Marketing Strategy The Heart Of Marketing Mix - 990 Words

Individual Assignment (Marketing) Introduction Product strategy lead an integral role in a firm in the area of decision making. According to Kotler (1991), product strategy is the heart of marketing mix. Adopted a suitable product strategy is imperative for a firm as it cause a direct impact on the satisfaction of the customers. The backpack presented focuses on the function for sports consumers’ needs. This report is to figure out the best comprehensive strategy to fulfil consumers’ needs and simultaneously lower the expenses to maximise the profit. Therefore, several strategies which are differentiate strategy and quality strategy are discussed by analysis their advantages and disadvantages. Alternative strategies 1. Branding strategy Branding is the way that conveys the message of confidence, quality and reliability to their target market. Branding strategy is altered to differentiate the product from other competitors. The main purposes are product identification, repeat sales and new product sales. The first purpose is to develop a brand name with high brand equity that familiar and easy to indicates. Secondly, repeat sales depend on the development of customers’ brand loyalty to purchase the product again. The third purpose is to facilitate new product sales when introducing a new product to gain more attention and acceptance. 1.1 Advantages of branding strategy Branding may create the perception of a marketing message virtually instantaneously. A trusted brand hasShow MoreRelatedDetermining The Final Marketing Mix1299 Words   |  6 Pages3. The final part of the assessment involves determining the final marketing mix in relation to the new marketing opportunity. As part of finalizing your marketing mix, answer the following questions: What environmental factors could have an impact on the selected marketing mix e.g. economic conditions, the political or legal environment, etc? 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In order to appreciate the differences in international advert ising from theRead MoreMarketing, Management And Finance1176 Words   |  5 Pages In the very complicated world of business there are three main things you need to focus on, Marketing, Management and Finance. Now to get more in depth on marketing. Marketing is a group of activities designed to expedite transactions by creating, distributing, pricing, and promoting goods, services, and ideas to create exchanges that satisfy individual and organizational goals. Marketing ensures that the products consumers want to buy are available at a price they are willing to pay and that theRead MoreBusinesses Are Profit Seeking Entities Essay933 Words   |  4 Pagesachieve these objectives, businesses have to satisfy the consumers’ needs. Marketing helps to realise this through marketing activities. By helping to sell, marketing activities contribute to the creation of wealth. According to the CIM (Chartered Institute of Marketing) â€Å"Marketing is the management process responsible for identifying, anticipating and satisfying consumers’ requirements profitably.† In other words, marketing helps businesses to put a product on the market at the right place, at theRead MoreSocial Marketing1446 Words   |  6 Pagestermed social marketing. Rather than dictating the way that information is to be conveyed from the top-down, public health professionals are learning to listen to the needs and desires of the target audience themselves, and building the program from there. This focus on the consumer involves in-depth research and constant re-evaluation of every aspect of the program. In fact, research and evaluation together form the very cornerstone of the social marketing process. Social marketing was born as

Literary Examples Of Didactic Literature - 1194 Words

Didactic literature is not always written alike, it has been and is written to teach children morals, politeness, how to be obedient and responsible and to teach children how they should conform to religious and cultural expectations. Authors use different didactic approaches to convey their desired lesson or persuasion. Examples of didactic readings from our class lectures are The Purple Jar by Maria Edgeworth which uses didacticism to teach that things are not always what they appear and the differences between need and want. In contrast, the story of The Good Little Boy by Mark Twain, uses poking fun at the didactic message of how a good boy is to behave to teach the lesson. Lastly, in the writings of James Janeaway’s A Token for†¦show more content†¦Rosamond is very disappointed and her mother reminds her that her of her input on Rosamond’s purchase that she did tell her to examine the beautiful purple jar before making her decision. Rosamond’s mother tells her â€Å"But didn’t I tell you that you had not examined it, and that perhaps you would be disappointed?† With this the author is teaching the didactic lesson that things are not always as they seem and the reader should always closely examine their decisions. Rosamond ends up with stones in her shoes causing her pain and eventually not being able to attend an event with her father due to her appearance. In this the author is showing the poor decision Rosamond made and the consequences of that decision. Rosamond confides in her mother that she made a poor decision and she would like new shoes now. Rosamond’s mother responds to her request with â€Å"No, Rosamond, you must abide by your own choice; and now the best thing you can possibly do is bear your disappointment with good humor.† The Purple Jar teaches the difference of need and want, that evaluation of the decision should be thorough as things are not always as they appear and th at there are consequences for every decision the readers make. In The Story of The Good Little Boy by Mark Twain, Twain takes a contrasting approach to didactic literature where he tells a story of Jacob Blivens who isShow MoreRelatedLiterature Review : The Great Thing About It Essay1525 Words   |  7 Pagesworld as we know it is fascinating, multifaceted, and cultured because of the literary aura that has been present throughout time. Just like the people that fill our world, some literature has been hurtful, some is beneficial to certain groups and cultures, and some is for pure entertainment. However, the great thing about it is that literature has the ability to connect any form of art through the past and present. Literature has no age and therefore can speak to generations and help enlighten futureRead MoreWhat Are The Literary Elements Used In Alices Adventures In Wonderland1110 Words   |  5 PagesAlice meets; for example, The Caterpillar is extremely wise and provides A lice with knowledge – while he is not extremely kind, he helped Alice by giving her the one tool needed to get through Wonderland; information. Furthermore, Alice meets the Chesire Cat, The Queen of Hearts, and The Hatter. Alice goes on many adventures in Wonderland which will be dissected later. Throughout the story, there are many literary elements however, Alices Adventures in Wonderland is a great example of a subversiveRead MoreSongs of Innocence and Songs of Experience by William Blake Essay example1126 Words   |  5 Pageshis time, is today thought to be an important and seminal figure in the literature of the Romantic period. Being such a figure he has no doubt helped to influence many great thinkers throughout history, one of whom I believe is Carroll. There are many instances throughout Carroll’s story where comparable concepts of innocence and adulthood are evident. Through its themes of romanticism, Carroll crafts a story that is anti-didactic by its very nature. Before defending such claims, it’s necessary to expandRead MoreEssay Modernism versus Modernismo1057 Words   |  5 Pages and the literary world, as well as the rest of the Western world, was shaken to its foundation (Harmon 298). Faith in modern Western civilization had been shaken, and disillusionment with modern society was widespread. The authors of the time who went on to form the Modernist movement, did not feel that the literary styles in use up to that point were adequate means of expressing the chaos which they were now witnesses to. They felt that a new period of history required a new literary medium toRead MoreThe Major Works of Thomas Carlyle Essay1582 Words   |  7 Pages The literature of Victorian England is infused with the scientific as well as the humanitarian spirit, the romantic as well as the didactic note. It was essentially an Age of Prose- the direct influence of the growth in science and the questioning spirit -with great progress in critical pr ose writing. The inconsistent features of the early Victorian Britain were clearly reflected in the pamphlets, essays, lectures, and books of Carlyle, the greatest figure in the general prose literature of hisRead MoreAnalysis Of Edgar Allen Poe s Influence On American Literature878 Words   |  4 PagesWhen thinking of American literature, it’s difficult to pinpoint an author who absolutely hits the nail on the head about what exactly defines American literature and what it means. The definition is also liable to change depending on the person’s depiction of each story that is written. You simply cannot wrap it up into one sentence and call it a concrete definition; there is too much diversity and complexity within its significance. There are also numerous centuries with different eras that allRead MoreDark Romanticism By Edgar Allen Poe1625 Words   |  7 PagesOne of the biggest literary of all times was known as dark romanticism. This kind of literature comes fro m the darkness inside of a person. Many people who like this style are know to be obsessed with gothic nature. Dark Romanticism is also know to come from darkness in the human soul, original sin, and a dark outlook on society. Dark Romanticism is the complete opposite of romanticism. According to what is dark romanticism â€Å" Dark Romanticism is. A sort of genre threat combines traditional love objectsRead MoreAchievements and Weaknesses of the Middle Kingdom and Its Downfall1316 Words   |  6 PagesC. to 1780 B.C.,[2] it was during the Twelfth Dynasty that Egyptians opened a wide trade amongst other countries, improved agricultural systems, fortified and expanded Egyptian borders with a strong military reputation, and explore the arts and literature to a depth which Egyptians had not previously. The Middle Kingdom has little weaknesses, but these did not prevent its gradual downfall. For Ancient Egypt, a significant advantage of the Middle Kingdom was its trade with other countries. In PalestineRead MoreConventions of Nursery Rhymes1167 Words   |  5 Pagesmetrical rhythms, rhyme schemes and repetition of words or sounds. In the poems Young Night-Thought and Where Go the Boats?, Robert Louis Stevenson follows the conventional form of nursery rhymes by using repetition and rhyme schemes to ensure the didactic message is absorbed. Repetition and rhyme scheme go hand in hand when present in nursery rhymes. In Young Night-Thought, Stevenson uses repetition of both sounds and of words as a technique to help with the understanding of basic language. The repetitionRead MoreThe Thousand and One Nights Essay931 Words   |  4 Pages from the proud to the humble, from the gruesome to the gleeful, the tales thread the whole scope of human experience into one long narrative. Some stories are stretched out and form a sort of mini-series. The Voyages of Sinbad the Sailor, for example, are told in seven installments. Others are short anecdotes, barely one page long. The stories in The Thousand and One Nights originated in a wide geographical area. Although most relate to medieval Arabic culture and civilization, many stories are

First Act of Death of a Salesman Essay Example For Students

First Act of Death of a Salesman Essay How and what do we learn about Willys Character and Beliefs from the First Act of Death of a Salesman?  In Act one of the play Miller begins with a dialogue between the main character Willy and his wife Linda. Willy is a travelling salesman and the reader learns that he is having trouble with his mind as it drifts from the past (memory) to the present (reality). Throughout the first act Miller begins to reveal Willys character and beliefs. The reader learns that Willy is an unsuccessful salesman; he believes that the key to success Is not what you know but who you know. From the opening scene Miller presents the reader with Willys first problem, we are told that while Willy was driving and admiring the scenery his car veered off the side of the road. Linda thinks the problem is with the car, however, Willy disagrees he says I absolutely forgot I was driving .I have such thoughts, I have such strange thoughts. This shows that Willy himself was abnormal. During Willys first flash back when Biff and Happy were children, we learn about Willys character with his eldest son, Biff. We find out that Biff is Willys favourite son as he is a star athlete, popular with the girls and well liked. Being well liked is an important part of Willys character. He believes that being liked, leads to success. Although Willy encourages success, he fails to provide his boys with morality. This can be seen when Biff steals a football from the school and Willy says Sure, hes gotta practise with a regulation ball, doesnt he? Coachll probably congratulate you on your initiative! Willy encourages his boys to steal building supplies from a building site so that he could build a new stoop and doesnt seem to care if they get caught. He even brags about what they steal, You shoulda seen the lumber they brought home last week. At least a dozen six-by-tens worth all kinds a money. He is proud of their theft. This encourages their deviant behaviour. It becomes apparent within Act 1, that Willys character is both immoral and dishonest. Dishonesty is common throughout the Death of a Salesman. Willy lies to Biff, Happy and Linda. The dishonesty begins at the start of the play when Willy tells Linda the reason he came home was because he couldnt drive any more. However, we later find out that the truth is because he almost ran over a child in Yonkers and it scared him. Willy also lies to his boys about having coffee with the Mayor of Providence and he claims, I can park my car in any street in New England and the cops protect it like their own. But we later find out that Willys lies cover up his lack of confidence. He later admits to Linda that people in New England appear to laugh at him. Finally, Willy lies about the amount he is selling. One minute he states his is making $1,200 and then the next he admits the truth, that he only made $120. The reason why Willy is dishonest to his boys and Linda is because he wants to impress them and not appear as a failure to them. Lying is his method of hiding what he sees as his inadequacies.  Willys immorality is evident in the disclosure by Miller of his mistress

Why Limits Are Imposed on Criminal Laws free essay sample

The founding of criminal law on the principle of rule of law means that the power of government is limited. Unlike royalty in the Middle Ages, which had limitless absolute power, governments are limited in the behavior that can be declared criminal and in the punishments that can be applied for violations of criminal laws. Seven benchmarks are used to assess the legality of criminal laws: * Principle of legality * Ex post facto laws * Due process * Right to privacy Void for over breadth * Cruel and unusual punishment Principle of legality refers to a principle that a person may not be prosecuted under a criminal law that has not been previously published. Before a man can be punished as a criminal under the law, his case must be plainly and unmistakably’ within the provisions of some statute. Ex post facto is a Latin term meaning from a thing done afterward. Ex post facto often refers to a law that applies retroactively, thereby criminalizing conduct that was legal when origi nally performed. We will write a custom essay sample on Why Limits Are Imposed on Criminal Laws or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The U. S. Constitution prohibits ex post facto laws. However, the Supreme Court has held that that the prohibition of retroactive laws applies only to criminal, not civil, laws. A sentencing law violates the ex post facto prohibition if it operates both retrospectively and to the potential disadvantage of the defendant. This is not limited to substantive changes in the content and criteria of legal rules. Restrictions on the extent of favorable discretion that a court can exercise are within the ex post facto prohibition, too. The ex post facto clause generally prohibits states from enacting any law that â€Å"changes The punishment, and inflicts a greater punishment than the law annexed to the crime, when it was committed. † For example, sex offender registration laws have been held not to violate the ex post facto clause on the basis that they are not intended as punishment, but as a deterrent against future offenses. A due process model is type of justice system which is based on the principle that a citizen has some absolute rights and cannot be deprived of life, liberty, or property without appropriate legal procedures and safeguards. Due process involves both procedural and substantive aspects. Procedural due process requires fairness in the methods used to deprive a person of life, liberty or property, while substantive due process requires valid governmental justification for taking a persons life liberty or property. Due process requirements apply to both criminal and civil law. Due process generally requires fairness in government proceedings. A person is entitled to notice and opportunity to be heard at a hearing when they have life, liberty. r property at stake. Laws should be applied to persons equally, without discrimination on prohibited grounds, such as gender, nationality, handicap, or age. In criminal cases, fair procedures help to ensure that an accused person will not be subjected to cruel and unusual punishment, which occurs when an innocent person is wrongly convicted. Due process requirements apply to such government proceedings as trials, parole hearings, and administrative hearings involving be nefits, among others. Void for Overbreadth are laws that go too far, that is, in an attempt to prevent a specific conduct, the law not only makes that conduct illegal but it also prohibits other behaviors that are legally protected. Void- for- overbradth laws frequently are connected with free speech and expressive conduct. Cases challenged for overbreadth that have made their way to the U. S. Supreme Court involve laws prohibiting activities such as public protest, nude dancing, panhandling, erotic art, and flag burning. Cruel and unusual punishment is prohibited by the U. S. Constitution as well as some state constitutions. The U. S. Constitutions Eighth Amendment states: Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted. â€Å" The defendant has the burden of proving that his punishment is greater than that imposed for more serious offenses in the state and that similar offenses in other states do not carry punishments as severe. Critics of the death penalty argue that it constitutes cruel and unusual punishment. The issue of cruel and unusual punishment often arises in claims of prisoner mistreatment by officials.

Pathophysiology of HELLP Syndrome

Pathophysiology of HELLP Syndrome Free Online Research Papers A maternity unit is generally filled with happy moments; however, when an obstetrical emergency walks through the door, those times can be hectic and chaotic. All persons involved need to be part of a delicate team who work together in order for the woman and her child to receive the best care and to ensure the most optimum outcome as possible. The preceding case study will show how to effectively manage HELLP syndrome, the acronym for hemolysis, elevated liver enzymes and low platelet count. N.N. is a 26-year old, gravida 2, para 1 at 37 weeks gestation per last menstrual period and early ultrasound. She presented to the labor and delivery unit with a direct statement of â€Å"I had HELLP syndrome with my last pregnancy and I think I have it again.† Her vital signs were: temperature 99.4 F, pulse was 126, respirations 26 and blood pressure was 156/93. Her weight is 185 pounds with a prepregnancy weight noted to be 167 pounds. This patient was placed on external fetal monitoring. The fetal heart rate was noted to be 145 beats per minute with moderate variability and shown to have a reactive strip. There were appropriate accelerations noted and no decelerations. Uterine contractions were shown to be irregular, 3-9 minutes apart lasting 40-60 seconds in duration. The uterine contractions palpated mild. Reflexes were tested and were abnormal at 3+ with clonus, and +2 pitting edema was noted in lower extremities. A cervical exam revealed a soft, thick closed cervix. An IV was started and lactated ringers was hung and infusing at 150 ml per hour. Labs were drawn for CBC, ABO RH and type and screen, comprehensive profile, PT, PTT, and a urinalysis. An ultrasound was ordered to rule out a hematoma on her liver and to check for a placental previa or abruption as well as to check for fetal well being. Her abdomen was soft, but tender to touch with pain in her upper right quadrant. She denied leaking of amniotic fluid and tested negative for nitrazine and ferning. She complained of a headache that she states she has had for two days. Her liver enzymes were elevated with an AST of 906 and ALT of 1042 and hemolysis of LDH at 1123. Her platelets were at 43,000. The urinalysis showed a trace amount of protein as well as ketones and bilirubin. The rest of the urinalysis was within normal limits. The ultrasound was negative for a liver hematoma. It also showed an active, apparent well fetus. She presented with 3+ pitting edema in her lower extremities. The PT, PTT and fibrinogen were within normal limits. The physician on call was immediately called and was on his way in. Because this patient had had HELLP syndrome in the past, it was likely she had it again. There is up to a 25% chance that a woman who has HELLP in previous pregnancies, she will have it again in subsequent pregnancies (Hagl-Fenton, 2008, p. 23.) Women who have had pregnancies complicated with preeclampsia have a 2-12 percent chance of developing HELLP in their pregnancy (Lealbe, Niebyt, Simpson, 2002, p. 956.) Many women who come into a labor and delivery unit are misdiagnosed because the symptoms mimic preeclampsia. The platelet count is one of the key indicators that it is more than preeclampsia, (O’Hara Padden, 1999, p. 829) as well as an increased bilirubin (Lealbe et al., p. 956.) There is not a definitive pathogenesis of HELLP syndrome. The discoveries of this multisystem disease are characterized by â€Å"abnormal vascular tone, vasospasm and coagulation defects† (O’Hara Padden, 1999, p. 830.) HELLP appears to be the last indicator of some attack that leads to microvascular endothelial impairment and â€Å"intravascular platelet activation† (O’Hara Padden, p. 830.) With the activation of the platelets, serotonin and thromboxane A are released, thus resulting in platelet agglutination and aggregation and then continued damage of the epithelium (O’Hara Padden, p. 830.) This can only be corrected by the delivery of the baby, if the gestation is greater than 32 weeks (O’Hara Padden, p. 32.) If the woman presents to a labor and delivery unit and is less than 32 weeks in gestation, medicinal therapeutics are first tried to help keep the patient pregnant as long as safe for her and her baby. Betamethasone 12mg IM is given twice in 24 hours to help mature the lungs of the premature infant. Giving Decadron, 10 mg IV every twelve hours, has been shown to improve many of the laboratory irregularities identified with HELLP syndrome (O’Hara Padden, 1999, p. 33.) Magnesium Sulfate, 4-6 gram bolus, intravenously, should be administered over a 20-30 minute time frame. A 2 gram maintenance dose of magnesium should be continued after the bolus is given. This can help lower the elevated blood pressure of the patient. A magnesium flow sheet should always be used to monitor for signs of magnesium toxicity. Reflexes should be tested each hour to assess for slow, sluggish or hyper reflexes. Visual disturbances, headaches and urinary output should also be assessed each hour. Platelet activation is believed to participate to the pathogenesis of preeclampsia and HELLP syndrome, which results in hemodynamic changes, vasoconstriction and endothelial injury (Sheu, Shen, Lin, Tzeng, 2002, p. 132.) Formation of Thromboxane A in platelets generally rises during pregnancy (Sheu et al., p. 133) and it has also shown that it is exacerbated when combined with a decrease in prostacyclin (Sheu et al., p. 133.) The hemolysis in HELLP syndrome is microangiopathic hemolytic anemia (O’Hara Padden, 1999, p. 830.) The red blood cells become odd shaped, known as traumatic hemolytic anemia. These red blood cells are seen in the peripheral blood when they are exposed to a large amount of turbulence and may been seen as schistocytes or echinocytes (burr cells) (Lowdermilk, Perry, Bobek, 1997, p. 792.) The persistent vasoconstriction that occurs causes fibrin deposits in the hepatic sinusoids (Leaton Martin, 2001, p. 32.) This block hepatic blood flow and changes liver function (Leaton Martin, p. 32.) The liver swells causing the pain in upper right quadrant as well as epigastric pain. ALT and AST are chief enzymes that initiate intracellular protein metabolism and are generally found in small quantities in the extracellular serum. An elevated AST may occur when there is liver ischemia. An increase in the ALT, found primarily in liver cells, is when the liver fails to function normally in its role of hemoglobin degradation. An increase in the bilirubin may also take place because of the effects on the liver (Lowdermilk et al., 1997, p. 792.) Vasoconstriction of the blood cells can cause limitations on the blood flow, thus hindering the blood from getting to the vital organs of both the mother and the fetus in the complication of decreased organ perfusion. If the placenta is not receiving sufficient blood, the baby can have complications that can be assessed by the fetal monitor. These complications can be seen as variables or decelerations. If the baby has run out of fetal reserves, the baby may not survive due to the lack of placental perfusion. Vasoconstriction has also been associated with intrauterine growth retardation (IUGR) (Robillard, Chaline, Chaouat, Hulsey, 2003, p. 131.) The obstetrician on-call that night was in the hospital within 12 minutes of the call he received. He assessed the patient and looked at the labs that were taken. He rechecked her cervix which showed no change in dilatation. Because of her gestation age of 37 weeks, the decision for an immediate cesarean was brought forth. He was concerned for the possibility of a long labor. The fact that she did not have a favorable cervix and using pitocin to augment her labor, could have had a poor outcome for both the mother and her baby. The time between decision for the cesarean section to incision was 17 minutes. N.N. had a 7lb. 13oz. baby boy. His apgars were eight at one minute and nine at five minutes. APGAR is an acronym for the scale or scoring used to determine how well the baby did after delivery. APGAR stands for activity (muscle tone), pulse, grimace (reflex ability), appearance (color of the newborn), and respirations. Each score rates either 0, 1, or 2. Two is the best a baby can achieve with each section of the scoring tool. This baby had one point taken off for color and tone at one minute and one point taken off for color at five minutes. There was no need for further intensive care for this baby. During the post partum period, the patient recovered without any further problems. The AST and ALT were back within normal limits by the second post partum day. Another ultrasound was done on her liver the second post partum day which showed no evidence of enlargement, bleeding or rupture. There was no evidence of post partum hemorrhage. Urinary output was greater than 30ml per hour after her cesarean section. By the third post partum day, the edema in the lower extremities was down to 1+ edema with no evidence of pitting. Her post op pain was controlled by as needed opioid medications as well as NSAID’s. The first nursing diagnosis that could have been used for this patient was risk for injury: maternal, related to vasospasm, high blood pressure. A second nursing diagnosis could have been anxiety related to fear of disease process and possible outcomes. A third nursing diagnosis could have been altered protection related to decreased platelet count as evidenced by platelet count of 43,000. A fourth nursing diagnosis could have been pain related to post operative procedure. The interventions used for this patient were used to help ensure the positive outcome for herself and her newborn. She was assessed and properly diagnosed within a very short period of time. The interventions that were done were to promote the patients comfort from the pain she was experiencing from both her abdomen and her head. She was placed on her side in order to not obstruct the blood flow from the vena cava; this can happen if the patient is lying flat on her back. She was assured as well as comforted to help to reduce the anxiety that she was feeling from the fear of what was happening to her. From the time she arrived on to the unit, until the time of her cesarean section, the time lapsed was only approximately 45 minutes. Had she not stated that she had, had HELLP syndrome with her first pregnancy, she may have been diagnosed with preeclampsia or another pregnancy related issue. The fact that she told the nursing staff when she arrived helped us by knowing what to order, what to look for when the results came back and how to properly treat her. The physician on call was not her regular physician and had never seen this patient before. As he was assessing this patient, he was also looking through her prenatal to view her history. With the patient’s symptoms, the fact she has had HELLP syndrome in the past and the labs and the radiology reports that came back, this patient had the best possible procedure that gave her the best outcome for her and her baby. Had this patient been under 36 weeks, she would have been transported to a level three hospital. Our hospital is a level one, community hospital and do not generally deliver babies under 36 weeks unless there is a risk to the mother or fetus. If this is the case, the neonatal intensive care unit (NICU) team from the level three hospital is called and informed. HELLP syndrome is a very traumatic and scary disease process for the patient. Without thorough evaluation and assessment of the patient and her fetus, both she and her baby could have been subjected to a very different outcome. Through team work by the medical staff, the nursing staff as well as the rest of the ancillary members that were involved with this patients care, the patient went home, with a healthy newborn, both with no residual damage. References Hagl-Fenton, D. J. (2008, March 2008). Beyond Preeclampsia. RN, 71(3), 22-25. Lealbe, S. G., Niebyt, J. R., Simpson, J. L. (2002). Obstetrics-Normal and Problem Pregnancies (4th ed.). Philadelphia, Pa.: Churchill Livingstone. Leaton, M. B., Martin, P. S. (2001). Dealing with coagulopathies of PIH. Nursing2001, 31(3), 32-35. Retrieved from ProQuest September 16, 2008 Lowdermilk, D. L., Perry, S. C., Bobek, I. M. (1997). Maternity Women’s Health Care (6th Ed.). New York, NY: Mosby. O’Hara Padden, M. (1999, September 1, 1999). HELLP syndrome: Recognition and perinatal management. American Family Physician, 60(3), 829-836. Retrieved from ProQuest September 16, 2008 Robillard, P. Y., Chaline, J., Chaouat, G., Hulsey, T. C. (2003). Preeclampsia/eclampsia and the evolution of the human brain. Current Anthropology, 44(1), 130-134. Retrieved from ProQuest September 30, 2008 Sheu, J. R., Shen, G., Lin, M. Y., Tzeng, W. Y. (2002). The hyperaggregability of platelets from normal pregnancy is mediated through thromboxane A2 and cyclic AMP pathways. Clinical Laboratory Haematology, 24(2), 121-129. Retrieved from ProQuest September 30, 2008 Research Papers on Pathophysiology of HELLP SyndromePersonal Experience with Teen PregnancyArguments for Physician-Assisted Suicide (PAS)The Relationship Between Delinquency and Drug UseLifes What IfsThe Hockey GameGenetic EngineeringWhere Wild and West MeetResearch Process Part One19 Century Society: A Deeply Divided EraTwilight of the UAW

Most Common Book or Essay Organization Patterns

Most Common Book or Essay Organization Patterns To improve your ability to understand a difficult book or passage, you might start by finding the organization pattern. This may sound more difficult than it is. There are a few ways that writers can choose to organize their work, and the organization depends very much on the topic. If you were writing a description of your bedroom, for example, you would most likely use a spatial organization pattern. In other words, you would most likely start by describing one space and move on to another space, and keep going until youve covered the entire room. Spatial organization would be a suitable type of pattern for real estate professionals to use when describing a property.   Then again, if you were required to describe the events that led up to a certain event in history, your most likely organization pattern would be chronological. Chronological refers to the order that things happen in time. You might describe the legislation that set the stage for a particular event, followed by the public response to that legislation, and followed again by social conditions that changed because of the previous events. So, one of the first things you should do when trying to understand a difficult text is to figure out the particular organization pattern. This helps you frame the entire work in your brain or on paper, as when youre writing  an outline. Chronological Organization A chronological organization is used by writers when they want to describe what happened or happens in a particular order. Your entire history book is most likely written in a chronological patter. Some of the types of work that might follow this patter include the following. You can see that this type of organization is best when describing things that happen over time. History chaptersBiographiesSummer vacation essaysLegal case studies Logical Organization A logical organization might be used in many ways. Logical organization refers to works that express a point or position using evidence. Argument essaysComparison essays Functional Organization A functional organization system is used to explain how or why things work. The following types of writing might use this organization pattern most effectively. How-to essaysStep-by-step essaysInstruction manuals  Recipes Spatial Organization Spatial organization is used in essays that describe or give direction concerning a physical location. DirectionsDescriptionsLayoutsAnatomy essayDescriptions in fiction The purpose of developing and understanding organization patters is to help our brains set the stage and know what to expect. These patterns help us to build a framework in our minds and place information in the correct places on that framework. Once you determine the overall organization of any text, youll be better equipped to process information as you read. When writing your essays and chapters, you should keep your intended organizational pattern in mind as you work, to provide your readers with a clear message that is easily processed.

Teacher Contract Negotiations Essay Example | Topics and Well Written Essays - 1000 words

Teacher Contract Negotiations - Essay Example There are conditions that each individual should meet in order to receive unemployment compensation benefit. Each state has different conditions for an individual to qualify for unemployment compensation. The two most important determinants for eligibility to unemployment compensation benefit are contract and reasonable assurance. Discussion Unemployment compensation is also commonly known as unemployment insurance (UI). It is a program by the government which provides financial support to unemployed workers who are qualified. The federal government sponsors and administers the benefit program through the taxes collected from employers. However, in every state there are different conditions and rules to qualify to unemployment compensation benefits. In the case of Harker v. ... act† which is defined as any written, oral, implied, expressed or even a notice of appointment that indicates individual’s services are being accepted. â€Å"Reasonable assurance† means a written, oral or implied agreement that individual will perform services in an institution of education or government agency in an instructional, research, principal administrative, or any other capacity during the ensuing academic year or term (Harker v. Shamoto, No.25615, 2004). http://www.state.hi.us/jud/22784sdo.htm (see 1) Since the records of the employer showed that Harker was on the preferred list of three schools in his district and even accepted and worked 90 assignments at 8 different schools beginning on July 9, 2000, he was disqualified to apply for unemployment compensation (Harker v. Shamoto, No.25615, 2004).http://www.google.com.ua/#sclient=psy-ab&hl=ru&source=hp&q=worked+90+assignments+at+8+different+schools+beginning+on+July+9%2C+2000%2C&pbx=1&oq=worked+90+assig nments+at+8+different+schools+beginning+on+July+9%2C+2000%2C&aq=f&aqi=&aql=1&gs_sm=s&gs_upl=20042l21665l5l22413l1l1l0l0l0l0l291l291l2-1l1l0&fp=f0afe8921f3de3cb&biw=1133&bih=770 In the case of Ideal Academy Public Charter School v. Bernola, No. 07-AA-1224 (2009), the case stated District of Columbia’s conditions of â€Å"unemployed† individual that may receive unemployment compensation and defined the meaning of being â€Å"unemployed.† According D.C.Code  §?51-109 (2001), an individual is unemployed â€Å"with respect to any week during which he performs no service and with respect to which no earnings are payable to him [.]† and to meet this definition, â€Å"an individual must not have performed any services or received any earnings during the period benefits are claimed.† Even if Bernola received the

Public Policy- Environmental Policy Essay Example | Topics and Well Written Essays - 1000 words

Public Policy- Environmental Policy - Essay Example and more so, the influences of population growth, urbanization, industrialisation, new expanding technological advances, exploitation of resource and their impact. Critical value of restoring as well as enhancing environmental quality to the welfare and progress of man are well emphasized. The role of stakeholders- Federal Government, public and private organizations in using practicable measures and means that include technical and financial assistance to promote the welfare and maintain states under which nature and man can coexist in a productive way to fulfil the economic, and social needs of future and present generations .The policy was to directly educate the Americans that, safe, aesthetically- culturally pleasing, healthful, productive, safe, important historic, and natural aspects of our heritage, biodiversity, and free choice can only be attained through environmental preservation. And this could only be achieved when a state of equilibrium is attained between population and the available resource for use to allow high standards of living and enhance promote renewable resources and approach to maximise recycling of the non-renewable resources. This therefore calls for recognition that every person is entitled to enjoy a healthful environment and the responsibility he has to contribute towards preserving and the environment. The policy vividly states the responsibilities of each individual as trustee of the environment for succeeding generations and assure the society of productive ,culturally, safe, healthful, and aesthetically pleasing surroundings the legislation should further enhance positive use of the environment without degradation other unintended consequences. Furthermore it stresses that government should utilize interdisciplinary approach to ensure integrated use of social and natural sciences in planning and for indecision making to impact on the environment. In the present societies, economic and social activities are

Conclusions with further remarks Essay Example for Free

Conclusions with further remarks Essay Undeniably, the factors that seemingly adhere onto the level of security of certain vicinities may be hard to simplify. Given the fact that individuals come in different ideals, beliefs and characteristics, the greed over power and sovereignty is implicitly the main reason why the issue on security and the plague on terrorism are undeniably swallowing the minds of the society (Laqueur, 1999). With such, it is an astounding standpoint that countries are now paying much attention on the ‘security’ of its people and the preparations onto competence in the arena of globalization (Buzan et al. , 1997). As the Australian Securitisation Forum Inc. notes in their mission: â€Å"To shape the future of the Australian securitisation industry for the ongoing benefit of its members,† piously, if the mission be fulfilled in the most ideal sense as it had been established, the attainment of the goals and hopes of the nation and of the world will be at reach in the most unifying array. Our purpose is an examination of the second issue—the politys response to the government’s move to the provision of security. Consequently, while passing reference may be made to causative factors (indeed, governmental response and the labeling of security may be viewed as causative) (Snyder, 1999), this work is most concerned with the manner in which conflict and consensus theories might interpret and predict governmental reactions to violence and other threats of the like. In essence, this horizon of defining the exactness of ‘security’ is still vague as of the time being because keeping up a nation under â€Å"maximum security† is vulnerable to jeopardizing consequences. References: BUZAN, B. W? VER, O. (2004) Regions and Powers: The Structure of International Security, New York, Cambridge University Press. BUZAN, B. , WVER, O. , WILDE, J. D. WAEVER, O. (1997) Security: A New Framework for Analysis, Florida, Lynne Rienner Pub. DEACON, J. (2004) Global Securitisation and CDOs, New York, Wiley. HAFTENDORN, H. (1991) The Security Puzzle: Theory-Building and Discipline-Building in International Security KRAUSE, K. WILLIAMS, M. C. (1996) Broadening the Agenda of Security Studies: Politics and Methods. Mershon International Studies Review, 40, 229-524. KUPCHAN, C. A. KUPCHAN, C. A. (1995) The Promise of Collective Security. 20, 52-61. MANWARING, M. G. (2003) The Search for Security, New York, Praeger Publishers. MORRISSEY, H. (1992) International Securitisation, New York NY, Ifr Publishing. PAQUETTE, L. (2002) Strategy and Ethnic Conflict: A Method, Theory, and Case Study, New York, Praeger Publishers. SNYDER, C. (1999) Contemporary Security and Strategy, New York, Routledge.

How the Australian Great Barrier Reef Succeeds at Preservation and Sust

How the Australian Great Barrier Reef Succeeds at Preservation and Sustainable Use and How it Applies to a Worldwide Problem Coral bleaching is a somewhat recent phenomenon that has prompted many communities and countries around the world to enact policies and legislation that deal with their dying coral reefs. In early 1998, a mass coral bleaching event took place on the Australian Great Barrier Reef, and broad scale aerial surveys confirmed that most of the inland reefs had experienced at least some bleaching (Lally 1999). The following analysis of the Great Barrier Reef will illustrate that a successful policy process must incorporate the people who live, work, and depend on the fragile environment into the decision-making about preservation policies, regardless of the method or policy tool chosen to do so. Effective management and policy tools must also carefully weigh both extractive and non-extractive uses - to not only preserve, but also sustain, the use of the coral reef ecosystem. First, I will give some background information about why the Australian Reef is of importance and why dying reefs are a worldwide problem. I will then further explain the scientific background of what coral reefs are, what coral bleaching is, and the human activities and other factors that cause it. Second, I will further explain the issues involved with the policy process of preserving coral reefs, and which is the priority that stands above the rest. Third, I will explain who the actors are and what their roles are in the policy process. Fourth, I will define the instruments that are used to guide the policy process. Lastly, I will explain the lessons, outcomes and alternatives that exist in the policy process of preserving coral reef... ...wan, R., N. Knowlton, A. Baker and J. Jara, "Landscape ecology of algal symbionts creates variation in episodes of coral bleaching," Nature, Vol. 388, No. 6639, p. 265-269, July 1997. Warner, M.E., "The Effects of Light and Elevated Temperature on the Photosynthetic Physiology of Symbiotic Dinoflagellates: Potential Pathways To Coral Bleaching," Dissertation Abstracts International Part B: Science and Engineering, Vol. 59, No. 10, p. 5213, April 1999. Warner, M.E., W.K. Fitt and G.W. Schmidt, "Damage to photosystem II in symbiotic dinoflagellates: A determinant of coral bleaching," Proceedings of the National Academy of Sciences, Vol. 96, No. 14, p. 8007-8012, July 6, 1999. White, M. "Sensitive Marine Environments and the Regulation of Shipping: The Great Barrier Reef Experience," Asia Pacific Journal of Environmental Law, Vol. 4, No. 3, 1999, p. 219-242.

Meaning of life essay Essay

?â€Å"You will never be happy if you continue to search for what happiness consists of. You will never live if you are looking for the meaning of life† (Camus). If you spend your whole life searching for one thing you will waste your life and it will only take a few moments for time to pass you by. The meaning of life is nonexistent and imponderable. ?â€Å"The meaning of life is contained in every single expression of life. It is present in the infinity of forms and phenomena that exist in all of creation† (Jackson). The meaning of life is simply the way you view it. Like religion everyone has different philosophies and opinions and only those who give life a meaning have the true understanding of the meaning of life. My Opinion on the Meaning of Life I believe the meaning of life is to give life a meaning, because there truly is no meaning otherwise. I believe everyone adds their own meaning to life. The meaning of life is never universal, never complex. I believe the meaning of life should be simple and potentially whatever we want it to be. I do what I do because I want to. It’s that simple for me; I do it because it means something to me. â€Å"Life is a great big canvas, and you should throw all the paint on it you can† (Kaye). I believe this quote is saying that you should give life your all and do whatever it takes to make your life the way you want it. This is saying someone should do what you believe the philosophy of your life is. Many people go about their lives searching for the meaning of life and how it applies to them but in reality they will waste their lives away looking for something that does not exist. â€Å"There is not one big cosmic meaning for all; there is only the meaning we each give to our life, an individual meaning, an individual plot, like an individual novel, a book for each person† (Nin). â€Å"Life has no meaning. Each of us has meaning and we bring it to life. It is a waste to be asking the question when you are the answer† (Campbell). This is saying how we bring the meaning to life and our thoughts and ideas on what we believe life is and should be. I do not believe in the idea of there being one specific meaning but millions for each and every soul around the earth. Various populations will all agree to disagree about their views but in retrospect you realize that everyone is right. Everyone gives their own meaning to the idea. Purposes and meanings will change, but the overall meaning to life, that there is no true meaning, will always stay the same. I believe the meaning of life is to give life a meaning. Works Cited ?†Albert Camus Quote. † BrainyQuote. Xplore. Web. 23 Mar. 2015. . ?†Anais Nin Quote. † BrainyQuote. Xplore. Web. 23 Mar. 2015. ?†Danny Kaye Quote. † BrainyQuote. Xplore. Web. 23 Mar. 2015. . ?†Michael Jackson Quote. † BrainyQuote. Xplore. Web. 23 Mar. 2015. .

Alternative to GDP

Topic: â€Å"There is rising criticism of the widespread use of GDP as an indicator of the health of an economy. In fact, some experts are of the opinion that GDP growth is making the society poorer. Critically analyse this opinion in view of the concept of sustainability and also discuss some alternate measures being suggested and their implications to the businesses? † GDP as an economic measure of the economic progress of a country Gross domestic product (GDP) is considered one of the most important factors that determine the economic activity and hence the progress of the development of a country. It is the monetary value of all the final goods and services produced by a country in a specified time. Therefore, it is considered that if the country’s economic production increases, other factors remaining positive, then it positively benefits all the citizens of the country. It is hence used as an indicator for the country’s standard of living[1]. Therefore, greater the GDP, better the health of an economy and hence better the lives of the citizens. Reasons for criticism on the use of GDP as an indicator of economic progress As GDP measures the monetary value of the final goods and services produced, it means that the money spent on the country’s well-being for example, millions spent on manufacturing fancy electronic gadgets, constructing a prison, cutting forests to use wood for production of further goods – are all considered at par while measuring the GDP. There is no emphasis on the quality of the output, the progress of the country in terms of the social state of affairs, human happiness, etc. As these are essential ingredients in determining the health of an economy, the concept of using GDP as a measuring scale of the economic progress of a country if criticised. Disadvantages of GDP GDP is criticised on many aspects – it obscures growing inequality, aids depletion of resources and one of the most prominent criticisms is that it measures expenditure on education at par with expenditure on cigarettes i. e. it does not differentiate whether the spending that aids the GDP percentage is going towards a positive or negative cause. GDP does not measures the economic services that nature provides – for example, prevention of floods and landslides by existence of dense forests – it does not account for health, clean environment, etc. i. e. GDP falls short in taking into account equally important things that exist to make a country liveable by fostering social cohesion, along with just the monetary value of goods and services * GDP takes into account the gove rnment spending, but from where the funding is sourced and where it is utilized is not taken into account. Hence, government borrowing is considered good for a country as far as GDP calculation is concerned * Money transactions that take place unofficially and go unrecorded are not accounted for in the calculation of GDP. Hence it does not help in avoiding taxes or prevention of illegal transactions and spending of such huge amount goes unnoticed * Harmful side effects like, pollution is not accounted for in the GDP. No deductions are made from GDP for their harmful effects but addition to GDP is made by market transactions that aid in removing these harmful effects. Hence the calculation of GDP is not balanced * The GDP takes into account the goods and services produced but not exchanged for money. For example, volunteer work or growing own food and consuming it is not included in the GDP whereas expenditure on buying food from the market is taken into account [2]. Adverse effects of using GDP as a sole measure for economic success As GDP takes into account only some value created in the country and does not take into account several key transactions, GDP often increases at the expense of real growth and progress. The result is that GDP fails miserably as an indicator of economic success on the sustainability scale. The environmental and social aspects are not covered by the GDP. Alternative measures & their business implications There are several alternative indicators of the progress of a country. These measure economic activity, environmental or social activities, well-being or changes in environmental, social or human capital. * Genuine Progress Indicator (GPI): It provides a complete picture of economical and social progress. There are several indicators used to calculate GPI that are broadly classified under three categories – economic, environmental and social. The economic category indicators are similar to gross product measurement. The environment factors measure cost of pollution, cost of change to natural resources, cost of climate change, etc. The social indicator includes the value of education, lost leisure time, cost of crime, etc. This indicator has been adopted by the state of Maryland and is altered to include the impact of income inequality on the economy of the state. This indicator indicated the need to focus on reducing the level of income inequality in order to improve Maryland’s overall economic and social growth. Hence, this indicator has been successfully implemented that includes all the factors of well-being in a society. This leads to modified business practices in order to reduce inequality and improve economic, environmental and social spheres of the state * Human Development Index (HDI): It is used by the UNDP to show how the improvement in economic growth and human development is improving conditions of the human in the various countries. The HDI is defined as process of widening choices available to humans in order to live an educated, long and healthy life and to have access to resources to have a healthy and decent standard of living. It makes use of political freedom, human rights and self-respect to measure the index but as they are difficult to measure, the index uses longevity, knowledgeable and decent standards of livings as indicators in lieu of prosperous and long lives. * Gross National Happiness (GNH): It is frequently used as an alternative measure of progress. It was originally suggested by Bhutan to be used instead of using GDP as an appropriate measure of progress. It measures quality of life or social progress in consistency with Bhutan’s culture and spiritual values rather than focusing more on economic activity. It measures seven types of wellness – economic, environmental, physical, mental, workplace, social and political. Several conferences have also been held on use of GNH and it was primarily used to base the progress of the country on reflections of the country’s Buddhist origins[3](Coztanza, Hart, Posner & Talberth, 2009). Conclusion There are several alternative measures that are suggested to be used to measure the progress and the social well-being of a country. GDP is flawed such that it aids detrimental activities and does not take into account the positive activities of a country. Hence, an alternative that measures not only the market value of final goods and service but which also takes into account the social, economic and environmental factors while calculating the progress of a country is imperative to lead to sustainable development. The current use of GDP leads to more consumption of harmful cigarettes with no emphasis on the environmental degradation from the industrial and business rocesses. Hence, although the economy is progressing in certain spheres of economic activity, it is indeed lagging on sustainable development which requires pollution control, reduced resource usage, better social and income equality. Therefore, alternate measures that take into account all the factors that impact a nation should be developed and the alternative measure that is a composite of all the factors should be used to ensure sustainable develop ment of the economy that reflects progress in daily lives of its citizens. References: 1. http://www.investopedia.com/terms/g/gdp.asp 2. http://zorach.wordpress.com/2010/08/27/why-gdp-gross-domestic-product-is-a-poor-measure-of-wealth-and-prosperity/ 3. (Coztanza, Hart, Posner & Talberth, 2009) – http://www.bu.edu/pardee/files/documents/PP-004-GDP.pdf

Сhromosomal abnormalities Essays

Ð ¡hromosomal abnormalities Essays Ð ¡hromosomal abnormalities Essay Ð ¡hromosomal abnormalities Essay The development of psychotic disorders has been linked to chromosomal abnormalities. Research conducted to establish whether there is a link between psychotic disorders and chromosomal abnormalities show that Schizophrenia and bipolar disorder are associated with chromosomal disruptions (Muir et al, 2008). Studies that have been conducted on patients who have been diagnosed with psychotic disorders show that about 30 per cent of the patients have a micro deletion at chromosome 22q11. In addition, researchers associate gene G72/G30 at chromosome 13q33.2 with susceptibility gene for developing schizophrenia at childhood. The development of brief psychotic disorder has been linked to the genes, and this support the claim that psychotic disorders have a biological origin. The link of brief psychotic disorder to the genes is due to the fact that for people who have family members who have bipolar disorder or have shown symptoms of mood disorder, development of brief psychotic disorder is common. However, arguments that the brief psychotic disorder is caused by poor coping skills shows that the genes are not the major cause of the disorder. A traumatic experience or major stress in a person increases one vulnerability to develop the disorder. Genes may increase one’s risk of developing the disorder and although the brief psychotic disorder has been associated to the genes one inherits from the parents, carefully controlled clinical studies have not been able to show that psychotic disorders are biological in origin. Manic depression which characterizes the brief psychotic disorder is associated with an imbalance of serotonin and norepinephrine in the body. During the depressed period, these two are in low levels while during the manic periods the chemicals are in high levels. The predominance of the bipolar disorder has been linked to genetic inheritance. A study done on twins supports the argument that psychotic disorders may have a biological origin . The study that has been conducted on twins show that bipolar disorder is predominant in identical (monozygotic) twins as compared to fraternal (dizygotic). This indicates that a greater chance of inheriting the disorder is in monozygotic twins The fact that psychotic disorders are treated using medication shows that the disorders have a biological component (Samuel, 2003) . For example, the bipolar disorder can be treated using medication. Examples of medication that is used to treat the disorders include mood stabilizers and medication that tries to balance the depressive and manic states in patients. The use of lithium results to counterbalancing of depression and mania effects since it increases the reuptake of nonepinephinne and serotonin. Anticonvulsants such as Carbamazepine (CBZ) and Valproate (VPA) are prescribed to treat bipolar disorders. A case of three sisters who had shared psychotic disorder in United States show that individual who are close can be affected by delusions. The disorder which is shared by individuals who had emotional ties involved three sisters (Kaustubh et al, 2006). The three sisters’ illness was linked to the family’s psychiatric history which showed that the sisters had two first degree relatives diagnosed with schizophrenia. Both the mother and brother had the psychotic disorder and the mother had been hospitalized often- based on this case. The information relating to the disorder show that the case of shared psychotic disorder may involve members of one family and cases of the disorder are more common in members of the same family. It is more common between sisters than in brothers. Research has been conducted on twins and multiple families and show that genetic factors play a major role in promoting the development of psychotic disorders. Studies that have been conducted on twins show that when one twin develops mood disorder, the identical twin is three times more likely to develop the disorder as compared to fraternal twins or siblings who have not been born as twins. In addition, researchers have asserted that the neurotransmitter system in one’s body plays a role in the development of bipolar disorder. However, more research is recommended to determine the exact role of neurotransmitter system in the development of the bipolar disorder. The potential cause of delusional disorder which characterizes psychotic disorders includes neurological abnormalities and changes in brain chemistry as well as heredity. In addition, the disorder has been associated with abnormalities in the limbic system. The limbic system in the brain regulates emotions. Research studies to determine whether biological factors play a role in causing schizophrenia have involved establishing whether there is any connection between Val66Met which is a brain-delivered neurotrophic factor. The results indicate that homozygous carriers Met/Met increased the risk of one developing schizophrenic by 10 percent (Gratacos et al, 2007). The connection between Val66met to the development of schizophrenia shows that psychotic disorders may have a biological origin. The development of psychotic disorder is linked to biological functioning of the brain. An imbalance of the neurotransmitting chemicals in ones brain contribute to the development of psychotic disorders. The imbalance is considered to be inherited or triggered by physical or psychological events. For example, some disruption of early brain development while in the womb may trigger psychotic disorders. Substance-induced psychotic disorders may be caused by one’s withdrawal from using a certain drug and this may to some extent support the claim that the development of the disorder has a biological component (Matcheri and John,1991). For instance, recreational drugs such as cocaine, PCP, Marijuana, alcohol, and hallucinogenics may result to psychotic reaction when a user withdraws from using them (Rashmi and Mark, 2009). In addition, psychotic symptoms may be induced by prescribed medication such as anticonvulsants, chemotherapeutic agents and steroids. Conclusion Psychotic disorders cause abnormal perceptions and thinking in patients. Hallucinations and delusions are two major symptoms of the disorders. Individuals who are affected by psychotic disorders have their ability to make good judgments and to think clearly altered. There are various types of psychotic disorders which vary in cause and treatment. Treatment of the disorder includes therapy and medication. Research that have been conducted in relation to psychotic disorders show that some cases of the disorder may have a biological origin. However,research on the disorders indicate that the disorders result from the interaction of biological, psychosocial and environmental factors. References Bentall, R. , and Slade, P. 1988. Sensory Deception. Taylor and Francis Publishers. Daryl, F. , and Iqbal, A. 2007. The spectrum of psychotic disorders: neurobiology, etiology, and Pathogenesis. Cambridge University Press Freudenreich, O. 2007. Psychotic Disorders: A Practical Guide, Practical Guides in Psychiatry Gratacos, M ET al. 2007. Brain-Derived Neurotrophic Factor Val66Met and Psychiatric Disorders: Meta-Analysis of Case-Control Studies Confirm Association to Substance- Related Disorders, Eating Disorders, and Schizophrenia Biological Psychiatry, Volume 61, Issue 7, Pages 911-922 Habermann, T. , and Ghosh, A. 2006. Mayo Clinic. Mayo Clinic Internal Medicine Board Review, CRC Press Publishers, 2006

Types of Ignorance

Types of Ignorance Types of Ignorance Types of Ignorance By Maeve Maddox As a teacher, I am always pained when I hear ignorant used as an insult. ignorance: n. lack of knowledge Everyone is born ignorant into the world. The word ignorance is from Latin ignorantia. The prefix in means not; Old Latin gnarus means aware, acquainted with. Mere ignorance is nothing to be ashamed of. Ignorant is not a synonym for stupid. Catholic theology recognizes three categories of ignorance: invincible ignorance: lack of knowledge that a person has no way to obtain vincible ignorance: lack of knowledge that a rational person is capable of acquiring by making an effort nescience: lack of knowledge that doesnt matter in the circumstances (from Latin ne-, not plus scire, to know. In Catholic theology, invincible ignorance, whether of the law or the fact, is always a valid excuse and excludes sin. In the secular realm, however, all ignorance is seen as vincible. For logicians, the term â€Å"invincible ignorance† means â€Å"the fallacy of insisting on the legitimacy of one’s position in the face of contradictory facts.† If the facts are presented, theres no excuse to refuse to acknowledge them. The law likewise does not allow for a category of information unavailable to the lawbreaker that would forgive the breach of the law: ignorantia juris non excusat, â€Å"ignorance of the law does not excuse.† Heres a lengthier definition of the secular take on invincible ignorance from Wikipedia: invincible ignorance: a deductive Fallacy of Circularity where the person in question simply refuses to believe the argument, ignoring any evidence given. Its not so much a fallacious tactic in argument as it is a refusal to argue in the proper sense of the word, the method instead being to make assertions with no consideration of objections. Fitness expert Greg Glassman has this recommendation for dealing with invincible ignorance: some simply cannot be swayed toward your way of thinking, so don’t try. †¦you’re probably best to walk away from a pointless debate. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Expressions category, check our popular posts, or choose a related post below:Writing Prompts 10155 Boxing Idioms20 Ways to Laugh

Introduction to Microeconomics Essay Example | Topics and Well Written Essays - 1000 words

Introduction to Microeconomics - Essay Example pply in positively related to price because at a higher price producers can earn more profit by supplying more output.(Ian Hobday, p 100,105) In a market price is determined at the level at which demand equate supply as illustrated in figure 3. This discipline also offers explanation of factors that determine demand and supply. The factors that determine and influence demand are many. Demand is determined by changes in incomes of consumers, changes in tastes and fashion, changes in income tax, changes in population, changes in price of related goods, advertising and others. All of these factors bring shifts in demand curve and change equilibrium price and output. â€Å"British Gas reported 98 percent increase its six months operating profits of 2010 as compared to the same period during previous year â€Å"The profits reached to ?585m due to unusual cold winter which boosted the demand of  gas prices  by 8 percent.†( Aubin Lawrence, 2010) Price of related goods affects de mand has been witnessed, â€Å"With oil constantly trading above $100, consumers -- particularly those looking to buy cars -- are vying for alternatives that aren't too heavy on their wallets†(Debarati Bose,2011) Supply is determined by changes in costs of production, technical progress, changes in weather/disasters and others. All of these cause supply curve to shift and change equilibrium price and quantity.(Dan Moynihan and Brian Titley , p158-165) see figure 4 .On many occasions shortages are observed due to climatic changes and so forth. â€Å"European wheat stocks are expected to hit a 30-year low as dry weather could cut yields of some major European producers up to 20 percent†( Cat Contiguglia, 2011).See figure 4. Microeconomics analysis tells firms whether of raise prices or to decrease them. This...This paper demonstrates the main concepts of the Microeconomics. There is also 4 figures in the essay which graphically illustrates these concepts Microeconomics can be defined as a study of market behavior at micro level such as behavior of households and firms. It focuses on interactions between individual buyers and sellers and the factors that influence their decisions. In its broadest sense study of microeconomics deals with the efficient allocation of limited recourses that are available to fulfill unlimited wants of the society. This concepts is known as the basic economic problem which occurs due to scarcity. Due to scarcity individuals have to make a choice. This applies the principle of â€Å"opportunity cost† which is the cost of next best alternative forgone. Goods and services are produced by bringing together the four factors of production namely, land, labor, capital and enterprise. Production Possibility curve demonstrates principles of opportunity cost and full-employment Microeconomics explains price determination in goods and services markets and analyses the behavior of firms and consumers. This discipline also offers explanation of factors that determine demand and supply. Demand is determined by changes in incomes of consumers, changes in tastes and fashion, changes in income tax, changes in population, changes in price of related goods, advertising and others. Supply is determined by changes in costs of production, technical progress, changes in weather/disasters and others. with the help of microeconomics societies can predict behavior of firms and consumers and respond to possible changes in the markets. Causes and correlations can be identified with the help of theories that the disciple offers.

Globalization of operations management Essay Example | Topics and Well Written Essays - 250 words

Globalization of operations management - Essay Example raw materials, skilled and low-cost labor force among others (Mahadevan 121). Economies of scale also arise after a company expands it production capacity due to lower cost of operation. The service sector on the other hand has capitalized on the skilled labor force available overseas at low cost e.g. outsourcing firms relocating to India (Mahadevan 138). This expansion or shifting centers of operation also affect operations management adversely. There is the need for the firm to operate within the laws and standards of the new markets which are not necessarily similar to those of original market. Client’s special needs and preferences should also be considered in production which can increase on costs. Global market place is also quite competitive raising the need to have sound operational management strategies. CONCLUSION Globalization has taken many organizations to greater heights in the competitive global market. This scenario has enabled them to gain competitive advantag e and increase on production which results to higher margins. A firm going global should therefore appreciate that it will have to initiate changes in its operations to suit the new market dynamics. Works cited Mahadevan, B. Operations Management: Theory and Practice. Pearson Education India, 2010.

Admin Law Essay Example | Topics and Well Written Essays - 2500 words

Admin Law - Essay Example tion that has taken over the function of the Spelsbury District Council has moved from the status of â€Å"state† to â€Å"person†, which are the only two groups in society that are assumed under the European Convention of Human Rights, which aims to protect the rights of â€Å"people† from the â€Å"state†. Thus, when a judicial review process is considered, the Spelsbury Council would clearly fall under the category of â€Å"state† and Tracy would be â€Å"person† whose rights have to be protected. However, since the limited liability1b aspects impart the status of personhood upon such corporations that enjoy its benefits, therefore the Directors of the new company would be absolved of responsibility for civil actions against them because the corporation itself would be considered a person, just like Tracy, thereby blurring the distinction that allows a judicial review process to proceed against a clearly defined public body. However, since the limited liability company has been set up to carry out a public function that was originally carried out by the Spelsbury District Council and for the benefit of the public, it is likely that the courts may be amenable on this aspect of the case and Tracy may be allowed to seek permission from the High Court to ask for a judicial review of the decision.2 Section 31 of the Supreme Court Act of 1981 governs the judicial review process in England, whereby the question of permission being granted by the High Court may be subject to whether the Court â€Å"†¦Ã¢â‚¬ ¦.considers that the applicant has a sufficient interest in the matter to which the application relates.†3 In the case of R v Inland Revenue Commission ex parte national Federation of Self Employed4 Lord Wilberforce set out three separate criteria on deciding whether sufficient interest exists and one of these was the relative positions of the defendant and the plaintiff and the nature of the breach that is alleged to have been committed. In this case, the decision has been

Proselytism, Conversion and the Freedom to Change Religion

Proselytism, Conversion and the Freedom to Change Religion A Critical Analysis Abstract This dissertation seeks to critique the extent to which Article 9 of the ECHR upholds an individuals â€Å"freedom to change his religion and belief†. It is respectfully submitted that the landmark decisions of the European court have provided inconsistent guidance with respect to the issues surrounding proselytism, conversion and the freedom to change ones religion; consequently, this will have significant implications on interreligious dialogue and the protections on the rights of adherents of new religious movements, minority religions, and religious converts. This paper proposes that the ECtHR jurisprudence ought to consider the theoretical perspectives advanced by Stahnke, Danchin, and Taylor to strengthen the protections of ones freedom to change their religion, underscoring that a careful consideration of these theoretical approaches may provide a positive contribution to protecting the freedom of religion more generally. Introduction Chapter 1: Issues surrounding proselytism, conversion and the Freedom of Religion 1.1: Introduction Stahnke highlights that the development of international principles governing the issues surrounding proselytism ‘is no easy task, especially in consideration of the varied state approaches to proselytism.[1] After reflecting upon the Strasbourg jurisprudence in relation to the complicated issues arising from cases relating to proselytism, an individuals right to change his or her religion, and the freedom of religion espoused by Article 9,[2] this paper asserts that Stahnkes statement is not only true in the global context, but is particularly acute in the European context as well. In this connection, it is evident that that the issues relating to proselytism pose pragmatic difficulties for jurists because it requires them to adjudicate between competing and conflicting rights claims.[3] As Malcolm Evans highlights, â€Å"how can the fundamental right of one individual to the freedom of thought, conscience and religion be reconciled with the fundamental right to another to th e same freedom, when the very possession of those beliefs might require a believer to present his views to others?†[4] In other words, the court has to determine, as Witte has concisely stated, â€Å"Whose rites get rights?†[5] This paper begins its analysis by suggesting that the protections of an individuals right to change his or her religion as well as its corresponding links with proselytism is further complicated by the theoretical disagreements concerning the legal definitions of religion, and the freedom of religion. For example, Carolyn Evans notes that even if a collection of states agree to be bound by an international agreement adhering to a general principle protecting the freedom of religion, it is possible that the states conceptual understanding over the rights and values at stake may differ significantly.[6] She further contends that the subsequent interpretations of Article 9 in the European court mirror the aforementioned problem. Similarly, the complexity of human rights issues relating to religion contribute to the challenges of formulating an overarching framework of adjudication since religion is inextricably linked with nationalistic and political participation, particular family his tories and cultures, spiritual and philosophical sentiments, and differing conceptions of morality.[7] 1.2: Religion and the difficulties of definition According to Gunn, a judge sitting on the European Court and their particularly personal definitions of ‘religion plays a considerable role in shaping that judges interpretations of Article 9 under the European Convention and how cases ought to be decided.[8] For example, judicial conceptions of religion may have significant practical implications on applicants seeking to determine whether or not a new religious movement or minority religion receives tax exemption status, or whether a persecuted religious asylum seeker is able to claim refugee status.[9] As we will soon discover, a judges conception of religion is likely to influence his/her decisions in cases involving proselytism and conversion.[10] However, this is complicated by the fact that the actual definition of religion under Article 9 does not exist since the issues of definition have been fraught with controversy since the drafting of the United Nations International Instruments, on which Article 9 is based.[11] Gunn astutely observes that there are underlying methodological difficulties concerning the natural definition of religion which necessarily involve assumptions concerning the nature of a religion—i.e., religions metaphysical nature and/or theological conceptions of religion, the psychological experience of adherents, and the socio-cultural impact of religion—and whether or not there are features that all religions share in common—i.e., does a religion have to possess a theistic element, or would a polytheistic, atheistic, or non-theistic conception of religion suffice?[12] Carolyn Evans highlights that although the European Court and Commission have adopted a broad, generous and liberal approach to defining religion, it is important to note that the courts have ruled that a religion ought to attain a sufficient degree of â€Å"cogency, seriousness, cohesion, and importance† to justify protection under Article 9.[13] Consequently, as Evan notes, vague conc eptions of religion are beyond the scope of the protections under Article 9. However, she also suggests that although there may be a genuine sincerity of an applicants beliefs, the requirement that an applicants belief possess a level of sufficient coherence â€Å"has the potential to exclude some more individualistic and personal beliefs†.[14] In this connection, it has been argued that legal definitions must also consider a range of other factors such as (a) ‘protecting freedom of religion, or (b) ‘prohibiting discrimination of religion—tasks that are difficult to adjudicate because of the range of different opinions as to what exactly constitutes the nature of religion, and what specific manifestations of religion warrant protection.[15] The jurisprudence surrounding freedom of religion cases under Article 9 appear to distinguish between the ‘private boundaries of religion and its inextricable links to the ‘internal adoption of a particular religious belief, with the ‘public boundaries and its corresponding links to ‘external manifestations of religious belief; these concepts are occasionally referred to as the forum internum and forum externum respectively.[16] Evans highlights that the interpretation of Article 9 typically underscores the primacy of the forum internum—that is, â€Å"the private thought, conscience, and religion of the individual†[17] and it is generally asserted that the state is prohibited from interfering with the forum internum.[18] However, it is unclear as to where the line between the ‘private conscience and ‘public expression, or forum internum and forum externum is to be drawn, especially considering that many religions do not necessarily de fine themselves in such dualistic terms.[19] For example, in highlighting the theoretical uncertainty in relation to the scope of the forum internum, Sullivan argues â€Å"many religious doctrines or beliefs dictate standards of social conduct and responsibility, and require believers to act accordingly. For those who follow such precepts of social responsibility, the distinction between religious and political activities may be artificial†.[20] Similarly, Gunn underscores the importance for judges to consider the multifaceted nature of religion in that it not only comprises an applicants ‘belief, but also an applicants ‘identity and ‘way of life.[21] Thus, he argues that â€Å"the adjudicator should seek to understand the religious facets of such cases not from the perspective of a person who might attend religious services a few times a year, but from the perspective of those who have chosen to devote their lives fully to their religion as they understand it†.[22] In other words, a prudential approach from the standpoint of an adjudicator would not merely reduce the definition of religion to the mere domain of the private sphere, but would take account of how an individuals private belief intersects and overlaps with his or her public manifestation of belief. Nowhere is the overlap between an individuals private belief and public manifestation of belief more evident than in the issues surrounding proselytism and conversion—a subject to which we now turn. 1.3: Linkages between, and issues surrounding, proselytism, conversion and the freedom of religion Given that Article 9 aims not only to protect an applicants private conceptions of religion, but also an individuals right to manifest his or her religion subject to certain limitations, Danchin and Stahnke similarly argue that because proclaiming and sharing ones faith is such an important and integral aspect of a host of world religions, it would be logically inconsistent if the attempt to convince another to adopt ones religious belief, experiences and faith was beyond the scope of protections under the freedom to manifest religion.[23] Additionally, it has also been suggested that â€Å"in modern human rights law, the right to change ones religion, in the absence of coercion and as a result of free will is considered a recognised freedom†.[24] Stahnke observes that the issues surrounding proselytism and conversion involve competing rights between the ‘source—that is, the proselytiser, the ‘target—that is, the individual receiving the information, and the role that the state should play in balancing the conflicting and competing rights between ‘source and ‘target.[25] Hence, it is evident that the multifaceted nature of proselytism and conversion present significant challenges for the jurist in reconciling competing claims to the freedom of religion under article 9. Witte concisely summarises the ‘modern problems of proselytism by asking, How does the state balance ones community right to exercise and expand its faith versus another persons or community right to be left alone to its own traditions? How does the state protect the juxtaposed rights claims of majority and minority religions or of foreign and indigenous religions? How does the state craft a general rule to govern multiple theological understandings of conversion or change of religion?[26] Although an analysis of the array of theological perspectives of conversion and the change of religion is beyond the scope of this study,[27] this subject is worth mentioning in order to illuminate the challenges of protecting the freedom of an individuals right to change his or her religion. For example, Witte notes that most Western conceptions of Christianity â€Å"have easy conversion into and out of the faith†, whereas â€Å"most Jews have difficult conversion into and out of the faith†.[28] However, traditional Islamic perspectives prohibit proselytism directed towards Muslims, but encourage Islamic proselytism towards nonbelievers.[29] Although traditional Islamic perspectives on proselytism have significantly influenced state policies restricting proselytism,[30] it is evident that the phenomenon of the pervasive role of religion and its influence on state practices is undoubtedly mirrored in the European context as illustrated by the facts in Kokkinakis v. Gree ce. Chapter 2: Freedom to change religion: The seminal case: Kokkinakis The decisive judgment concerning the protections of religious freedoms as well as the issues surrounding proselytism is illustrated in Kokkinakis v. Greece.[31] Gunn notes that between 1955 and 1993, only 45 of 20,000 applications challenging Article 9 were published by the European Commission, and Kokkinakis was the first case to be considered under Article 9[32] where the court found a member state in violation of the provisions protecting the freedom of religion.[33] 2.1 The facts In 1936 at the age of 17, Mr. Kokkinakis converted from Greek Orthodoxy into the minority Jehovahs Witness religion and was arrested over 60 times, and imprisoned on several occasions for proselytism throughout the course of his life.[34] After exhausting all domestic remedies, Mr. Kokkinakis applied to the European Commission on Human Rights in 1988, who unanimously declared that there had been a violation of Article 9.[35] His case was then submitted to the European court. By a 6-3 majority, the court held that there had been a breach of Mr. Kokkanakis freedom of religion under article 9. 2.2: The reasoning of the court The court reasoned that the â€Å"freedom of thought, conscience and religion† is one of the hallmarks of a pluralistic democratic society—serving not only as a protection for ardent religious believers—but also for â€Å"atheists, agnostics, sceptics and the unconcerned†.[36] In this connection, the court affirmed the right to manifest ones religion encompasses not only public and private expressions of belief, but also â€Å"includes in principle the right to try to convince ones neighbour†.[37] Otherwise, the provision in Article 9 protecting the ‘freedom to change [ones] religion or belief â€Å"would be likely to remain a dead letter†.[38] However, the court issued a caveat, acknowledging that in democratic societies, in which several religions coexist within one and the same population, it may be necessary to place restrictions on this freedom in order to reconcile the interests of the various groups and ensure that everyones beliefs are respected.[39] To sum up the courts ruling, under Article 9(1), sections 31-36 of the judgment highlight that the sentence imposed by the Greek government interfered with Mr. Kokkanakiss right to manifest his religion under Article 9. However, the court then sought to determine whether the restrictions imposed on Mr. Kokkanakis by the Greek government were permissible under Article 9(2) by referring to the three tests of whether the actions were ‘prescribed by law, had a ‘legitimate aim, and whether the actions were ‘necessary in a democratic society. Firstly, in paragraphs 40-41, the court highlighted that the existence of domestic case law prohibiting proselytism fell within the meaning of ‘prescribed by law within ‘Article 9(2) of the convention.[40] Secondly, the courts sought to determine whether the governments ‘measure was in pursuit of a legitimate aim. The courts affirmed the Greek governments arguments that it was obliged to protect â€Å"the peaceful enjoyment of the person freedoms of all those living on its territory†, and therefore, â€Å"the impugned measure was in pursuit of a legitimate aim under Article 9(2), namely the protection of the rights and freedoms of others†.[41] Finally, the court referred to the doctrine of the ‘margin of appreciation—which permits States to â€Å"assess the existence and extent of the necessity of an interferencesubject to European supervision†.[42] To do this, the court distinguished between ‘proper and ‘improper proselytism, highlighting that the former is a reflection of â€Å"true evangelismand the responsibility of every Christian and every church† whereas the latter is a â€Å"corruption or deformation of it†.[43] The court also noted that a coercive expression of proselytism could â€Å"take the form of activities offering material or social advantages with a view to gaining new members for a Church or exerting improper pressure on people in distress or in need; it may even entail the use of violence or brainwashing†[44]. Thus, any coercive expression would be deemed incompatible with the provisions set out in Article 9(2). Consequently, the court held that the Gr eek government failed to demonstrate that Mr. Kokkinakiss proselytising activities were of a coercive nature. Furthermore, the Strasbourg Court highlighted that Mr. Kokkinakiss criminal conviction was unjustified on the grounds of a ‘pressing social need; therefore, Court ruled in favour of Mr. Kokkinakis, citing the measures enacted by the Greek government failed to demonstrate that they were â€Å"proportionate to the legitimate aim pursued† or â€Å"necessary in a democratic societyfor the protection of the rights and freedoms of others†.[45] 2.3: The polarised responses of the judges It is interesting to highlight the polarised responses between some of the judges, as it is clear that particular understandings of religion and proselytism played a decisive role in shaping the judicial opinion in Kokkinakis. On the one hand, it is apparent that Judge Martens analysis prioritised the rights of the proselytiser,[46] where he reasoned that it is not within the province of the State to interfere in this ‘conflict between proselytiser and proselytised. First, because—since respect for human dignity and human freedom implies that the State is bound to accept that in principle everybody is capable of determining his fate in a way that he deems best—there is no justification for the State to use its power ‘to protect the proselytisedSecondly, because even the ‘public order argument cannot justify use of coercive State power in a field where tolerance demands that ‘free argument and debate should be decisive. And thirdly, because under the Convention all religions and beliefs should, as far as the State is concerned, be equal.[47] Judge Martens further argues that the â€Å"State, being bound to strict neutrality in religious matters, lacks the necessary touchstone and therefore should not set itself up as the arbiter for assessing whether particular religious behaviour is ‘proper or ‘improper. [secondly], the rising tide of religious intolerance makes it imperative to keep the States powers in this field within the strictest possible boundaries.[48] In other words, states are under a strict duty to minimise interfering in an individuals freedom to manifest religion as much as possible. Conversely, on the opposite extreme, Judge Valtico gave primacy to the rights of the target by arguing that the recipient of a ‘conversion effort has a right to a peaceful enjoyment of his or her religion, and therefore ought to be protected from unwanted attempts to changing his or her religion: Let us look now at the facts of the case. On the one hand, we have a militant Jehovahs Witness, a hardbitten adept of proselytism, a specialist in conversion, a martyr of the criminal courts whose earlier convictions have served only to harden him in his militancy, and, on the other hand, the ideal victim, a naive woman, the wife of a cantor in the Orthodox Church (if he manages to convert her, what a triumph!). He swoops on her, trumpets that he has good news for her (the play on words is obvious but no doubt to her), manages to get himself let in and, as an experienced commercial traveller and cunning purveyor of a faith he wants to spread, expounds to her his intellectual wares cunningly wrapped up in a mantle of universal peace and radiant happiness. Who, indeed, would not like peace and happiness? But in this the mere exposition of Mr. Kokkinakiss beliefs or is it not rather an attempt to beguile the simple soul of the cantors wife? Does the Convention afford its protection to s uch undertakings? Certainly not.[49] We now turn to the criticisms of Kokkinakis and the subsequent case law and its relationship to proselytism, conversion and the Freedom of Religion. Chapter 3: Criticisms and observations of the case law 3.1 Critique of Judge Martens Judge Valtico Naivety and prejudice in legal reasoning As mentioned in the previous chapter, both judges reasoning reflect extreme positions of adjudication. On the one hand, judge Martens—a judge aligning his perspective with the majority— upheld a strict position of minimal state interference into an individuals freedom to manifest his or her religion by appealing to a principle of ‘strict neutrality whereas judge Valticos dissenting judgement reflected a hostile view of the applicants particular manifestation of religion. It is respectfully submitted that the reasoning of both judges illustrated naivety[50] and prejudice[51] respectively. 3.1.1: Naivety It has been argued Judge Martens position merely reduced the issues surrounding proselytism to the competing rights claims of the personal, autonomous, and individualistic manifestation of the proselytiser with the rights claims of adherents of the majority religion and the majoritys attendant conceptions of the ‘common good.[52] Whilst true that the court had to adjudicate between the competing rights claims of the adherent of a minority religion with the ‘collective good, it is submitted that judge Martens not only overlooked the competing and conflicting individual rights claims of the proselytisers right to share his/her faith with the individual rights claims of the recipient of the attempted proselytism to peacefully enjoy and practice his/her freedom of religion, but also the competing and conflicting conceptions of the common good as well.[53] Moreover, judge Martens also referred to the notion that the state is bound to ‘strict neutrality with respect to â €˜religious matters; however, his contention begs the question of whether there is such a concept of ‘religious neutrality in the first place?[54] 3.1.2: Prejudice: Privileging majority over minority religions Conversely, judge Valticos position has been widely criticised on the grounds that it demonstrates a biased and prejudicial approach consequently privileging the rights of adherents of the established religion over the rights of adherents of minority religions.[55] At one point, judge Valtico even suggested that proselytism amounts to â€Å"rape of the belief of others†[56] but it is apparent that this perspective dismisses the centrality of proselytism to the beliefs of Jehovahs Witnesses and that such beliefs could potentially contribute to the common good.[57] Consequently, it is evident that judge Valticos position demonstrates significant hostility towards the practices of minority religions such as the Jehovahs Witnesses as well as an individuals freedom of religion. By casting a minority religious group in such negative terms, an unsettling consequence nevertheless arises in that religious liberty becomes further threatened, and a public backlash towards such groups could potentially ensue.[58] Moreover, this could have insidious and deleterious effects on interreligious dialogue between adherents of majority religious groups, with adherents of new, minority religious movements aiming to promote a heightened understanding of their novel religious practices, hopes of integrating into the broader socio-cultural milieu, and quest for legitimacy.[59] Additionally, it is contended that judge Valticos view is an affront to the hallmarks of human rights law and its corresponding commitments to non-discrimination and equality.[60] Perhaps judge Valticos position reflects the deference of the European Court to the constitutions, practices and statutes of member states overtly privileging the position of established churches, whilst correspondingly neglecting the impact of such laws on adherents of minority religious groups.[61] Interestingly, there is evidence to suggest that acts of proselytism conducted by adherents of the Greek Orthodox faith have not resulted in arrest, unlike the proselytising actions of religious minorities; consequently, an implicit value in judicial support of the Greek Governments actions is the notion that â€Å"the law is applied in Greece to allow prosecutorial decisions based on an individuals religious status, not his or her actions†.[62] Furthermore, one of the pressing anxieties over the privileged position of the established churches in member states is that such protections create a ‘two-tiered system of religious rights which will continue to afford major mainstr eam churches the full rights, privileges, and immunities that are associated with traditional parameters of religious freedom, while simultaneously denying minority religions and new religious movements both equal legal status for their organizations and equal protection for their adherents.[63] In doing so, this paper submits that the reasoning offered by the European Court potentially inhibits the protections of religious freedom more generally. Furthermore, this paper maintains that judge Valticos perspective could have insidious and deleterious effects not only on the freedom of religion of religious minorities, but also the freedom of religion for adherents of dominant religious faiths as well. For example, some national legislators may claim to be enacting general or ‘neutrally applicable laws, but the outcomes do not necessarily reflect this; rather, they serve as an indicia of a privileged majority restricting the expansion of specific religious minorities, especially in member states where powerful churches aligned with the state can wield formidable political pressure on governments.[64] In this connection, perhaps we can surmise that if a hypothetical faction within a privileged religious group were to dissent from a religious majority powerfully aligned wit h the state, the faction could potentially encounter significant limitations to their religious freedom. Perhaps the astute observations of a revolutionary writing from prison in 1916 underscoring the importance of protecting the freedoms of minority groups would provide some insight to assist the courts adjudication: â€Å"Freedom only for supporters of the government, for members of the party—though they are quite numerous—is no freedom at all. Freedom always means freedom for the dissenters†.[65] Consequently, the Kokkinakis decision has been problematic because the judges seemed to have minimised and dismissed the complexity of the theoretical and substantive issues relating to justified state intervention in cases involving proselytism, and only found an ‘impermissible violation of an individuals freedom of religion when the specific facts arose in the case, rather than attempting to develop broader principles surrounding proselytism when given the opportunity.[66] We now turn to the critiques surrounding the courts adjudication regarding the limitations to religious freedom and permissible scope of state restrictions under article 9(2) of the ECHR. 3.2 Prescribed by law: Implications and the purpose of domestic legislation Although the court accepted that the Greek governments restrictions on proselytism were prescribed by law and had a legitimate aim in Kokkinakis, the Court eventually held that the Greek government failed to demonstrate that the measures were ‘necessary and ‘proportionate in a democratic society. However, a common criticism of the Kokkinakis decision is that the courts failed to develop substantive protections of the rights of religious minorities and unpopular religions to proselytise as well as the concomitant rights of individuals to change their religion. For example, Taylor highlights that the European courts failure to â€Å"impugn Greeces anti-proselytism law† consequently ignored both the purpose of the legislation and the reality that the domestic law was often consistently applied as an instrument of discrimination.[67] Similarly, it is also worthwhile to note that the courts only adjudicated on the particular facts of the case rather than developing broader principles in relation to proselytism and the freedom to change ones religion.[68] In this connection, by merely narrowing its focus on Mr. Kokkinakis conviction, it is evident that the court failed to critique Greeces anti-proselytism measures—measures which have been used as an instrument of disc rimination as evidenced by the frequency of incarceration rates of minority believers.[69] Not only was the bias against unpopular and minority religious groups evident in Kokkinakis, but the reality that the domestic law has been used in a discriminatory fashion has also been reflected in the subsequent case law. For example, in Larissis, a group of Greek Pentecostal air force officers were convicted of proselytising to several of their ‘subordinate fellow servicemen as well as a number of civilians under Greek law. The European court held that the Greek authorities were justified in protecting the rights of the subordinate servicemen and therefore did not find a violation of Article 9 in that particular instance because of the likelihood that the lower ranking airmen could potentially be subjected to ‘improper pressure; however, the European court found that the Greek government could not justify the convictions of the Pentecostal Air Force officers in relation to the attempts of proselytising the civilians since the civilians were not subject to the same con straints and pressures of the lower-ranking airmen, and therefore, in violation of Article 9.[70] The court reasoned, [The] hierarchical structures which are a feature of life in the armed forces may colour every aspect of the relations between military personnel, making it difficult for a subordinate to rebuff the approaches of an individual of superior rank or to withdraw from a conversation initiated by him. Thus, what would in the civilian world be seen as an innocuous exchange of ideas which the recipient is free to accept or reject, may, within the confines of military life, be viewed as a form of harassment or the application of undue pressure in abuse of power.[71] Whilst understandable that the State was justified to intervene in order to protect the rights of the lower-ranking airmen since ‘hierarchical structures of military life could make â€Å"it difficult for a subordinate to rebuff the approaches of an individual of superior rank†,[72] the court avoided considering the question of whether the Greek legislation prohibiting proselytism was in and of itself a violation of Article 9.[73] In this connection, it is evident that the courts failure to address whether the Greek criminalisation of the proselytism law ought to be reformed or abolished appears to demonstrate the European courts tacit approval of systematic state justifications of laws discriminating and negatively impacting the rights of religious minorities[74] and new religious movements seeking to attract converts.[75] In doing so, it appears that the court instituted its own objective assessment of how the laws would discriminate against the rights of religious min orities to proselytise rather than adopting a perspective acknowledging the vantage point of the religious minorities themselves.[76] In other words, the court appears to dismiss the subjective experiences of the religious minorities in question; consequently, the courts â€Å"have shown little regard for the plight of sincere, committed believers whose claims that States actions interfere with their religion or belief are routinely dismissed by institutions prepared to substitute their judgment for the judgment of the believers†.[77] 3.3 Legitimate Aim The court noted that the ‘impugned measures of the Greek government were â€Å"in pursuit of a legitimate aim under Article 9(2)† in protecting â€Å"the rights and freedoms of others†.[78] However, one of the most unsettling features of the courts reasoning in Kokkinakis is its failure to further develop this conclusion.[79] Under Article 9(2), state limitations to the manifestation of belief are only justified â€Å"in the interests of public safety, for the protection of public order, health or morals, or for the protection of the rights and freedoms of others†,[80] but one criticism levelled towards the approach in Kokkinakis is that â€Å"the Court effectively holds that a government satisfies its burden by offering any justification that can be tied, however remotely, to the ‘protection of the rights and freedoms of others†.[81] In other words, a government may sufficiently meet the ‘legitimate aim requirement at its own discretion, irrespective of whether the government arrived at its conclusion in an arbitrary or capricious manner as lo