Irish Freedom Media

Sample details Pages: 18 Words: 5472 Downloads: 7 Date added: 2017/06/26 Category Statistics Essay Did you like this example? Freedom of the Press and Defamation and Privacy Reform : A model of media freedom for Ireland and Article 40.6 gets some clout? Introduction In the history of Irish Freedom of Expression jurisprudence there has never been any explicit judicial recognition of one model of media freedom as informing judicial decision-making or legislative drafting. It is arguable that a failure to recognise a single formula for media freedom has done disservice to the free expression of media organs especially when confronted with the tort of defamation freedom of expression often having to bow in favour of the right to a good name. Don’t waste time! Our writers will create an original "Irish Freedom Media | Law Dissertations" essay for you Create order In Ireland, the law starts from the premise that the maker of a disparaging statement is liable and [it] starts therefore with an easily established and potentially immense range of liability hence, freedom of expression occupies an inferior position in the lexicon of Irish values, one of those values being the right to a good name. With the introduction of new Defamation and Privacy legislation in Ireland it is envisaged that the developments of both the Irish and European Courts will be reflected in the modernising legislation. Accompanying this development, it would be hoped that the new legislation reflects a robust commitment to a model of media freedom. With particular reference to defamation, a liberalising trend regarding that realm of the law, on an international scale has become discernable over the past twenty of years. Undoubtedly international treaties such as the European Convention on Human Rights (ECHR), the Universal Declaration of Human Rights (UDHR) and the International Covenant on Civil and Political Rights (ICCPR) are answerable for this trend. The Defamation and Privacy Bills 2006 could be seen as symptomatic of Ireland honouring its commitment to the European and International covenants to which it has subscribed. This essay will endeavour to decipher the model of media freedom that is evident in the recent case law of the Irish Courts (under the influence of the Strasbourg jurisprudence). Secondly, it will consider the provisions of the new legislation and identify whether or not the new legislation equally reflects such developments. Finally, it will consider whether recent decisions such as Leech v. Independent Newspapers may be leaning towards extending a more generous hand to media organs in their defence of free expression than is currently enshrined in the new legislation. Before applying the theories of freedom of expression of media organs to the Irish context it is appropriate to set-the-scene of Media Freedom in general Ireland: Article 40.6.1of Bunreacht na hEireann guarantees freedom to express opinions and convictions , subject to considerations of public order and morality : The State guarantees liberty for the exercise of the following rights, subject to public order and morality: i. The right of the citizens to express freely their convictions and opinions. The education of public opinion being, however, a matter of such grave import to the common good, the State shall endeavour to ensure that organs of public opinion, such as the radio, the press, the cinema, while preserving their rightful liberty of expression, including criticism of Government policy, shall not be used to undermine public order or morality or the authority of the State. The publication or utterance of blasphemous, seditious, or indecent matter is an offence which shall be punishable in accordance with law. Traditionally, the Irish Courts response to pleas for vindication of freedom of expression has been one of characteristic Common Law scepticism. Indeed, it is clear from the language of the Article that the emphasis in Irish Law is on the limitations to the right of freedom of expression rather than on the right itself. Citizens are supposed to have the right to express freely their convictions and opinions, yet how can they freely exercise this right if it is subject to public order and morality, as stated at the very beginning of the Article?. Furthermore, public order and morality are not the only considerations which work to qualify this right in practice, for example, injury to a persons good name or their privacy will also place limitation on the exercise of Article 40.6.1 It includes enough qualifications to leave in some doubt the commitment of the Constitution to full, democratic, freedom of thought and freedom of speech. The Press is specifically mentioned in Article 40.6. 1 (i), but in a type of parenthesis. The rightful liberty of the press, which includes criticism of government policy, has to be preserved but the education of public opinion is so important that the onus is on the State to ensure that the organs of public opinion are not used to undermine the important values of public order, morality etc. As McGonagle underlines; The formulation is unfortunate and does little to secure media freedoms. The result has been that, until recently, the Courts did not pay much attention to the guarantee of freedom of expression particularly in the media context. Other rights were allowed to take precedence over it. Long-standing common law rules, such as defamation and contempt of court were allowed to operate unperturbed. There are relatively few Irish judicial decisions where Article 40.6.1 (i) is invoked in support of media freedom, examples of the Court considering that ..the matter of the freedom of the press and of communication .cannot be lightly curtailed include X v. RTE , AG for England and Wales v. Brandon Book Publishers and Cullen v. Toibin . McGonagle points that in Ireland, the Constitutional statement on freedom of the press has been considered too weak to have any real impact on the common-law approach to defamation. She contrasts this with the approach of the United States ..with its strong First Amendment commitment to freedom of the press.. which has ..dominated and reshaped the tort of defamation in that country. In Ireland, as a consequence of following the lead of Britain, which does not have a Constitutional guarantee of freedom of expression, the tort of defamation in Ireland operated in a manner (as in Britain) that virtually ignored the existence of our constitutional values protecting freedom of expression. McGonagle points that there was an underlying assumption that the common law of defamation partly codified in the Defamation Act, had got the balance right. This opinion was ill-informed. Irish Law is aimed at achieving equilibrium between three Constitutionally-protected interests: Right of Freedom of Expression (Article 40.6. 1), Right to Communicate (Article 40.3.1) and the Right to a Good Name (Article 40.3. 2). The Defamation Act 1961 mimics the equivalent British legislation and this has meant that Irish libel law has failed to take account of our own Constitutional values, outlined above. The Act makes no attempt to balance the three Constitutional provisions and has operated as a law that assumes that freedom of expression is a bad thing. In 1996 the Constitution Review Group asked The essential question whether the defamation laws effect a fair balance between the right of free speech on the one hand and the need to protect individual reputations on the other?. The answer to their question had been provided a few years earlier by the Law Reform Commission in their Consultation on the Civil Law of Defamation 1991: We believe that current Irish Defamation Law fails to serve each of these interests satisfactorily in many areas. Since the 1991 Report, the jurisprudence of the Irish Courts has moved-on to take account of the influence of ECtHR jurisprudence (since it formed part of Irish Law at sub-constitutional level in 2003) and developments in the common law. In Goodwin v. Hamilton No.2 the Courts intimated that, with respect to Constitutional Rights, good name is not a trump card that takes precedence over all other rights. This could be seen as the first step towards a new constitutionalising of the tort of defamation. This sets the backdrop to the introduction of the Defamation and Privacy Bill 2006. The Irish laws on Defamation and Privacy are long-overdue an overhaul, media law commentators such as ODell have highlighted the acute need for the modernisation of Irish Defamation Law and have criticised the delay of government in instituting this modernisation. McGonagle points that Delay has meant that those affected by defamation, whether as plaintiffs or defendants as well as the public at large have had to soldier on under very outdated laws, drafted at a time when television was only beginning in Ireland and the Internet was not even heard of. It is envisaged that the new Bills spell the end of, as in the case of the Defamation Act 1961, an over-reliance in decision-making by the House of Lords and the introduction of law that better-reflects Irish Constitutional mores and developments of the ECtHR. Both the Defamation and Privacy Bills 2006 have conceptual implications for the status of media freedom in Ireland and together, the Bills acknowledge a model of freedom of the press which has heretofore not been specifically recognised in Irish jurisprudence. Before discussing the model of media freedom that appears to exist in Ireland, it is first appropriate to discuss the different theories of freedom of expression and of the press advanced by various legal scholars. The proper functioning of modern, participatory democracy requires that the media be free, active, professional and enquiring. Barendt discusses four main rationales for the importance of freedom of speech the argument from truth, the argument from self-fulfilment and self-development, the argument from democracy and the argument from freedom from state coercion. Scott has highlighted the importance of not over-emphasising the discreteness of these explanations and moreover, he opines that it is important not to expect that any particular corpus of rights will reflect specific philosophies. Jacob Rowbottom contends that the relationship between the right of expression and media freedom is complex. He advances three well-known justifications for freedom of expression: The first, as discussed by Barendt, justifies freedom of expression as essential to a persons autonomy and self-fulfillment. The second justification is the market place of ideas rationale : ..that minimal government regulation will allow robust debate between citizens that is most likely to lead to the truth. This echoes Miltons idea in Areopagitica in the 17th century when he declared Let Truth and Flasehood grapple; whoever knew Truth put to the worse, in a free and open encounter?. The third justification highlights that freedom of expression is a necessary component of a democratic government. These theories of freedom of expression all overlap and have each been criticised in turn. Rowbottom also points to instrumental justifications such as the medias public function in the dissemination of information as supporting media freedom It is very largely through the media that they (the public) will be so alerted and informed. The proper functioning of modern participatory democracy requires that the media be free, active, professional and inquiring. However, any argument in favour of an uninhibited press must be accompanied with the reminder that the media exercises their freedom in a manner that is different from that of individual speakers and sometimes mass media will use its controlling force to undermine individuals rights to free expression. On this point, Rowbottom quotes from Democracy in the Mass Media where Judith Litchenberg opines that Unlike freedom of speech, to which certain aspects of which our commitment must be virtually unconditional, freedom of the press should be contingent on the degree to which it promotes certain values at the core of our interest in freedom of expression generally. This is redolent of the approach to Article 10 ECHR taken by the Strasbourg Court in Jersild v. Denmark where the special role of the media as a public watchdog was afforded protection. It is now proposed to decipher the model of media freedom which appears to have been embraced by recent jurisprudence of the Irish Courts and the new legislation. A Democratic Model of Media Freedom? Despite the lack of any explicit judicial recognition, it is arguable that in recent years the Irish Courts have moved towards recognising the Democratic Model of media freedom as being the leitmotif of Defamation and Privacy Law. This idea is embodied in the new reforms in the law. The precepts of the democratic model are best illuminated when placed in contrast with the free market model of media freedom: The free market model embraces the Milton Ideal of the Free Market of Ideas where theories succeed or fail on their own merits. It was advocated by Justices Holmes and Brandeis in Abrams v. US where is was declared that..[t]he best test of truth is the power of the thought to get itself accepted in the competition of the market. The seminal decision of New York Times v. Sullivan provided that the defamation suit taken by a public figure was only sustainable when actual malice on the part of the Defendant was found. The highlights the free-market models focus on the honesty of the person making the statement rather than the truth of the statement. In contrast, the Democratic Model envisages a pedagogical role for the Media. It views the Sullivan-Style immunity for untrue statements as damaging to democracy, the once free market becomes polluted with false information and this licence for false information is viewed as inimical to robust, informed debate by citizens on matters of public interest. This model for press freedom has been embraced in Canada, Australia, New Zealand and in the House of Lords. Irish jurisprudence never truly favoured any one model. The only important role of the media that has been recognised is that of public watchdog(Irish Times v. Ireland [1998]). However, Article 40.6. 1 describes the media as organs of public opinion and recent decisions on defamation and privacy appear to subscribe to the notion of the media as a vital facilitator of citizens debate also. Hence, it is reasonable to conclude that the Democratic Model has most influence on Irish Law: Defamation: Recent high profile cases such as Hunter v. Duckworth [2003] IEHR 81 and Leech v. Independent Newspapers [2007] IEHR 223 are testimony to the Democratic Model informing judicial decision-making. In Hunter, OCaoimh J. endorsed the decision of Nicholls J. in Reynolds v. Times Newspapers liberalising the law of defamation and extending the Qualified Privilege Defence, applying the Reynolds-Style privilege to a publication that the Courts deem to be the product of responsible journalism. He noted with approval Nicholls J.s list of non-exhaustive factors that indicate responsible journalism as well as his focus on the extent to which the subject the subject matter is of public concern. The case concerned two members of the Birmingham Six who claimed they had been libelled by the author and publisher of a booklet entitled The Birmingham Six and Other Cases: Victims of Circumstances. The plaintiffs claimed the inference or innuendo contained in the booklet was tantamount to depriving them of their innocence, despite the quashing of their convictions. The defendant relied on his Article 40.6.1 and 40.3 rights to freely express his opinions. Despite OCaoimh Js strong endorsement of Nicholls Js decision in Reynolds he allowed another Article 40.3 right to take precedence over free speech. He emphasised that reputation is an important part of the dignity of the individual to the extent that he would weigh the balance in favour of reputation in this case. Despite advocating Nicholls Js approach, OCaoimh J. was adamant that while the tort of defamation could act as a disincentive to freedom of expression, so to would any law that tempers that right. The legitimate end of reputation justified the means of restricting freedom of expression. The Hunter case provides a good example of the democratic model of freedom of expression asserting itself in Ireland to the extent that OCaoimh J. displayed enthusiasm for the ten- point indicia of responsible journalism as well as the degree to which a story is of public concern of Reynolds and these factors place emphasis on the accuracy and veracity of a published story hence, it falls into the mould of a democratic model. However the decision can only stand as obiter in this context as the defendant employed the Reynolds decision to support a different argument .. the defendant wanted to protect his opinion and relied on the Reynolds expansion on libel defences by analogy in support of his proposition that his opinion should be constitutionally protected, not that he should be entitled to rely on Reynolds-privilege. The case of Leech [2007] is a better reaffirmation of the expansion of libel defences in Irish Law. . Charleton J.s judgement gave more leeway to media on the libel defence. It copper-fastens the Reynolds defence of reasonable publication/responsible journalism in the public interest to libel actions in Irish Law but Charleton J. also wisely injected some common sense eschewal of technicality, directing attention and analysis away from the ten criteria to the underlying questions of public interest and responsible journalism. The Reynolds defence has been heralded as groundbreaking but subsequent case law revealed that it was being applied in a haphazard manner and had little effect on decisions at First Instance. Cases such as GKR Karate v Yorkshire PostLtd, Grobbelaar v News Group Newspapers and Al-Fagih v HH Saudi Research Marketing (UK) Ltd are illustrative of this fact. It was only with the judgement in Jameel v Wall Street Journal that a welcome clarification was provided to some of the unrealistic attitudes displayed by the judiciary in applying the Nicholls J. ten- point indicia It breathes life into Reynolds, restating, and possibly liberalising the Reynolds approach. It was precisely this attitude that Charleton J. adopted in Leech. He recognised the ten point criteria as a useful guide but not as a determinative tool. He placed the emphasis on the questions of the public interest in the story and whether responsible journalism had been displayed by the defendant. ODell welcomes Charleton Js adoption of the Jameel ratio as first and foremost and his demotion of the non-determinative Reynolds criteria to a secondary place. The judgement further promises liberalising defamation law in its treatment of medias libel defences as a public interest defence.Throughout the judgement, Charleton J. repeatedly asserts the public interest (rather than public importance) of a publication I would rule that a public interest defence can arise where the subject-matter of a publication be it an article or radio or television report, considered as a whole was a matter of public interest I would rule as well that there is a professional duty on the part of journalists to both seek out information that is of a public interest and to impart it to the public and that while that is a matter of professional skill and training, that is also a matter of responsibility. This statement is significant because it asserts that in Irish Law, the press may publish something that is wrong (or not provably right) and they will not be penalised provided they have followed good practice. It levels the pendulum between the right of the public to be informed and the right to reputation. This is affords a very wide defence and it is debatable whether such a wide interpretation would be carried through in the new legislation or whether it would even survive a Supreme Court appeal. While as it stands, Leech remains a fragile precedent, it is a welcome step in recognising a model of media freedom which echoes ECtHR decisions such as Schwabe v. Austria and Bergens Tidende v. Norway. It is to be noted also that the scope of the Constitutional guarantee of media freedom has also been connected to the question of privacy and the public interest as outlined in the recent decision of Cogley v. RTE. In his decision, Clarke J. emphasised the importance of balancing the protection of privacy against the Constitutional requirement that there be a vigorous and informed debate on issues of importance. The public interest in broadcasting the programme in question eclipsed the fact that the information was unlawfully obtained and infringed the privacy rights of individual residents of an Irish nursing home.Clarke J. also warned that the public interest would have to be very significant to warrant interference with the Right to Privacy. The Court must be conscious of ..the fact that It is all too easy to dress up very many issues with an exaggerated and unreal public dimension. The fact that the public interest is a prerequisite for Constitutional protection again nods to a democratic conception of press freedom. The Defamation Bill 2006: (published by Irish Government, July 2006) The new Irish Defamation Bill revises part of the law on defamation in Ireland as well as updates the law to reflect the developments in Irish and ECtHR jurisprudence. It is submitted that its provisions also reflect a democratic model of media freedom. Section 16 of the Bill places the defence of qualified privilege on a statutory footing and more innovatively, the Bill also provides a separate new defence of fair and reasonable publication on a matter of public importance in Section 24. This defence, contained in Section24(1) reflects Nicholls LJs approach in Reynolds. Section 24(2) contains a list of factors reminiscent of Nicholls LJs criteria for responsible journalism. The emphasis on accuracy in s.24(2) rather than pure participation in public debate is indicative of the democratic model. Schedule 2 of the Bill refers to the public interest being served by ..ethical, accurate and truthful reporting by the Press this again echoes the democratic model. The defence contained in S ection 24 has been criticised by academic commentators such as McGonagle and ODell who notes that: The current text of the defence is so hedged that it invites the kind of narrow and rigid parsing that is likely to render it dead on arrival, a statutory dead letter even on the day of its enactment . It is for this reason that ODell welcomes the very wide approach taken by Charleton J. to medias libel defences in Leech. It is submitted that the Leech decision goes even further than the legislative text of Section 24(1). Section 24(2) does not provide a realistically workable defence of fair and reasonable publication. Indeed, it is not desirable that section 24(2) would be invoked in the same rigidly formulaic fashion as the Reynolds indicia (the inspiration of section 24(2). It would be advisable to recast this section in the mould of Charleton Js assertions in Leech which advocated the Jameel correction of the Reynolds defence. The question then remains as to how much of the Leech ratio would survive the enactment of the Defamation Bill. ODell underlines that if the decision had a constitutional basis, it would be harder for the Bills enactment to dilute Leechs effect on the law. Privacy Bill 2006: It is submitted that the Privacy Bill 2006 echoes the Defamation Bill in that it protects media freedom exercised within the parameters of educating citizens on matters of public importance. The newly- created Tort of Violation of Privacy in Ireland indicates that a free market regime of publication does not exist in Ireland. Tort is actionable without proof of special damage and privacy is within the parameters of privacy that is reasonable in all the circumstances having regard to the rights of others and the requirements of public order, public morality and the common good Certain actions that shall amount to privacy include subjecting a person to surveillance, disclosing information or documentation obtained by surveillance without the consent of the individual for financial gain, disclosing diaries etc or harassment. It is to be noted that the Irish LRC were in favour of separate categories of torts of invasion of privacy rather than the rolled-into-one approach mentioned above. Section 4 demands that the Court has regard to a persons office/position when determining their expectation of privacy. Section 5(e) defends an act of newsgathering for a subject of public importance that is fair and reasonable in all circumstances. There may be some problematic implications of the Bills as regards the required public importance and fair and reasonable character of publications. Judges are obliged to review a publication for its public importance but neither Bill gives any definition or guidance on this term. From Cogley, it could be submitted that the term would be afforded an expansive interpretation as that case concerned private individuals the judgement did not insist that the publication be limited to publication concerning elected officials only. Judges recoil from being arbiters of the truth but it is suggested by that they would probably adopt a procedural approach when examining the investigation and accurate presentation (or not) of information to decide whether there was a fair and reasonable publication within the meaning of both new Bills. The adoption of a Press Code as suggested in Section 24(2) Defamation Bill would aid in such adjudication. Without such a guideline, this might have dangerous implications for source protection as considered in recent High Court decision against the Irish Times. That said, it is contended that, while the judges in Mahon held that forcing disclosure of sources in that case was justified under Article 10(2) ECHR and necessary to preserving integrity and confidence in the Tribunal process, the decision must be welcomed as affording strong support to press freedom despite the fact that the decision was quite damning of the conduct of the Irish Times. Dicta from the judgements of President of the High Court, Richard Johnson and Kelly J. and ONeill J. are clearly informed by the importance placed on press freedom by the ECtHR. The judgement acknowledges ..the public interest in the preservation from disclosure of journalistic sources, as an essential prerequisite of a free press in a democratic society?, a principle not recognised as robustly before. The judgement also endorses ..the critical importance of a free press as an essential organ in a democratic society. An essential feature of the operation of a free press is the availability of sources of information. Without sources of information journalists will be unable to keep society informed on matters which are or should be of public interest. Thus there is a very great public interest in the cultivation of and protection of journalistic sources of information as an essential feature of a free and effective press. Conclusion While the provisions of the Defamation and Privacy Bills 2006 are as they stand, imperfect and the law in Ireland is not yet entirely settled (as evinced in the contrast between the decisions in Mahon v. Post Publications and the grounds of the Supreme Court Appeal (announced November 9th) to be taken by the Irish Times against the Mahon Tribunal.) the modernisation and liberalisation of Irish media freedom which they envision is to be commended. They form part of the movement of Irish law towards a democratic model of media freedom. This casts off the shackles of traditional I,rish, common-law scepticism towards freedom of expression. The change has already been signalled in recent decisions of the Irish Courts in Cogley and Leech. However, the success of the libel defences in the new Defamation Bill whether or not they are recast in the language of Leech and the defences in the Privacy Bill, will be largely dependant on individual judges willingness to endorse a democratic model of media freedom. It is submitted that Fennelly Js recent resounding endorsement of freedom of expression gives readers reason to be hopeful on this point : The media are not required to justify publication by reference to any public interest other than freedom of expression itself. They are free to publish material which is not in the public interest. I have no doubt that much of the material which appears in the news serves no public interest whatsoever. I have equally no doubt that much of it is motivated and perfectly permissibly so, by the pursuit of profit. Publication may indeed be prompted by less noble motives. Bibliography Judgments cited: UK decisions: Reynolds v. Times Newspapers [2001] 2 AC 127. Jameel v. Wall Street Journal [2007] 1 AC 359 McCartan v. Times Newspapers[2001] 2 AC 180 GKR Karate v Yorkshire Post Ltd[2000] 1 WLR 257 Grobbelaar v News Group Newspapers [2001] 2 All ER 437. Al-Fagih v HH Saudi Research Marketing (UK) Ltd [2001] EWCA Civ 1634. Ireland decisions: Murphy v. IRTC [1999]IR12 Goodwin v. Hamilton No.2 [1993] 3 IR 307. AG v. Paperlink [1984] ILRM 348 Hunter v Gerald Duckworth Co Ltd. (unreported High Court 31 July 2003 OCaoimh J). Leech v. Indepedant Newspapers [2007]IEHR 223. Cogley v. RTE [2005] 4 I.R. 79. Mahon v. Post Publications [2005] IEHC 307, [2007] IESC 15. Judge Mahon and Others v Keena and Kennedy, [2007] IEHC 348. ECtHR decisions: Murphy v. Ireland (2004) 38 EHRR 13. Jersild v. Denmark (1995) 19 EHRR 1. Schwabe v. Austria (1992) Series A No 204-B. Bergens Tidende v. Norway (2001) 31 EHRR 16. Thorgeirson v Iceland (1992) 14 EHRR 843. Other Common Law Jurisdictions: Abrams v. US 250 US 616 (1919) New York Times v. Sullivan 376 U.S. 254 (1964) Lange v Atkinson [2000] 3 NZLR 385. Lange v. ABC (1997) 147 A.L.R. 96. Hill v. Church of Scientology [1995] 2 S.C.R. 1130 AT 1183 dicta of Cory J. Textbooks: McGonagle, Marie, Media Law, (2003)2nded. Thompson/Roundhall. Fenwick and Phillipson, Media Freedom and the Human Rights Act,(2006) Oxford University Press. Journals cited: Kelly, Deirdre, Bearing Falsewitness against your neighbour: The Evolution, perils and possibilities of the development of Qualifies Privilege in Defamation Law (2007) 7UCDLR109. K Beattie, New Life for the Reynolds Public Interest Defence? Jameel v Wall Street Journal Europe (2007) 1 Euro Human Rights L Rev 81. I Loveland The Ongoing Evolution of Reynolds Privilege in Domestic Libel Law (2003) 14 Entertainment L Rev 178. Hooper The Importance of the Jameel case (2007) 18(2) Entertainment L Rev 62. B Docherty Defamation Law: Positive Jurisprudence (2000) 13 Harvard Human Rights J 12. Wildhaber, The Right to Offend, Shock or Disturb? (2001) 36 Irish Jurist. McDonald, Towards a Constitutional Analysis of non-media qualifies privilege (1989) 11 DULJ. ODell, Does defamation value free expression? [1990] 12 DULJ at 62. McGonagle, Marie, Reforming Media Law in Ireland:Part 1: Defamation and Privacy, (2006) Communications Law ,11(6), 195-200 Rowbottom, Jacob, Media Freedom and Political Debate in the Digital Era (2006)MLR 69(4) 489-513 ONeill, Corporate Freedom of Expression (2005) 27 DULJ 185 Bonnington Reynolds Rides Again(2006) 11 Communications L 147 Hooper The Importance of the Jameel case (2007) 18(2) Entertainment L Rev 62 Loveland The Ongoing Evolution of Reynolds Privilege in Domestic Libel Law (2003) 14 Entertainment L Rev 178, 179. Cram, Reducing Uncertainty in Libel Law After Reynolds v Times Newspapers? Jameel and the Unfolding Defence of Qualified Privilege(2004) 15 Entertainment L Rev 147. Conference Papers/Essays: Carolan, Freedom Of The Press After Defamation and Privacy Reform (paper presented at conference on The Defamation and Privacy Bills 2006 September 2006 at Trinity College, Dublin). Now published in Irish Bar Review November edition. Corbett An Overview of the Privacy Bill 2006 (paper presented at Conference on the Defamation and Privacy Bills 2006 September 2006, Trinity College, Dublin.) Schauer, Is Freedom of the Press a Human Right? Frank Stanton Professor of the First Amendment, John F. Kennedy School of Government, Harvard University, and George Eastman Visiting Professor and Fellow of Balliol College, Oxford University. Paper was delivered at the annual Broadcasting, Society and the Law Lecture, delivered at University College Dublin on 25 October 2007, under the sponsorship of University College Dublin and Radio Telefs ireann. Nagle, The interaction between Article 40.6 and Article 10 ECHR after Murphy v. IRTC, Murphy v. Ireland and Hunter and Duckworth.. (December 2003, Trinity College, Dublin) Websites/Blogs: ODell, www.cearta.ie www.mediaforum.ie Scott, Murray, Tambini, Mansell, https://www.lsemediapal.blogspot.com www.oireachtas.ie www.courts.ie www.taoiseach.ie. WWW.IRLII.ORG WWW.BAILII.ORG www.lawreform.ie www.ireland.com www.village.ie Newspaper Articles: OToole Fintan, Caught between Free Expression and protecting citizens from unjust attack, Irish Times, Tues. Oct.21st 2003. Carolan, Mary, Leech judge gives more leeway to media on libel defence, The Irish Times, 30 June 2007. Carolan, Mary, PR adviser faces large bill after libel claim rejected, The Irish Times, 29 June 2007.

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The Fashion Channel HBS Case Notes Free Essays

Introduction The protagonist of this case is Dana Wheeler who is the senior vice president of marketing for TFH She was looking into preparing a new Segmentation and Positioning Strategy If her boss liked what he heard then they would move forward with a 60 million dollar MIMIC campaign utilizing national advertising, promotion, and public relations. This was an increase of 15 million dollars from last year. Background TFH was a successful cable network that was the only one who broadcasted up-to- date news about fashion 24 hours a day, 7 days a week It was founded in 1996 It has had consistent and constant growth since the beginning, revenue was projected to grow to 310 million dollars in 2006 marking another steady year of growth. We will write a custom essay sample on The Fashion Channel HBS Case Notes or any similar topic only for you Order Now The channel was one of the most widely available niche networks reaching 80 million US households (this number represents the number of people who had TFH in their package not those watching it) Women between 34 and 54 years were its most avid viewer according to its annual demographic survey Beyond basic demographics the network had no other information on its viewers Nor did it attempt to market to any viewer segments in particular Early on the network had chosen a something for everyone† type of strategy in its programming and advertising TFH has clearly grown quickly despite it lack of targeted marketing, however at the beginning of 2006 TFH had realized that other networks were taking note of its success Some of its biggest competitors became Lifetime and CNN who had added fashion programming to their lineup This is what prompted Tech’s CEO to want to change up TFH marketing and be more strategic with their marketing, this is why they hired Dana who extensive experi ence with marketing packaged consumer goods as well as broad experience in advertising. Tech’s CEO and other executives felt some urge to resist change and didn’t want to â€Å"fix what wasn’t broken† Wheeler’s Plans Frazier (senior up of ad sales) had warned that TFH would need to drop the price of a unit of advertising by 10 % if changes weren’t made in Tech’s performance He mentioned that CNN and Lifetime’s fashion shows were achieving notable ratings (EXHIBIT 1) Frazier was a great salesman and was Justifiably worried about sales Wheeler knew that in order to hold or increase the price it would be crucial to attract a critical mass of viewers who were interested in the network’s content and were attractive to advertisers The key would be targeting the right viewers and offering advertiser an attractive mix of viewers when compared to their competitors BUT if she changed the network’s offering in a way that disappointed too many consumers it could risk losing its distribution support Her plan was t o build a strategy for segmentation and use it as a base to employ all marketing tools at her disposal, traditional/internet ads, PR and promotions to reach targeted consumers Everyone felt that advertising was TFH primary growth opportunity. Tiff’s Advertising Revenue Model TFH was on target to generate 230. Million dollars in 2006 from advertising The advertising business model was built on attracting a mix of male and female viewers on a regular basis – think â€Å"something for everyone† strategy Tuft average rating was 1. 0 with 110 million households or 1. 1 million people people watching at any given time. The ad sales team sold access to viewers through 30 to 60 second spots to a variety of advertisers which included automobile manufacturers, clothes companies, and cosmetic companies There were usually 6 minutes of advertising per 30 minutes of programming (20 percent); 24 hours per day; for a total of 2016 minutes per week In 2006 industry data showed that advertisers spent 20 billion dollars on advertising in cable industry, however there were over a hundred networks competing for these dollars which made competition fierce. TFH was the only dedicated fashion network If CNN and Lifetime are successful more channels may copy them creating more competition for TFH The network based ad unit prices on several factors The number of viewers (ratings) The audience characteristics (demographics and lifestyle) Both of the are hurting ad sales and hurting Tech’s CPM TFH was facing additional competitive challenges in its attractiveness to cable affiliates. On a scale of 1 to 5 TFH achieved a 3. 8 whereas fashion programming on CNN scored a 4. 3 while Lifetime scored a 4. 5 On awareness TFH scored 4. 1; CNN 4. 6; and Lifetime 4. 5 On perceived value TFH scored 3. 7; CNN 4. 1; and Lifetime 4. Memo’s use the aforementioned data to determine Affiliate Fees and which package to offer TFH in. If TFH continues to underperformed it may be offered in less appealing packages making it seen in even fewer households, ruining its prospects of revenue growth or even survival. The Data strongly indicates that change in programming need to happen so that TFH can increase consumer interest, awareness, and perceived value This change could result in upsetting some of the existing loyal viewers The Management team had been with TFH for years and experienced large amount of their growth arguing safe marketing strategies where Wheeler is asking them to take a risk. Attitudinal Research Findings The Following Data can be found in Exhibit 2 and Exhibit 3 There are four unique groups of viewers Factionists Planners Shoppers Sustainability Basics While the segments varied in size, Wheeler quickly noticed that the smallest -The Factionists- had a high degree of interest in fashion Most of the male interest occurred in the Basics cluster- the least likely to be engaged with TFH content. Factionists, Planners, and Sustainability all had cluster of women between the ages 18 to 34, the premium demographic. By investing in a major marketing/advertising campaign it would be reasonable to expect that awareness and viewing of the channel would go up This could deliver a ratings boost of 20% and would take the rating from 1. 0 to 1. 2 If the current audience mix stayed the same, ad sales were predicting a ten percent drop to $1. 80 Wheelers Preferred Strategy Targeting Factionist’s, Shoppers/Planners, and Situational All segments mentioned have clusters of the desired age group but both Planners and Situational are made up of older women their existing audience and they would all be targeted It is likely to assume that ratings would increase from 1. 0 to 1. No clear data is given about CPM No clear data is given about the increase in cost of programming Alternative Strategies Focusing on Factionists This segment was strong in the highly valued 18-34 female demographic It was smaller that other segments represent Primarily targeting Men Pursue a desirable demographic as men of all ages are a premium demographic No data on ratings No data on CPM No data on Programming costs, however it would be likely to assume that costs would pike as all current programming is geared to slightly older women (their current primary demographic) They would likely and very quickly lose all of their current audience due to shift in programming for a demographic that they are unsure they can even secure. High short-term risk as all current audience will be lost and could result in ratings loss and being taken off the basic cable package Long-term if this strategy is successful, men could be a larger audience than women as more age groups are desired by advertisers. This could result in greater affiliate fees and ad sales. How to cite The Fashion Channel HBS Case Notes, Essays

Microeconomics and its Application

Question: Discuss about the Microeconomics and its Application. Answer: Introduction The article provides an overview about Nomura that attitudes a fall in productivity to a higher employment share on lower-productivity sectors. The other factors that led to fall in output are the increasing costs in the course of higher international economic vagueness. The increase in unit labor costs leads firms to increase prices, stoking apprehension over stagflation. According to the IMF estimates, Singapore was considered as the richest country in the world. It was also considered as the most competitive as well as business-friendly country in the world. However, the country was infected by deep structural inequality as well as widespread poverty and high unemployment. The productivity growth of Singapore was not expected to pick up in the next few years due to fall in global growth. The article shows that fiscal policy is likely to be a stable balancing act with the government probable to remain in the course of restructuring. The outlook for Singapore corporate may not be mi serable in spite of the sluggish GDP growth rate. It has also become difficult for Singapore to totally decouple from the gentleness in foreign demand with net exports accounting for 20 to 30 per cent of real GDP (Leong 2016). Macroeconomic Indicators The drive of Singapore to restructure its economy in order to lift productivity has failed so far. This is mostly due to the increase in aging population that had led to fall in potential growth rate. Productivity is considered as the efficiency with which resources like labor and capital are converted into outputs such as commodities and services. Outputs are mostly measured by market value in order to enable global comparison. In the context of Singapore, value-added per employee is what the officials of government mostly refer. Labor productivity is considered as an imperative measure as it is associated closely to the incomes of the individuals. the improvement of productivity is an imperative aspect for countries like Singapore as its inputs factors are close to being completely utilized. In the early stages of development, countries were able to expand their economies by organizing under-utilized factors on inputs. As these factors are utilized, the competence with which these are utilized then turn out to be the most imperative factor (Reuters 2016). Despite of having tight labor market, the growth of wages in Singapore diminished sharply as compared to the wage growth of 2013. As a result, economic growth and productivity slowed down. Singapore also announced a shock loosening of monetary policy in order to start the shuttering economy. In the context of Singapore, growth development forms the central objective due to the fact that Singapore is a developing country. As a result, it is imperative to have a stronger economic growth in the country as it affords the individuals with the prospects to join the ranks of developed economies in the world. The economic policies in Singapore are mostly implemented to trade-off negativity of growth. The slower growth rate of Singapore is also likely to lead to probable recession. A recession mostly leads to fall in real GDP. Due to recession, Singapore is likely to have a period of negative economic growth (Tanzi 2015). Demand side shock is considered as one of the major cause that leads to recession. This in turn will also lead to decrease in aggregate demand in Singapore due to high rate of interest rate that in reduces borrowing and investment (Greenstone, Mas and Nguyen 2014). Another most imperative cause that leads to recession is supply side shock that leads to lower level of real GDP as well as higher rate of inflation. A level of national income changes during the short-term during supply-side shock. There are several causes that lead to supply side shocks. The most common factor is level of wages that affects the unit labor cost of a firm (Coibion and Gorodnichenko 2015). Economic growth is mostly a long-run procedure that takes place as the potential output of the economy raises. As aggregate demand and aggregate supply changes, changes in real GDP from quarter-to-quarter fluctuate. Economic growth is mostly defined as a procedure with the help of which an economy accomplishes an outward shift in the production possibilities curve. In order to produce potential level of output, Singapore requires to operate on its production possibilities curve (Nicholson and Snyder 2014). This will in turn imply an outward shift in the production possibilities curve. In the structure of the macroeconomic model of aggregate demand and supply, economic growth shifts towards the right in the long-run aggregate supply curve. There are three key points that leads to economic growth: Growth is a procedure: It is not considered as a single procedure rather an unfolding series of events. Growth is defined in terms of the ability of the economy to produce commodities and services as specified by its level of output. Growth also suggests that the ability of the economy to produce commodities and services is increasing. In order to increase economic growth as well as decrease unemployment, the government of Singapore requires to increase investment on commodities and services. The government of Singapore had implemented the Resilience Package that includes a rise in investment on infrastructure to raise economic growth in the crisis. This will also lead to an increase in disposable income to raise consumption expenditure by diminishing direct taxes or increasing transfer payments. A decrease in corporate income tax leads to larger expected after-tax proceeds along with increase in consumption expenditure on designed investments that result in a rise in investment expenditure. On the other hand, the increase in consumption expenditure as well as investment expenditure on commodities and services leads to an increase in aggregate demand. This results in an increase in national output that leads to an increase in the demand for workers in the economy, ensuing in the fall in unemployment (Chong Tee 2013 ). Economic growth is also likely to lessen the problems related to poverty that would raise the standard of living of the general population directly. This will also help to create more jobs and can also determine the internal macroeconomic objectives. If the growth in aggregate demand is so fast that rises in the productive capacity, constancy is undermined as Singapore will risk inflation as the economy experiences blockages (Ostry, Berg and Tsangarides 2014). In the half-yearly Macroeconomic Review, it has been noted by the Central Bank that the economy of Singapore has been presently in a cyclical downturn after logging a sharp contraction of 4.1 percent. Singapore also has a small multiplier mostly due to the high savings and high imports. The Monetary Authority of Singapore administers policy by letting the Singapore dollar increase or decrease against the currencies of its major trading partners within an unrevealed trading band on the basis on its nominal effective exchange rate. The country uses currency policy rather than rate of interest as a tool to pull the economy of the island. It manages the dollar against an unrevealed basket of currencies of its key trading partners as well as competitors. The country had originally boarded on industrialization with the most important objective of providing employment for its domestic inhabitants. Value-added per employee is mostly used in Singapore in order to measure labor productivity (T ang, Liu and Cheung 2013). Another most imperative macroeconomic indicator is that of rate of savings. This savings could be raised that indicates less dependency on foreign borrowings. The rate of saving in Singapore is considered the maximum in the world. The mobilization of domestic assets materializes to have played a very imperative role, along with foreign capital in the economic expansion of the country. The development policy of the Singapore state is mostly marked by large saving and investment (Hermes and Lensink 2013). The report also provides an overview about the fact that increase in unit labor cost may force firms to increase prices encouraging concern over stagflation as well as higher core inflation in spite of lower economic growth. However, to decrease inflation the government requires to diminish expenditure on commodities and services. Fiscal policy is a demand-side policy that is required to control expenditure of the government to manipulate aggregate demand (Cohen and Amors 2014). One of the major solutions to decrease stagflation is to increase aggregate supply side policies. In other words, stagflation can also be decreased with the help of privatization and deregulation to augment efficiency. The concern was over stagflation as well as higher core inflation as stagflation is a term that is used by most of the economists to describe an economy that has inflation. The economy of Singapore can also have a slow or sluggish economic growth due to stagflation that leads to high rate of unemployment. The policymakers of the country are trying to get rid of stagflation at any cost. This mostly because, high rate of unemployment further adds to slower economic growth (Cohen-Setton, Hausman and Wieland 2016). According to economists, any disadvantage to the Singapore economy to be counterbalance by stronger US demand that a rate high ought to denote. High tax rates are likely to deject work, saving, investment as well as innovation. Economic activity reflects a balance between what individuals, trades and governments requires to purchase as well as what they want to sell. In the long run, supply plays the important role to determine economic potential. The long run effect of tax policy not only depends on their inducement effects but also on deficit effects. The broadcast to Singapore from shifts in rates of US money market will be fast and significant. However, the most negative collision from a US rate hike on Singapore market is likely to come from the foreign exchange markets. High tax rate is likely to affect the economy through changes in federal finances. However, if the change is revenue-neutral, there will no issues related to financing effects. The initial tax rate is likely to have an impact on the tax cut of a given size. The tax cut should be financed by some combination of future expenditure cuts or future tax rises. In the absence of future expenditure cuts, tax cuts are likely to increase the federal budget deficit (Tan 2016). High tax rate will lead to increase in cost of borrowing. Interest payments on credit cards are more costly and as a result, it discourages individuals from borrowing as well as saving. On the other hand, people who already have credit cards will have less disposable income as they are likely to spend more on interest payments. As a result, other areas of expenditure are likely to fall. Mortgage interest payments will also be increased. Hence, consumer expenditure will be impacted largely. Higher interest rate will make it more attractive for increased incentive as it will make it more attractive to save in a deposit account. The economy of Singapore is likely to face fall in both investment and consumption. As a result, the confidence of both customers and business are likely to be decreased (Atkinson and Stiglitz 2015). Economic Policy Chosen by the Government The government will require to reduce borrowing as a percentage of GDP. In other words, future budgets require to restrict investment as well as increase taxes. The risk that is associated with high tax rise is that if tax are increased too early or too fast, it could slaughter out the recovery as well as lead to a further recession. If taxes are not increased, markets may be distressed at size of borrowing. With economic growth to remain sluggish in Singapore amid a monotonous international outlook, the government is reviewing its forecast of 1 to 3 percent growth. The Monetary Authority of Singapore (MAS), along with the Ministry of Trade and Industry, will mostly conduct the review. The government has also displayed its overall obligation towards the policies of active export promotion as well as openness towards overseas trade. The government had also recognized prospects in Western markets that also encouraged local investors to work together. The government had also generated a n environment to progress reliability as well as reputation (Reinhart and Rogoff 2013). The investment made by the government also leads to crowding-out impact that is mostly viewed as complementary to private investment. The policy of the government is mostly intended to promote export-led development as well as attract foreign investors by making Singapore as the most attractive places to invest in. The government of Singapore subsidies private investors with the help of active strategies. This comprises high quality infrastructure, education, and training. Subsidies are also mostly concentrated on strategic industrial clusters as well as those who are targeted by the government to influence overseas investors (Brander, Du and Hellmann 2015). Conclusion It can be concluded that the economy of Singapore has had an experience that was not popular among other former colonies that includes continued economic growth. It is important to have a stronger economic growth in the country as it affords the individuals with the prospects to join the ranks of developed economies in the world. A steady macroeconomic environment with low level of inflation had generated a positive environment for a long-standing business viewpoint in the planning investment decision. It can also be concluded that Singapore requires to operate on its production possibilities curve. This will in turn imply an external shift in the production possibilities curve. The economy of Singapore is mostly relied on exported commodities that include customer electronic goods, information technology products and pharmaceuticals. The country also has large inflow of overseas capital and it also has the largest investment ratio. Higher interest rate will make it more attractive f or increased incentive as it will make it more attractive to save in a deposit account. The outward and inward investment has also steadily increased in Singapore. It can also be concluded that the slower growth rate of Singapore is also likely to lead to probable recession that will also lead to sluggish growth rate in the country. References Atkinson, A.B. and Stiglitz, J.E., 2015.Lectures on public economics. Princeton University Press. Brander, J.A., Du, Q. and Hellmann, T., 2015. The effects of government-sponsored venture capital: international evidence.Review of Finance,19(2), pp.571-618. Chong Tee, O., 2013. An exchange-rate-centred monetary policy system: Singapore's experience.BIS Paper, (73w). Cohen, B. and Amors, J.E., 2014. Municipal demand-side policy tools and the strategic management of technology life cycles.Technovation,34(12), pp.797-806. Cohen-Setton, J., Hausman, J.K. and Wieland, J.F., 2016.Supply-Side Policies in the Depression: Evidence from France(No. w22140). National Bureau of Economic Research. Coibion, O. and Gorodnichenko, Y., 2015. Is the phillips curve alive and well after all? inflation expectations and the missing disinflation.American Economic Journal: Macroeconomics,7(1), pp.197-232. Greenstone, M., Mas, A. and Nguyen, H.L., 2014.Do credit market shocks affect the real economy? Quasi-experimental evidence from the Great Recession and normaleconomic times(No. w20704). National Bureau of Economic Research. Hermes, N. and Lensink, R., 2013.Financial development and economic growth: theory and experiences from developing countries. Routledge. Leong, G., 2016. Singapore productivity growth sluggish: Nomura. The Straits Times. Retrieved 26 December 2016, from https://www.straitstimes.com/business/economy/singapore-productivity-growth-sluggish-nomura Nicholson, W. and Snyder, C.M., 2014.Intermediate microeconomics and its application. Nelson Education. Ostry, M.J.D., Berg, M.A. and Tsangarides, M.C.G., 2014.Redistribution, inequality, and growth. International Monetary Fund. Reinhart, C. and Rogoff, K., 2013. Financial and sovereign debt crises: some lessons learned and those forgotten. Singapore second-quarter economic growth seen sluggish, keeps central bank pressured. 2016.Reuters. Retrieved 26 December 2016, from https://www.reuters.com/article/us-singapore-economy-gdp-idUSKCN0ZS0DM?il=0 Tan, C.H., 2016. The Beijing Consensus and Possible Lessons from the'Singapore Model'?.NUS-Centre for Asian Legal Studies. Tang, H.C., Liu, P. and Cheung, E.C., 2013. Changing impact of fiscal policy on selected ASEAN countries.Journal of Asian Economics,24, pp.103-116. Tanzi, V., 2015. Fiscal and monetary policies during the Great Recession: a critical evaluation.Comparative Economic Studies,57(2), pp.243-275.

Economic History of Modern Europe Essay Example

Economic History of Modern Europe Essay Name: Course: Instructor: Date: We will write a custom essay sample on Economic History of Modern Europe specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Economic History of Modern Europe specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Economic History of Modern Europe specifically for you FOR ONLY $16.38 $13.9/page Hire Writer Economic History of Modern Europe Europe has undergone one of the most profound changes in various aspects such as the economic conditions and sociopolitical values. This is due to the increase in interactions between various societies enhancing the aspect of globalization and multiculturalism. Historical events such as trade across the whole of Europe are among the instigating factors of the widespread economic development across Europe. In addition, this also placed Europe as a significant force of trade to reckon around the world leading to the ability of empires in Europe to access numerous products, which enhanced the development and growth of civilization in European countries. Economic structures in Europe have changed over the years, as a result of the increase in democracy and new approaches to enhance equity in the distribution of resources (Clough, Charles, 27). Land is considered a crucial factor of production. Land carries all life and economic potential of a given region. This is evidenced by the increasing values of land accruable to prime properties because of the presence of infrastructure or resources on the land. As a factor of production, land is important in the sense that it is considered as the origin of all material wealth. The value of land and the ability to access the same has changed considerably over the years because of the changes in the uses of and in the demand for the same over the years. Land in historical Europe was essentially used for agricultural purposes. This is because agriculture is the main economic means of ensuring sustenance. Land is an essential factor of production as it provides a producer with the much-needed area or space for production purposes. In addition, it also avails the much-needed resources such as mineral that are raw materials for production (Clough Charles, 33). From the perspective of a landowner, the use of land over the years has been the main of drivers of demand for land in Europe. This is attributable to the increased demand for housing, production sites and agricultural sites for production. The agricultural revolution took place in Europe as a means of transition into civilization from other means of survival such as hunting and gathering, which were unpredictable and unreliable for sustenance of large numbers of people in communities. Increase in the value of land is attributable to the increase in population sizes as well as the growth of industrialization. Industrialization is defined as the process of transition or change from an era of agrarian processes into an ear of industrial processes. The increase in population necessitates the need for ample land to provide housing to people in the society. In addition, it also leads to subsequent need for land, which is usable for set up of industries for production of consumable goods. The changes in the prices of land have resulted in wealthy individuals because of the increase in their land values. Hence, an upward change in land value usually results in the increase in wealth for a landowner. On the other hand, it also results in the inability of other individuals belonging to a low economic class to make acquisition of land. This is one of the main effects of increase in demand of land and the subsequent prices. This has resulted in the division in classes in terms of those who have the ability to make purchases of land and those who are unable to purchase of land. In addition, this is among the main reasons of the presence of a large size of the population in the world without access to ownership of land (Wasserstein, 47). PART II It is evident from available literature that a majority of Europe in the medieval years focused on means of survival. This is evidenced by the focus on agrarian activities to ensure that people had access to food for survival. Majority of labor in Europe focused on agriculture as this sector was the largest employer. Agriculture and commerce are among the main drivers of the economic changes in Europe. Agriculture necessitated the need for innovations and inventions to ensure that there was high production in the field for satisfaction of the increasing demand (Clough, Charles, 46). The industrial revolution is estimated to have taken place between the eighteenth and nineteenth centuries in Europe. Changes in terms of the transition from agriculture to industrialization were one of the main instigating factors of the unprecedented population growth in Europe. Industrialization has resulted in the growth and expansion of industries, such as services and manufacturing, all of which require land as a main factor of production in terms of the site of issue of the services and production of goods. Literature evidenced provides that in the period of 1870 majority of the labor force was embedded in agriculture as the primary source of income and sustenance. However, there was also dire need for transition from the traditional means of agriculture to large-scale farming for the increasing population. In addition, this resulted in the struggle for new means of economic growth. This resulted in innovations, which encouraged large-scale farming resulting in the dire need to dispose the produce because it was in surplus. This was a driver for the need by European countries to engage in commerce to ensure that they were able to access varied products and sell their produce to foreigners (Wasserstein, 52). The developments in agriculture are evidenced in the modern European societies as they are able to ensure large-scale farming at negligible costs due to innovations in farming practices. In addition, commerce is also another major aspect in the modern society in terms of the economic activities engaged by the European societies. Technological changes have enabled increased productivity in economic activities such as agriculture. Innovations are aimed at enhancing productivity and increasing the economic benefits accrued from agricultural activities. Real estate is a lucrative economic activity, which has gained large-scale acceptance. This is because of the increase in demand driven up by increases in population. Increase in population translates in a dire need for land to increase production of goods and issue of services and agricultural activities, which form a substantial economic activity around the world. Modern land prices, when compared to historical land prices could be simply termed as exorbitant (Wasserstein, 57). In addition, issues such as politics have also been factors, which have dictated the ownership and ability towards the acquisition of land by the public in Europe. Policies instated in Europe have been major determinants in terms of enhancing or restricting the ability of the populace to acquire and own land in Europe. Economic conditions have also changed leading to changes in terms of ability of the populace in Europe to acquire and own land. Increasing costs of living have resulted in a scramble for the available employment opportunities, which are essentially inadequate for an ever-increasing population (Berend, 36). Economic conditions usually translate to the effects of aspects such as rates of inflation. Inflation determines the availability of disposable incomes, which in turn affect the purchasing or buying power of the population. Hence, a decline in the inflation rates usually results in subsequent increases in the disposable incomes and thus increases in the purchasing power of the populace. This usually results in economic effects such as property booms and bubbles which if unregulated could result in collapse of real estate markets. On the other hand, high inflation usually translates to reduced disposable incomes and the ability of the population to make real estate or land purchases. Hence, a landowner has the value of his or her land stagnating or declining. Reductions in value also translate to lower rates of real estate developments and the establishment of industrial plants (Berend, 39). Socio-cultural values of land in Europe differ from one region to another. Some parts of Europe only allow ownership of land at certain areas because of historical values placed on some parts of Europe. Land, which is regarded as a heritage, is usually regarded as government property irrespective of such land hanging, been under private ownership. However, there is a transition from the traditional means of business, which focused largely on manufacturing of goods. Consumerism has changed in that, specific focus on service industries than on products consumed is needed. This is because of the changes around the world in terms of consumer preferences and changing consumer needs and focus (Pounds, 57). Land value increase is attributable to improvements in the labor sector in terms of working conditions and remuneration accruable to a laborer. In addition, this is also directly intertwined to the increasing costs of living resulting in the dire need by the labor industry to give in to the demands for higher wages. In essence, land costs and inflation are mutual events, which affect the ordinary citizen. Land costs are determined by the costs of living. In addition, the products, which are derived for use by consumers, are usually produced with the availability of land. Products such as consumables are usually the modern means of sustenance. Some are derived through agriculture whereas others are derived from production processes (Pounds, 63). Hence, increase in the value of land usually translates in the increase, in costs of production of goods such as agricultural products from farms and other manufactured goods. This is because the cost burden is usually transferred to the consumer by either the farmer or producer to the consumer. In addition, production costs of goods are increased by costs such as lease for land and purchase of the same. However, such costs are recoupable as the probability of increase in the value of land is usually high resulting in increased value of the acquired land. Focus on industry and services have resulted in high demand for land, in urban areas because of the high number of population. Service industries usually require high turnover and traffic flow of potential customers for making tier sales. Hence, this resulted in abandonment of agricultural land and new focus on the service and manufacturing industries. Hence, land value is usually different in either the urban areas or the rural areas or between less populated areas and highly populated areas. This is because of the high value attributable to large movement of population because service industries are considered as the modern day businesses (Pounds, 68). Social value of land over the years has evolved because of the changes in the social norms and values. Historically land has been associated with wealth and power. However, in the modern world land is associated with peasantry and agriculture. This is because large farms are usually held by farmers, which might require extensive labor hours to ensure maximum productivity. Hence, modern society has changed in terms of the consideration of land. The value of land is usually associated with prime locations. This is evidence of the changes in the value land in that, urban land is essential in comparison to rural land, which might be more productive than the land located in the urban areas. Landowners over the years have faced challenges brought about by changes in the ability of acquisition of land. New policies have resulted in the reduction of ability of people to won land. Restriction of ownership of land has been necessitated by the need to ensure parity in the acquisition and subsequent ownership of land in a given country. Policies are instituted to ensure the presence of transparency in terms of land ownership. Land is historically an asset, which has been associated with graft in numerous countries around the world. It is also an asset, which has the potency to result in conflict, in the case of disputes over land. Due to the changes in governance structures, land disputes are on the decline. In addition, there are provided avenues for settlement of disputes such as through mediation teams and the main avenue, which is through law courts (Broadberry, Kevin, 47). However, the value of land is constant in that, it is associated with wealth but from a different perspective. Land is valued in terms of its accessibility and proximity of social services or amenities and to the urban areas. Changes in society such as increased rural to urban migration have resulted in the decline in the value of the land in rural areas. This has resulted in appending of high values on land and subsequent developments in urban areas because of the high demand of such land and the scarcity in terms of availability. This represents an elaborate demand and supply chain. The move towards industrialization was influenced by the availability of land and the presence of resources for production. Landowners during the historical period were forced to give up prime land for the establishment of industries and extraction of raw materials for the industries, which sought to satisfy an insatiable consumer need for the products. Additionally, this resulted in appreciation of land value and thus subsequent high demand for land (Brodaberry, 67). In conclusion, land is a primary factor of production as well as for economic development. This is because society appends high value to land as it provides raw materials, goods such as agricultural products, and provides for sites to establish industries and premises for issue of services. Land in Europe was historically sued for agriculture as the main economic activity. However, the economic activities in Europe have changed over the years resulting in a focus on new activities such as the service and manufacturing industries. This is because of the changes in social norms, values and resulting change in consumer behavior. Work Cited Brodaberry, Stephen. â€Å"An Economic History Of Modern Europe: Sectoral Developments, 1870-1914† Unifying the European Experience: An Economic History of Modern Europe, Volume 2: Pp. 1870-2000, 2005. Print. Broadberry, S N, Kevin H. O’Rourke. The Cambridge Economic History of Modern Europe. New York: Cambridge University Press, 2010. Print. Berend, T I. An Economic History of Twentieth-Century Europe: Economic Regimes from Laissez-Faire to Globalization. Cambridge, UK: Cambridge University Press, 2006. Print. Clough, Shepard B, Charles W. Cole. Economic History of Europe. Boston: Heath, 1952. Print. Pounds, Norman J. G. An Economic History of Medieval Europe. London: Longman, 1974. Print. Wasserstein, Bernard. Barbarism and Civilization: A History of Europe in Our Time. Oxford: Oxford University Press, 2007. Print

Correlation between Resistivity and dopant concentration essays

Correlation between Resistivity and dopant concentration essays From observation alone, we can notice that the higher the concentration, the lower the resistivity. This is consistent with the Drude model, which states that the higher the concentration of conducting charges is, the higher conductivity would result. In this case, where the dopant is boron which has only three electrons in its outmost shell, the conducting would be predominantly holes, while electron conduction could only account for small part of conductivity. So theoretically, we can just consider the contribution of holes. However, we would expect some deviation due to this approximation. Among all the samples, the ones with lower dopant concentration would be expected to have more contribution from electrons, which means the resistivity would be lower than the theoretical result. Moreover, according to formula for calculation of resistivity , the tips of probes would have large resistivity, which in return depends on the extend to which the probe contact with the wafer. For different wafer, errors exist. In this sense, we would not expect the logarithm graph of the experiment to be perfect linear. Impurities and the scratches on the surface may also contribute to the errors. As we stated before, the higher the concentration, the lower the resistivity. For high concentration samples, the resistivity would be small so that the small change in current does not result in much change in voltage determined, according to the formula V=IR. We would expect the voltage readings to be quite stable. In contrast, for lower concentration samples, resistivity would be larger, and the voltage would be easily affected. So we would expect it fluctuate from time to time, as we observed in the experiment. Furthermore, because the lab has a lot of electronic appliances, such as handphones and computers, which would exert an electromagnetic field to their ambience (in fact the apparatus is just beside a computer), the Hall effect would occur ...

To explore the relationship between motivation, job satisfaction & its Thesis Proposal

To explore the relationship between motivation, job satisfaction & its impact on employees performance - A study of 4.5 star hotel in Australia - Melbourne - Thesis Proposal Example Egan, Yang, and Bartlett (2004) carried out a study on how job satisfaction and organizational learning culture affected turnover intention and motivation to transfer learning where they carried out an examination of the relationship between job satisfaction, organizational outcome variables, and organization learning culture using IT employees sample in the USA. They then realized that Motivation to transfer learning and IT employee job satisfaction were associated together with organizational culture. They also found out that job satisfaction and organizational learning culture negatively influenced the turnover intention. The people who most of their times are cheerful and positive do tend to have a higher job satisfaction, and they express it rather than those who are gloomy and down most of their time. This is according to the research carried out by R. Ilies and T. Judge (2003, p. 754). They continued saying that the match between outcomes of the individual value in the jobs and how they perceive the availability of outcomes of such kind, more especially for the facets of jobs that are highly valued, primarily determine the job satisfaction (Hirsch, 2004, p. 114). Boswell, Boudreau, and Tichy (2005, p. 885) give the concept of honeymoon and hangover effect in job satisfaction. They view honeymoon effect as the propensity of enjoying high satisfaction level on new jobs, which they have taken as a response to dissatisfaction of the old jobs. They also explain the hangover effect as the tendency of the satisfaction level to drop with time, from the time when a position is new to the time more experience is gained. On comparing job involvement, organizational commitment, and job satisfaction, Moynihan and Sanjay (2007) examined the effects of job characteristics, organizational variables, and individual attributes on some aspects on work motivation,

Philosophy of African culture Essay Example | Topics and Well Written Essays - 1000 words

Philosophy of African culture - Essay Example The African culture has a special concern and regard for the cosmos and the humanity’s place in the cosmos. Most of the African stories are crafted concerning nature, animals , tricksters ad other themes with the common aim being explaining the existence of some occurrences that are perceived by the humanity to be controlled by the divine, and beyond the humanity control. Family values are very important in the Asian stories, with families occupying a special place in the lives of all members. How the tortoise got its rough shell is one of the stories that define the relations between cosmos and humanity in the African culture. Though the story is a trickster, it has a good lesson on the role of humanity in the universe as characterized by the animals. This story is a characterization of animals that were going to the heavens to see God Eke in appeasing him to send forth rains to quench the scorched earth, and bring about produce. From the story, the tortoise had to attend but had no wings to fly, so the birds accepted to donate each a feather to help the tortoise (Uche, 2). As the story narrates, the animals agree on brotherhood and so should help one another (Uche,3). The animals agree to sacrifice in order to appease Eke to send rain and end starvation that had claimed many lives (Uche, 4). The story explains of selfishness (Uche, 7) where the eagle remarks that the tortoise stands better to be sacrificed and the tortoise shows his selfishness by tricking others into eating all the food offered (Uche, 8). From the story above the aspect of humanity in the universe is evident. ... Hard work with no visible goals leads Temba to recount his 30 years of hard work in his daily labor with nothing to show of it (Achebe and Innes, 67). Again in this story, the sun has scorched the earth and humans are hungry again as Temba’s family still count on him to deliver failure to which they might die. The presence of a deity or god who provides in times of difficulty and despair is clear as Temba is provided with a meal for the family after hunger bites hard with no fish to catch (Achebe & Innes, 68). As Temba monologue continues, he wishes that the humanity on earth appease the Gods to send forth rains to end the suffering. This narrative portrays a good relation between God, man and the interdependence of man on God, in times of despair. The strong faith in African culture is evident that enables Temba to get food form God to feed his family. Drought is seen as a punishment from God. Wake, is another African story that spells of despair and desperation in times of n eeds. The story is about the shootings of Soweto in South Africa and largely narrates of the ordeal of death and how it is viewed in the African culture. The signing choirs explain a religious nature of the African people and the respect that the dead are given in their last send off (Achebe and Innes, 33). Death is viewed with a lot of respect in the African culture with multitudes paying their last respects and God appeased through songs for the sake of the dead. The sanctity and belief in respecting the human life is clear (35) as the narrator curses the whites who she accuses of being responsible for the death of their daughters and sons. All the above stories portray a strongly

Learning model 4 Essay Example | Topics and Well Written Essays - 1500 words

Learning model 4 - Essay Example Author (Year) noted that, universities had "recognized the importance of public ethics. The field’s national accrediting body requires graduates, education in ethics, and all introductory public administration textbooks include a discussion of ethics† (p.451). In this regard, the US government requires all its employees to learn the importance of good ethics in the work place while at college. Therefore, ethical behavior effectively becomes the most important aspect for business and public administration. Managing the critics of good governance remained the biggest challenge for multinationals and public organizations in the USA. For this reason, Author (Year) notes, â€Å"Congress has enacted laws and presidents issued executive orders that†¦insure the integrity of federal employees† (p.451). This has enabled the federal employees to stick to laid down structures of governance and financial regulations. Author (Year) further notes, that this results to improved integrity â€Å"clarity, simplicity, and straightforwardness† (p.451). Therefore, all federal employees adherence to enacted legislation while offering their services in all federal offices led to accountability and efficiency. A favorable working environment is crucial in the administration of allocated duties at the work place. According to Author (Year), federal employees must be protected to enable them â€Å"disclose a suspected violation of law, rule or regulation without fear of reprisal† (p.452). In fact, 14 percent of government workers â€Å"feel pressured to compromise ethical standards in the course of their jobs† (Author, Year, p.452). In this regard, the federal government needs to ensure that its employees are adequately protected from intimidation by powerful cartels in their administrative functions, which is eliminating the â€Å"encounter [of] ethical dilemmas at work† (Author, Year, p.452). Employees’ morale is equally important with the result being a commitment to

The Great Gatsby Bibliography

The Great Gatsby Bibliography Barret, Laura. From Wonderland to Wasteland: The Wonderful Wizard of Oz, the Great Gatsby and the New American Fairy Tale. Papers on Language and Literature. 42.2. 2006; 150 153. Fitzgerald uses Gatsby to reflect his own perception on the American dream. Barret, however, in analyzing the New American Fairy Tale, classifies the novel as being an example of an Anti-Fairy Tale. The novel, according to Barret, illustrates The unreality of reality, a promise that the rock of the world was founded securely on a fairys wing (150). As such, the novel does not have a fairy tale ending, which is contrasted by the Wizard of Oz, which does have a more classic ending consistent with traditional fairy tales. Gatsby, as a result, paints the failure of the American dream twenty Five years later (150). Bloom, Harold. Gatsby. New York: Chelsea House, 1991. This book examines Gatsby as a romantic hero being entirely crafted from the perspective of the narrator Nick. According to the author, Nicks biased interpretation of Gatsby leaves the individuals essential qualities forever hidden (178). Bloom further explains, Gatsby depends on his efforts to translate the mysterious mans dramatic gestures into a revelation of their hidden significance (178). The reader, as a result, has to either accept the perspective of Nick or attempt to read between the lines to draw his/her own conclusions on what is really occurring. Canterbury, E. Ray. Thorsetin Veblen and The Great Gatsby.' Journal of Economic Issues. 33.2. 1999; 297-301. This particular article denotes the connection between the Gatsby narrative, the American Dream and Social Darwinism. According to the author, the point of view provided by Nick is outlining an American Dream that is unrelenting and that can swallow up those who dare seek it out. Like Darwinism, the only the most suitable and adaptable will survive. For Gatsby, his death at the end of the tale is a caution that he was ill equipped to deal with the rigors related to the pursuit of the American Dream. Rather than something to be celebrated, the American Dream and the pursuit thereof is something to be viewed with caution and scrutiny. Dyson, A.E. The Great Gatsby: Thirty Six Years After. F. Scott Fitzgerald: A Collection of Critical Essays. Ed. A. Mizener. New York: Prentice Hall, 1963. This article illustrated how the novel is distinctly American and is part of the cultural attributes of being an American and the American Dream for its respective era. For people reading the novel outs ide of the country, Dyson suggests that the novel still is of value; however, he suggests that some of the finer attributes that would be recognizable to an American would not be apparent to an outsider. Nick, as a narrator, takes some of these attributes for granted in the storytelling process. Fitzgerald, F. Scott. The Great Gatsby. New York, Scribner, 1995. As the primary source from which the study is being conducted, the use of this novel will be done with specific regards to critical statements that back the relevant theses. For example, the primary quotes that will be employed are those that reflect Nicks perspective on Gatsby. These will be coupled with outside character point of view perspectives on Gatsby when Nick switches from first to third person in the narrative. Two of the examples that will be employed of the third person nature are one conversation between Henry Gatz to Nick about Gatsby and one Jordan and Lucille talking about Gatsby. Giltrow, Janet and David Stouck. Style as Politics in The Great Gatsby. Studies in the Novel. 29.4. 1997; 476-480. This work pays particular attention to the historical era in which the novel was written with attention to Nicks role as a narrator. As the voice of the people living in that time, Nick is the medium by which those voices are heard and, as principle speaker in the text, he serves as a translator of the dreams and social ambitions of the people who surround him (476). Nicks voice, however, is suspect to interpretation and the reader is forced to figure out if Nick is critical of Gatsbys romantic notions or if Nick is truly a conservative reflection of the events that are taking place. Great Neck. The Columbia Encyclopedia. 6th Edition. Columbia University Press; New York, 2009. This particular article illustrated the Great Neck area and explains how the setting pertains to The Great Gatsby. According to the entry, geographically, Great Neck is located on the North Shore of Long Island in Nassau county. It is commutable proximity to New York City and is therefore a popular retreat for the rich as an opposition to city life. Fitzgerald lived in this area and based the fame novel on the region. Gross, Dalton and MaryJean Gross. Understand the Great Gatsby: A Student Casebook to Issues, Sources and Historical Documents. New York: Greenwood Press, 1998. Gross and Gross identify the basic plot of the novel as being fairly simple. On the other hand, it is the symbolism and mechanisms used by the author that makes the story compelling and classic. On a cursory glance, the novel simply recounts a story of man who takes on a life of crime to make the necessary money to woo a female from his past. When she finds about about his past, she rejects him and this ultimately leads to his downfall. Hawkes, Lesley. And One Fine Morning: Gatsby, Obama, and the Resurrection of Hope. Social Alternatives. 28.8. 2009; 20-24. Hawkes attempts to draw connections between the hope and the American Dream attributes of Gatsby to the recent Obama campaign in the United States. Gatsby, which is referred to as The unfinished American Epic, has a potential to be resurrected in modern times through hope and a new political paradigm (20). This article is not infallible and it has a high amount of personal bias, however, it does indicate how the novel is an enduri ng part of the American cultural experience. In terms of point of view, the entirety of the experience is based on the point of view provided by Nick, the novels narrator. Layng, George W. Fitzgeralds the great Gatsby. The Explicator. 56.2. 1998; 93-95. The point of view presented by Nick in The Great Gatsby is one that is able to articulate and make sense of the past in such a way that it is conveyed to the reader. According to Layng, Gatsbys decline is alluded to in the very next sentenceand Nick begins to save and assemble his own history. By the novels end, Gatsby is the ghost literally dead, his past with Daisy lost and nick emerges as the apostle-protagonist. (93).

Ben-hur Essay -- essays research papers

Ben-Hur was transformed from bible scripture to a movie because it is the most read scripture in the Bible. The scripture tells the story of a man, Judah Ben-Hur, who trades his life as the prince of Jerusalem with the life of a slave. The story tells of his journeys and triumphs as a slave. The story starts with the five wise men as their journey to find Jesus. When they arrive in Bethlehem they come bearing gifts for the newborn king. After the birth of Jesus the movie changes to two Roman soldiers who are in a meeting. One of the soldiers, Tribune Musala, is an old friend of Judah. Judah comes in and meets with Musala and invites him to his home for dinner and to see his family. Musala tells Judah how the Romans will conquer his people and if he wants to save his family he can turn in the Rebels who plan to revolt. Judah is enraged that his friend would ask him to turn in his own people, and storms out of the meeting. After the meeting Judah returns home to find an old friend/slave of his there waiting for him. The slave asks permission that his daughter be allowed to marry. Judah gladly grants his wish and meets the young woman, Esther. The two have a private talk in which Judah grants Esther her freedom and says that he will wear her slavery ring until he finds his true love. The Romans enter Jerusalem and the entire city watched from rooftops. As Judah and Esther watched Esther accidentally knocks a shingle loose and scares a horse causing it to kick and buck a general from the horse killing the general. The Romans enter the city and arrest Judah, his sister, and mother. His friend Musala orders Judah to be sent to the galleys. Judah escapes from confines to find Musala and asks him why he would do this to a friend. Musala says, "People will fear me for persecuting my own friend." A chain gang of slaves traveling through the desert stop so the Romans can get a drink of water. The guards allow the slaves very little water, but allow their horses to drink a plentiful amount. The guards say "No water for him" referring to Judah. A man gives Judah water and the guard gets angry and yells at the man. The guard and the man look at each other and the guard cowards. The man is portrayed as Jesus. At the end of the desert travels Judah finds himself in the galleys of a boat as a num... ...ate Musala’s legs, however he wants to wait to see Judah first. Judah arrives and Musala tells him that his family is not dead and that they are in fact in the valley of the lepers. Musala then died in front of Judah. When Judah goes to the valley of the lepers he sees Esther, he gets angry with her for lying to him. She explains their plea to her. Judah then returns to the valley again the next day, this time to see his mother and sister. When he sees his mother she tells him that his sister, Tirza is dying. They go to see Tirza and take her to Rome. When they arrive they find out that a man is being tried. They find that the man being tried was actually Jesus being crucified. As Jesus is carrying his cross up the hill he falls down and is whipped. Judah gave him some water as he did for Judah in the past. One of the guards kicks the water away from Jesus. The four watch as Jesus is crucified. Later that night the three women are sitting in a cave when a bad storm rolls in. At the peak of the storm Jesus died. After the death of Jesus Marium and Tirza are cured of their Leprosy. They then see Judah the next day and everyone was happy that they were cured.