Realism And The Victorian Era - 859 Words

So what does one do when said individuals that are of different blood and social statuses fall in love? The Victorian Era was a time where your social status could be construed as directly correlating to whom said individual could socialize with, marry, or have any ties too. Perhaps maybe there weren’t three individuals that knew this more than the three of Wuthering Heights Edgar Linton, Catherine Earnshaw, and Heathcliff. The Victorian Era had many elements that could be tied to it but the one that will be the center focus for this paper will be realism. Realism emphasized the middle class and rejected the heroic in favor of the ordinary, focusing on common people and common situations. In realism the middle class was simply feed up with social statuses and not having a voice in society. Another group of people that simply were feed up with the norms of society was that of women. Realism not only focused on the common class as a whole but on the empowerment of women and lett ing these ladies voices be heard whether it was through writings such as Wuthering Heights. Nevertheless, the Victorian Era was a time in which many would considered was the ultimate turning point for two different group of people as a whole the commoners as well as the women of this era. Edgar Linton was a young man of noble blood that makes the love between Catherine Earnshaw and Heathcliff very complicated. From the story of Wuthering Heights Linton definitely would be the ideal guy for CatherineShow MoreRelatedThe Era Of The Victorian Era1565 Words   |  7 PagesThe Victorian Era is a period prominent in harboring peace, prosperity as well as introducing the later shifts in industrial and political reforms. Queen Victoria a notable person of the era, began her reign in 1837 and influenced England by the values she encouraged. The Victorian Era is divided into four categories: â€Å"The Early Period is known as â€Å"A time of Troubles†, The Mid-Victorian Period, The La te Period and The Nineties.†(Stephen Greenblatt). The Nineties is thoroughly separated among theRead MoreEnglish Language And Composition Of The Victorian Era1320 Words   |  6 PagesMichael Linares Ms. Sipars AP English Language and Composition 15 September 2015 Response #1 England’s Victorian Era was a very influential and interesting Era that took place during the time that Queen Victoria was the Queen of England. The Victorian Era started around 1830 and lasted up until the start of the 20th Century. During this Era England became very powerful. Many amazing masterpieces were created by great artists like Oscar Wilde and Charles Dickens. The three class system which weRead MoreHenrik Ibsen s A Doll House Essay1501 Words   |  7 PagesHenrik Ibsen’s play â€Å"A Doll House† was set in the Victorian era, a time where women were highly respected. Women in this time period did not work, they had nannies to take care of their children and maids to take care of their homes. Many women had no real responsibilities, they spent their time having tea parties and socializing with their friends. Henrik Ibsen dared to show the realism of the Victorian era while everyone else would only focus on the romantic aspect. In the play, â€Å"A Dol l House†Read MoreThe Importance Of Realism In Hard Times By Charles Dickens1575 Words   |  7 Pages Ian Watt earlier discussed the term realism and form of the novel in his infamous text â€Å"Realism and the Novel Form.† In this book, the author has presented many different forms of stories where realism is succinctly touched upon. The novel is one of the most active literary forms emerged during the late seventeenth century having its apex form in the eighteenth century. Watt has found that novel is an actual attempt to be an authentic account of reality since most of the eighteenth and nineteenth-centuryRead MoreBrowning And Morality : The Victorian Era976 Words   |  4 PagesBrowning and Morality: The Victorian Era The purpose of this prospectus is to identify the thesis and research goals, explain the findings of a literature search, and explain how they are intended to be applied. Having chosen from the list of suggested topics, the decided thesis will be on the topic of the importance of morality and how it relates to the Victorian era, specifically morality’s role Victorian literature. It is commonly held that the Victorian era can be characterized by the shock experiencedRead MoreCharles Dickens Biography1626 Words   |  7 Pagesyoung, mischievous, and perplexed characters Oliver Twist and David Copperfield. He proves that he is a product of the Victorian era as he brings attention to the childhood cruelty, the less fortunate in an English society, and the unwealthy dysfunctional families of the early Victorian time period. Charles Dickens reflects these and other issues as he brings to life the realism of writing. While others were writing about the way things should be, rather t han the way things were, Dickens was challengingRead MoreThe Role Of Realism In If I Were A Man By Charlotte Perkins Gilman1295 Words   |  6 Pagesthe Victorian Era feminist movement, Charlotte Perkins Gilman and Kate Chopin. These women were both part of the realism movement that rose to prominence in American literature during the 19th century and used their stories to shed light on the problem of female oppression to a vast audience. These two feminist contemporaries are similar in the writing style, theme, and characters they use in the stories that they wrote. Gilman and Chopin’s writing styles both have characteristics of realism. â€Å"IfRead MoreRealism and the Humanities 1718 Words   |  7 PagesRealism in and of itself is a broad subject, and has many different areas that can be discussed. The Realism Movement directly challenged Romanticism and the romanticists, because it was more interested in showing how things were, rather than feelings, beauty, and subjectivity that the romantics favored. Many things were gained from the movement, and its effects still stay around today. This is obvious in various works, like Chekhov and Ibsen, and in artwork that is still revered today. The RealismRead MoreCharacteristics Of Victorian Literature1437 Words   |  6 Pages Are the Victorians Romantics? Characteristics of Victorian literature are largely artists that are inspired by both the art that came before them and the event that occurred during the time that they were working. Victorian literature is largely characterized by the struggle of working people and the triumph of right over wrong, which do in part can be hard to decipher at times. This means that a piece of work can seem Victoria, but may not have been written in the Victorian era, or something canRead MoreImages of Victorian Women by the Pre-Raphaelite Brotherhood Essay1012 Words   |  5 PagesThe Victorian Era was one of great changes in England. Revolutionary movements, such as the Chartist demonstration and the fall of the Second Empire in France, paved the way for new ideologies. The Pre-Raphaelites were inspired by the changing atmosphere of the times and through their art attempted to introduce emotion, realism and originality back into British painting. The members of the Pre-Raphaelite Brotherhood we re John Everett Millais, William Holman Hunt, Dante Gabriel Rossetti, F.G. Stephens

Analysis Of Philippa Gregory s Three Sisters Three...

Three Sisters, Three Queens, a historical fiction novel written by Philippa Gregory, takes place in 16th century Europe, an era characterized by powerful monarchs whose personal and political life are incredibly complex and intertwined. In particular, this story focuses on three women who will become the queens of Scotland, France, and England, respectively: Margaret, her sister, Mary, and their sister-in-law, Katherine of Aragon. The story is told from Margaret’s point of view, who provides a unique yet often disregarded female perspective of this era intended to demonstrate that these ruling women are just as important to history as their male counterparts, namely Henry VIII and James IV. The novel is centered around two types of†¦show more content†¦It would spoil everything if Mary’s is French cut or more richly embroidered, or more fashionable† (293-294). Her superficial nature and blatant sense of entitlement resulting from her privileged upbringing becomes almost comical, especially as she is so heavily concerned with her possessions even while her country is engulfed in both civil war and war with England. Nevertheless, Margaret still does mature with age, as she and her sisters come to realize that they should be working together rather than separately: â€Å"We spent our time admiring and envying each other and we should have been guiding and protecting each other† (544). Ironically, on that very same page Margaret expresses delight over her sisters’ misfortunes: â€Å"I am in a better place than both my sisters. I cling to this little joy, as stubborn as when we were girls jockeying for supremacy† (544). Margaret’s fickle nature embodies her time period, where many of the monarchs share similar competitive desires and betrayal is commonplace. On an even grander scale, Gregory highlights a natural human flaw and defies the idea of a perfect protagonist. Even though Margaret changes for the bet ter, a little part of her young and selfish self will always remain within her. Margaret is not always a likable character, but she is certainly a relatable one, whose experiences to achieve power and happiness teach her that she should have confidence in herself and her sisters to defy gender norms

Electronic Media

Question: What are thecodes of practices regarding marketing through direct relations and use of electronic media? Answer: Introduction The present report entails the legal factors of Australia, regulations and legislations that may impact the marketing operations. For an organisation to function, the national standards of the country provide a framework, within company practices are limited. There are several organisations that take responsibility for implementation of laws and code of practices, in Australia, that effectively control malpractices by organisation that damage the customer rights. The objective of such regulations is to maintain reliable advertisement techniques, as deceptive claims regarding products or service can lead the consumers to make a purchase under false pretenses (Lister, 2016). Legislations and Regulations Marketing operations by organisations are filtered through the following laws to protect the consumers from misleading promotions and advertisements.1. Australian Consumer Law (2010): Its regulating body is ACCC, which applies its practices to consumers and businesses. Its aim is to protect the consumer rights regarding deception or misleading information, transaction, product safety, and empowering the consumers in case of company malpractice (Commonwealth of Australia, 2016).2. Competition and Consumer Act (2010): The purpose of this Act is to enhance the safety of Australians consumers by endorsing just transaction and market competition, through safe product provision, reducing unethical marketing, supervise pricing strategies, and laws regarding mergers and acquisition strategy (Australian Competition and Consumer Commission, 2014). Code of practiceSeveral organisations have enforced codes of practices regarding marketing through direct relations and use of electronic media, res pectively. These codes are described as following.1. Direct Marketing Code of Practice: This code of practice has been regulated by ADMA, which is required to be followed by all members of the association. Its objective is to aid organisations to improve marketing outcomes through the progressive use of direct marketing (Australian Direct Marketing Association, 2010). It minimizes the danger of infringing the legislations placed and promote ethical practices (ADMA, 2016). 2. Australian e-Marketing Code of Practice: This code of practices provides limitation for the corporates regarding sending commercial messages through electronic media (email, mobile) and other promotional practices (ACA, 2005). Confidentiality and Privacy issues: Australian consumers demand security and discretion, with regard to personal information. Since 2001, the Australian Government formed a Privacy Act in 1988 which regulates the handling of personal information of citizens. Office of Australian Information Commissioner (OAIC) is appointed as the regulatory body for the implementation of this act (OAIC, 2015).Big data can be quite valuable for businesses for attaining insight of the customer profile, such as using birthdays marked on social calendars to offer gifting services. To decrease breach of such sensitive data, the Spam Act and Privacy Act, in terms of marketing, restricts the companies to approach customers regarding promotions through email and messages without their consent (Saadati Christie, 2013). Social Responsibility and Cultural Diversity OECD guidelines for Multinational Corporations, in Australia, guide the organisations to make economic, environmental and social progress, abide by human rights and maintain good governance to build trust between the company and the society as part of their social responsibility (ACCSR, n.d.).Australia boasts a diverse culture which can be used to the advantage of corporations for marketing, through linguistic skills and cultural knowledge (FECCA, 2013). The cultural diversity in a society can benefit the corporates economically through catering to tourists and exports. It drives the market by bringing competition to the market for innovative ideas (SGS Economics and Planning Pty Ltd., n.d.). Ethical Principles Marketing, since the introduction of technology has been expanded to global scale. It makes misuse of information and application of unethical tactics likely. To address these ethical concerns, ethical codes have been prepared by different organisations.1. AANA Code of Ethics: This code is implemented by AAN, through which they aim to regulate their advertising and marketing practices. The produced promotions are required to be legally reliable and authentic claims should be made in marketing campaigns (AANA, 2013). 2. AMSRS Code of Professional Ethics: The members of Australian Market and Social Research Society (AMSRS) are to adhere to this set of regulations. Its main purpose entails implementation of ethical regulation for marketing, organisation and social researchers so that the public can trust the researchers (AMSRS, 2015). Safety issues ACCC has regulated the provision of safe products, through the Australian Consumer Law (ACL). It includes preventing sale of banned products that are restricted by the state. Consumer guarantees are provided for the consumer to refund a product if deemed unsafe, and in case of failure to comply, customers can take action against the responsible company. Similarly, there are rules regarding mandatory standards for product, bans, recall, product liability etc. (ACCC, 2013). Conclusion The framework and set of rules outline the method to which the companies should conform to. Australia has appointed several organisations to ensure the protection of consumer rights and effective marketing within the boundaries of ethical code provided by state laws and other organisations empowered by the federation for the implementation of these laws. It highlights the importance of consumer rights and empowerment in Australia. References AANA. (2013). CODE OF ETHICS. Retrieved from https://aana.com.au/content/uploads/2014/05/AANA-Code-of-Ethics.pdfACA. (2005). Australian eMarketing code of practice. Retrieved from /Australian%20EMarketing%20Code%20of%20Practice.pdfACCC. (2013). Product safety. Retrieved July 22, 2016, from https://www.accc.gov.au/business/treating-customers-fairly/product-safety#product-safety-regulationACCSR. What is CSR? Retrieved July 22, 2016, from https://accsr.com.au/what-is-csr/ADMA. (2016). ADMA code of practice. Retrieved July 22, 2016, from https://www.admaknowledgelab.com.au/compliance/compliance-help/general/data-and-privacy/codes-and-guides/adma-code-of-practice/AMSRS. (2015). AMSRS code of professional behaviour. Retrieved from https://www.amsrs.com.au/documents/item/194Australian Competition and Consumer Commission. (2014). Legislation. Retrieved July 22, 2016, from https://www.accc.gov.au/about-us/australian-competition-consumer-commission/legislationFECCA. (2013). Factsheet 9 Cultural diversity and market development1. Retrieved from https://fecca.org.au/wp-content/uploads/2015/06/factsheet-9-cultural-diversity-and-market-development1.pdfOAIC. (2015, July 28). Privacy act. Retrieved July 22, 2016, from https://www.oaic.gov.au/privacy-law/privacy-act/SGS Economics and Planning Pty Ltd. Economic benefits of cultural diversity - SGS economics planning. Retrieved July 22, 2016, from https://www.sgsep.com.au/publications/economic-benefits-cultural-diversity.

Margaret Mead And Ruth Benedict Essays - Anthropology, Humanities

Margaret Mead And Ruth Benedict Ruth Benedict & Margaret Mead After high school, Ruth Benedict took a year off to travel overseas. Upon returning home she was unsure of what she wanted to do with her life. Years later, she married Stanley Benedict, a Biochemistry Professor at Cornell Medical School. In the fall of 1919, Ruth went back to school and began to focus more on anthropology. She studied under the famous diffusionist Franz Boas and became his assistant. Ruth taught Margaret Mead. Ruth and Margaret became good friends and developed a shared need of each other. Ruth concentrated most of her efforts on researching and studying different cultures on which many of her writings were based. She wrote of the differences between the cultures around the world and talked about different patterns related to culture and behavior. Ruth was very talented in summarizing and clearly arranging facts which were characteristic of her writings and ultimately her approach to anthropology; this, perhaps, may be the reason many of her reviews were published in professional papers and magazines throughout her career. Ruth Benedict was a very important figure in early anthropology and even more so in cultural anthropology. She was one of the first female anthropologists of her time. Her books serve as a referral of humanistic thought in the 20th century. Ruth Benedict has helped shape the discipline of anthropology not only in the United States, but also for the rest of the world. After a year at Depauw University at Greencastle, Indiana, Margaret Mead, entered Barnard College, Columbia University. It was here that she decided to make anthropology her major. She later received her B.A. degree. She also got her M.A. degree in psychology. In 1929, she received her Ph.D. Dr. Margaret Mead is a specialist in what she herself describes as ?conditioning of the social personalities of both sexes.? She had several field trips. First, she was in the Samoan Islands and than the Manus tribe of the Admiralty Islands in the West Pacific Ocean. In 1930, Dr. Mead went to study an American Indian Tribe the identity that is hidden by the name of ?the Antlers? in her book noting her findings and conclusions. Between 1931 and 1933, Dr. Mead went in the New Guinea area to do research on three contrasted tribes, the Arapesh, the Mundugumor, and the Tchumbuli. For three years, starting in 1936, Dr. Mead was busy on fieldwork in Bali and New Guinea. She has always found her profession so different that she has not felt the need for a hobby; she reportedly enjoys the theater and reads good poetry. Anthropology

Machiavellis Views of Human Nature and Their Relevance to Todays World essays

Machiavellis Views of Human Nature and Their Relevance to Todays World essays Born in Florence, Italy in 1469, Niccol Machiavelli was the first great political philosopher of the Renaissance. Once a bureaucrat and diplomat for the state of Florence, he was removed from office when the Medici family was restored to power in 1512. He retired to his country home where he, among other works, penned The Prince, a work which has become a political handbook for modern day politicians as well as for those who desire powerwhether it be on Wall Street, through corporate conglomerates, or in their personal relationships. The Prince is a philosophical political view on how one might gain, maintain, and expand the power over the state or states in which a ruler has authority. While Machiavellis views are based on maintaining a monarchy, they can be equated to the corporate world of modern times. In this essay, I will discuss how Machiavellis views of human nature are relevant in the world today, particularly in capitalist economies that produce massive conglomerates. First lets review some of Machiavellis viewpoints. Machiavelli suggests that after overthrowing the current monarchy the new ruling Prince should be the sole authority, making all decisions in his own best interests.1 Any members of the old regime should be annihilated, thus preventing them from regaining power.2 The Prince should be distrustful of the citizens over whom he rules, as they will turn against him when times are bad.3 He should, however, not mistreat them, for even though men are generally ungrateful, liars, and deceivers, they will remain loyal if treated well. This is particularly true to those who are in the best positions to oppose the Prince. If you allow them to believe you are interested in their advice, providing you ask them for their opinions on matters that concern you, theyll feel flattered and inclined to please.4 Machiavelli believed in a separation from the church. The chur...

How to Become a Veterinary Technician

How to Become a Veterinary Technician When you think of life in a veterinarian’s office, you might think of a Doctor Doolittle-style situation, with amusing animal hijinks and lots of kitten-cuddling. In reality, it’s a busy medical office- and while there may indeed be cuddling, it’s like any other healthcare practice, working hard to treat patients and send everyone (and everydog) out the door healthier than they came in. Veterinary technicians (also known as vet techs) are an essential part of a veterinary clinic. They work with doctors to provide care- but they do it across species lines.The Day-to-DayVet techs are often the core nursing staff in an animal clinic. Depending on what kinds of animals the clinic specializes in treating, this could entail working with patients from small rodents all the way up to horses and livestock. Vet techs typically work in standard private vet clinics, but they can also be found in emergency care pet clinics, in zoos, in medical laboratories, or visiting animal owners’ homes to provide care.  Because the majority of vet techs work in a clinic/office setting, the most common work week is a standard 40-hour one, but techs who work in critical care or in unusual settings (zoos, farms) may work on an on-call basis.Vet techs are usually responsible for the following tasks:Observing the behavior and condition of animals in order to diagnose illness or injuryProviding nursing careAdministering emergency first aid to animalsPerforming grooming servicesRestraining animals during exams or proceduresAdministering anesthesia to animals, and monitoring vital signsCollecting laboratory samples for testing, such as blood, urine, or tissuePerforming diagnostic laboratory testsTaking and developing x-raysPreparing animals and instruments for surgeryVaccinating and administering medication prescribed by the veterinarianMaintaining patient charts and medical historiesFor more on what it’s like to be a veterinary technician, check out these v ideos:Career Choices – Vet Technician  A Day in the Life – Veterinary Technician  Becoming a Veterinary Technician  The RequirementsVet techs usually have at least an associate’s degree from a program accredited by the American Veterinary Medical Association. Many states also require certification in addition to the standard education and training, so be sure to research what your state’s requirements are for vet techs.The PayThe median salary for veterinary technicians is $31,070, or $14.94 per hour. Experienced technicians can often make about $41,000 per year.  Per a Salary.com survey, vet techs rate their career as â€Å"very satisfying.†The OutlookOpportunities for veterinary technicians are exploding: the Bureau of Labor Statistics expects that the field will have a major surge of at least 19% by 2024. This makes it one of the fastest-growing Allied Health careers out there. Also, the most kitten-intensive.

Stress Coursework Example | Topics and Well Written Essays - 250 words

Stress - Coursework Example If things were entirely out of my control, I would leave the matter to God understanding the fact that I have made the necessary effort. Some new techniques of stress management that I have learnt in this module include exercise and yoga. I would definitely like to try these techniques because they have many benefits in addition to relieving stress. For example, exercise keeps you physically fit and healthy while nourishing the brain (Nordqvist, 2009). Your body has a direct impact on your mind. The healthier the body, the healthier the mind gets. Likewise, yoga helps you concentrate and focus your attention, which helps relieve anxiety and depression because the mind gets free of ambiguities. My decision to start school requires me to make certain changes in my life. For example, to be able to achieve this goal, I would have to be more punctual. I would have to develop better time management skills. Furthermore, I would have to develop interest in academics and be dedicated to my wo rk to be able to achieve perfection in this

Department of Maritime and Logistics Management Essay - 1

Department of Maritime and Logistics Management - Essay Example Businesses tend to opt for air cargo due to quick and safe on time delivery. The cargo handling and processing procedure is critical as goods need to be transported elegantly and safely (Wensveen, 2012,p.14). Airlines throughout the globe ensure to deliver best cargo services as revenue generation from cargo is more than passengers’ shipment. The purpose of this paper is to elucidate about the acquisitions and deployment of aircrafts into the fleets. The key factors involved in the aircrafts addition to the fleets have been elaborated. Furthermore, the air cargo handling procedure along with the difference from handling passengers and luggage is demonstrated. The intention remains to present the entire view about the airlines logistics management. Acquisitions and Deployment of Aircrafts: The addition of aircrafts into the fleet is a matter of serious concern for the organization. Several elements need to be examined before taking this step. Initially the need and requirement paradigm is explored. The strategic business units dig in that either it is adequate and necessary to pursue for this step or not. The organizational expeditions are certainly expanded by opting for the option of adding aircrafts into the fleet. The mergers and acquisitions in the airlines industry have not worked out pretty well in the past. The only successful merger was of Air France with KLM in 2004, making it Air France KLM. The newly merged company escorted for adding new aircrafts into the fleet but that decision was made after one year operations collectively (Gudmundsson, 2010, p.48). The management of aircrafts previously became an issue for the organization but they sorted it out by inaugurating information systems into the firm. All the operations were virtually connected and scheduling of flights and delivery of cargo was certainly more transparent and viable. After getting heads up in the respective area, Air France KLM went to the addition of aircrafts into the fleet (Romano, 2012, p.23). Some of the key factors that need to be considered airline’s decision in adding aircrafts into the fleet are given below. Organizational Status: The airlines need to determine that either it is internally strong enough to deploy and acquire aircrafts into the fleet. The strategic business department of the airline needs to watch this matter deeply and scrutinize that either is the organization capable to handle the load. The requirement aspect wants to be covered too. The addition of aircrafts into the fleet without acknowledging, that either airlines market position is stable or not is vital. The organization propensity and tendency is crucial too. The addition of aircrafts requires expansion in staff and more finances for the organization. Some of the airlines go for acquisition and deployment step without working on these steps (Borken-Kleefeld, Berntsen and Fuglestvedt, 2010, p.5702). The precise understanding of the magnitude of coming events is imp ortant in the airlines industry. There are several external and internal factors that affect business endeavors of airlines industry, so it is eminent for the firms to concisely acknowledge the organizational status before stepping into something deep. The customers and business requirement is secondary issue but it is of much more significance. Airlines should have well equipped technological setup that would create synergy between the

Progressive era Essay Example for Free

Progressive era Essay The Progressive Era was a period of social and political reformation that flourished under the leadership of President Woodrow Wilson. When the United States entered World War 1 on April 6, 1917, the whole nation was united under a moral cause. However, the war quickly busied Americans creating no time for Progressive movements and the events following the war put an end to the Era all together. During the beginning of the war, Wilson’s foreign policy was to remain on a neutral tide. With his reelection, he even won against Charles Hughes under his slogan, â€Å"He kept us out of war†, that persuaded Americans that choosing Hughes would lead them into direct contact with the war. Americans united under this foreign policy trying to stay out of European affairs under the philosophy of isolationism. When Germany’s unauthorized submarines caused for the sinking of the RMS Lusitania and their efforts chose to continue unrestricted submarine warfare the United States was infuriated. This is one factor that kept the United States busy with working to remain excluded from war. However, President Wilson addressed to Congress and declared he wanted â€Å"to make the world safe for democracy†, leading America into World War 1, under this moral cause. (Doc 2) Now that the United States was in the war, Americans started to become less concerned with social reforms and busier working, supporting, and fighting the war together. Women, for one, took over the jobs of all the men who went out to war, and worked to supply the belligerents, keeping women very busy. The United States Food Administration, under Herbert Hoover, promoted rationing of food through â€Å"Meatless Mondays† and â€Å"Wheatless Wednesdays†. This helped to conserve food and save for those fighting overseas. (Doc 6) Trench warfare was how most of World War 1 was fought and living in these trenches was rather a tough condition. This ensured that supporting and working hard together in America for our men was required to aid their health and capability of being able to fight effectively. (Doc 3) The war ended with a high number of casualties for America. Many of these casualties resulted from the influenza epidemic that attacked the world’s population and battle fights, such as those that occurred highly within the use of trenches. (Doc 3) This high death effected lives of Americans and their families, keeping them from being motivated to continue the Progressive movement. The Treaty of Versailles created at the Paris Peace Conference in 1919, put an end to World War 1, but did so with a lot of problems. President Wilson, as devised in his 14 Point Peace Plan called for a creation of a League of Nations, an international peace organization. This organization caused for a split in American views. The United States, as a majority, voted not to join, as it took away the power of Congress to declare war and would ruin America’s self-determination. (Doc 9) This split in decision effected formally agreeing and creating more social reforms. The Progressive Era ended with World War 1, as many Americans were too busy with a plethora of events to help the United States fight the war. When the United States entered the war, they were morally united under a new crusade. However, they had to put their further ideas of reformations on hold as the war demanded serious attention to be fought effectively. The further Americans became deeply involved into the war, the further attention was dragged away from the progressive movement. Even after the war was over, Americans were still busy caught up in dealing with the aftermath and the approach of another worldwide outbreak.

The Crusades Essay -- essays research papers

The Crusades A major turning point in Medieval history were the Crusades. The Crusades were a series of wars fought between the Christian Europeans and the Muslim Turks, which occurred between the years of 1096 to 1272. In this Holy War the Christians goal was to obtain the Holy Land from the Turks, in which they did not succeed. Although the Christians did not meet their goal, many positives did come out of their attempt. Due to the reason that they did not meet their goal, yet numerous positives came out of their effort, many refer to this as a successful failure. A main cause of the Crusades was the treatment of Christian pilgrims. They were robbed, beaten, and then sold. The main group of Turks, the Seljuk Turks, were threatening and growing in power. The Byzantine Emperor, Alexus I, began to become worried and sent out an urgent plea to Pope Urban II, in Rome. He requested for Christian knights to help him fight the Turks. Pope Urban II did agree to his appeal although Byzantine Emperors and Roman Popes were longtime rivals. He also did agree with Alexus I, in fearing that the Turks were expanding. Pope Urban encouraged French and German Bishops and Nobles to also take part in this. â€Å" An accused race has violently invaded the lands of those Christians and had depopulated them by pillage and fire.† This is when Pope Urban II called for a crusade to free the Holy Land. Urban did agree to this having some of his own motives in mind. He was hoping his power would grow in ...

Horizontal Integration

Competition DG Information, communication and multimedia Media Vertical and horizontal integration in the media sector and EU competition law Miguel Mendes Pereira* â€Å"The ICT and Media Sectors within the EU Policy Framework† U. L. B. -SMIT (Studies on Media, Information and Telecommunications) CEAS-Norwegian School of Management, Oslo Telenor Broadcast Brussels, 7 April 2003 OUTLINE Introduction I. Convergence and integration 1. Technical convergence 2. Economic convergence 3. Efficiencies II. Competition issues 1. The competitive arena 2.Foreclosure 3. The dominance test III. Vertical integration 1. 2. 3. 4. The gate-keeper issue Foreclosure of input markets Leveraging Network effects IV. Horizontal integration 1. General assessment 2. The Newscorp/Telepiu case 3. The EMI/Time Warner case V. Remedies 1. The balance between efficiencies and foreclosure 2. Remedies in the Newscorp/Telepiu case 3. Remedies in the cases Vivendi/Seagram/Canal Plus, Vizzavi and AOL/Time Warner Conclusion * Administrator, European Commission/DG Competition/Media Unit. Lecturer at the Law School of the University of Lisbon.The opinions expressed are purely personal and only engage the author. â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira Ladies and Gentlemen, I wish first of all to thank the SMIT Center and Telenor for inviting me to speak here today. I intend to give you a brief overview of the competition issues raised by vertical and horizontal integration of companies in the media sector. I will start by referring to the convergence trend in the media and telecommunications sectors and its link to the concentration wave we have witnessed during these past three years.I will then highlight the main competition issues which this type of operations raise from a theoretical point of view. I will subsequently address the issues linked specifically to vertical as well as to horizontal integration, and c onclude by illustrating how the European Commission has dealt with these problems by means of remedies accepted as a condition for the approval of this type of concentrations. In so doing, I will refer to a number of cases recently assessed by the Commission such as AOL/Time Warner, EMI/Time Warner, Vizzavi, Vivendi/Seagram/Canal Plus and, decided just last week, Newscorp/Telepiu.I. CONVERGENCE & INTEGRATION Convergence has become all too familiar to most of us as one of the main driving forces behind the recent changes occurred in the media and telecom industries. However, as it so frequently happens with notions that turn into â€Å"buzzwords†, the many meanings attributed to the term â€Å"convergence† are often ambiguous and, as such, unhelpful in order to describe the evolution of the media and telecom industries. Let me therefore turn, first of all, to the two meanings of the term â€Å"convergence† that I consider to be most relevant from a competition la w point of view. . Technical convergence Technical convergence mainly concerns the possibilities offered by digital technology. Those possibilities are reflected, for example, in the infra-structures required to deliver contents like movies or music. With the current digital technology, huge amounts of data may be transmitted to a high number of users through different networks (mobile networks, Internet, satellite). This allows for the dematerialization of media products traditionally sold as physical products (newspapers, films, CD’s) by transforming them into packages of bytes.At the same time, digital technology allows for the convergence of traditionally separate media into a single product, putting together text, sound, video and voice in what has become known as multimedia. Access to TV broadcasting, or rather webcastig, on the Internet is already nowadays a reality and listening to an MP3 music file on a cellular phone is nothing new. 2. Economic convergence Audio-vis ual products were never cheap but the growing competition induced by the proliferation of TV channels has inflated production costs. For example, the by now famous saga â€Å"The Lord of the Rings† has had reported costs of â‚ ¬ 278 million.In order to have an idea of the recent increase in the price for audio-visual contents it is sufficient to compare, for example, the price paid for broadcasting rights of the Football World Cups of 1990, 1994 and 1998 – 241 million ECU – with the price paid for the same rights in respect of the World Cups of 2002 and 2006 – 1,7 billion Euro. Only large companies seem to be able to afford such astronomical costs. 2 â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira In face of economic barriers of such dimension, media companies have shown a trend towards concentration. . Efficiencies What appeared to be particularly new about these alliances and mer gers in the media industry was the search of not only the traditional economies of scale but, above all, the search of economies of scope. This translated into an attempt to use the same product in a number of different ways: pure entertainment and telecommunication, or entertainment and information, or information and telecommunication. From an economic point of view, economies of scope basically translate in lower Average Total Costs as a result of producing a wide range of products.The main feature of this type of concentrations is the vertical integration of the different levels of production and distribution of media products that leads to companies which are able to, for example, produce films or music, register them in DVDs or CDs and distribute them not only to â€Å"brick and mortar† shops but also through the cable, satellite or mobile telephony networks they own. Vertically integrated companies are in a position to exploit their products at every single level of th e value chain. „Create Once, Place Everywhere! seemed to be the motto for the media industry during the Internet bubble, illustrating the need for media producers to place their products in the largest possible number of different platforms. This was the underlying reason for alliances and mergers between companies which are active in sectors of the economy that used to be separate like television and telecommunications. Operations like AOL/Time Warner, Vivendi/Universal, Vivendi/Vodafone for the setting up of portal Vizzavi or the acquisition of Dutch entertainment producer Endemol by the Spanish telecom company Telefonica clearly illustrate this trend.It should be said that, to a large extent, the ratio underlying some of these operations was a deep faith in the Internet potential and a strong belief in the synergies resulting from cross-supply between different technical platforms belonging to the same vertically integrated company. The burst of the â€Å"dotcom bubbleâ₠¬  showed how some of these expectations were possibly premature. We now start seeing some of the vertically integrated groups selling off some of their units (AOL/TW or Vivendi/Universal) and witness consolidation caused by heavy losses incurred during these past few years.Such is the case of the pay-TV industry, as illustrated by the merger in Spain of the platforms Canal Satelite and Via Digital and the merger in Italy between the platforms Stream and Telepiu, approved by the Commission just last week. After a period of extensive vertical integration, we now witness a reflux of horizontal integration dictated to some extent by financial reasons. II. COMPETITION ISSUES 1. The competitive arena Turning now to the competition issues raised by integration of companies, the first step required in order to understand the forces at play is to determine the perimeter of the competitive arena.What do media companies compete for, whom do they try to sell their products to and how do they intend to do it? Media companies compete for – essentially – three things. First, they compete for content, which is what they will ultimately sell to their customers. Access to content produced by third parties or the establishment of production facilities is a sine qua non condition for entering or staying in business. Secondly, they compete for the best way to deliver such content to customers. Access to delivery channels owned by third parties or 3 â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M.Mendes Pereira the possibility to establish their own paths to the customer is what allows media companies to distribute their output. Finally, they compete for the obvious ultimate addressee of all this competition: the customer. But this is a contest which goes beyond the obvious competition for a onetime sale. Some of the businesses in the media & telecom sector (e. g; pay-TV, Internet access), like most IT-driven b usinesses, are based on a durable relationship with the customer. An established customer basis allows for the progressive development of new services and products and for the consequent increase in ARPU1.Access to potential clients managed by third parties or the build-up of their own client basis is the ultimate target of media companies. 2. Foreclosure Foreclosure of the competitive arena is a central concern of EU competition policy in relation to vertical agreements and mergers. Restricted access to input markets (copyrights or contents) or to sales markets (customers, at retail level) may limit inter-brand competition. The extreme example is where a company, as a result of a vertical or horizontal integration, succeeds in simply barring the access to a given market to its competitors.However, in real life foreclosure does not arise in such simplistic terms and mostly materialises by indirect means. For example, by raising rivals’ costs, by raising barriers to entry or b y engaging in tying/bundling. Tying is particularly relevant in the media and telecom sectors given that it is often present in explicit (and in most cases, legitimate) commercial offers: for example, a bundled offer of pay-TV and Internet access, or both plus fixed telephony (so called â€Å"triple play†). The ability to raise rivals’ costs may easily arise where a dominant firm is in a position or acquires such position as a result of a concentration) to control the access by competitors to a given infra-structure or input (a technology or a copyright) and where it has the possibility to charge supra-competitive prices for such access. In the media sector one could think about, for example, access to a satellite platform for TV distribution or to a proprietary standard for Conditional Access System. A company in these circumstances is commonly referred to as a â€Å"gate-keeper†. A central element in the assessment of market power of a company and its possibil ity of foreclosing a given market is the concept of barriers to entry.Where entry barriers do not exist, easy entry will quickly eliminate the problem, even where the incumbent holds large market shares. Entry barriers might be described as â€Å"the advantages of established sellers in an industry over potential entrant sellers, these advantages being reflected in the extent to which established sellers can persistently raise their prices above a competitive level without attracting new firms to enter the industry†2. Although in most cases barriers to entry will indeed have an economic nature, they may in some cases assume other forms.Regulation may function as an entry barrier when it provides for the establishment of special rights, for example when only a limited number of licenses is foreseen. This is the case of terrestrial TV and/or radio broadcasting due to spectrum scarcity. 3. The dominance test Most competition law issues related to vertical and horizontal integrat ion in the media sector have been dealt with by the European Commission under the Merger Regulation, i. e. in respect of concentrations notified under the EC Merger Regulation3. As 2 3 1 Average Revenue per User.J. Bain, Barriers to Competition, H. U. P. 1965, p. 3. Council Regulation (EC) No 4064/89 of 21 December 1989 on the control of concentrations 4 â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira you know, pursuant to Article 2 (3) of the Merger Regulation, â€Å"a concentration which creates or strengthens a dominant position as a result of which effective competition would be significantly impeded in the common market or in a substantial part of it, shall be declared incompatible with the common market. The test applied by the Commission when assessing these operations was therefore a dominance test. The concept of dominance used under the Merger Regulation is equivalent to the one defined by the Court o f Justice in Article 82 cases: â€Å"The dominant position (†¦) relates to a position of economic strength enjoyed by an undertaking which enables it to prevent effective competition being maintained on the relevant market by giving it the power to behave to an appreciable extent independently of its competitors, customers and ultimately of its consumers†4. (†¦) such a position does not preclude some competition, which it does where there is a monopoly or quasi-monopoly, but enables the undertaking which profits by it, if not to determine, at least to have an appreciable influence on the conditions under which that competition will develop, and in any case to act largely in discard of it so long as such conduct does not operate to its detriment. †5 III.Vertical integration The reason why vertical integration is a particularly relevant competition issue in the media sector is because many media companies have during these past years actively sought to take vert ical integration as far as possible. This has been a constant between undertakings, OJ L 395/1, 30. 12. 1989, as amended by Council Regulation (EC) No 1310/97 of 30 June 1997, OJ L 40/17, 13. 2. 1998. ECJ, United Brands, case 2/76, ECR [1978] 207. ECJ, Hoffman-La Roche, case 85/76, ECR [1979] 461. eature of the concentrations in the media sector assessed by the Commission. The multiplication of the presence of a company throughout a number of markets along the value chain of the product concomitantly multiplies the possibilities for such a company to foreclose one or more of the corresponding markets where the company possesses market power. In these circumstances, vertical integration may in itself raise barriers to entry. A number of recurrent competition issues has arisen in the cases dealt with by the Commission, and I propose to address the most significant ones. 1.The gate-keeper A gate-keeper role is played by a company possessing a certain infra-structure, technology or know -how allowing it to exert a significant degree of control in respect of the access to a given market. This degree of control is relevant from a competition point of view only where the market power of the gate-keeper is significant and where the infrastructure is a crucial gateway to the market or where the technology at stake is an essential input for any potential new entrant. A gatekeeper will be able to engage in exclusionary practices vis-a-vis its competitors and/or excessive pricing vis-a-vis its customers.A clear gate-keeper issue arose in the recent Newscorp/Telepiu case6, concerning the merger of the two Italian pay-TV platforms Stream and Telepiu. As a result of the merger, the new entity would become the gate-keeper in respect of the access to the only satellite platform in Italy for the provision of pay-TV distribution services. Furthermore, it would become the gate-keeper in respect of a number of technical services associated to 6 Case COMP/M. 2876 Newscorp/Telepiu. S ee prior notification notice in OJCE, C255, 23. 10. 2002, p. 20; press release IP/02/1782 of 29. 11. 2002; press release IP/03/478 of 02. 4. 2003. 5 4 5 â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira pay-TV such as Conditional Access Systems, set-top boxes and Electronic Programme Guides. A gate-keeper issue also arose in the AOL/Time Warner merger7 approved in the year 2000. AOL was the leading Internet access provider in the US and the only provider with a presence in most EU Member States. Time Warner, on the other hand, was one of the world’s largest media and entertainment companies with interests in TV networks, magazines, book publishing, music, filmed entertainment and cable networks.The Commission found that the new entity resulting from the merger would have been able to play a gate-keeper role and to dictate the technical standards for on-line music delivery, i. e. streaming and downloading of music from the Internet. Consequently, AOL/TW could end up holding a dominant position on the emerging market for on-line music delivery. This could happen in two ways. First, AOL/Time Warner would be in a position to develop a closed proprietary formatting technology for all the downloads and streaming of Time Warner and Bertelsmann tracks.The formatting language of AOL/Time Warner could become an industry standard and competing record companies wishing to distribute their music on-line would be required to format their music using the new entity’s technology. Because of its control over the relevant technology, the new entity would be in a position to control downloadable music and streaming over the Internet and raise competitor’s costs through excessive license fees. Alternatively, AOL/Time Warner could format its music (and Bertelsmann’s) to make it compatible with its own software Winamp nly, ensuring at the same time that Winamp could support and play di fferent formats used by other record companies. By formatting its music and the music from Bertelsmann to make them compatible with its own software Winamp only, the new entity would cause Winamp to become the only â€Å"player† in the world capable of playing virtually all the music available on the Internet. By refusing to license its technology, the new entity would impose Winamp as the dominant music player as no other player would be able to decode the proprietary format of TW and Bertelsmann music.As a result of the merger, the new entity would control the dominant player software and could charge supra-competitive prices for it. 2. Foreclosure of input markets A given company may hold a significant degree control over the source of the different businesses at stake in the relevant markets, i. e. of the primary input at the top of the value chain of the product. In the media industries, this will generally refer to the company producing the audio-visual product (films, music, TV-programmes) and/or holding the corresponding copyrights.The control exerted at the source will become relevant from a competition law point of view where the amount or breadth of products and/or copyrights is such as to allow the company to gain a competitive advantage by means of exclusionary or discriminatory practices vis-a-vis its competitors. In AOL/Time Warner, for example, the combined entity would not only possess one of the largest music libraries in the world (Warner Music is one of the 5 music majors) but would also, due to contractual links, have preferential access to the library of Bertelsmann Music Group, also part to the group of the 5 music majors.This would result in the combined entity controlling the leading source of music publishing rights in Europe. 6 7 Case COMP/M. 1845 AOL/Time Warner, decision of 11. 10. 2000, OJ L 268/28, 9. 10. 2001. â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes P ereira The problem was aggravated due to the simultaneous notification of the projected merger between EMI and Time Warner8. The preferential access by AOL/Time Warner to the music copyrights of EMI, Warner and Bertelsmann would have put in the hands of the new entity half of all the music content available in Europe for on-line delivery.A similar problem arose in the Vivendi/Seagram/Canal Plus9 merger in respect of both music and films. Vivendi was a leading company in the telecommunications and media sector, with interests in mobile telephony networks, cinema production and distribution, and pay-TV services. Seagram was a Canadian company which, among other interests, controlled the Universal music and filmed entertainment businesses. In terms of content, the merged entity would have the world’s second largest film library and the second largest library of TV programming in the EEA.It would also be number one in recorded music combined with an important position in terms of publishing rights in the EEA. The position of Vivendi/Universal concerning music rights became particularly relevant in respect of the Vizzavi portal, a portal run by a joint-venture between Vivendi and Vodafone. The Vizzavi joint-venture10 had itself been notified to the Commission just some months before the Vivendi/Universal merger. 3. Leveraging A classic competition concern is the leveraging ability of the parties, i. e. their ability to transpose their market power in a iven market into a neighbouring market, thereby creating or strengthening a dominant position. This problem may become particularly acute in cases where the parties extend their activities into different product or services markets, something that is explicitly sought for by media companies wishing to distribute their products across different platforms. In the Vizzavi case, the creation of the jointventure raised concerns in respect of the ability of the parties to leverage their market power in the market fo r mobile telephony into the market for mobile Internet access.The stated purpose of the Vizzavi portal was to create a â€Å"horizontal, multi-access Internet portal†, providing customers with a range of web-based services across a variety of platforms (PCs, mobile phones, TV set-top boxes). As regards Internet access via mobile phone handsets, the issue arose in respect of the significant market position of Vodafone in the market for mobile telephony in a number of European countries (and of Vivendi in France). Vodafone and Vivendi already had a very significant customer basis in these countries and therefore a solid path to the future customers of the JV was already established.On the basis of their client basis for mobile telephony services, the position of the JV-parties in the market for mobile Internet access would be strengthened by the Vizzavi branded and integrated approach to Internet across various platforms, which would allow for cross-selling and bundling of offe rs. This would allow the new entity to leverage a strong position in the mobile telephony market into a dominant position on the mobile Internet access market.As regards Internet access via TV set-top boxes, a similarly solid distribution channel was also owned by Canal+ in respect of its customer basis for pay-TV services. A similar concern therefore arose in respect of the ability of Canal+ leveraging its strong market 7 Case COMP/M. 1852 Time Warner/EMI, see Press Release IP/00/617 of 14. 06. 2000. 9 Case COMP/M. 2050 Vivendi/ Seagram/ Canal Plus, decision of 13. 10. 2000, OJ C 311/3, 31. 10. 2000. 10 Case COMP/JV. 48 Vodafone/Vivendi/Canal Plus, see Press Release IP/00/821 of 24. 07. 2000. 8 Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira position in the pay-TV market into the market for Internet access via set-top boxes. The overall concern therefore arose in respect of the ability of both Vodafone and Canal+ to m igrate their customer basis from the mobile telephony and pay-TV markets to the Internet access markets by using the already existing distribution channels. Another clear vertical leveraging issue arose in the Vizzavi case, as regards the buying power of the J-V parties.Already before the operation, Canal+ was an important buyer of content for pay-TV, such as TVprogramming, sports and films. Furthermore, it had a large customer basis accustomed to pay for content. The Vizzavi portal would combine a powerful new Internet access mechanism with paid-for content. Given the dominant position that the parties would acquire on the Internet access markets which I mentioned before, the operation would allow the parties to leverage their market power in the markets for Internet access into the market for the acquisition of paid-for content for the Internet.Moreover, the structural link between Vivendi and Canal+ and AOL France (55%) made the concern in respect of the increase in the bargainin g power of the parties even more serious. The leverage allowed for by the operation would naturally work in detriment of the parties’ competitors in the markets for mobile telephony and pay-TV. The concerns identified in the Vizzavi operation were strengthened when Vivendi and Canal+ notified some months later their acquisition of Seagram, the Canadian company owning the music and film business of Universal.The Commission considered that Canal+ would further increase its dominant position on a number of European pay-TV markets at national level. Already before the operation Canal+ enjoyed an almost monopolistic position in respect of the acquisition of the exclusivity on Hollywood films produced by the major studios (in France, Spain and Italy). The acquisition of Universal Studios would further strengthen Canal+’s position as purchaser of Hollywood films, not only in respect of Universal itself but also in relation to other studios due to underlying financial links.Du e to the vertical integration of Universal and Canal+, Canal+ would be able to leverage its position in order to secure the renewal of the exclusive agreements for pay-TV with all of the Hollywood studios and in fact also to enter into new deals. The bargaining power of Canal+ vis-a-vis the film studios would therefore be increased, allowing Canal+ to further foreclose the payTV markets where it already was active. 4.Network effects Let me now turn to another issue that often arises in media cases, most notably since convergence with the telecom industry became a reality: network effects. A network effect may, in simple terms, be described as the self-multiplying power of a network. In economic terms, a network effect occurs when the benefit of an individual who is linked to the network increases with the accession of other individuals. In AOL/Time Warner, the Commission found that the distribution strength of AOL combined with the content of Time Warner and Bertelsmann would create network effects n respect of both content providers and consumers: – for content providers, the AOL Internet community would become an essential outlet for the distribution of their products; – on their side, consumers, would be deprived of any incentive abandon AOL. The network effects would work both ways: more subscribers would bring more content and more content would bring more subscribers. Newcomers would also be attracted to AOL community because the 8 â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira arger the community, the more the possibilities to chat and communicate through AOL. The reason for this lies at the critical mass of content owned by Time Warner and Bertelsmann (namely their huge music library) combined with the huge Internet community formed by AOL subscribers and the members to its Instant Messaging services. The critical mass of content owned by TW and Bertelsmann would att ract further music from other record companies. Competing record companies would feel obliged to distribute their products through AOL’s online outlet, which would end up having access to all the available music.Furthermore, AOL would be able to bundle TW and Bertelsmann music content (or filmed entertainment content) with Internet access and other proprietary services and give its subscribers preferential access to that content, allowing for instance its subscribers to access new releases before they were made public through other distribution channels. Attractive content such as music or films could also be used as promotional tools or loss-leaders in order to subscribe to Internetaccess services.Consequently, the more subscribers AOL would attract, the more important it would become as a carrier for content providers seeking to secure maximum distribution. First mover advantages are particularly strong in network industries. It comes as no surprise that, for example, mobil e telephony companies give away, or strongly subsidise, mobile handsets to their customers such as to quickly establish a significant customer basis leading to increasingly stronger network effects.This circumstance justifies a particular attention by the Commission when assessing concentrations in the media & telecom industries. The combination of network effects with a strong market position may significantly raise barriers to entry and consequently lead to market foreclosure. IV. Horizontal integration Competition problems which are specific to the media sector are more likely to be found in cases of vertical integration than in cases of horizontal integration.I would argue that in cases of horizontal integration, the competition issues arising in the media sector are equivalent to the ones to be found in any other sector. The issue basically concerns classic market power and the required exercise translates into measuring such market power with the help of the traditional analyt ical tools: market shares, barriers to entry, etc. Furthermore, there haven’t been that many examples of problematic cases of horizontal integration in the media sector dealt with by the Commission.The two most significant examples are probably EMI/Time Warner and the recent Newscorp/Telepiu. 1. The Newscorp/Telepiu case This concentration was notified to the Commission on 16 October 2002 and was cleared on 2 April 2003, further to the submission by the parties of an extensive package of undertakings. Newscorp, the acquiring firm, is a global media company, which is active in the film and TV industries, publishing (newspapers and books) and a number of other areas.It controlled the Italian (satellite) pay-TV platform Stream jointly with Telecom Italia. Telepiu, the acquired firm, was controlled by Vivendi Universal, itself a global media group. Telepiu is the dominant pay-TV operator in Italy. Its platform started operating via analogue-terrestrial means in 1991 and went on s atellite in 1996. The markets affected by the operation were: a) the market for pay-TV services; b) the markets for the acquisition of contents, namely: 9 Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira G G G G premium films; football events; other sports; TV channels. parties’ music recording publishing11 businesses. and music It should be underlined that experience shows that some of this content, namely premium films and football, is crucial for the success of any pay-TV operation. The notified operation would give rise to significant horizontal overlaps and would have a very strong impact on actual competition.In more concrete terms, the operation would lead to: a) the creation of a near monopoly in the Italian market for pay-TV; b) the creation of a near monopsony in the markets for the acquisition of rights Furthermore, the characteristics of the markets at stake would cause entry barriers to rise signific antly. 2. The EMI/Time Warner case This concentration was notified to the Commission on 5 May 2000. It never materialised given that, further to a statement of objections issued by the Commission, the parties withdrew their notification.Time Warner is a global media company, with interests extending from film production and distribution to TV production and broadcasting, cable systems operation, magazine publishing, book publishing, recorded music and music publishing. EMI is a company incorporated in the UK, its main activities being music recording and publishing world-wide. The notified concentration involved the combination of the There were serious doubts as to the compatibility of the proposed operation with the common market due to the significant horizontal overlaps in the relevant markets.The assessment carried out by the Commission showed a very high likelihood of the operation resulting in a single dominance of the merged entity in the music publishing business and collec tive dominance, jointly with the other four remaining music â€Å"Majors†, in the market for recorded music. V. Remedies Having gone through some of the competition problems raised by vertical and horizontal integration in the media industry, let me now conclude by explaining how the Commission has tried to solve these problems.The Commission had to achieve a balance between two somehow conflicting elements: – on the one hand, the Commission was aware of the reasons that lead companies to seek further integration, namely where these reasons were related to clear efficiencies; – on the other, it became aware of the serious competition problems to which some of these concentrations gave rise, namely the risk of foreclosure of the affected markets. The approach taken by the Commission was therefore not to prohibit most of these operations but rather approving them on the basis of strict undertakings proposed by the parties and accepted as a condition for the approv al.However, the Commission can only accept commitments by the parties when the 11 Music publishing consists of the acquisition by publishers of rights to musical works and their subsequent exploitation upon remuneration, mostly in the form of a commission charged by the publisher to the author on the revenues generated by the commercial exploitation of musical works. 10 â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M. Mendes Pereira competition problems are effectively solved.In fact, the underlying objective of any remedy package should be to create the conditions for actual competition to subsist and/or for potential competition to emerge. This aim must be achieved by lowering barriers to entry in the affected markets and through the creation of competitive constraints which effectively operate as a disciplining and restraining factor of the dominant player. The main concern of the Commission in media-related cases was to ens ure access, access to the relevant markets or access to those crucial elements allowing for new entrants to establish themselves in those markets.In parallel, the Commission has often imposed divestitures or the severance of structural links that aggravated the foreclosure problems. 1. Remedies in the Newscorp/Telepiu case In Newscorp/Telepiu, the undertakings accepted by the Commission can be divided in three major groups: a) access to content, via namely a reduction in the duration of exclusivity agreements with premium content providers and the establishment of a sub-licensing scheme through a wholesale offer; b) access to infra-structure, i. . access to the satellite platform for pay-TV distribution as well as to the technical services associated with pay-TV; c) withdrawal from terrestrial broadcasting activities. As regards access to content, with respect to ongoing exclusive contracts, a unilateral termination right shall be granted to film producers and football clubs. Furthe rmore, the new entity will waive exclusive rights with respect to TV platforms other than DTH12 (terrestrial, cable, UMTS, Internet etc. ).The parties shall also waive any other protection rights as regards means of transmission other than DTH. With respect to future exclusive contracts, the new entity shall not subscribe contracts exceeding two years with football clubs and three years with film producers. The exclusivity attached to these contracts will only cover DTH transmission and would not apply to other means of transmission (for example, terrestrial, cable, UMTS and Internet ). Furthermore, the parties shall waive any protection rights as regards means of transmission other than DTH.Lastly, the merged entity shall offer third parties, on a unbundled and non-exclusive basis, the right to distribute on platforms other than DTH any premium contents if and for as long as the combined platform offers such premium contents to its retail customers. Such wholesale offer will be mad e on the basis of the retail minus principle and will imply an account separation and cost allocation between wholesale and retail operation of the platform. The beneficiaries of the wholesale offer shall be free to determine their own pricing policy.As regards access to the infra-structure, the merged entity shall grant third parties access to its satellite platform and access to the application program interface (API) and conditional access system (CAS), according to a fair non-discriminatory pricing formula. The new entity will also have the obligation of entering into simulcrypt agreements in Italy as soon as reasonably possible and in any event within 9 months from the written request from an interested third party. As regards the withdrawal from terrestrial activities, the merged entity shall divest of Telepiu's digital and analogue terrestrial 2 Direct To Home satellite. 11 â€Å"Vertical and horizontal integration in the media sector and EU competition law† – M . Mendes Pereira broadcasting assets and commits not to enter into any further DTT activities, neither as network nor as retail operator. The frequencies will have to be acquired by a company willing to include pay-TV broadcasting of or more channels in its business plan for the operation of the divested business after the switchover from analogue to digital terrestrial television broadcasting in Italy. . Remedies in the Vivendi/Seagram/Canal Plus, Vizzavi and AOL/Time Warner cases In Vizzavi, the project of the parties provided for the Vizzavi portal to be the default portal on Vodafone and SFR mobile phone customers, as well as on Canal+ set-top boxes. The Commission imposed the possibility of customers changing the default portal on their devices, as well as the possibility of competing telecom operators accessing the customers’ devices.This commitment by the parties prevented them from bundling their offers on a fully exclusive basis and prevented them consequently from l everaging their market power in a way such as to gain dominant positions in the markets for Internet access and Internet portals. In Vivendi/Seagram/Canal Plus, the parties undertook to grant access to Universal’s music content to any third party on a nondiscriminatory basis, therefore reducing the concerns in respect of the Internet portals market and the on-line music market.The parties also undertook not to offer more than 50% of the Universal’s film production to Canal+, thereby reducing the concerns in respect of the foreclosure by Canal+ of the pay-TV markets. As regards the severance of structural links, Vivendi undertook to divest from BSkyB in which it held a 25% stake. The severance of this link to Fox, namely through their joint venture UIP for the distribution of films in Europe, significantly reduced the impact of the acquisition of Universal.In AOL/TW, you may recall that the competition concerns started at the source, due to the breadth of music copyrigh ts that the new entity would control. Warner Music, combined with Bertelsmann music due to crossed shareholdings, and in addition the EMI library (should the EMI/TW merger be approved), would put in the hands of the new entity a huge amount of content that rendered the gate-keeper role played by AOL in respect of music player software and the network effects resulting from the AOL community as serious competition concerns. The abortion of the EMI/Time Warner merger already reduced significantly the competition concerns.Therefore, the attention of the Commission was focussed on the structural link between AOL and Bertelsmann in AOL Europe and AOL France. In this respect, AOL undertook to put in place a mechanism pursuant to which Bertelsmann would exit from AOL Europe. Once solved the problem at the source, the other concerns were partially dissipated. As regards online music delivery, AOL also undertook not to take any action that would result in Bertelsmann music being available on line exclusively through AOL or being formatted in a proprietary format that was playable only on an AOL music player.Conclusion If I had to sum up the Commission’s approach in three words as regards competition in the media markets, they would certainly be: access, access and access! No matter how far media companies integrate, vertically or horizontally, access is crucial. Access to inputs, access to contents and access to infra-structure remains fundamental in order to ensure the freedom of choice by the ultimate addressee of competition policy: the consumer. Thank you for your attention. 12

A Late Aubade

A person praises other of his daily activities and says that he does not waste his time and he utilizes his time in useful activities. He then asks him to bring them some eatables.Paraphrase:Now you could be seated in a carrel and turning rotten page or mounting in a caged lift that was moving toward Ladies’ Apparel. You could be sowing in a rough field of salvia while wearing rubber gloves or contemplating over a series of thought of somebody’s love with a disappointing head. Or you are helping a dejected setter to nurse back to health or paying heed to an unwelcoming lecture on Schoenberg's serial technique.1Is this nit something superior?Consider the whole time you are not dissipating and would not be bothered to throw away. Express gratitude to God that such things are not of your flavor. Take into account the time you have by a woman’s calculations and you who had somewhat lazed in bed and kiss, may use your thought and time for this than something else. You declare that it is about midday?If so, time takes wings and I feel no want to repeat the flowery topic of years old poetry. If you have to leave, stay for a short time and after that move downward and fetch some ice-cold white wine with some blue cheese, crackers and some amount of excellent reddish pears. Â  

Oasis Theory and the Origins of Agriculture

Oasis Theory and the Origins of Agriculture The Oasis Theory (known variously as the Propinquity Theory or Desiccation Theory) is a core concept in archaeology, referring to one of the main hypotheses about the origins of agriculture: that people started to domesticate plants and animals because they were forced to, because of climate change. The fact that people changed from hunting and gathering to farming as a subsistence method has never seemed like a logical choice. To archaeologists and anthropologists, hunting and gathering in a universe of limited population and plentiful resources is less demanding work than plowing, and certainly more flexible. Agriculture requires cooperation, and living in settlements reaps social impacts, like diseases, ranking, social inequality, and division of labor. Most European and American social scientists in the first half of the 20th century simply didnt believe that human beings were naturally inventive or inclined to change their ways of life unless compelled to do so. Nevertheless, at the end of the last Ice Age, people did reinvent their method of living. What Do Oases Have to Do With the Origins of Agriculture? The Oasis Theory was defined by Australian-born archaeologist Vere Gordon Childe [1892-1957], in his 1928 book, The Most Ancient Near East. Childe was writing decades before the invention of radiocarbon dating and a half-century before the serious collection of the vast amount of climatic information that we have today had begun. He argued that at the end of the Pleistocene, North Africa and the Near East experienced a period of desiccation, a period of an increased occurrence of drought, with higher temperatures and decreased precipitation. That aridity, he argued, drove both people and animals to congregate at oases and river valleys; that propinquity created both population growth and a closer familiarity with plants and animals. Communities developed and were pushed out of the fertile zones, living on the edges of the oases where they were forced to learn how to raise crops and animals in places that were not ideal. Childe was not the first scholar to suggest that cultural change can be driven by environmental changethat was American geologist Raphael Pumpelly [1837-1923] who suggested in 1905 that central Asian cities collapsed because of desiccation. But during the first half of the 20th century, the available evidence suggested that farming appeared first on the dry plains of Mesopotamia with the Sumerians, and the most popular theory for that adoption was environmental change. Modifying the Oasis Theory Generations of scholars beginning in the 1950s with Robert Braidwood, in the 1960s with Lewis Binford, and in the 1980s with Ofer Bar-Yosef, built, dismantled, rebuilt, and refined the environmental hypothesis. And along the way, dating technologies and the ability to identify evidence and timing of past climate change blossomed. Since then, oxygen-isotope variations have allowed scholars to develop detailed reconstructions of the environmental past, and a vastly improved picture of past climate change has been developed. Maher, Banning, and Chazen recently compiled comparative data on radiocarbon dates on cultural developments in the Near East and radiocarbon dates on climatic events during that period. They noted there is substantial and growing evidence that the transition from hunting and gathering to agriculture was a very long and variable process, lasting thousands of years in some places and with some crops. Further, the physical effects of climate change also were and are variable across the region: some regions were severely impacted, others less so. Maher and colleagues concluded that climate change alone cannot have been the sole trigger for specific shifts in technological and cultural change. They add that that doesnt disqualify climatic instability as providing the context for the long transition from mobile hunter-gatherer to sedentary agricultural societies in the Near East, but rather that the process was simply far more complex than the Oasis theory can sustain. Childes Theories To be fair, though, throughout his career, Childe didnt simply attribute cultural change to environmental change: he said that you had to include significant elements of social change as drivers as well. Archaeologist Bruce Trigger put it this way, restating Ruth Tringhams comprehensive review of a handful of Childe biographies: Childe viewed every society as containing within itself both progressive and conservative tendencies which are linked by dynamic unity as well as by persistent antagonism. The latter provides the energy that in the long run brings about irreversible social change. Hence every society contains within itself the seeds for the destruction of its present state and the creation of a new social order. Sources Braidwood RJ. 1957. Jericho and its Setting in Near Eastern History. Antiquity 31(122):73-81.Braidwood RJ, Çambel H, Lawrence B, Redman CL, and Stewart RB. 1974. Beginnings of Village-Farming Communities in Southeastern Turkey1972. Proceedings of the National Academy of Sciences 71(2):568-572.Childe VG. 1969. New Light on the Most Ancient East. London: Norton Company.Childe VG. 1928. The Most Ancient Near East. London: Norton Company.Maher LA, Banning EB, and Chazan M. 2011. Oasis or Mirage? Assessing the Role of Abrupt Climate Change in the Prehistory of the Southern Levant. Cambridge Archaeological Journal 21(01):1-30.Trigger BG. 1984. Childe and Soviet Archaeology. Australian Archaeology 18:1-16.Tringham R. 1983. V. Gordon Childe 25 Years After: His Relevance for the Archaeology of the Eighties. Journal of Field Archaeology 10(1):85-100.Verhoeven M. 2011. The Birth of a Concept and the Origins of the Neolithic: A History of Prehistoric Farmers in the Near East. Palà ©orient oasis37(1):75-87. Weisdorf JL. 2005. From Foraging To Farming: Explaining The Neolithic Revolution. Journal of Economic Surveys 19(4):561-586.Wright HE. 1970. Environmental Changes and the Origin of Agriculture in the near East. BioScience 20(4):210-217.

20 Creative College Halloween Party Ideas

20 Creative College Halloween Party Ideas Gearing up for Halloween is one of the best parts of fall. If youve let the part planning slide a bit, dont worry. Weve rounded up twenty tips that will let you piece together the perfect party complete with decorations, costume ideas and even help with the nibbles. Set the Scene 1. Have a classic horror movie playing in the background. If youre going for a classic Halloween party vibe, choose a series of scary movies to have playing in the background. Running every installment of Friday the 13th or Nightmare on Elm Street is a great way to get people talking and provide the perfect backdrop for Halloween. Keep the volume low and limit it to one TV set – be sure you have music playing elsewhere. 2. A great play list is a work of art. Dont leave setting your music until the last minute. This isnt the time to throw your MP3 collection on shuffle and hope for the best. Comb through your collection and ask friends to chip in as well. Include every Halloween reference you can by including tunes from modern artists like Rob Zombie and the classic rock group the Zombies. 3. Set the table. If youre using one large table for food, cover the top with a black sheet and put striped socks on each leg. Finish the look with old shoes at the bottom of each leg – instant witchs table! 4. Get every room. Make sure every room guests will be in is decorated – including the bathroom. Rolls of crime scene tape, â€Å"bloody† hand prints made with dyed corn syrup and plastic bugs and snakes can all give a room an instantly creepy feel. Costume Themes 5. The Time Travelers – Everyone has to come dressed up as themselves from the last year in junior high. 6. 8-Bit Party – Have your guests dress as their favorite 8-bit character. Extra points for guests who can imitate their characters signature sounds like being able to talk in Q-Bert or beat their chest like Donkey Kong. 7. Still a Better Love Story than Twilight – Have guests come as any two-some they want. Meanwhile team up with a fellow party host (or hosts) to dress as the main characters from Twilight. 8. Rick Astley, LOLCatz and More Cowbell – Guests can dress as their favorite internet meme. 9. Saturday Morning Cartoons – Guests dress up as their favorite character from Saturday Morning cartoons, past or present. Offer special prizes for the oldest character. 10. Fast Forward – Pick your favorite reality show personality and then dress as them 30 years in the future. What will a 40 year old Honey Boo Boo look like? How about a 60 year old Snooki? Take a look at our blog on Halloween costume ideas if you need more ideas! Decorations 11. Hit the local thrift shops. Thrift stores may have some Halloween items, but youre really looking for creepy dolls, half broken toys and clothes that would make a zombie turn around and walk the other way. Remember – one mans trash is another mans nightmare. 12. Fill clear latex gloves with candy and tie the wrists with ribbon. Spread them around the party as handy candy for people to take away with them. 13. Get back in touch with your childhood cutting skills. Take a garbage bag, fold it into a triangle, then again. Cut away panels and then open it – instant (and huge) spider web. 14. Make a massive spider for your new web. Get a foam ball core or just crunch up tin foil. Use foil covered pipe cleaners for the legs. 15. Make glow in the dark balloons. Pick up plain white balloons from a dollar store and put a glow stick inside before you blow them up. Do them right before guests start to arrive so the sticks stay bright throughout the party. Food Ideas 16. Hands in the Punchbowl. Get two rubber gloves and wash the inside really well to get out any powder. Fill with water, freeze then pop out two perfect disembodied hands to keep your punchbowl chilly. 17. Recruit the help of chemistry students. Have your friends bring in beakers and flasks and serve drinks in them instead of glasses or cups. 18. Make Brain cupcakes. Get a frosting bag with a thin tip or just grab an empty ketchup or mustard squeeze bottle. Make cupcakes per normal but ice them with white frosting in thin lines to replicate the look of brains. 19. Fossil Cookies. Make sugar cookies per normal. Press plastic bugs into the top of each cookie, remove then freeze until set (about 30 minutes) Bake as usual and serve. 20. Bleeding Heart Cake. Fill a heart shaped cake tin with opaque pink Jello and let it set. Then fill a plastic bag with corn syrup and red food coloring, strawberry jam or blended berries. Set the bag in the middle of the set cake and fill the tin with another batch of solid pink Jello. Let the whole thing set overnight and then serve. Use a Psycho knife to cut and be sure to remove any bits of the plastic bag before serving it to your guests. Have you thrown an epic Halloween party? Share your own tips for a historic Halloween below. If you are too tired to throw a party on your own, you can visit one of scariest Halloween hapennings. Happy Halloween!

Describe the concept of privacy as an implied right and provide Essay

Describe the concept of privacy as an implied right and provide examples to demonstrate how different governments protect or infringe upon this right - Essay Example Several governments have enacted laws to maintain privacy. For instance, the G8 nations met in Washington (1997) and together decided to tackle high-tech crimes. The US government has some laws on safekeeping of network and computer, fortification of consumer and distance selling, protection of privacy and data. The UK government has played a part in privacy protection because of the ongoing growth and outburst of computing cloud, which impose a challenge to information technology. Hence, in November 2010, European commission, proposed a â€Å"right to be forgotten†. This enables internet users to delete their information on social networks permanently and further the progression of nondisclosure of information. Some governments have formed organizations to combat such cases like in Asia the very first response to incidence organization called â€Å"Korea Computer Emergency Response Team and Coordination Centre† (CERTCC-KR). In conclusion, it is clear to say that privac y is a solemn issue that should not be ignored (Sembok,

BUSN300 UNIT 5DB Research Paper Example | Topics and Well Written Essays - 250 words

BUSN300 UNIT 5DB - Research Paper Example In general both of them can be used interchangeably in studying, meaning that one can be used while implementing a project (Haugan, 57). The primary role of PERT is to identify the critical path that a project takes from planning to completion. It lays down the activities that need to be done in the entire project period giving the timelines to be used in implementing a series of activities performed either sequentially or parallel with other activities. In the flow chart, the initial stage of project implementation must start from step 1 before it proceeds to step 2. Some part of the project can directly go straight to step 5 from step 2 so long as at this stage it is independent. A part of the project can go through step 3, on the diagram, before finalizing at step 5. Still, some task can take the direction through step 4 and end at step, so long as it is independent of step 2 and 3. Each step has planned number of days, weeks or months to complete. It can be in terms of days, weeks or even months. Step 1 to step 4 and eventually to step 5 can take months while in the other hand, step 1 to step 2 can take days or weeks and step 2 to step 5 can take months or several weeks. Through step 3, the timeline can be months but eventually ending at step 5. Each step’s timeline can be different, but when implemented either in parallel or concurrently, it will all end at step 5 at the project completion stage. All stages of the process are what are referred to as the critical path that the project takes in order to realize completion as planned. The stages have to be meticulously planned and implemented as planned in order not to delay the entire project from completion. The steps have to be synchronized accordingly, and necessary resources should be allocated and availed in time. Such resources include tools and equipment, labor and materials. The necessary inspection and servicing of tools and equipment should be done to reduce chances of breakdown. All materials

What are fusion centers and how are these a part of homeland security Research Paper

What are fusion centers and how are these a part of homeland security Are they effective - Research Paper Example This goal can only be achieved successfully when the local law enforcement agencies work together with the federal intelligent agencies by sharing any threat information. This was clearly stressed in the 9/11 commission report. Former US president George, W. Bush on August 3, 2007 signed the 9/11 Commission Act of 2007. With reference to the 9/11 Commission Act, the department of homeland security should have formal discussions with program directors of information sharing context and the attorney general so as to create a state, local, and regional fusion centers initiates (Abbott and Hetzel,2010). The centers are made up of representatives from local law enforcement, state and federal agencies. Federal intelligence officers also form part of the centers. When the centers get any threat information from the federal government, it is their task to analyze the information, ensure the information is disseminated to the local agencies then gather inside information they have received, l eads given and the suspicious activity reporting by the public and also local agencies. The idea of fusion has sprung up as the most important process to enhance the ability of sharing information that assists in providing homeland security and also sharing of any information that helps in knowing of any criminal activities taking place and also sharing of intelligence (Abbott and Hetzel, 2010). The fusion process involves a comprehensive process of controlling the flow of any threat information and intelligence through different levels and sectors of the private agencies and the government. After receiving information from various sources, that is; the public, law enforcement agencies, and the private sector agencies; the information is then analyzed and afterwards turned into applicable knowledge. Fusion centers do not merge all federal databases that reveal personally recognizable information with

The Sovereignty EU Parliament

The Sovereignty EU Parliament Sovereignty of Member States (UK) after joining European Union structures – does it still exist? It is important first to address what the perception of the doctrine of supremacy is to then examine what effect membership of the European Union has had on the sovereignty of the United Kingdom Parliament. The doctrine of Parliamentary sovereignty in the UK can be traced back to the Glorious Revolution of 1688, which is considered by some as being one of the most important events in the long evolution of the respective powers of Parliament, establishing the superiority of statute over prerogative powers. Parliament’s legislative supremacy involves not only the right to change the law, but that they alone should have that right. By the sovereignty of Parliament it is meant that there are no constitutional limitations on legislative powers of ‘Parliament’: the Queen in Parliament, through which a Bill approved by the House of Commons and House of Lords receives Royal Assent and becomes an Act of Parliament. It also extends to include the concept that the courts are under an obligation to give effect to legislation passed by Parliament, and not to question Parliamentary decisions embodied in statute. Thus defined, Dicey said of Parliament, which is had ‘under the English constitution, the right to make or unmake any law whatever; and further that no person or body is recognised by the law of England as having a right to override or set aside the legislation of Parliament.’(Dicey, The Law of the Constitution 1885 p39-40). This statement by Dicey exemplifies the classic interpretation of the doctrine of Parliamentary sovereignty. However, the Diceyan concept of the absolute, infinite sovereignty of Parliament is considered out of date and therefore in need of being revised. The impact of European law on the ‘sovereignty’ of Member States is one of the most controversial aspects of its working. Sovereignty is generally taken to be the capacity of a state for independent action both within and outside its own territory. That definition may be broken down into three elements. First, and most importantly in the context of international law, comes external sovereignty or the capacity of a state freely to determine its relations with other states or international organisations. A state possessing such capacity is clearly independent of other states. So, in this context, independence is a near synonym for external sovereignty. The counter part of (and necessary condition for) external sovereignty is internal sovereignty which is a state’s exclusive right and jurisdiction to establish its own internal institutions, to make the necessary arrangements for their working, to legislate for all purposes and to secure observance of such legislation. Finally territorial sovereignty is the exclusive authority which a state may exercise over anything or anybody within, above or beneath its territory. This includes the jealousy guarded right to regulate access to the air space above the territory or, for example, to seize foreign submarines which encroach within the territorial waters of a maritime country. Clearly, sovereignty as so defined cannot be absolute. All states must respect the sovereignty of others and accept limitations to their sovereignty stemming either from their interaction with other states or, for example, from treaties which they have entered into. Sovereignty is defined as the ultimate overseer or supreme authority in a state.   In a state sovereignty is vested in the institution, person, or body to impose law on everyone else and to alter any pre-existing law. The word sovereignty is also defined in another ways. Nation states are said to renounce part of their sovereignty, for example by signing a Treaty or by agreeing to an EU Directive which removes the right of decision from the national government or parliament in a particular field. Or they are said to share sovereignty by agreeing to common action though EU institutions, thus participating in decisions taken by the EU in accordance with its procedures, and no longer retaining the right to act unilaterally. In this use of sovereignty it virtually means the same as freedom to decide unilaterally. Before analyzing sovereignty of UK after joining the EU, it is important to outline the reasoning for the supremacy of Community Law from the Community point of view, and then a definition of Parliamentary sovereignty will be given. To summarise the Community view on supremacy according to the Court of Justice is that Community law, because of its unique nature, denies the Member States the right to resolve conflicts of law by reference to their own rules or constitutional provisions. Community law obtains its supremacy because of the transfer of state power and sovereignty to the Community by the Member States in those areas agreed. Furthermore, the Member States have provided the Community with legislative powers to enable it to perform its tasks. There would be no point in such a transfer of powers if the Member States could annul or suspend the effect of Community law by later national law or provisions of the constitutions. If that were allowed to be the case, the existence of t he Community legal order and the Community itself would be called into question. A precondition of the existence and functioning of the Community is the uniform and consistent application of Community law and the Community legal order in all the Member States. It can only achieve such an effect if it takes precedence over national law. Therefore the legal and logical consequence of this is that any provision of national law which conflicts with Community law must be invalid. Now that the supremacy of the Community has been considered, Parliamentary sovereignty must now be considered. Basically, in terms of dicey, the doctrine of Parliamentary sovereignty means that there are no legal limitations of Parliament and it has the right to make or unmake any law whatsoever. Further, no person or body is recognised as having a right to override or set aside the legislation of Parliament. The doctrine also implies that it is impossible to bind future Parliaments. Any subsequent Act expressly or impliedly overrides a prior Act and even international treaties can be expressly overridden by municipal. The UK’s membership of the European Union produces difficult questions of competing supremacies of Parliament and the primacy of EU law. Britain’s accession to the European Economic Community on 1st January 1973, was described by Anthony King as having â€Å"profound constitutional consequences†. (Does the United Kingdom Still Have a Constitution? 2001 p54) Britain’s application for membership was made in 1967, the Treaty of Accession signed on 22nd January 1972 and this was implemented by the European Communities Act 1972. The basis of this Act was a white paper published by the Labour government in 1967, intended to address the constitutional implications of membership of the EC. The paper pointed out that the effect of the UK adhering in advance to future instruments imposed by the Community institutions had no precedent in this country, and would result in a ‘constitutional innovation’. Whether this innovation could be successfully impleme nted was never resolved before the introduction of the 1972 Act. Many have said since our membership in 1973 that our sovereignty has been said to be handed over to the EU. The issues surrounding sovereignty in the UK system are affected by Britain’s membership of the European Union (EU). The laws of the EU are binding on all member states, and therefore, take precedence over British domestic law. Apart from a few exceptions, EU legislation automatically becomes law within the UK, irrespective of the opinion of the British Parliament. Although this is the case, parliament could agree to repeal previous legislation, withdraw from the EU to demonstrate that parliamentary sovereignty still exists. Therefore this leads to the argument that Britain has kept its sovereignty with the fact that it could pass an Act to, â€Å"renounce the Treaty, or would that be an illegal act of rebellion?† (Norman Tebbit Nov. 1998) However, I believe this to be unlikely unless one of the mainstream political parties were to adopt a strong anti-EU policy. T he 1986 Single European Act and the Maastrict Treaty can be seen as reducing Britain’s sovereignty since they have extended the range of policy areas on which the EU can legislate. This has caused many British Conservative members of the European Parliament to continually vote against many proposals, not because they necessarily disagree with them, but that they think they should be dealt with at a national level. Upon Britain’s accession to the EU in 1973, direct effect was accepted by us pretty much immediately. However this was completely opposite when it came to the United Kingdom accepting the supremacy of EU law. This was seen to be a problem because the doctrine conflicts centrally with the concept of having British constitution of ‘parliamentary sovereignty.’ The acts of parliament override all existing law or legislation. However in 1990 the House of Lords found a way to reconcile British parliamentary sovereignty and supremacy. As on a reference from the House of Lords, the European Court of Justice ruled that a 1988 act of British parliament was in breach of EU law. â€Å"The House of Lords accepted the judgement on the grounds that in passing the 1972 act of accession to the EU, British parliament had voluntarily accepted the EU legal system of which the supremacy of EU law is a central part. The House of Lords also argued that this does not compromise parliamentary sovereignty, as a future British parliament could repeal this act of accession.† (The political system of the European Union, Simon Hix, Macmillan Press, London, page 117) Britain’s entry into the European Treatys has attracted huge reform, as British Parliament must legislate in conjunction with EU law. And Acts and Laws already in existence must be interpreted to conform to EU Law, and the State has to ensure that all EU law is transposed and implemented accurately. This puts a huge strain on the Courts whilst ruling, thus making a mockery of Precedent as any case incorporating EU legislation can only be considered using the purposive approach, in order that EU directive can be met. So then this means that Britain has not in fact reserved its sovereignty as promised when first mentioned to the public all those years before. To understand the concept, we first need to acknowledge the unwritten code of the constitution and its efforts to ensure that Parliament is the executive law producing body of the land. And so, any Act of Parliaments will need to be adhered to directly by the applicable national court. In the case of Regina v Secretary of State for Transport, ex parte Factortame it is easy to see the ingratiating manoeuvres of The House of Lords as it bows to supremacy of EU law.