The Importance of Conclusions

For many people, the most difficult part of writing a blog post is the conclusion. Conclusions can be tricky, but treating them as an afterthought is a recipe for reader apathy. In order to write more memorable posts, you need to finish with a bang. The Importance of a Strong Conclusion Like great sporting moments or dramatic performances, it’s the strong finishes that people remember most – the touchdown in the final minute or the crescendo at the end of a symphony. Unfortunately, many blog writers rush the conclusion and the post just fizzles out. If you want people to share your blog post, talk about it and take further action, you need to put more effort into the conclusion. A compelling conclusion will: Encourage readers to leave comments. Boost subscriptions to your blog. Convert more visitors into leads. Increase click-throughs to other blog posts. Boost shares via social media. Keep more users engaged with your brand. A Strong Conclusion Includes a Call to Action Again, your article has a purpose. Whether that purpose is saving the tuna or informing a reader about a local insurance agency, your conclusion should encourage your reader to carefully consider and act on the information you’ve just presented. There’s no one right way to structure a concluding paragraph, but there are certain guidelines you can following when putting one together. Start with a transition from the previous paragraph. In a regular conversation, you rarely just stop what you’re saying and say goodbye. The same is true with your website articles. Craft a good sentence that will move from the paragraph before to the conclusion. Give a more forceful version of your thesis statement. This is the place to really hit the reader with your message. State your intent strongly and plainly. State your final thoughts. Here, you should explain why your message is important and end the article. There’s no right way to build a concluding paragraph, but there are plenty of wrong ways. Remember to keep your message as the most important part of your article. A conclusion will adequately end your article while giving your reader something to think about or act upon. Don’t just walk away from your reader; make your ending important. A concluding paragraph is a way to say goodbye to your reader and make sure that the message you wanted to convey is presented one more time. Abruptly ending your article is the same as simply walking away from someone mid-conversation, so don’t do it. Use a conclusion to neatly bookend your article. 7 Conclusion Writing Techniques 1. Answer the Question â€Å"So What?† Your article probably has an important message to deliver; after all, you’ve set aside time to actually write about it! So take the opportunity to say why your message is important. For instance, if you are writing content about reducing tuna fishing in the North Atlantic, you might want to mention how the extinction of tuna would affect the environment. Make the message the centerpiece of your conclusion and make a statement of that message’s importance. One way to approach this is by asking yourself, â€Å"so what?† What’s the significance of the information your just shared? 2. The Summary If you do nothing else, a quick review of your post is a simple way to end any article. But instead of simply summing up your main ideas, try to show how all your ideas fit together. In other words, synthesize, don’t just summarize. Like a lawyer’s closing argument, your conclusion should tie together everything you’ve covered and really pack a punch. To find out the core issue of your blog post, ask yourself: â€Å"So what?† Then use the answer to drive home your message. 3. The Full Circle Technique Look back at the introduction of your blog post. Are there any metaphors, images or anecdotes you can return to? By letting your introduction inspire your ending — perhaps by repeating a word or phrase — you can make your post seem more complete and give your audience a sense of closure. 4. The Pan to the Horizon Try to tie your topic to a larger issue, or make the reader think about similar issues that relate to the main theme. This gives people something more to think about after reading your post. This technique is really useful for blog posts that are a part of a series. It’s a simple way to call attention to other related posts, or persuade readers to come back to learn more about a subject in future content. 5. The Question Master At the end of many blog posts, the writer will ask the reader a question. It gets people thinking. For example, you could question their behavior and attitudes, or ask for further ideas in response to your article. This is a great way to encourage more comments on your blog. 6. Be Yourself People are more likely to take notice if you reveal more of your personality. Being more emotional, transparent or even controversial will help set you apart from every other blog writer. Try writing the same way you speak. Include your own quirks of language and style, but avoid clichà ©s. It will all help to make your conclusion more memorable. 7. The Phantom Ending Exercise If you’re struggling to come up with effective conclusions, here’s a simple exercise to get your brain in gear: Copy someone else’s blog post but leave out the last paragraph or conclusion. Now read the post and try to write your own conclusion. When you’ve finished, look at the original conclusion and compare it to your own. How does your version differ from the original? Is there anything you can learn from the original to make your version better? Over to You Everyone always talks about the importance of first impressions, but last impressions can pack a powerful punch. Strong conclusions make your writing more engaging, your ideas more memorable and inspire readers to take action. Do your posts finish with a bang? If you find endings tricky, these techniques are a great place to start. Try them out when you write your next post, and see how your audience reacts. Are there any special techniques you use to make conclusions more memorable? We want to know! Share your tips in the comments section below.

John Lennons Death essays

John Lennon's Death essays John Lennon was shot December 8th 1980 in New York by a man named Mark Chapman. As the limo pulled up and Lennon and his wife stepped out, Chapman pulled out a revolver and shot Lennon. With two bullets in the back piercing his lungs, a third. Shattering his shoulder bone, the fourth and fifth shattering his wind pipe. After shooting Lennon, Chapman sat on the sidewalk and read. Lennnon stumbled into the hotel bleeding to death. He was soonrushed to the hospital where doctors used every devide imaginbable to bring jogn back, but nothing worked. The official cause of death was shock produced by massive haemorrhaging, he lost 80% of his blood. There has never been a public trial, causing mystery about Chapman's motive. Chapman had a history of disillusuions starting from his early child hood. As a teen Mark heard the voices of "little people" that he believed lived in the walls of his bedroom. This disturbed mental state later lead Chapman to attempt suicide and be put in psychiatric counselling as he battled paranoid schizophrenia. Chapmans behavior was guided to the events of Dec. 8th by subliminal "clues" and special signs that he felt were ment for him through John's lyrics and music. Mark belivedhe was able to recieve these hidden messages that the rest of us could not. Through this he turned the murder of John Lennon into somewhat of an heroic act. The only question i have, could be simply summed up as "why?". I could probably read into it and learn more about the lyricsa that Mark Chapman had thought were intended for him, but there is still a whole side to it. A side in Chapman's brain that i supose none of us will ever understand. I can only see this as a very unfortunate acident that happened to Lennon, because Chapman"s mental state couldn't have been helped at the time, because in chapman's mind he had done the right thing. No one could have changed that thinking. John Lennon was a music legend. Had he st...

Working in business Assignment Example | Topics and Well Written Essays - 2750 words

Working in business - Assignment Example This portfolio development had considered the Big five forces of personality development to understand the factors that are required for my own development. The reason for using Big five forces is that it has been identified as an integrated framework that allows in understanding about a person’s normal personality. Meta-analytical studies on the Big five forces have revealed that there are certain deviations in the conclusions reached by researchers. For instance, the work of Leung and Bozionelos (2004) have shown that extroversion, conscientiousness and emotional stability have a strong positive correlation with effective leadership qualities but same cannot be said about the other two dimensions that namely agreeableness and openness. From the results that have been obtained it can be argued that I have to develop on three main aspects of my personality namely neuroticism, extraversion and conscientiousness. Researchers have found out that development of neuroticism is directly related to development of emotional stability to handle stress. It has been observed that Extraversion is related to managing relationships with others in a smoother manner (Bartone, et al., 2009). Similarly, conscientiousness is related to being dependable and reliable for others. These findings are consistent with the findings of Judge & Ilies (2002) who had found that among the five factors of personality development it is extremely important to develop extroversion and conscientiousness. I am an efficient worker yet I tend to lose focus at times of high stress. This can malign my reliability and dependability to some extent. My personal experiences have shown that I need to improve my understanding of cultural differences in a better manner. There have been instances in my life where I have been unable to perform under levels of high stress showing that I need to develop on my neuroticism. I have found that when I am

ISSUES IN CRIMINAL JUSTICE Essay Example | Topics and Well Written Essays - 1500 words

ISSUES IN CRIMINAL JUSTICE - Essay Example 21). In the event that such a situation arises, the judges must ensure proper interpretation of the statute before applying the statute in a case. The interpretation of such statutes is important to ensure proper identification and elimination of any ambiguity in the statute before applying the law in deciding a given case. However, this has never been an easy undertaking to many judges. As a result, in interpreting any statute, they must follow certain rules and procedures contained in the Interpretation Act of 1978. Apart from following the rules and procedures contained in the Interpretation Act of 1978, judges also have certain rules that help them in interpreting a statute with an ambiguity or error. The first rule that judges must apply in the interpretation of any given statute is the literal rule. Normally, under the literal rule, the judges to a case are required to give the statute its ordinary meaning without any amendment. This implies that the statute is taken the way pa rliament has made it without making sense of the law as applied in the case of R v Harris (1836) 7 C & P 446 (Gifford 1990, p. 14). In this case, the defendant was accused of biting the nose the plaintiff’s nose. ... The judges attributed this to the fact that the words stab cut or wound in their literal meaning means there is the use of an instrument. This resulted in the squashing of the defendant’s conviction, as noted by (Sullivan 2007, p.38). The same literal rule was applied in the interpretation of ambiguity, in statute, in Fisher v Bell [1961] 1 QB 394. In this case, the statute the defendant displayed a knife at the window of his shop with a price tag indicating that it was for sale. This is notwithstanding the fact that the statute law criminalized any offer for sale of a flick knife. However, the court quashed the defendant’s conviction on grounds that displaying goods in a shop does not constitute to an ‘offer,’ rather an invitation to treat. The judges also applied the literal rule in the interpretation of Whitely v Chappel (1868) LR 4 QB 147(Solan 2010, p.31). The judges can also apply the golden rule in the interpretation of a statute. The golden rule is mainly applied in the interpretation of a statute where the judges feel that the use of the literal rule may result in absurdity or inconsistency. As such, the event that the judges are convinced that applying the literal rule may result in inconsistency or ambiguity then they are allowed to proceed and apply a secondary meaning of the statute. The application of the golden rule has been demonstrated in a number of cases in the past. One such was in R v Allen (1872) LR 1 CCR 367 in which the defendant was accused of bigamy (Solan 2010, p. 28). The statute at that time prohibited bigamy by maintaining that any person already married cannot marry another person as long as the other partner is still alive. When deciding the case, the judges noted an ambiguity as

A fundamental objective of the Land Registration Act 2002 Essay

A fundamental objective of the Land Registration Act 2002 - Essay Example The Land Registration Act 2002 aims at allowing prospective buyers of land know the existence of any equitable interests that may be attached to the land1. The basic assumption of the law is that prospective buyers should not take the burden of verifying the adverse interests attached on the land, but should rely on the land register that reflects any equitable interests attached to the land2. The Act also eliminates most of overriding interests in land by ensuring the duty of disclosure and reasonable inspection of interests attached to land3. This paper will mainly focus on the main provisions of the Act that has ensured accurate and timely reflection of the status of title of land. The enactment of the act provided a new breakthrough in the land title registration and verification since it changed the mechanism of sale and purchase of registered land from paper based transactions to electronic transactions. The Act followed the three principles articulated by Thoedore Ruoff, a for mer Land registrar of England. The principles are ‘mirror principle, curtain principle and insurance principle. For unregistered land, the title of the land must be inspected under the old rules and seller must prove 15 years unbroken chain of the title from the root of the title. The purchaser has the duty to register his title to the register within the stipulated time, failure to which he or she will lose his legal estate in the land. The Land registry provides a description of the piece of land, the legal owner and any other interests that may affect the value and ownership of the land. ... The electronic network capturers all transactions related to the land including the registration of the title by the parties. The Act has laid down formalities relating to electronic conveyance such as time and date when the electronic dispositions should take effect. All the electronic signatures must be authenticated and such electronic documents must be signed by all involved parties. Section 4 (1) (g) of the Act requires registration on the creation of a protected first legal mortgage that is protected by the deposit of title deeds and also registration of leases with a term remaining of more than seven years. The Act also grants the land registrar powers to use transaction information on the network in order to monitor and disclose such appropriate information to other parties in electronic conveyance chain5. The Act also facilitates electronic settlement by granting the Land registrar the powers to form or assist in formation of a company or invest in a company with this system of electronic settlement. In the case of Abbey National Building society v, Cann, the main concern was the registration gap that occurs when an interest is created at the point of registration but before completion6. However, The House of Lords ruled that a party must have actual occupation of the land at the date of completion of registration of any interest to land in order to attain an overriding status to the land. In practical basis, the purchase of the land is not completed on the day the purchaser makes official search, but after few days has lapsed. Provided the purchaser lodges a registration within the stipulated period, he or she is not bound by notices or restrictions that may be made within the intervening period7. Section 7 (1)

Understanding Your Personal Worldview

Understanding Your Personal Worldview Understanding your personal worldview is important because this is how we assess all aspects of life the world around us and our place in it. The Christian worldview the laws of logic are universal and unchanging because they reflect the nature of the living God. How do people define the terms God, Ethics, and Knowledge? How do the terms affect the daily lives of others? I have found during my worldview search, that these three components play a huge role in how I shape my thoughts experiences, education, and life decisions. My beliefs about the existence and the character of God (Theology), the nature of Knowledge (Epistemology), and discussing the main question is truth relative? In addition I have discussed my beliefs about Ethics (Morality) and who is right and wrong? Who defines right and wrong? Are the moral laws the same for all people in all cultures? It is difficult for the natural man to believe in something he cannot see, touch, or feel (1Cor.2:14).The question for the Christian is solved with the first verse in the Bible. In the beginning God created the heaven and the earth (Gen.1:1) the greatest proof in addition to scripture is our daily fellowship in prayer, Gods revelations and our personal experiences. (Psalms 19:1) states The Heavens declare the Glory of God and the firmament shows His handy work. This passage is clearly saying there is no excuse for man not to believe in God, for the beauty and the glory of the Heavens speak loudly saying God exists. Knowledge is possible because of how God has made us. We learn from our senses our experiences, but all true knowledge is ultimately dependent upon God. (Proverbs1:7).The fear of the Lord is the beginning of knowledge: but fools despise wisdom an instruction. Ethics, or that which is good, is a reflection of the character of God. God is the standard of good by which all things are measured, and his standards are revealed through his word. Moral laws are pretty much the same in all cultures, but their moral reasoning can be different depending on the specific culture. But seek first the kingdom of God and His righteousness, and all these things shall be added to you.(Matthew 6:33). The only real ethic is to glorify God by having faith in him and giving his kingdom priority in our lives. God has given us his revelation and to guide us in ethics, in knowing what we should and should not do. The book of Proverbs was given to us to teach us the right conduct. To know wisdom and instruction; to perceive the words of understanding, to receive the instruction of wisdom, justice and judgment, and equity: to give subtlety to the simple, to the young man knowledge and discretion. A wise man will hear, and will increase learning; and a man of understanding shall attain unto wise counsels. The fear of the Lord is the beginning of knowledge: but fools despise wisdom and instruction. Clearly the Bible teaches that truth is absolute and that it exists under the authority and revelation of Jesus Christ. Religion describes our connection to God as the one thing that exists. From this foundation we see the clear connection of how our worldviews are formed. Understanding ones personal and Christian worldviews are important, because they are determining factor of our moral code and ethics, and other beliefs. These worldviews give us a general picture of all reality, which we relate our experiences and knowledge. It helps us to put our daily experiences and choices into clearer prospective. (Cosgrove, p. 28) As a Christian my worldviews are important for my on salvation, for the well-being of my family, for the betterment of my community and workplace. A Christian worldview is powered by knowing the Spirit that lives inside of us is greater than the spirit who lives in the world. I can do no less than to love the Lord thy God with all my heart and soul. The same came for a witness, to bear witness of the light that all men through Him might believe.(1 John 7) Conclusion In conclusion the personal world view is a substantial part of how we relate to life, world events, each other, and helps us determine our part in this introspective living experience. The Christian Worldview and how it supports Christianity, which is necessary in building a relationship with the Living God. People across the world have their individual personal views relating to God, ethics, and knowledge and strive to perfect their religion, which is necessary in building a relationship with the creator.

Fed and Interest Rates Essay example -- essays research papers

The Fed and Interest Rates Dave Pettit of The Wall Street Journal writes a daily column that appears inside the first page of the journal's Money & Investment section. If the headlines of Mr. Pettit's daily column are any accurate record of economic concerns and current issues in the business world, the late weeks of March and the early weeks of April in 1994 were intensely concerned with interest rates. To quote, "Industrials Edge Up 4.32 Points Amid Caution on Interest Rates," and "Industrials Track On 13.53 Points Despite Interest-Rate Concerns." Why such a concern with interest rates? A week before, in the last week of March, the Fed had pushed up the short-term rates. This being the first increase in almost five years, it caused quite a stir. When the Fed decides the economy is growing at too quick a pace, or inflation is getting out of hand, it can take actions to slow spending and decrease the money supply. This corresponding with the money equation MV = PY, by lowering both M and V, P and Y can stabilize if they are increasing too rapidly. The Fed does this by selling securities on the open market. This, in turn, reduces bank's reserves and forces the interest rate to rise so the banks can afford to make loans. People seeing these rises in rates will tend to sell their low interest assets, in order to acquire additional money, they tend move toward higher yielding accounts, also further increasing the rate. Soon this small change by the Fed affects all aspects of business, from the price level to interest rates on credit cards. Rises and falls in the interest rate can reflect many changes in an economy. When the economy is in a recession and needs a type of stimulus package, the Fed may attempt to decrease the interest rates to encourage growth and spending in the markets. This was the case from 1989 until last month, during which the nation's economy was generally considered to be in a slight to moderate recession. During this period the Fed tried to keep interest rates low to facilitate growth and spending in hard times. However, when inflation is increasing too quickly and the economy is gaining strength, the Fed will attempt to raise rates, as it did late last March. This can be considered a sign that we are pulling out of the r... ..."slight" increase as opposed to one of "somewhat greater" magnitude. This article is interesting because it shows that even the Fed can be uncertain about what is best for the economy, but it still focuses on the power of Allen Greenspan, as well as the committee as a whole. It compares the two arguments of each method, and shows a weakness in the Fed that may have been unknown to the reader before. The Wall Street Journal (Mon. April 11, 1994) - "Fed Moved Too Slow On Increasing Rates" This recent article criticizes the Fed's actions in raising the interest rate, and complains that the Fed has fallen behind in it's job. It discusses the plan for a "Neutral" policy and what the Fed has tried to do and not do to maintain this so called policy. It argues the motives and reasons for wanting a lower interest rate and compares past decades to today's standings. Overall it focuses deeply on the need to check inflation and if it is valid. It shows that the Fed tends to take a more conservative approach to the economy than some analysts would prefer, but that the Fed will probably continue to raise interest rates.

Childhood Essay

Though many are of the view that childhood is the happiest time of a person’s life I do not think we can generalize it is so. Of cause childhood is a very enjoyable phase in a man’s life which is free from many responsibilities and challenges of the adulthood. However I believe there are several conditions that need to be satisfied for a happy childhood. First and foremost, a child should have loving and caring parents who could provide physical, emotional, social and intellectual needs of their child. How many children have such parents today? There are thousands of children raised by foster homes or orphanages. Most of these children have never experienced the love of their mothers or fathers. In fact many a them even do not know who their parents are. These children are often deprived from many privileges and rights of a normal child. We could also see that the numbers of single parents are ever increasing due to various socio economic reasons. It is a known fact that single parents have to struggle hard to raise their children without the help of their partner and in most cases they fail to provide necessary requirements of their children, especially with respect to emotional factors. The security of the child is another important factor that decides whether the childhood is a happy one or not. In my country there was a civil war which spanned for thirty years and fortunately became to an end in the last year. The children who were born during these thirty years of war were raised under its dark shadows. In most families, the fathers had to join the army to fight against the terrorists. Many did not return home leaving endless problems for their families. There were frequent bomb blasts directed on civilians by the terrorists and in many instances children were victims. Also the children in the areas under terrorist control were abducted by the terrorists to strengthen their carders. These children were completely deprived from all their rights as children. They were neither allowed to be with their loved ones nor to attend school. Instead they were given a gun and trained to fire at the enemy. They were taught to hate not to love. How can we say that the childhood is the happiest time for such children?

Torts Cases and Digest

SERGIO F. NAGUIAT, doing business under the name and style SERGIO F. NAGUIAT ENT. , INC. , & CLARK FIELD TAXI, INC. , petitioners, NATIONAL LABOR RELATIONS COMMISSION (THIRD DIVISION), NATIONAL ORGANIZATION OF WORKINGMEN and its members, LEONARDO T. GALANG, et al. , respondents. FACTS: Naguiat is the president and a stockholder of Clark Field Taxi, Inc. (CFT). Due to the phase-out of the US bases in the country, Clark Air Base was closed and the taxi drivers of CFTI were separated from service.The drivers filed a complaint for the payment of sep. pay due to the termination/phase-out. NLRC held Naguiat and the company solidarily liable for the payment of sep. pay. ISSUE: WON Naguait should be held solidarily liable with CFTI. YES. HELD: Under the Corporation Code, Naguait is liable bec: (1) he actively managed the business; (2) there was evidence that CFTI obtained reasonably adequate insurance; and (3) there was a corporate tort in this case. Our jurisprudence is wanting to the defin ite scope of â€Å"corporate tort. Essentially, â€Å"tort† consists in the violation of a right given or the omission of a duty imposed by law. Simply stated, it is a breach of legal duty. PHILIPPINE NATIONAL BANK, petitioner, vs. THE COURT OF APPEALS, RITA GUECO TAPNIO, CECILIO GUECO and THE PHILIPPINE AMERICAN GENERAL INSURANCE COMPANY, INC. , respondents. Medina, Locsin, Coruna, & Sumbillo for petitioner. Manuel Lim & Associates for private respondents. Facts: Rita Gueco Tapnio had an export sugar quota of 1,000 piculs for the agricultural year 1956-1957.Since, she did not need it, she agreed to allow Mr. Jacobo Tuazon to use the said quotafor consideration of 2,500. Her sugar cannot be exported without sugar quota allotments. Sometimes, however a planter harvests less sugar than her quota so her excess quota is usedby her mother who pays for it. This is her arrangement with Mr. Tuazon. At the time of theagreement, she was indebted to PNB of San Fernando, Pampanga. Her i ndebtedness wasknown as a crop loan and was secured by her sugar crop, and since her quota was mortgagedto PNB, her arrangement with Mr.Tuazon had to be approved by the bank. Upon presentmentof the lease arrangement, the PNB branch manager revised it by increasing the lease amount to P2. 80 per picul for a total of P2,800. Such increase was agreed to by both Rita and Jacobo. However, when it was presented to the Board of Directors for approval, they further increasedthe amount to P3. 00 per picul. Jacobo asked for the reconsideration but he was denied thesame. The matter stood as it was until Jacobo informed Rita and PNB that he had lost interestin pursuing the deal.In the meantime, the debt of Rita with the PNB matured. Since she had asurety agreement with the Philippine American General Insurance Co. Inc. (Philamgen), thelatter paid her outstanding debt. Philamgen in turn demanded from Rita the amount whichthey paid the bank. Instead of paying the bank, Rita claimed that she told Philamgen that shedid not consider herself indebted to the bank since she had an agreement with Jacobo Tuazon. When such was discontinued, she failed to realized the income with which she couldhave paid her creditors.Philamgen filed a complaint for the collection of sum of moneyagainst Rita. Rita implicated PNB as a third party defendant claiming that her failure to paywas due to the fault or negligence of PNB. Issue: WON PNB is liable for the damage caused to Rita. Held: ?There is no question that Rita’s failure to utilize her sugar quota was due to thedisapproval of the lease by the Board of Directors of the petitioner, thus PNB should beheld liable. ? The Board justified the increase to P 3. 00 per picul by saying that it was the prevalent rateat that time.However, there was no proof that any other person was willing to lease thesugar quota allotment of Rita for a price higher than P2. 80 per picul. Just because thereare isolated transactions where the lease price was P3. 00 per picul does not mean thatthere are always ready takers. ?While PNB had the ultimate authority of approving or disapproving the proposed leasesince the quota was mortgaged to the bank, the latter certainly cannot escape itsresponsibility of observing precaution and vigilance which the circumstances of the case justly demanded in approving or disapproving the lease of said sugar quota. According to Art. 19 of the Civil Code, â€Å"[e]very person must in the exercise of his rightsand the performance of his duties, act with justice, give everyone his due and observehonesty and good faith. † This the petitioner failed to do. As a consequence, Art. 21 states,[a]ny person who willfully causes loss or injury to another in a manner that is contrary tomorals, good customs or public policy shall compensate the latter for the damage.On the liability of the corporation, the court ruled that, â€Å"[a] corporation is civilly liable inthe same manner as natural persons for torts, bec ause generally speaking, the rulesgoverning the liability of a principal or master for a tort committed by an agent or servantare the same whether the principal or master be a natural person or artificial person. All of the authorities agree that a principal or master is liable for every tort which he expresslydirects or authorizes, and this is just as true of a corporation as of a natural person.Acorporation, is liable therefore, whenever a tortuous act is committed by an officer oragent under express direction or authority from the stockholders or members acting as abody, or generally, from the directors as the governing body. NOTE: CLV tells us that it is clear from the ruling of the Court in this case that not everytortuous act committed by an officer can be ascribed to the corporation as its liability, for it isreasonable to presume that in the granting of authority by the corporation to its agent, such agrant did not include a direction to commit tortuous acts against third pa rties.Only when thecorporation has expressly directed the commission of such tortuous act, would the damagesresulting therefrom be ascribable to the corporation. And such a direction by the corporation,is manifested either by its board adopting a resolution to such effect, as in this case, orhaving taken advantage of such a tortuous act the corporation, through its board, expresslyor impliedly ratifies such an act or is estopped from impugning such an act. Our jurisprudence is wanting as to the definite scope of â€Å"corporate tort. Essentially,â€Å"tort† consists in the violation of a right given or the omission of a duty imposed by law; abreach of a legal duty. The failure of the corporate employer to comply with the law-imposedduty under the Labor Code to grant separation pay to employees in case of cessation of operations constitutes tort and its stockholder who was actively engaged in the managementor operation of the business should be held personally liable. Q: When is a corporation liable for tort?A: A corporation is liable for tort when: (a) the act is committed by an officer or agent (2) underexpress direction of authority from the stockholders or members acting as a body or through theBoard of Directors. Q: How can authority given to the agent of the corporation be determined? A: Either by: (a) such direction by the corporation is manifested, by its board adopting aresolution to such effect (b) by having takien advantage of such a tortious act, the corporationthrough its board, has expressly or impliedly ratified such an act or estopped from impugning thesame.Q: What is a derivative suit? A: Since, the act of the board is essentially that of the corporation and therefore corporate assetscannot escape enforcement of the award of damage to the tort victim. As a remedy, thestockholders may institute a derivative suit against the responsible board members and officersfor the damages suffered by the corporation as a result of the tort suit. M. H. WYLIE and CAPT. JAMES WILLIAMS, petitioners, vs. AURORA I. RARANG and THE HONORABLE INTERMEDIATE APPELLATE COURT, respondents. FACTSPetitioners Wylie and Williams were the assistant administrative officer and commandingofficer, respectively, of the US Naval base in Subic. Respondent Aurora Rarang was an employee inthe Office of the Provost Marshal assigned as the merchandise control guard. Wylie, as one of his duties, supervised the publication of the ? Plan of the Day? a daily publication thatfeatured among others, an ? action line inquiry?. On Feb. 3, 1978, an inquiry was published saying thatconfiscated goods were being consumed/ used for personal benefit by the merchandise controlinspector and that a certain ?Auring? was, in herself, a disgrace to the office. Rarang, being the onlyperson named Auring in the said office, went to press an action for damages against Wylie and Williamsand the US Naval Base. (That Rarang was indeed the Auring mentioned in the inquiry was provenby the apology letter issued by Wylie for the inadvertent publication. )She alleged that the article constituted false, injurious, and malicious defamation and libel tending toimpeach her honesty, virtue and reputation exposing her to public hatred, contempt and ridicule.Defendants alleged that (1) defendants acted in performance of their official functions as officersof the US Navy and are thus immune from suit (2) US Naval Base is immune from suit being aninstrumentality of the US Government and (3) the RTC has no jurisdiction over the subject matter andthe parties involved. Lower court ruling: defendants pay damages because acts were not official acts of the USgovernment, but personal and tortious acts (which are not included in the rule that a sovereign countrycan? t be sued without its consent). Suit against US Naval Base was dismissed.ISSUES1. WON officials of the US Naval Base inside Philippine Territory, in discharge of their official duties, areimmune from suit. 2. Are US offi cers who commit a crime or tortious act while discharging official functions still coveredby the principle of state immunity from suit? HELD1. Yes, they are immune. Ratio Officers of the US Navy as instrumentalities of the US government are immune from suit (but onlywhen they are acting/ discharging their official functions. Art. XVI, sec. 3 of 1987 constitution provides that state may not be sued without its consent.Buteven without this affirmation, court is still bound by the doctrine of incorporation. Thedoctrine is applicable not only to suits against the state but also to complaints filedagainst officials for acts allegedly performed by them in discharge of their official duties. The traditional rule of immunity excepts a State from being sued in the courts of another Statewithout its consent or waiver. This rule is a necessary consequence of the principles of independenceand equality of States. Because the activities of states have multiplied, it has been necessary todistingui sh them ? etween sovereign and governmental acts (jure imperii) and private, commercial and proprietary acts (jure gestionis). The result is that State immunity now extends only toacts jure imperii. There is no question, therefore, that the petitioners actively participated in screening thefeatures and articles in the POD as part of their official functions. Under the rule that U. S. officials in the performance of their official functions are immune fromsuit, then it should follow that the petitioners may not be held liable for the questioned publication.It is to be noted, however, that the petitioners were sued in their personal capacities for their allegedtortious acts in publishing a libelous article. 2. No. Ratio. Our laws and, we presume, those of the United States do not allow the commission of crimes in the name of official duty. The general rule is that public officials can be heldpersonally accountable for acts claimed to have been performed in connection with officialduti es where they have acted ultra vires or where there is showing of bad faith.Immunity from suitcannot institutionalize irresponsibility and non-accountability nor grant a privileged status notclaimed by any other official of the Republic. Under Art. 2176 of the civil code, whoever by act or omission, causes damage to another, therebeing fault or negligence is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and isgoverned by the provisions of this Chapter. Indeed the imputation of theft contained in the POD dated February 3, 1978 is adefamation against the character and reputation of the private respondent.Petitioner Wyliehimself admitted that the Office of the Provost Marshal explicitly recommended the deletion of thename Auring if the article were published. The petitioners, however, were negligentbecause under their direction they issued the publication without deleting the name â€Å"Auring. â€Å"Such act or omission is ultra vires and cannot be part of official duty. It was a tortious act whichridiculed the private respondent. The petitioners, alone, in their personal capacities are liable forthe damages they caused the private respondent GASHEM SHOOKAT BAKSH, petitioner, vs. HON.COURT OF APPEALS and MARILOU T. GONZALES, respondents. Public Attorney's Office for petitioner. Corleto R. Castro for private respondent. FACTS: Petitioner Gashem Shookat Baksh was an Iranian citizen, exchange student taking a medical course in Dagupan City, who courted private respondent Marilou Gonzales, and promised to marry her. On the condition that they would get married, she reciprocated his love. They then set the marriage after the end of the school semester. He visited Marilou’s parents to secure their approval of marriage. In August 1987, he forced her to live with him, which she did.However, his attitude toward her changed after a while; he would maltre at and even threatened to kill her, from which she sustained injuries. Upon confrontation with the barangay captain, he repudiated their marriage agreement, saying that he was already married to someone living in Bacolod. Marilou then filed for damages before the RTC. Baksh denied the accusations but asserted that he told her not to go to his place since he discovered her stealing his money and passport. The RTC ruled in favor of Gonzales. The CA affirmed the RTC decision. ISSUES:Whether or not breach of promise to marry is an actionable wrong. Whether or not Art. 21 of the Civil Code applies to this case. Whether or not pari delicto applies in t his case. HELD: The existing rule is that a breach of promise to marry per se is not an actionable wrong. This, notwithstanding, Art. 21 is designed to expand the concept of torts or quasi-delict in this jurisdictions by granting adequate legal remedy for the untold number of moral wrongs which is impossible for human foresight to specifica lly enumerate and punish in the statute books.Art. 21 defines quasi-delict: Whoever by act or omission causes damage to another, there being fault or negligence is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called quasi-delict and is governed by the (Civil Code). It is clear that petitioner harbors a condescending if not sarcastic regard for the private respondent on account of the latter’s ignoble birth, inferior educational background, poverty and, as perceived by him, dishonorable employment.From the beginning, obviously, he was not at all moved by good faith and an honest motive. Thus, his profession of love and promise to marry were empty words directly intended to fool, dupe, entice, beguile and deceive the poor woman into believing that indeed, he loved her and would want her to be his life partner. His was nothing but pure lust which he wanted satisfied by a Filipina who honest ly believed that by accepting his proffer of love and proposal of marriage, she would be able to enjoy a life of ease and security.Petitioner clearly violated the Filipino concept of morality and so brazenly defied the traditional respect Filipinos have for their women. It can even be said that the petitioner committed such deplorable acts in blatant disregard of Article 19 of the Civil Code which directs every person to act with justice, give everyone his due, and observe honesty and good faith in the exercise of his right and in the performance of his obligations. No foreigner must be allowed to make a mockery of our laws, customs and traditions. She is not in pari delicto with the petitioner.Pari delicto means in equal fault. At most, it could be conceded that she is merely in delicto. Equity often interfered for the relief of the less guilty of the parties, where his transgression has been brought about by the imposition of undue influence of the party on whom the burden of the original wrong principally rests, or where his consent to the transaction was itself procured by fraud. Phoenix Construction Inc. vs. IAC PHOENIX CONSTRUCTION INC V IAC (DIONISIO) 148 SCRA 353FELICIANO; March 10, 1987 NATURE PETITION for review of the decision of the IACFACTS – 130AM 15 November 1975 – Leonardo Dionisio, driving hisVolkswagen car, was on his way home to Makati from acocktails-and-dinner meeting with his boss where had taken â€Å"ashot or two† of liquor. Crossing the intersection of GeneralLacuna and General Santos Streets at Bangkal, Makati, not far from his home, when his car headlights (in his allegation)suddenly failed. He switched his headlights on â€Å"bright† andthereupon he saw a Ford dump truck looming some21/2meters away from his car. The dump truck, owned andregistered by Phoenix Construction Inc. as parked askew(partly blocking the way of oncoming traffic) on the right handside of General Lacuna Street facing the oncoming tra ffic. There were no lights nor any so-called â€Å"early warning† reflector devices set anywhere near the dump truck. The dump truckhad earlier that evening been driven home by Carbonel, itsregular driver. Dionisio claimed that he tried to avoid a collisionby swerving his car to the left but it was too late and his car smashed into the dump truck. As a result of the collision,Dionisio suffered some physical injuries including somepermanent facial scars, a â€Å"nervous breakdown† and loss of twogold bridge dentures. Dionisio commenced an action for damages claiming that thelegal and proximate cause of his injuries was the negligentmanner in which Carbonel had parked the dump truck. Phoenix and Carbonel countered that the proximate cause of Dionisio's injuries was his own recklessness in driving fast atthe time of the accident, while under the influence of liquor,without his headlights on and without a curfew pass. Phoenixalso sought to establish that it had exercised d ue care in theselection and supervision of the dump truck driver. CFI: in favor of Dionisio- IAC: affirmed TC but modified amounts ISSUE (obiter) WON last clear chance doctrine should be appliedtherefore exculpating Phoenix from paying any damages HELD NO- We hold that private respondent Dionisio's negligence was†only contributory,† that the â€Å"immediate and proximate cause†of the injury remained the truck driver's â€Å"lack of due care† andthat consequently respondent Dionisio may recover damages P a g e 6 though such damages are subject to mitigation by the courts(Article 2179, Civil Code of the Philippines). Ob iter Phoenix and Carbonel also ask us to apply what they refer toas the â€Å"last clear chance† doctrine. The theory here of petitioners is that while the petitioner truck driver wasnegligent, private respondent Dionisio had the â€Å"last clear chance† of avoiding the accident and hence his injuries, andthat Dionisio having fai led to take that â€Å"last clear chance† mustbear his own injuries alone. The last clear chance doctrine of the common law was imported into our jurisdiction by Picart vs. Smith but it is a matter for debate whether, or to what extent, ithas found its way into the Civil Code of the Philippines.Thehistorical function of that doctrine in the common law was tomitigate the harshness of another common law doctrine or rule-that of contributory negligence. The common law rule of contributory negligence prevented any recovery at all by aplaintiff who was also negligent, even if the plaintiff'snegligence was relatively minor as compared with the wrongfulact or omission of the defendant. The common law notion of last clear chance permitted courts to grant recovery to aplaintiff who had also been negligent provided that thedefendant had the last clear chance to avoid the casualty andfailed to do so.Accordingly, it is difficult to see what role, if any,the common law last clear chance d octrine has to play in a jurisdiction where the common law concept of contributorynegligence as an absolute bar to recovery by the plaintiff, hasitself been rejected, as it has been in A2179 CC- Is there perhaps a general concept of â€Å"last clear chance† thatmay be extracted from its common law matrix and utilized as ageneral rule in negligence cases in a civil law jurisdiction likeours?We do not believe so. Under A2179, the task of a court,in technical terms, is to determine whose negligence-theplaintiff's or the defendant's-was the legal or proximate causeof the injury. That task is not simply or even primarily anexercise in chronology or physics, as the petitioners seem toimply by the use of terms like â€Å"last† or â€Å"intervening† or â€Å"immediate. The relative location in the continuum of time of the plaintiff's and the defendant's negligent acts or omissions,is only one of the relevant factors that may be taken intoaccount. Of more fundamental im portance are the nature of thenegligent act or omission of each party and the character andgravity of the risks created by such act or omission for the restof the community.The petitioners urge that the truck driver (and therefore his employer) should be absolved fromresponsibility for his own prior negligence because theunfortunate plaintiff failed to act with that increased diligencewhich had become necessary to avoid the peril preciselycreated by the truck driver's own wrongful act or omission, Toaccept this proposition is to come too close to wiping out thefundamental principle of law that a man must respond for theforseeable consequences of his own negligent act or omission.Our law on quasi-delicts seeks to reduce the risks and burdensof living in society and to allocate them among the members of society. To accept the petitioners' proposition must tend toweaken the very bonds of society. Disposition CA decision is modified by reducing theaggregate amount of compensatory damage s, loss of expectedincome and moral damages Dionisio is entitled to by 20% of such amount REYNALDA GATCHALIAN, petitioner, vs. ARSENIO DELIM and the HON. COURT OF APPEALS, respondents. Pedro G. Peralta for petitioner. Florentino G. Libatique for private respondent.On July 11, 1973, petitioner Reynalda Gatchalian boarded as paying passenger a minibus owned by respondents. While the bus was running along the highway, a â€Å"snapping sound† was heard, and after a short while, the bus bumped a cement flower pot, turned turtle and fell into a ditch. The passengers were confined in the hospital, and their bills were paid by respondent’s spouse on July 14. Before Mrs. Delim left, she had the injured passengers sign an already prepared affidavit waiving their claims against respondents. Petitioner was among those who signed.Notwithstanding the said document, petitioner filed a claim to recover actual and moral damages for loss of employment opportunities, mental suffering and inferiority complex caused by the scar on her forehead. Respondents raised in defense force majeure and the waiver signed by petitioner. The trial court upheld the validity of the waiver and dismissed the complaint. The appellate court ruled that the waiver was invalid, but also that the petitioner is not entitled to damages. Issues: (1) Whether there was a valid waiver (2) Whether the respondent was negligent 3) Whether the petitioner is entitled to actual and moral damages Held: (1) We agree with the majority of the Court of Appeals who held that no valid waiver of her cause of action had been made by petitioner. A waiver, to be valid and effective, must in the first place be couched in clear and unequivocal terms which leave no doubt as to the intention of a person to give up a right or benefit which legally pertains to him. A waiver may not casually be attributed to a person when the terms thereof do not explicitly and clearly evidence an intent to abandon a right vested in suc h person.The circumstances under which the Joint Affidavit was signed by petitioner Gatchalian need to be considered. Petitioner testified that she was still reeling from the effects of the vehicular accident when the purported waiver in the form of the Joint Affidavit was presented to her for signing; that while reading the same, she experienced dizziness but that, seeing the other passengers who had also suffered injuries sign the document, she too signed without bothering to read the Joint Affidavit in its entirety.Considering these circumstances, there appears substantial doubt whether petitioner understood fully the import of the Joint Affidavit (prepared by or at the instance of private respondent) she signed and whether she actually intended thereby to waive any right of action against private respondent. Finally, because what is involved here is the liability of a common carrier for injuries sustained by passengers in respect of whose safety a common carrier must exercise ex traordinary diligence, we must construe any such purported waiver most strictly against the common carrier.To uphold a supposed waiver of any right to claim damages by an injured passenger, under circumstances like those exhibited in this case, would be to dilute and weaken the standard of extraordinary diligence exacted by the law from common carriers and hence to render that standard unenforceable. We believe such a purported waiver is offensive to public policy. (2) In case of death or injuries to passengers, a statutory presumption arises that the common carrier was at fault or had acted negligently â€Å"unless it proves that it [had] observed extraordinary diligence as prescribed in Articles 1733 and 1755. To overcome this presumption, the common carrier must show to the court that it had exercised extraordinary diligence to present the injuries. The standard of extraordinary diligence imposed upon common carriers is considerably more demanding than the standard of ordinary d iligence. A common carrier is bound to carry its passengers safely â€Å"as far as human care and foresight can provide, using the utmost diligence of a very cautious person, with due regard to all the circumstances†. The records before the Court are bereft of any evidence showing that respondent had exercised the extraordinary diligence required by law.The obvious continued failure of respondent to look after the roadworthiness and safety of the bus, coupled with the driver's refusal or neglect to stop the mini-bus after he had heard once again the â€Å"snapping sound† and the cry of alarm from one of the passengers, constituted wanton disregard of the physical safety of the passengers, and hence gross negligence on the part of respondent and his driver. (3) At the time of the accident, she was no longer employed in a public school. Her employment as a substitute teacher was occasional and episodic, contingent upon the availability of vacancies for substitute teacher s.She could not be said to have in fact lost any employment after and by reason of the accident. She may not be awarded damages on the basis of speculation or conjecture. Petitioner's claim for the cost of plastic surgery for removal of the scar on her forehead, is another matter. A person is entitled to the physical integrity of his or her body; if that integrity is violated or diminished, actual injury is suffered for which actual or compensatory damages are due and assessable. Petitioner Gatchalian is entitled to be placed as nearly as possible in the condition that she was before the mishap.A scar, especially one on the face of the woman, resulting from the infliction of injury upon her, is a violation of bodily integrity, giving raise to a legitimate claim for restoration to her conditio ante. Moral damages may be awarded where gross negligence on the part of the common carrier is shown. Considering the extent of pain and anxiety which petitioner must have suffered as a result of her physical injuries including the permanent scar on her forehead, we believe that the amount of P30,000. 00 would be a reasonable award. Petitioner's claim for P1,000. 00 as attorney's ees is in fact even more modest. JOSUE ARLEGUI, petitioner, vs. HON. COURT OF APPEALS and SPOUSES GIL AND BEATRIZ GENGUYON, respondents. Residential Apartment Unit no. 15 was leased for more than 20 years by Serafia Real Estate, Inc. tospouses Gil and Beatriz. In 1984, Alberto Barretto (one of the owners of Serafia) informed the tenants of the apartment bldg. that Serfia and its assets had already been assigned and transferred to A. B. Barretto. The tenants formed an organization called Barretto Apartment Tenant Association to represent them innegotiations with A. B.Barretto Enterprises for the purchase of the apartment units. Josue Arlegui waselected vice president and Mateo Tan Lu as auditor of the association. Genguyons were later surprised tolearn that the unit they were leasing had been sold to Mateo Tan Lu. Genguyons continued to occupy thepremises and paid rentals. They were then informed that Mateo Tan sold the apartment to Josue Arlegui. Arlegui demanded Genguyons to vacate the premises. ISSUE: Whether or not a constructive trust existed HELD: The petitioner denies that a constructive trust was created and maintains that there was no fraudcommitted.He neither received money from the Genguyons, nor was he unjustly enriched. However, therecords show that the Genguyons, along with the other tenants and members of the association,contributed money to enable the officers to negotiate with the Barrettos. Besides, constructive trusts donot only arise out of fraud or duress, but also by abuse of confidence, in order to satisfy the demands of justice. The petitioner also argues that the Genguyons’ failed to prove the existence of an implied or constructivetrust. We disagree.There is ample documentary and testimonial evidence to establish the existence of afiduciary r elationship between them, and that petitioner’s subsequent acts betrayed the trust andconfidence reposed on him. It is further argued that no implied trust, as defined under Article 1456 of the New Civil Code, was createdbecause the petitioner did not acquire the subject property through mistake or fraud. Nevertheless, theabsence of fraud or mistake on the part of the petitioner does not prevent the court from ruling that animplied or constructive trust was created nonethelessA constructive trust, otherwise known as a trust ex maleficio, a trust ex delicto, a trust de son tort, aninvoluntary trust, or an implied trust, is a trust by operation of law which arises contrary to intention and ininvitum, against one who, by fraud, actual or constructive, by duress or abuse of confidence, bycommission of wrong, or by any form of unconscionable conduct, artifice, concealment, or questionablemeans, or who in any way against equity and good conscience, either has obtained or holds the legalright to property which he ought not, in equity and good conscience, hold and enjoy.It is raised by equityto satisfy the demands of justice. However, a constructive trust does not arise on every moral wrong inacquiring or holding property or on every abuse of confidence in business or other affairs; ordinarily sucha trust arises and will be declared only on wrongful acquisitions or retentions of property of which equity,in accordance with its fundamental principles and the traditional exercise of its jurisdiction or inaccordance with statutory provision, takes cognizance.It has been broadly ruled that a breach of confidence, although in business or social relations, rendering an acquisition or retention of property byone person unconscionable against another, raises a constructive trust. *There was a breach of trust by the officers. SC annulled the sale of the apartment and ordered Arlegui toexecute deed of conveyance to Genguyon spouses BPI EXPRESS CARD CORPORATION, petitioner , vs. COURT OF APPEALS and RICARDO J. MARASIGAN, respondents. Marasigan was the holder of a BPI credit card. Due to his delinquency in payment, immediate demand was given by BPI to pay account.Marasigan issued a postdated check. The check was thereafter kept in custiody by BPI and card was temporarily suspended. And on a relevant date, Marasigan after eating in Cafe Adriatico tried to use his card to pay but it was dishonored. HELD: The issuance of the postdated check was not effective payment on the part of Marasigan and thus, the bank was justified in suspending temporarily his use of the credit card. A check is only a substitute for money and not money, and the delivery of such instrument doesn't itself operate as payment. BEATRIZ P. WASSMER, plaintiff-appellee, vs. FRANCISCO X.VELEZ, defendant-appellant. Jalandoni & Jamir for defendant-appellant. Samson S. Alcantara for plaintiff-appellee. FACTS: Respondent Francisco Velez and petitioner Beatriz Wassmer were lovers who set their marriage for Sept. 4, 1954. On Sept. 2, however, Francisco left for Cagayan de Oro, leaving Beatriz with a note that his mother was approved to the marriage. A day before the supposed wedding, on Sept. 3, Francisco telegrammed Beatriz that nothing changed and that he assured her of his return and love. Francisco did not appear after all nor words were heard from him again; despite the fact that preparations were all made.They applied for a marriage license on Aug. 23, and was issued thereof; invitations were printed and distributed to friends and relatives; dresses and other apparel were already bought; the two bought a matrimonial bed; bridal showers were given and gifts received. Beatriz then filed damages for breach of promise to marry. ISSUE: Whether or not breach of promise to marry is an actionable wrong. HELD: Mere breach of promise to marry is not an actionable wrong. But to formally set a wedding and go through all the preparations and publicity, and to walk out of it when the matrimony is about to be solemnized, is quite different.This is palpably and unjustifiably contrary to customs for which Francisco must be held answerable for damages in accordance with Art. 21 of the Civil Code. Under Art. 2232 of the Civil Code, the conditions precedent is that the defendant acted in a wanton, fraudulent, reckless, oppressive or malevolent manner. When a breach of promise to marry is actionable under Article 21, moral damages may be awarded under Art. 2219 (10) of the Civil Code. Exemplary damages may also be awarded under Art. 2232 of the Code where it is proven that the defendant clearly acted in wanton, reckless and oppressive manner.

Free Essays on Murder In The Catacombs

Murder in the Catacombs Edgar Allan Poe was born in Boston on January 19, 1809. His father, David Poe, deserted his wife and son shortly after the birth. Poe’s mother, Elizabeth Arnold Poe, became seriously ill with tuberculosis and died at the age of twenty-four. Poe was devastated by his mother’s illness. He was only three when he watched his mother vomit blood and men dressed in black take her from him forever. John Allan, of Richmond, took Poe into his home and provided his early education. Poe met another challenge early in life, as Allan and he had a falling out, his finances were depleted and he had to withdraw from the University of Virginia. In an effort to support himself Poe turned to his writing. He published his first volume of poetry, Tamerlane and Other Poems, at the age of eighteen in Boston (Wilson p 1). Poe later moved to Baltimore, to live with his aunt Mrs. Maria Poe Clemm, where he began writing prose-tales. He submitted his prose-tales in an effort to win prize money. He married his cousin, Virginia Clemm, in 1836 and it is said they never lived as most husband and wives live. He was editor of Burton’s Gentleman’s Magazine for six years then he moved to New York to work for the New York Evening Mirror. After many works had been written and several published finally, Poe reached fame for his poem The Raven. The last years of Poe’s life seemed as much of a challenge as his first years: his wife became ill and died in 1847, his employment ended as the journal failed, and his own health weakened. Edgar Allan Poe died at the age of forty on October 7,1849. The writings of Edgar Allan Poe received much criticism. Perhaps no other American writer has been subjected to such critical appraisals. â€Å"The European mind has always been more hospitable to Poe than the American mind†. Charles Baudelaire led the French in a discovery of Poe†¦.Recently the French Structuarlists have resurrected Poe from many year... Free Essays on Murder In The Catacombs Free Essays on Murder In The Catacombs Murder in the Catacombs Edgar Allan Poe was born in Boston on January 19, 1809. His father, David Poe, deserted his wife and son shortly after the birth. Poe’s mother, Elizabeth Arnold Poe, became seriously ill with tuberculosis and died at the age of twenty-four. Poe was devastated by his mother’s illness. He was only three when he watched his mother vomit blood and men dressed in black take her from him forever. John Allan, of Richmond, took Poe into his home and provided his early education. Poe met another challenge early in life, as Allan and he had a falling out, his finances were depleted and he had to withdraw from the University of Virginia. In an effort to support himself Poe turned to his writing. He published his first volume of poetry, Tamerlane and Other Poems, at the age of eighteen in Boston (Wilson p 1). Poe later moved to Baltimore, to live with his aunt Mrs. Maria Poe Clemm, where he began writing prose-tales. He submitted his prose-tales in an effort to win prize money. He married his cousin, Virginia Clemm, in 1836 and it is said they never lived as most husband and wives live. He was editor of Burton’s Gentleman’s Magazine for six years then he moved to New York to work for the New York Evening Mirror. After many works had been written and several published finally, Poe reached fame for his poem The Raven. The last years of Poe’s life seemed as much of a challenge as his first years: his wife became ill and died in 1847, his employment ended as the journal failed, and his own health weakened. Edgar Allan Poe died at the age of forty on October 7,1849. The writings of Edgar Allan Poe received much criticism. Perhaps no other American writer has been subjected to such critical appraisals. â€Å"The European mind has always been more hospitable to Poe than the American mind†. Charles Baudelaire led the French in a discovery of Poe†¦.Recently the French Structuarlists have resurrected Poe from many year...

Research proposal on the impact of marketing strategies and loyalty Dissertation

Research proposal on the impact of marketing strategies and loyalty scheme of TESCO - Dissertation Example The methodology to be adopted in conducting the research proposal consists of both primary research and secondary research aimed at the management and consumer base of Tesco. The data obtained from the research consist of qualitative data, through interview and observation and quantitative data, with the help of questionnaires. These quantitative and qualitative data were analysed based on the answers of the interviewee and also with the help of graphs and charts obtained from questionnaires. Description Background to Research Literature Review Marketing Strategies Ranchhod and Gurau (2012:1) reflect that the strategies framed by a business corporation reflecting on key changes in the external environment while working effectively based on its resource base to gain enhanced position in the existing market place constitutes the marketing strategies of the firm. The external environment of a business corporation is susceptible to large amount of changes owing to alterations in the dema nd pattern of the existing consumer base owing to alterations in the socio-economic profile of the people. Further the external environment of a business corporation is also subjected to legislative and policy changes where again new technologies are also introduced in the business unit. Depending on such changes the strategies of the company focusing on the market trends also tend to change accordingly. Marketing Strategies in Retail Retail companies operating in the global sphere also tend to act based on different marketing strategies to compete effectively in the different markets. Lamb, Hair and McDaniel (2011:241-245) state that the marketing strategies of retail corporations are created and made effective to fulfil certain key objectives like gaining an enhancement of consumer traffic in the different stores, enhancing the sale of its products and services and also in gaining an enhanced consumer awareness in the densely populated retail market. The first strategic initiative that needs to be taken by the retail companies is to focus on gaining the target market through effective segmentation based on demographic, psychographic and geographic profile of the total consumer base. Further the retail market being an integral part of the service marketing companies tend to work based on the seven Ps to formulate the total marketing mix strategy. Firstly retail companies’ work on enhancing the assortment depth of the products thereby helping consumers to choose from a plethora of different options in regards to a specific product category. Secondly in close conformity to the type of consumers in the target market based on social and economic conditions the retail companies are required to set the price for its products. The retail companies can also go for a price mix where certain categories of products can be priced in a premium fashion, while others in a discounted or low price fashion depending

IT security Coursework Example | Topics and Well Written Essays - 2500 words

IT security - Coursework Example In this scenario, most of the data stored is extremely secret and not intended for common people screening in addition to the outside business access. In addition, a lot of companies are exclusively dependent on their business and economical data which is proficiently stored in computers like any web based enterprise. In case of such businesses we can have customer records, private employee’s information, employee’s salary details, advertising and sales data and bank account information stored on electronic database systems. In this scenario, without this business and economical data, it would frequently be extremely difficult for a company to work effectively. For this reason new and more enhanced technology based structures and security systems are implemented to protect such kinds of sensitive business data and information which can later on be used for effective decision making. However, better business information security systems include a variety of processes, ex pertise, safety products and measures. In addition, the software applications that offer virus protection scanners and firewall information safety are not sufficient on behalf of their performance to defend huge and extensive information stores. Thus, a group of systems and practices are required to be implemented to successfully discourage illegal entry and interpretation to information systems and databases (Crystal, 2011), (Anderson & Schneier, 2008) and (Grimaila, 2004). Information security is becoming extremely important for all the businesses. This report presents a comprehensive analysis of one of the biggest global business Wal-Mart. This report will analyze some of the prime IT security procedures that Wal-Mart organization currently uses. This report will also outline that how these security procedures are used and what threats they are designed to combat. Wal-Mart is one of the biggest worldwide retailers. It is one of biggest financial power, a glowing ruler for argumen t and an intellectual experience. In addition, the Wal-Mart is the mind-piece of Sam Walton, who is having a personal thinking to offer customer lesser prices than they get somewhere. That fundamental policy has made the Wal-Mart's culture and presently formulated as a biggest business monster. At present Wal-Mart business setup is exceptionally massive. Moreover, it has amazing power to create employment marketplaces worldwide as well as transform the method all companies generally do their jobs (Wilbert, 2011), (Walmart, 2011) and (William F. Achtmeyer Center for Global Leadership, 2002). WAL-MART: BUSINESS OVERVIEW Wal-Mart business setup was established in 1962 by the Sam Walton, with a first Wal-Mart store that was started at Rogers, Arkansas. This business attained annual sales of $1 billion after 17 years of its development. At the end of January 2002, Wal-Mart business Stores, Inc. turned out to be a world’s biggest seller, along with $218 billion of annual sales. Add itionally,