.In addition, the Court decided that the plaintiffs' complaint must specify the reason or reasons why the statements made by THC in its press releases were misleading. Brody and Crawford argued that in order for statement not to be misleading, â€Å"once disclosure is made, there is a duty to make it complete and accurate†, for which the Court found no support in the case law. The case law? only prohibits misleading and untrue statements, not statements that are incomplete. FOOTNOTES: ? Sections 10(b), 14(e), and 20(a) of the Exchange Act, 15 U. S. C.  §Ã‚ § 78j (b), 78n (e), and 78t (a), and Rules 10b-5 and 14e 3, 17 C.F. R.  §Ã‚ § 240. 10b-5 and 240. 14e-3, promulgated thereunder by the Securities Exchange Commission (â€Å"SEC†) ? Rule 10b-5 and Section 14(e) Full case: BRODY v. TRAN SITIONAL HOSPITALS CORPORATION Jules BRODY; Joyce T. Crawford, Plaintiffs-Appellants, v. TRANSITIONAL HOSPITALS CORPORATION; Wendy L. Simpson; Richard L. Conte, Defendants-Appellees. No.? 99-15672. Argued and Submitted July 11, 2001. — February 07, 2002 Before: HALL, WARDLAW and BERZON, Circuit Judges. Jeffrey S. Abraham, New York, NY, for the plaintiffs-appellants. Mark R. McDonald, Morrison & Foerster, Los Angeles, CA, for the defendants-appellees.In this case we address several securities fraud issues, centering on whether a plaintiff must have traded at about the same time as the insider it allege violated securities laws. ? Jules Brody and Joyce T. Crawford brought suit against Transitional Hospital Corporation (â€Å"THC† or â€Å"the company†) and its officers claiming violations of the Securities and Exchange Act of 1934 (â€Å"Exchange Act†) and state law because the defendants both traded in reliance on inside information and released misleading public information. ? The district court granted the defendant's motion to dismiss for failure to state a claim. Brody and Crawford now appeal the district court's order on several grounds. BACKGROUND In determining whether the complaint states a claim upon which relief could be granted, we assume the facts alleged in the complaint to be true. ?Ronconi v. Larkin, 253 F. 3d 423, 427 (9th Cir. 2001). ? The facts alleged in the complaint are as follows: THC was a Nevada corporation that delivered long-term acute care services through hospitals and satellite facilities across the United States. ? In August 1996, the company announced its plan to buy back from time to time on the open market up to $25 million in company stock. Two months later, THC expanded the repurchase plan to $75 million. On February 24, 1997, Vencor, Inc. submitted to THC's board of directors a written offer to acquire the company for $11. 50 per share. ? THC did not disclose this offer publicly. ? Between February 26 and February 28, THC purchased 800,000 shares of its own stock at an average price of $9. 25 per share. ? This $7. 4 million buy-back was in addition to another $21. 1 million that THC had spent purchasing its stock in the three month period that ended on February 28, 1997. The plaintiffs do not allege that the total repurchase exceeded $75 million. THC issued a press release on March 19, 1997, detailing the progress and extent of its stock repurchase program. ? The press release did not mention Vencor or any other party's interest in acquiring THC. The plaintiffs argue that because of this omission, the March press release was misleading. On April 1, 1997, Vencor increased its offer to purchase THC to $13 per share. ? In the next few weeks, THC also received offers from two other competing bidders. ? On April 24, after receiving all hree offers, THC issued another press release, stating that the company had â€Å"received expressions of interest from certain parties who have i ndicated an interest in acquiring† it. ? The same document also stated that THC had hired â€Å"financial advisers to advise the company in connection with a possible sale. † ? The plaintiffs argue that this press release was also misleading; because it did not state that substantial due diligence had already taken place, that THC had received competing offers exceeding $13 per share, or that a THC board meeting would take place two days later to consider these offers.At the board meeting, the THC board voted to negotiate a merger agreement with Select Medical Corporation (â€Å"Select†). ? On May 4, THC publicly announced that it and Select had entered into a definitive merger agreement and that Select would purchase THC at $14. 55 per share. ? Vencor thereupon threatened a hostile takeover. ? To fend off that maneuver, THC ultimately agreed, on June 12, to a takeover by Vencor rather than Select, at $16 per share. Brody and Crawford sold shares at times that sa ndwich the April 24 press release. ? Two days before that press release was issued, Crawford sold 500 shares at $8. 75 per share. ? Brody sold 3,000 shares of THC stock at $10. 50 per share on April 24, just after the press release was made public. ? The plaintiffs argue that had they not been misled by THC, they would have held onto their shares, and benefitted from their subsequent increase in value. Brody and Crawford filed a class action complaint against THC and its officers on August 28, 1997. ? In addition to alleging violations of Nevada state law, Brody and Crawford alleged violations of Sections 10(b), 14(e), and 20(a) of the Exchange Act, 15 U. S. C.  §Ã‚ §? 78j(b), 78n(e), and 78t(a), and Rules 10b-5 and 14e 3, 17 C.F. R.  §Ã‚ §? 240. 10b-5 and 240. 14e-3, promulgated thereunder by the Securities Exchange Commission (â€Å"SEC†). ? These claims focus on two aspects of THC's course of action: Brody and Crawford accuse the company of illegal insider trading beca use THC repurchased 800,000 shares of its stock between February 26 and February 28 without first disclosing that Vencor and other parties had expressed interest in THC. In addition, Brody and Crawford claim that THC, in its March 19 and April 24 press releases, materially misled them about THC's progress toward its eventual merger.The district court dismissed all of Brody and Crawford's claims. ? In so doing, the district court held that Brody and Crawford are not proper parties to assert any insider trading claims, as Brody and Crawford did not trade contemporaneously with THC. In addition, the district court decided that the plaintiffs failed to state a claim under Rule 10b-5 or any other law based on materially misleading information, as the press releases were not misleading under the applicable standards. The plaintiffs appeal these aspects of the district court's dismissal. We review de novo the district court's dismissal for failure to state a claim pursuant to Federal Rule of Procedure Rule 12(b)(6). ?Zimmerman v. City of Oakland, 255 F. 3d 734, 737 (9th Cir. 2001). DISCUSSION A.? Insider Trading As they pertain to insider trading, Section 10(b), Rule 10b-5, Section 14(e) and Rule 14e-3 make it illegal in some circumstances for those possessing inside information about a company to trade in that company's securities unless they first disclose the information. See, e. g. , United States v. Smith, 155 F. 3d 1051, 1063-64 (9th Cir. 998). ? This type of prohibition is known as an â€Å"abstain or disclose† rule, because it requires insiders either to abstain from trading or to disclose the inside information that they possess. The district court dismissed the insider trading claims, holding that the named plaintiffs could not assert them because they did not trade contemporaneously with THC. On appeal, Brody and Crawford argue that nothing in the applicable securities laws requires investors to have traded contemporaneously with insiders in order t o maintain a suit for insider trading. In addition, they argue that even if such a requirement exists, they in fact did trade contemporaneously with THC. 1.? Section 10(b) and Rule 10b-5 Neither section 10(b)1 nor Rule 10b-52 contain an express right of action for private parties. ? The Supreme Court has held, however, that proper plaintiffs may sue for damages for violation of the statute and rule. ? See Superintendent of Ins. v. Bankers Life and Cas. Co. , 404 U. S. 6, 13 n. 9, 92 S. Ct. 165, 30 L. Ed. 2d 128 (1971). Because neither the statute nor the rule contains an express right of action, they also do not delineate who is a proper plaintiff. ? In the absence of explicit Congressional guidance, courts have developed various â€Å"standing† limitations, primarily on policy bases. 3 For example, in Blue Chip Stamps v. Manor Drug Stores, 421 U. S. 723, 95 S. Ct. 1917, 44 L. Ed. 2d 539 (1975), the Supreme Court held that to bring an insider trading claim under Rule 10b-5, a plaintiff must have traded in the same stock or other securities as the insider trader. The contemporaneous trading requirement, at issue in this case, is another judicially-created standing requirement, specifying that to bring an insider trading claim, the plaintiff must have traded in a company's stock at about the same time as the alleged insider. ?In Neubronner v. Milken, 6 F. 3d 666, 669 (9th Cir. 1993), the Ninth Circuit adopted a contemporaneous trading requirement for Section 10(b) and Rule 10b-5 actions. ? See also In re Worlds of Wonder Sec. Litig. , 35 F. 3d 1407, 1427 (9th Cir. 1994). Neubronner explained that two reasons animate this rule: First, â€Å"noncontemporaneous traders do not require the protection of the ‘disclose or abstain’ rule because they do not suffer the disadvantage of trading with someone who has superior access to information. † ? 6 F. 3d at 669-70 (quoting Wilson v. Comtech Telecommunications Corp. , 648 F. 2d 88, 94 95 (2d Ci r. 1981)). ? Second, the contemporaneous trading requirement puts reasonable limits on Section 10(b) and Rule 10b-5's reach; without such a limitation, an insider defendant could be liable to a very large number of parties. Id. at 670. Brody and Crawford offer two reasons why the contemporaneous trading rule adopted in Neubronner should not here apply. ? First, they argue that the rule does not make sense, as a matter of statutory interpretation. ? In other words, they request that we declare that Neubronner's interpretation of Section 10(b) and Rule 10b-5 was incorrect. ? Although the decision in Neubronner is not beyond debate, we do not consider the question further, as a Ninth Circuit panel may not overrule a prior Ninth Circuit decision. ?Hart v. Massanari, 266 F. 3d 1155, 1171 (9th Cir. 2001).Brody and Crawford attempt to avoid this precedential barrier by claiming that Neubronner's implementation of the contemporaneous rule was dictum, and therefore not binding on us. ? It wa s not. ?Neubronner explicitly described its ruling regarding the contemporaneous trading requirement as a â€Å"holding. † ? 6 F. 3d at 670. ? In addition, the determination was a necessary predicate for the case's ultimate conclusion that contemporaneous trading must be pleaded with particularity. ? Id. at 673. Brody and Crawford's second submission in avoidance of Neubronner is that United States v. O'Hagan, 521 U. S. 642, 117 S. Ct. 2199, 138 L.Ed. 2d 724 (1997), overruled Neubronner. ? That assertion is simply wrong. ? O'Hagan, which was a criminal case, addressed neither the contemporaneous trading requirement in private actions nor any other standing rule. ? Instead, by approving of an expansive concept of who qualifies as an insider under Section 10(b), the Supreme Court in O'Hagan clarified that more defendants may be liable under Section 10(b) than some courts have previously thought. ? Id. at 650, 117 S. Ct. 2199. ? In so doing, the Supreme Court did not alter pre-e xisting notions concerning whom insiders harm when they trade based on privileged information. Brody and Crawford next argue that even if the Section 10(b) and Rule 10b-5 contemporaneous trading requirements remain, the court should define contemporaneous trades as trades that take place within six months of one another. ? Under this definition, Brody and Crawford would have standing, as they sold their stock just under two months after they allege THC bought the large block of stock in February. [3]? In Neubronner, this court did not decide the length of the contemporaneous trading period for insider trading violations under Section 10(b) and Rule 10b-5, 6 F. d at 670, nor has this court decided the question since. ? Because the two-month time period presented by the facts of this case exceeds any possible delineation of a contemporaneous trading period, it is not necessary in this case either to define the exact contours of the period. ? We simply note that a contemporaneous tradi ng period of two months would gut the contemporaneous trading rule's premise-that there is a need to filter out plaintiffs who could not possibly have traded with the insider, given the manner in which public trades are transacted. 2.?Section 14(e) and Rule 14e-3 Brody and Crawford also argue that the district court erred in dismissing their claims under Section 14(e)4 and Rule 14e-35 by holding that insider trading actions brought under Section 14(e) and Rule 14e-3 must also conform to a contemporaneous trading requirement. ? In making this argument, the plaintiffs urge that we hold for them on two matters of first impression: (1) whether a private right of action exists under Rule 14e-3; and (2) if a private right of action does exist, whether it contains a contemporaneous standing requirement. We can assume, without deciding, that a private right of action exists under Rule 14e-3, for we see no reason why the same contemporaneous trading rule that applies under Rule 10b-5 would n ot apply in such an action. ?As noted, this court has definitively adopted a contemporaneous trading requirement under Rule 10b-5. ? Although Rule 14e-3 differs in some respects from Rule 10b-5, (and was adopted in order to plug some holes the SEC perceived in Rule 10b-5),6 its core, like the core of Rule 10b-5, is an â€Å"abstain or disclose† requirement. And, as is true of the â€Å"abstain or disclose† requirement of Rule 10b-5, the similar requirement of Rule 14e-3 is designed to prevent the disadvantage that inheres in trading with an insider with superior access to information. ?45 Fed. Reg. 60411-12 (1980). ? So we would have to have some excellent reason to adopt a different standing rule under Rule 14e 3 from the one we use under Rule 10b-5. ? We are convinced that there is no basis for drawing such a distinction. The best candidate appellants have advanced as a basis for differentiating the standing requirement under the two Rules is Plaine v. McCabe, 797 F. d 713 (9th Cir. 1986). ?Plaine held that a plaintiff suing under Section 14(e) need not have traded at all, let alone contemporaneously. ? Id. at 718. The fulcrum of Plaine was a distinction suggested by Piper v. Chris-Craft Indus. , Inc. , 430 U. S. 1, 38-39, 97 S. Ct. 926, 51 L. Ed. 2d 124 (1977), between the types of shareholder protections contained in Sections 10(b) and 14(e): Piper noted that while Section 10(b) was enacted to protect only individuals who actually traded in stocks, Section 14(e) can be understood as protecting not only those who buy or sell stocks but also shareholders who decide not to trade. 430 U. S. at 38-39, 97 S. Ct. 926. ? Because Rule 14e-3 was promulgated under Section 14(e), the argument that a plaintiff who alleges insider trading under Section 14(e) or Rule 14e-3 need not worry about the contemporaneous trading requirement-because he need not have traded at all-has some initial plausibility. On a closer examination, however, Plaine does not speak to the issue at hand. Rather, Plaine focused only on non-insider trading claims brought under Section 14(e), and did not consider the standing requirements for an insider trading claim brought under Rule 14e-3. Section 14(e) broadly prohibits â€Å"fraudulent, deceptive, or manipulative acts or practices, in connection with any tender offer;† it does not contain any specific reference to insider trading. ? Rule 14e-3, on the other hand, focuses on one type of behavior, insider trading, whose prohibition is thought to prevent fraudulent, deceptive, or manipulative acts. ? See O'Hagan, 521 U. S. at 672-73, 117 S. Ct. 2199. ? In accordance with its specific, prophylactic focus, Rule 14e-3 applies to a different set of behaviors than does Section 14(e): Section 14(e) centers on the actual tender offer, whereas Rule 14e-3 regulates illegal insider trading that takes place while a tender offer is under consideration. ? As appellants' brief states, â€Å"[a]ll the elements of a Sec tion 14(e)/Rule 14e-3 insider trading violation are supplied by the language of Rule 14e-3. A comparison of the facts in Plaine with the facts in this case illustrates the difference between the Section 14(e) claim considered in Plaine and the Rule 14e-3 claim considered here. ? Plaine held shares in a company subject to a tender offer. ? She complained that false information in proxy materials had induced other shareholders to tender their shares. ? Because so many other shareholders tendered their shares, the merger went through at a price Plaine viewed as inadequate. Although Plaine did not tender her shares, the court ruled that she alleged injury occurring as a result of fraudulent activity in connection with a tender offer and had standing to assert her claim. ?797 F. 2d at 717. ? Plaine did not, however, allege insider trading, and therefore could not have made out a claim under Rule 14e-3. Brody and Crawford, on the other hand, did allege insider trading but did not allege t hat THC manipulated the tender offer process through the use of false information or by any other means. ? As such, the facts in the current case present a very different situation than that presented in Plaine. The circumstances do, however, bear a much closer resemblance to those in Neubronner, a Rule 10b-5 case centering around accusations of insider trading in violation of an abstain-or-disclose requirement. ? See Neubronner, 6 F. 3d at 667. Despite the similarities of the issues here and in Neubronner and between Rules 10b-5 and 14e-3, as applied to insider trading allegations, Brody and Crawford emphasize the differences between the Rules. ? Unlike Rule 10b-5, Rule 14e-3 does not require proof that a person traded on information obtained in violation of a duty owed to the source of the inside information. Instead, Rule 14e-3(a) creates a duty for a person with inside information to abstain or disclose â€Å"without regard to whether the trader owes a pre-existing fiduciary du ty to respect the confidentiality of the information. † ? O'Hagan, 521 U. S. at 669, 117 S. Ct. 2199 (quoting United States v. Chestman, 947 F. 2d 551, 557 (2d Cir. 1991) (en banc)). ? Although Rule 14e-3 thus expands the notion of who is an insider, it does not follow that the Rule also expands the class of shareholders who may complain when an insider trades without disclosing insider information. As a result, the fact that Rule 10b-5 and Rule 14e-3 are not identical does not lead to the conclusion that one has a contemporaneous trading requirement and the other does not. More importantly, perhaps, in this case, the allegation is that THC traded in its own stock on the basis of inside information. ? Such allegations would state a â€Å"†¦Ã¢â‚¬Ëœtraditional’ or ‘classical’ theory of insider trading liability [under] Rule 10b-5 based on ‘a relationship of trust and confidence between the shareholders of a corporation and those insiders who have obtained information by reason of their position with that corporation. †¦Ã¢â‚¬  ? O'Hagan, 521 U. S. at 651-652, 117 S. Ct. 2199 (quoting Chiarella, 445 U. S. at 228, 100 S. Ct. 1108). ? As such, this case is one that could be-and indeed, was-brought under both Rule 10b-5 and Rule 14e-3, and as to which any differences between the two rules regarding the necessary relationship between the insider and the source of information is not relevant. Brody and Crawford note another reason that, they argue, suggests an expansive reading of Rule 14e-3 is appropriate. In O'Hagan, the Supreme Court ruled that the SEC is permitted to promulgate rules under Section 14(e), such as Rule 14e-3, that prohibit acts not themselves fraudulent under the common law if the rules are reasonably designed to prevent acts that are. ?521 U. S. at 671-73, 117 S. Ct. 2199. ? This authority derives from the prophylactic rule-making power granted to the SEC by Section 14(e), a power that has no parallel in S ection 10(b). ?Id.That the SEC had more power to protect investors when it promulgated Rule 14e-3 than it did when it promulgated Rule 10b-5 does not mean, however, that the SEC exercised that power so as to protect noncontemporaneous traders under Rule 14e-3. ? And, in fact, what evidence there is demonstrates that the SEC did not intend to protect investors who could not have possibly traded with the insiders. In O'Hagan, the Supreme Court quoted at length from and afforded deference to the SEC's explanation of why it promulgated Rule 14e-3. Part of the Federal Register excerpt quoted in O'Hagan stated: The Commission has previously expressed and continues to have serious concerns about trading by persons in possession of material, nonpublic information relating to a tender offer. ? This practice results in unfair disparities in market information and market disruption. ? Security holders who purchase from or sell to such persons are effectively denied the benefits of disclosure a nd the substantive protections of the [legislation that includes Section 14(e)]. 21 U. S. at 674, 117 S. Ct. 2199 (quoting 45 Fed. Reg. 60412 (1980)). This quotation evinces a particular concern for those who â€Å"purchase from or sell to† insiders, and suggests that these shareholders, and not others who trade later, are the intended beneficiaries of Rule 14e-3. ? The contemporaneous trading requirement, designed to limit the class of potential plaintiffs to only those who could have possibly traded with the insider, is therefore precisely congruent with the SEC's expressed purpose in promulgating Rule 14e-3.In sum, Rule 10b-5 and Rule 14e-3 contain similar insider trading prohibitions, triggered by similar concerns. ? While Rule 14e-3 focuses on the tender offer context, the background history and language of Rule 14e-3 indicate that the Rule does not alter the premise that a shareholder must have traded with an insider or have traded at about the same time as an insider t o be harmed by the insider's trading. ? We conclude that there is no principled distinction between Rules 10b-5 and 14e-3 as regards the need for a contemporaneous trading allegation.We therefore extend the contemporaneous trading requirement to insider trading actions brought under Section 14(e) and Rule 14e-3 actions. ? Because Brody and Crawford traded nearly two months after they allege THC traded, they did not trade contemporaneously with THC. The district court was correct in dismissing their Rule 14e-3 insider trading claims. B.? Misrepresentation We next consider a different set of concerns addressed by the securities laws: Rule 10b-5 and Section 14(e)'s explicit prohibition against the making of untrue or misleading statements. The plaintiffs do not maintain that either press release issued by THC was untrue. ? They do argue, though, that THC violated the prohibitions against making misleading statements when it issued the two press releases here at issue. ? In order to sur vive a motion to dismiss under the heightened pleading standards of the Private Securities Litigation Reform Act (â€Å"PSLRA†), the plaintiffs' complaint must specify the reason or reasons why the statements made by THC were misleading. ?15 U. S. C.  §? 78u-4(b) (1); see also Ronconi, 253 F. 3d at 429.As an initial matter, Brody and Crawford correctly assert that a statement that is literally true can be misleading and thus actionable under the securities laws. ? See In re GlenFed Sec. Litig. , 42 F. 3d 1541, 1551 (9th Cir. 1994). ? But they err when they argue that in order for a statement not to be misleading, â€Å"once a disclosure is made, there is a duty to make it complete and accurate. † This proposition has no support in the case law. ?Rule 10b-5 and Section 14(e) in terms prohibit only misleading and untrue statements, not statements that are incomplete.Similarly, the primary case upon which Brody and Crawford rely for their innovative completeness rule su pports only a rule requiring that parties not mislead. ? Virginia Bankshares, Inc. v. Sandberg, 501 U. S. 1083, 1098 n. 7, 111 S. Ct. 2749, 115 L. Ed. 2d 929 (1991). ? Often, a statement will not mislead even if it is incomplete or does not include all relevant facts. 8 ? Further, a completeness rule such as Brody and Crawford suggest could implicate nearly all public statements potentially affecting securities sales or tender offers. No matter how detailed and accurate disclosure statements are, there are likely to be additional details that could have been disclosed but were not. ? To be actionable under the securities laws, an omission must be misleading; in other words it must affirmatively create an impression of a state of affairs that differs in a material way from the one that actually exists. ? See McCormick v. The Fund American Cos. , 26 F. 3d 869, 880 (9th Cir. 1994).We conclude that neither Rule 10b-5 nor Section 14(e) contains a freestanding completeness requirement; th e requirement is that any public statements companies make that could affect security sales or tender offers not be misleading or untrue. ? Thus, in order to survive a motion to dismiss under the heightened pleading standards of the Private Securities Litigation Reform Act (â€Å"PSLRA†), the plaintiffs' complaint must specify the reason or reasons why the statements made by THC were misleading or untrue, not simply why the statements were incomplete. 15 U. S. C.  §? 78u-4(b) (1); see also Ronconi, 253 F. 3d at 429. ?Brody and Crawford's allegations do not comport with this requirement. ? They allege, first, that the press release issued on March 19 was misleading because it provided information about THC's stock repurchase program but did not contain information regarding THC's possible takeover. ? Although Brody and Crawford specify what information THC omitted, they do not indicate why the statement THC made was misleading. ? If the press elease had affirmatively intimat ed that no merger was imminent, it may well have been misleading. ? The actual press release, however, neither stated nor implied anything regarding a merger. ?Brody and Crawford also claim that THC's second press release, issued on April 24, was misleading. ? Again, the plaintiffs do not argue that the press release was untrue. ? Instead, they argue that it was misleading because it stated generally that THC had received â€Å"expressions of interest† from potential acquirers, when in fact it had received actual proposals from three different parties. Importantly, the complaint does not provide an explanation as to why this general statement was misleading, nor is it self-evident that it was. A proposal is certainly an â€Å"expression of interest. † ? Moreover, the press release did not simply state that there had been vague â€Å"expressions of interest;† it went on to state that the â€Å"expressions† were â€Å"from certain parties who have indicate d an interest in acquiring either the entire company or in acquiring the company, with the company's shareholders retaining their pro rata interests in Behavioral Healthcare Corporation [a THC subsidiary]. ? This specificity concerning the nature of the parties' proposals certainly suggests that something more than preliminary inquiries had taken place. Further, the press release additionally stated that the â€Å"Board of Directors has engaged financial advisors to advise the company in connection with a possible sale. † ? This additional information again suggested proposals that were concrete enough to be taken seriously. ? And the reference to multiple parties contained in the press release suggests an ongoing auction for THC was taking place with at least two participants.In short, the press release did not give the impression that THC had not received actual proposals from three parties or otherwise mislead readers about the stage of the negotiations. ? Instead, althoug h the press release did not provide all the information that THC possessed about its possible sale, the information THC did provide-and the reasonable inferences one could draw from that information-were entirely consistent with the more detailed explanation of the merger process that Brody and Crawford argue the press release should have included. Put another way, Brody, if he read the press release, would have been on notice, before he sold his shares, of the distinct possibility that the value of the shares would increase in the near future because of a takeover contest. 9 [11] Because Brody and Crawford have not alleged facts indicating that THC's April 24 press release was misleading, the district court properly dismissed that aspect of the plaintiffs' complaint. CONCLUSION Brody and Crawford have not met the contemporaneous trading requirements necessary to have standing in the insider trading claims they assert. Additionally, they have failed properly to allege misrepresentat ion against THC. As a result, we affirm the district court's decision to dismiss Brody and Crawford's complaint for failure to state a claim upon which relief could be granted. AFFIRMED FOOTNOTES 1. ?Section 10, in relevant part, states: It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce or of the mails, or of any facility of any national securities exchange-?..... b)? To use or employ, in connection with the purchase or sale of any security registered on a national securities exchange or any security not so registered, or any securities-based swap agreement (as defined in section 206B of the Gramm-Leach-Bliley Act), any manipulative or deceptive device or contrivance in contravention of such rules and regulations as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors. 2. Rule 10b-5 states: It shall be unlawful for any person, directly or indirec tly, by the use of any means or instrumentality of interstate commerce, or of the mails or of any facility of any national securities exchange,(a)? To employ any device, scheme, or artifice to defraud,(b)? To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or(c)?To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person, in connection with the purchase or sale of any security. 3. ?These â€Å"standing† limitations are not, of course of the constitutional variety, grounded in Article III of the Constitution, but simply delineate the scope of the implied cause of action. 4. ?Section 14(e) states: It shall be unlawful for any person to make any untrue statement of a material fact or omit to tate any material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or to engage in any fraudulent, deceptive, or manipulative acts or practices, in connection with any tender offer or request or invitation for tenders, or any solicitation of security holders in opposition to or in favor of any such offer, request, or invitation. ? The Commission shall, for the purposes of this subsection, by rules and regulations define, and prescribe means reasonably designed to prevent, such acts and practices as are fraudulent, deceptive, or manipulative. . ?Rule 14e-3(a) states:(a)? If any person has taken a substantial step or steps to commence, or has commenced, a tender offer (the â€Å"offering person†), it shall constitute a fraudulent, deceptive or manipulative act or practice within the meaning of section 14(e) of the Act for any other person who is in possession of material information relating to such tender offer which information he knows or has reason to know is non public and which he knows or has reason to know has been acquired directly or indirectly from:(1)? The offering person,(2)? The issuer of the securities sought or to be sought by such tender offer, or(3)?Any officer, director, partner or employee or any other person acting on behalf of the offering person or such issuer, to purchase or sell or cause to be purchased or sold any of such securities or any securities convertible into or exchangeable for any such securities or any option or right to obtain or to dispose of any of the foregoing securities, unless within a reasonable time prior to any purchase or sale such information and its source are publicly disclosed by press release or otherwise. 6. ?Chiarella v. United States, 445 U. S. 222, 100 S. Ct. 1108, 63 L. Ed. d 348 (1980), considered, but did not decide, the viability of a misappropriation theory of liability under Rule 10b-5. ?445 U. S. at 235-37, 100 S. Ct. 1108. ?(A misappropriation theory extends liability to some parti es who trade in a company's securities on the basis of confidential information but who have no special relationship with the company's shareholders. ) Following Chiarella, the SEC promulgated Rule 14e-3, which clearly creates liability for insiders who trade in connection with a tender offer and do not disclose the inside information, regardless of their relationship to the shareholders or the source of the information. Then in 1997, the Supreme Court decided O'Hagan, answering the question left open by Chiarella and deciding that Section 10(b) and Rule 10b-5 do create liability under a misappropriation theory. ?521 U. S. at 650, 117 S. Ct. 2199. ? The upshot is that Rules 10b-5 and 14e-3 largely overlap with regard to the scope of insider trader liability, although they differ in some respects not here pertinent. ? See p. 1004, infra. 7. As we discuss below, in O'Hagan the Supreme Court approved Rule 14e-3 as a prophylactic rule designed to prevent core violations of Section 14(e) . ? See p. 1004, infra. 8. ?For example, if a company reports that its sales have risen from one year to the next, that statement is not misleading even though it does not include a detailed breakdown of the company's region by region or month by month sales. 9. ?We note that Crawford sold his shares before the April 24 press release, so he could not have been influenced in his trading by the release. BERZON, Circuit Judge.