Westpac Essay Example | Topics and Well Written Essays - 750 words

Westpac - Essay Example Not only the net income of the bank has been improving but the total assets of the bank have increased to $670,228 million in the year 2011 from a figure of $618,277 million in 2010. Therefore the bank has been prospering and improving its profitability with the passage of time. This report analyzes the performance of the first Australian Bank, Westpac and the environment in which the bank has been operating. The report first analyzes the conditions and pressures that would impact the performance of the bank and then the report examines the effectiveness of the response and progress of the company towards the sustainability strategies. Moreover, the report analyzes the competitive positioning and then highlights the unique internal capabilities that the bank has which have helped in making the bank successful over the years. Financial indicators have been examined of the bank that have helped in analyzing how profitability the company has been from its past years. After the financial crisis, the banking industry has observed several changes. Banks throughout the world including in Australia did not observe good time period after the financial crisis. Several banks became more cautious and implemented different strategies to minimize their risk and to improve their profitability. With the passage of time, several banks have been able to recover from the impacts of recession; however there are still some banks that have still been struggling to find their footstep back on the right track after being hit by the financial crisis. Westpac can be considered as one of the banks that have been able to achieve profitability after being hit by the great financial crisis and therefore the strategies adapted by the bank need to be examined and discussed. Different banks have adapted different kinds of strategies to improve their profitability. One of the strategies that have been successful to a certain extent has been to merge or acquire

Cantonese opera Essay Example for Free

Cantonese opera Essay Most foreign people know what Bejing opera is, but Chinese national Opera has a long history and 275 species of Chinese operas have been saved, there are a wide range of operas were not extended yet, Cantonese opera is very popular in the south of China, many Chinese people prefer Cantonese opera to Beijing Opera. The biggest difference between Beijing Opera and Cantonese Opera is language, the Beijing Opera use Mandarin, the Cantonese Opera use Cantonese. Cantonese opera is local opera in Han Dynasty is formerly known as drama or Guangdong opera from the Southern Opera. Cantonese opera began to appear in Guangdong, Guangxi from AD 1522 to 1566 (Ming Dynasty Jiajing) included singing, read, hit musicians ,soundtrack, stage costumes, The abstract body performing arts. Each Cantonese opera role has its own unique costumes dress. The initial performance language is Zhongyuan phonological, also called matshed Mandarin. At the end of the Qing Dynasty, the intellectuals changed the opera language to Guangzhou language in order to facilitate their revolution, also aimed to make Cantonese understand easier. Cantonese opera ranked into national intangible cultural heritage on May 20, 2006. The UNESCO add Cantonese opera in the human intangible cultural heritage list on September 30, 2009. Cantonese opera originated in the Chinese folk songs which called Qi folk songs, the earliest folk songs can be traced back to the Book of Songs from pre-Qin Dynasty, but this is the common origin of all Chinese opera, such as Beijing opera, Cantonese opera, class opera, Shanghai opera, Shaoxing opera, and Huangmei opera. The stage art style is impressionistic. The scenery is simple, the play provides situational by virtual performance program, or write captions on board like riverside, alpine instead of stage background. Performances who in the city called GD-HK learned drama, opera and movies to improved their performance and made theme reflect contemporary life. Later, people Change falsetto into true voice in Cantonese opera. The men sing like relatively stable, low; women sing like very delicate and mellow. As some Cantonese opera are very favorite in new media, these famous Cantonese opera has recomposed in movies, TV series, dramas, and music. For example, Princess Chang Ping Purple Hairpin Peony Pavilion , Gemini worship the Moon, The Reincarnation of Hongmei mind Butterfly and Red Pear Hanada Baxi Xiangluo Otsuka Red Cherry broken heart A Dry White Begonia Red, A Dream of Red Mansions the Sanxiao marriage White Rabbit Guizhi complain Dou E Yuan (also known as June Feishuang or June Snow ), also included the first national intangible cultural heritage Butterfly Lovers.

Operations Management Assignment Concept Design Services

Operations Management Assignment Concept Design Services Concept Design Services (CDS), Linda Fleet, marketing director of CDS is working with design house, providing end-to-end product design, manufacturing and high-quality designer goods distribution integrated service provider. All three types of operations management responsibilities have been working, the implementation of CDS which helps them succeed. Direct responsibility, is directly related to the service and delivery of products and production activities. Before that, they used to do industrial moldings as aerospace and some cheap household goods. According to Linda fleet management, they found that they could also become one of the main advantages of high produce profitable business. They all went to the companys customer service, so retain revenue customers and win new customers the ability to contribute. Indirect responsibility is involved in activities with other parts of the CDS interact. However, CDS new products need more complex mechanical and longer working hours. As the company grows, enlarged the demand for their products, operations management is to achieve time efficiency is very important. This is crucial, because it makes the right production plan through coordination between sales, manufacturing activities and design. Promote the companys costs, so if effectively managed, can reduce the cost of the entire enterprise. Broad responsibilities involve scanning is a political environment, social and business in which the existence of the organization is to understand the broader context of its mission. In its production process and the complexity of delivering services require good management, if they are to meet their customers needs time to succeed. Through proper operation and management, stock appeared greatly accurately forecast sales lead to lower delivery costs reduced. If managed properly, could damage the product and customer traffic adversely affect the companys reputation. In any case, the role of operations management can be highlighted by achieving business goals. Minimize costs, maximize revenue and avoid excessive investment, and the development of future innovation capacity. Operating performance objective is to ensure the proper operation of resource allocation, there are performance necessary to monitor, review the operation and record. A solution role in this process is the performance that relates to the internal and external factors that are associated with the appropriate measures to identify administrative competitiveness. This enables organizations to describe performance goals to measure its results of operations of the five basic operations are performance objective are quality, speed, reliability, flexibility and cost. Quality is very important in our list of performance objective, as many authorities believe it is the most important. The meaning of quality is a service and product, as it should be. In other words, it is consistent with its specification. CDS external influences customers complain less, this will make it easier for customers and good quality satisfaction. This brings more revenue CDS. If the CDS high quality consistency for all business processes and activities will progress is being made very few mistakes. This usually means that, CDS costs are saved, and increased reliability of the response speed increases. Speed is saying responsiveness of speed shorthand. This means that the external or internal customer requests a product or service, and they get it to the interval. CDS external speed is important, because it helps to quickly respond to customers. This is usually a positive consumer will be more prospective to return with more business observation. Sometimes it is possible to charge a higher price when the service is fast. Have a great impact on the speed of the internal relationship between cost reduction will mean faster throughput customers reduce costs. When the material system in the long hang around, as well as more opportunities for them to get lost. Dependability refers to the time customers receive their products or services on. External Dependability is generally considered a good thing by the customer. Of course, late delivery of goods and services can be considerable stimulus customers. CDS can guarantee its sustainability and success is also equipped with an increase in customers provide more opportunities for companies and of brands CDS return. CDS internal reliability is to save time, save money directly and through a CDS stability to enable it to improve its efficiency. Flexibility always means to change the operation in some way. Flexibility subdivided into different types of products or services flexibility , delivery flexibility, mix flexibility, volume flexibility. For external flexibility to benefit CDS, CDS they can let consumers to customize their new product or service and they want to deliver by the CDS. It also allows CDS to make a huge number of products or services in order to reduce costs. (Slack, 2007). It allows the internal impact of CDS, to meet our customers faster response in dealing maintain the reliability of the change based on market demand and contribute to the provision of goods and CDS save time and money. First, the cost structure of different company can vary significantly. Note how the costs of different types of four different examples. Second, and most important, the other four performance objective are caused by internal, to reduce costs. CDS must manage their own products, a large number of products produced. It can save more costs, it can make more profit. Price is very important for each customer. If cheap, you can get good quality products, every customer will buy as much as they can. Volume: It is considered high. While this case study does not specify the amount of production, it can be inferred yield. Another sign of mass production is, CDS from its key line subcontract to other mounding company, so they can focus on producing its own concept. Variety: It considers the reasons for the high cause CDS market is a highly competitive, innovative design which determines the corporate life. CDSs capacity of develop products that are stylish, and its adaptability to change, because change is the key to the fashion business survival. Change: It also believes that the reasons for the high variety, CDS is forced to continue to produce innovative design, will retain their customers are interested in, and therefore maintain a high demand for the same reason. Visibility: You can consider is the high and low. When there is the visible part of the operation of final product I do not think theyll like this better if they insist they know best plastic molding, specializing in it, which makes standardized speed up production processes and reduce their unit costs. In operation, I believe that if they separate from other business cooperation activities, but mainly decided to do or from a central executive body, it works to their advantage. This is because, through the provision of priority, designers, which caused delays and friction within the company as well as to customers waiting. For the CDS must also improve their business, they need to develop a more accurate and reliable sales forecasts in order to achieve : higher utilization , better customer service and cost savings. Provide cross-training between designers and marketing departments in order to improve sales forecasting additional activities can be carried out. From product testing to scheduling and forecasting work closely with all aspects of those unit costs will be reduced, because the waste reduction will be minimal, and provide feedback to the designer. This will let them know what the feedback of marketing products out there getting greetings, EM brass and what is and what is not. The company seems to be more and more clients from a narrow El has been re -based accounts, which is why the separation operation, so that more concentration should be placed on them to ensure they select and hire guaranteed, and tell them they are a priority for some can easily change their states that its operation is visible, but not to their satisfaction. As for the other part of the normal activities of daily orders and can be set to meet the flexibility and scope of these commands so that you can request from that seems to take longer, so deal with a wider range of color variations speeding customers who may not have weighty order to allow both types of client needs treatment.

Macbeths Ambition :: essays research papers

Macbeth’s Ambition Political ambition undermines man’s loyalty. In the play, Macbeth decides to kill his king because of his ambition for position. At the beginning of the play, he portrays himself as a noble person. He fights in the battle against Norway and proves his loyalty; however, as soon as the witches prophesize that Macbeth “shall be king hereafter'; (1.3.53), he is not longer trustworthy. Ambition for power starts creeping into his head. After Macbeth’s internal conflict over whether or not to kill Duncan, he decides to do it quickly (1.7.3) in order to hasten the predictions. He decides to kill the king because he wants to extend his power all over the country by becoming the new monarch. He desires to be more wealthy and respected by the nobility as well as by the common people. Becoming king represents the highest rang in the political pyramid. The act of murdering is the only way to make his dreams come true because Duncan’s fair and prosperous rule over Scotland experience the support of the whole population. As Malcom and Donalbain fly to England, he automatically takes possession of the throne. Macbeth displays political ambition first of all because of his wife. After she reads her husband’s letter about his meeting with the witches, she suggests for Macbeth to kill Duncan so she could be queen. At the beginning Macbeth hesitates to talk about such a thing and even lists the reason not to kill: he is his king, his uncle and his guest. Not completely sure about it and victim of his own desires for power he finally accepts Lady Macbeth’s plan for murdering the ruler of Scotland. This decision portrays Macbeth’s dirty morality and easily manageable personality. Macbeth’s character is a clear example of how ambition corrupts man’s personality. After a brief period of hesitation, he finally decides to take the infamous way of murder in order to make his political desires come true. His ambition, stronger than the moral and social condemnation of killing, becomes his sole motive. The American philosopher David Young goes further in this analysis and sees in Macbeth how “the act of regicide is a ready means of illustrating the genesis of tragic structure in struggles for power'; (Young 318).

“Homeless” by Anna Quindlen Essay

In this story â€Å"Homeless† Anna writes about analyzing what homeless don’t have and to look at them differently, it all started by a women named Ann and there she had realized of the homeless. She, Quindlen, knows what Ann is talking about how home is very meaningful, I also understand. Hopelessly Quindlen terminates that our faculty of being home has adjusted. During the time, I originally discord with Anna that the homeless are the one to give tender feelings. She convinced us to focus on what they needed other than who we think they should be. Feeling that she had pulled my strings at the beginning by reason of she decided upon as her homeless person not a crazy lady but a woman she had met at the Port Authority terminal that claimed that she’s not really homeless. Ann pulls out a photo but not a weapon I sensed Quindlen had ambushed me. I admit that â€Å"Home is where the heart is at† after all I also eulogize my 2 bedroom apartment that is occupied by nine people. Yet it keeps us secured and stable. Home is where memories are made, kept and given. The homeless that I’ve seen are mostly men walking around asking for money most of them don’t have card-boards to live in. They seem to scare me. I’m afraid that one of these days they’ll abduct me and maybe I’ll end up spiritless. When mother and I go for a walk in the area of East Los Angeles I hold her close to me, we’re both constantly on guard because the homeless are everywhere. I feel like running home where I can hide and have protection. In one’s view, a person can’t be fulfilled without a permanent home for many cases. A person without a permanent home is similar to not living. If it’s a temporary home then the person would be frustrated for the reason that he or she won’t be able to live in a home for long and wants to have a life where she or he can keep inviting guests and have a home where that person will be able to do anything. On the other hand, if it is not a permanent home nor a temporary home this is an incomparable situation seeing that a person who is homeless isn’t achieving anything and not experiencing how it feels to have a home. Seeing others eating well, dressing well, having a healthy life is not making the homeless feel satisfied for what they have-not. Assuming that Quindlen’s essay was about how the homeless require a home alike any other human, this case which I acknowledge here and now, the purpose can do more than that an unimaginable home where a person can confidentially do anything just plenty that we need to produce the homeless. Quindlen mentions however she does not adjust on those who prevent shelters because of personal reasons they have been through the past. We should know their needs as well. And we need to consider providing a place free of fear for those who, instead of wanting to paint a room blue, would like to read a book or watch a movie on TV. I agree, that home is everything, Ann needs a home that she can call her own, but to be a compassionate people, we should take the time to understand and help even those who don’t have pictures of yellow houses in their soiled bags.

The Impressive Range of Impress

The Impressive Range of Impress The Impressive Range of Impress The Impressive Range of Impress By Mark Nichol Impress has various meanings, both literal and figurative. This post explorers those senses and the meanings of various words in which impress is the root. Impress is derived from the Latin verb premere, meaning â€Å"press† and the source of press in all its senses. It usually is a verb and can mean â€Å"imprint by applying pressure† or â€Å"affect significantly.† (It is also a synonym for transfer and transmit.) One can impress a design onto an object using heat or physical pressure, such as by branding or stamping, and one can impress another person by performing an action the other person considers impactful or meaningful. One can also do or say something to impress on another person the significance of a fact or opinion. Another sense of impress is â€Å"force or take by force,† as in the case of sailors or soldiers enlisted against their will or someone coerced or pressured into undertaking an action or a task. However, impress is also a noun, though its use as such is not as common as its employment as a verb. An impress is an imprint or a stamp or seal, an effect, or an act of forcing such as one of those described in the previous paragraph. The act, however, is usually referred to as impressment. An impression is an effect of, or a feeling based on, an action or an imprint or mark on an object or an act such as imprinting or marking. The word also refers to a first coat of ink or paint or the amount of pressure with which it is applied, or the entirety of a set of printed materials produced in one batch. It also pertains to an imitation of a recognizable person that exploits well-known traits such as a unique voice or distinctive mannerisms; one is said to do an impression of someone else, and a person who routinely does impressions for entertainment purposes is called an impressionist. Impressionist also refers to an artist who creates visual art, literature, or music intended to capture feelings instead of details or represents impressions of reality rather than reality itself. In painting, the term is often capitalized, and the art form is called Impressionism. The adjective pertaining to the artist sense is impressionistic. Two other adjectives stemming from impress but distinct from impressionistic and each other in meaning are impressive and impressionable. The former means â€Å"eliciting admiration or awe,† while the former means â€Å"tending to be easily influenced† and usually pertains to children or young people who have not yet acquired critical-thinking skills, though it may also apply, in a pejorative sense, to adults who are insufficiently skeptical. The less common adjective impressible, however, applies to the sense of imprinting. The noun impresario, referring to a conductor, manager, promoter, or sponsor of an entertainment event or series, is unrelated; taken directly from Italian, it derives ultimately from the Latin verb prehendere, meaning â€Å"seize† (also the source of apprehend, comprehend, and prehensile). Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Vocabulary category, check our popular posts, or choose a related post below:50 Redundant Phrases to Avoid8 Types of Parenthetical PhrasesDealing With A Character's Internal Thoughts

Inferential Statistics and Findings Essay Example

Inferential Statistics and Findings Essay Example Inferential Statistics and Findings Essay Inferential Statistics and Findings Essay Inferential Statistic is the procedure of pulling decisions from informations that are capable to random fluctuation. for illustration. experimental mistakes or trying fluctuation. Our squad uses illative statistic to compare two groups. which are Melks and DHL. This paper outlines the sampling and informations aggregation process used to prove the void hypothesis. The nothing and surrogate hypotheses are: ( There is no important difference in trade name consciousness based on the selling channel used ) . ( There is a important difference in trade name consciousness on the footing of the selling channel used ) . Here is an illustration of the statistics of our consequences depicting the entire figure of people from minimal age to maximum from ages 35 to 55. Mock information for the independent variables for Melks. The Pie chart below states the per centums of income of each part surveyed. get downing with Los Angeles taking with 44 % . New York with 35 % . and the southern part with 21 % . Los Angeles and New York combined holds about 80 % of the income documented in the studies. The following pie graphs explicate how MELKS services where utilized from consumers by telling ware online from Online shops like Amazon. eBay. Craig’s list. and a bunch of section shops while and having by Melks bearers. Besides one of the graphs show the per centum DHL controls with their bringings from these same online shops. Although the graphs expression really similar. nevertheless they are different in the figure of clients of whom use the services. The above column chart shows how we picked the targeted group for our squad survey with the people in the 35-55 old ages old age group. These peculiar groups of people have households. and they use bringing services of some type when telling. delivering or buying merchandises through the Internet. In decision Inferential Statistics is pulling decisions from informations that are capable to random fluctuation in this instance is Melks and DHL and this shows us the difference in per centum of use between the two bearer services Melks and DHL. This has give us more information to find if the void hypothesis will be right or if we will necessitate to accept the alternate hypothesis. Mention Heppner. P. P. . Kivlighan. D. M. . Jr. . A ; Wampold. B. E. ( 1999 ) . Research design in guidance ( 2nd ed. ) . New York: Brooks/Cole. Kerlinger. F. N. ( 1986 ) . Foundations of behavioural research ( 3rd ed. ) . Fort Worth: Holt. Rinehart and Winston. Inc. Smith. Ph. D. . S. ( 2013 ) . Determining Sample Size: How to Guarantee You Get the Correct Sample Size. Retrieved from hypertext transfer protocol: //www. qualtrics. com/blog/determining-sample-size Nichols. J. ( 2014 ) ehow subscriber. The Average Income Per Household by State. Retrieved from hypertext transfer protocol: //www. ehow. com/info_7750187_average-income-per-household-state. hypertext markup language

Future of Smart Phones

Future of Smart Phones Executive Summary The paper uses qualitative statistical forecasting to analyze, futuristically, the world of smart phones. The paper finds that to have headway, the company should engage in strong planning and anticipate future products. Additionally, they should adopt a leadership structure conducive to this.Advertising We will write a custom essay sample on Future of Smart Phones specifically for you for only $16.05 $11/page Learn More We will examine the development of the smart phone technology. This is one of the most evolving things the world over. The smart phone has adopted many of the features of a variety of products. This includes alarm clocks, GPS tracker, watches among others. This is likely to change even further. This paper will explore the likely direction Smart Phone development is likely to take in the next five years. Thereafter, we conduct an analysis of what this will mean for our consultancy business and take a position on whether it w ould be prudent to take a leadership role or not. Prediction of Development in the Next Five Years Smart phones are developing much faster than PCs. Leading companies such as Apple and Samsung are investing billions in an attempt to come up with the next-big-thing in phone technology. Currently, there are smart phones with applications that release different fragrances when different people call the phone owner. In future, Smart Phones will be able to predict the user’s mood and health situation(Sher Lee, 2004). Some predict that the phones might actually be embedded in the users’ brains. Such phones will make calls based on users’ thoughts and connect when the receiving party thinks of the caller. Of course, the insertion of the chip into the brain will be a risky affair. Another aspect of change is also in the size of the smart phones. I predict that in future phones will be miniature devices. Some even propose that phones will be as small as watches. This wil l definitely increase the convenience of carrying them around(Scott-Curran Lampe, 2012). Meaning of This Development It is crucial to note that IT is the bedrock of current organizational operations. Currently, Smart Phones form a large part of IT since business executives use them to work on the go. Hence, a possible failure or fault in IT could have catastrophic ramifications.Our company should adopt a leveraged strategy and planning methodology in its operations(Davenport Brooks, 2004).Advertising Looking for essay on business economics? Let's see if we can help you! Get your first paper with 15% OFF Learn More This development implies that we will be able to exchange information with our clients much faster than today. In the reverse, clients will require much faster response from us. It also increases the importance of data security. If the smart phones act according to the users’ emotions, important data may be compromised leading to losses fo r our clients. The firm also needs to beware of competition, which could adopt the new technology and put us out of business. The Role The firmshould adopt a leadership role. This allows the customer to have confidence and trust in their products. Additionally, it gives the customer a head start in the market that is constantly changing (Northouse, 2013). Adopting a leadership role requires massive investment in technology before competitors. Owning leading technology is an expensive affair that needs proper management. The firm needs to make a provision for these expenses in advance. The second consideration the firm needs to take before adopting a leadership position is which technology to adopt and which to ignore. In a leadership position, it is difficult to know which technology will eventually be a hit and which will fail. The firm needs to employ IT specialists to assist in this area. References Davenport, T. H. Brooks, J. D. (2004).Enterprise systems and the supply chain.Jou rnal of Enterprise Information Management, 17(1): 8-19. Northouse, P. G. (2013). Leadership: theory and practice. Thousand Oaks: Sage. Scott-Curran, S. Lampe, T. (2012).Smartphone Of The Future Will Be In Your Brain. Retrieved from https://edition.cnn.com/2012/10/05/opinion/curran-lampe-mobile-phones/Advertising We will write a custom essay sample on Future of Smart Phones specifically for you for only $16.05 $11/page Learn More Sher, P. J. Lee, V. C. (2004).Information technology as a facilitator for enhancing dynamic capabilities through knowledge management.Information Management, 41 (8): 933-945.

Assignment 2 Essay Example | Topics and Well Written Essays - 500 words

Assignment 2 - Essay Example However, the study results from Wald Testing methodology and actual juvenile court records indicated there was not a considerable difference between neglectful parenting and authoritative parenting. This is identified in Table 2 in the study, however this was based on quantitative multi-variate testing and not only the self-report inventories returned by the chosen sample group of youths. The study conducted by Simons & Conger also predicted, based on previous literature, that authoritative parenting would breed better adjusted adolescents in relation to academics or the broader social environment. However, this article predicted that having two authoritative parents would be rare considering the dimensions of adult-based control needs that would negate both parents taking an authoritative role. The article identifies neglectful parenting styles versus authoritarian styles, with modifications for a variety of combinations of both styles. This study’s methodology differed and i nvolved questionnaires filled out by key sample participants and then a follow-up observational approach using videotape as documentation. Important dimensions of this sample’s self-reporting dealt with perceptions of hostility in the home, monitoring and parenting style.

Steamboal Bill. Jr Movie Review Example | Topics and Well Written Essays - 750 words

Steamboal Bill. Jr - Movie Review Example This movie is a silent comedy thriller produced in 1928 by Charles Reisner featuring Buster Keaton and he has written the story along with Carl Harbaugh. It is a story about William Canfield (Steamboat Bill) who is a captain owning ship and is awaiting his son to come and join his business who has finished his graduation. But to his dismay, his son arrives with his lover who is the daughter of his business rival King. Steamboat gets jailed for misconduct and his son tries to save him from jail but end up in the middle of the cyclone storm. The storm strikes down building and the wind buffet Steamboat bill Jr. He takes shelter under a tree and it gets uprooted and he land up at the waterfront. Then he gets chance to show his manlihood and ends the rivalry between William and King and save all of them from the accident. The story has a theme of rivalry and triumph of a son. The story has a focus on the rivalry between Canfield and King and which led both the people in trouble. This is also the reason why Canfield hesitates for the marriage between his son and lover. The other theme being the delicate triumph of son over his father where he saves his father and his rival from an accident. It is good to see that the movie has lush scenery which makes the movie a pleasant watch. The movie has a good measure of sympathy and suspense. The different episodes of the movie are depicted discreetly and this enhances the drama of the movie. The special effects of the movie are note worthy as the picturization of storm was technically flawless. It was realistic and added to the technical quality of the movie. The stunts and special effects were inventive and wildly inventive. The Keaton played as a good protagonist with his athletic expression and comedic physicality. Keaton’s stunt shots are immortal .The movie had romance, action and humor. The camera angles of the movie were interesting and there was an innovative

Do you need decoration to create a pleasing environment PowerPoint Presentation

Do you need decoration to create a pleasing environment - PowerPoint Presentation Example The modern movement was largely against the use of heavy decorations in architecture and regarded it as unnecessary and a â€Å"waste of labor† by many. However, this is in fact not true. There are numerous historical evidences which point to the contrary, i.e. decoration or the use of decorative elements in architecture has more to offer than an eye pleasing environment. As opposed to the use of structural elements such as stones, trees and ponds, decorative elements or artifacts lend a human touch to a natural scene, where most of them are known to have functional use. For instance lanterns which were extensively used as decorative elements could be used to light pathways in gardens and the water basins used in gardens could alternatively be used for purification prior to a tea ceremony and artifacts such as the Buddhist statues and miniature pagodas carried sacred inscriptions. The new Brazilian architecture (Figure 3) for example, is known for the use of such decorative elements as the glazed tiles and granite blocks of colonial art. However, besides acting as decoration, the extensive use of such materials as, tiles and granite has proved to be an excellent alternative for protection of the exterior of the buildings against rain and sun, where no other material could withhold it, especially in buildings near the sea. Where modernist architects considered the post modernist architecture as â€Å"vulgar† and dominated by heavy decorations, the post modernist architects on the other hand regarded the modernist architecture as mundane and lacking in taste The Piazza of the Campidoglio in Rome is known for its perfect synchronization on an inlaid pavement. The artistic creation and patterns used helps in creating a stunning contrast between the buildings. Although the architecture, might be regarded as lacking in structural relevance it does

Evocative Object Research Proposal Example | Topics and Well Written Essays - 250 words

Evocative Object - Research Proposal Example Constant suspense is a common trait that fearful people possess. There are many kinds of fear. These are namely fear of getting old, decision-making, career change, public speaking and many other kinds. Another very common source of fear is from superstition. A very common example of superstition is that of Friday the 13 of any month of the year. Previous researchers such as Dosey shows that Friday the 13th superstitions are rooted in ancient bad luck associations especially with the day Friday and the number 13 (119). There is also a biblical reference to 13 as an unlucky number. Judas, who was one of the apostles, betrayed Jesus and was said to have been the 13th guest during the Last Supper. This research will predominantly involve interaction with people since fear is something that is developed in people’s minds. The kinds of research designs to be employed in this research are Quantitative and Qualitative. According to Belinda in a Quantitative research design, the Descriptive Model would be most favorable since it describes phenomena as they exist (45). This model makes use of raw data for research. This data is collected through administering questionnaires, carrying out observations and interviews. The people to participate in the interviews will be sampled using Random Sampling techniques. This research may refer to research that relates to this current research to get good information from it. Based on the information collected from the research, evaluation and analysis shall be carried out. The results from the analysis shall be used to create patterns from which decisions will be made to state whether the research was successful or futile. Dr. Belinda Biscoe, presented an article that shows the different types of research designs that can be used in any research. They have been broken down such that the reader may understand the differences put into gathering of information for the

Johnthan Edward 1703-1758 Essay Example | Topics and Well Written Essays - 1250 words

Johnthan Edward 1703-1758 - Essay Example Such beliefs lead us all toward a common good and teach us a better way of life. Religion is also quite complex and difficult, at times, to understand. Theologians attempt to make sense of this difficult subject in an effort to bring people closer to an understanding of the divine nature of the world. While many such famous theologians come from Europe, Jonathan Edwards was born and raised right here in America and is still consider to be one the greatest and most intellectual theologians that ever lived. Jonathan Edwards lived a relatively short life of only 55 years. During his life, however, he contributed many things to American culture, and to the spiritual lives of people around the world. He was quite a smart child, entering Yale College when he was only 13 years old. At that time, Yale was still a seminary instructing students with a Biblical background. During his college years, he quickly began his career as a spiritual and theological writer and graduated as the Valedictor ian in his class. By the time he graduated, he seemed to have already formulated a philosophy of life that he would use as the foundation of his future writings that are still well read today. What follows is a brief, yet thorough, description of the theological and intellectual influence of John Edwards on America. The Writings of Jonathan Edward Jonathan Edwards spend much of his time leading various churches in the Connecticut and New York area. In early adulthood, he learned a lot from his grandfather, who was seen as a spiritual man in the New England area. His grandfather, then, had a huge influence on the philosophy that Edwards would begin to adopt through his studies at Yale and beyond. Not only did people in New England really like Edwards as a person, his great influence probably came from his writings. He wrote volumes of books in intellectual and theological topics during his all to short life. As Phillip Sinitiere wrote, â€Å"Edwards was known both from his large net work or correspondents and through his voluminous writing ministry† (744). He wrote about such concepts as the extent of sin, the importance of ethics and virtue, they dynamics of the human will, and the nature of mission work (Sinitiere 745). There are many scholars who contend that Jonathan Edwards is America’s greatest philosophical theologian. This would put him up there with such European philosophers as Martin Luther. More than being just a theologian, however, it should be pointed out the Edwards contributed a great deal to the intellect of those who read his works. His writings were both deep and profound. Many people still study his works because they are complex, yet so revealing about the world in which we live. It is amazing any time someone who lived 300 years ago is still mentioned today. Edwards is not only mentioned, but studied as if he is still around and living today. That speaks volumes of the respect he must have had while he lived, worked, and wrot e in the New England area. As people continue to study the various writings of Jonathan Edwards, they have discovered that he spoke a great deal about ethics. This conversation is still as relevant today as it was when he first wrote. Philip Quin wrote that Edwards ha â€Å"something to contribute to contemporary conversations and debates in ethics† (300). This shows us that people today are still discussing his view on ethics. Conversations about ethics are

Genre analysis Essay Example | Topics and Well Written Essays - 750 words - 1

Genre analysis - Essay Example At the same time it has made my reflexes so much better, I can feel the difference for myself. Earlier, I was really slow and my reflexes were extremely slow but thanks to the game, I have become much faster now. My hand-eye coordination has also improved tremendously. In addition to this playing online has helped me a lot, I have made so many friends and I constantly play against them to see how good I really am. We also meet outside and spend time together. I became excessively involved and that was when I asked myself some really important questions? Questions like what is the future on gaming and how can I benefit from it? I am investing so much time into it what will I get out of it? These were some extremely important questions that I asked myself and it was very important for me to ask myself these questions and I am delighted I asked these questions just at the right time. â€Å"To narrow my analysis I stumbled upon the Virgin Gaming website.† (Virgin Gaming) The Virgin Gaming website has been developed by the Virgin group and it provides an ideal platform for gamers to grow and develop. I also came across twitch TV website. The Twitch TV website allows gamers to stream gaming videos and attract audience. That was when I started believing that one can make a career out of gaming and I started working towards it. There are so many gamers who have made a career out of gaming and this is certainly possible. So many of them have already been immensely successful. Twitch TV is similar to Youtube and they pay content producers for involving more and more people, this is very similar to Youtube partner program. The audience can contribute greatly, they can chip in with their comments and the types of series they would want to see and the content producers can produce exactly what is required and demanded by the audience. Virgin Gaming is a different ball game altogether. It involves competitive game

Evocative Object Research Proposal Example | Topics and Well Written Essays - 250 words

Evocative Object - Research Proposal Example Constant suspense is a common trait that fearful people possess. There are many kinds of fear. These are namely fear of getting old, decision-making, career change, public speaking and many other kinds. Another very common source of fear is from superstition. A very common example of superstition is that of Friday the 13 of any month of the year. Previous researchers such as Dosey shows that Friday the 13th superstitions are rooted in ancient bad luck associations especially with the day Friday and the number 13 (119). There is also a biblical reference to 13 as an unlucky number. Judas, who was one of the apostles, betrayed Jesus and was said to have been the 13th guest during the Last Supper. This research will predominantly involve interaction with people since fear is something that is developed in people’s minds. The kinds of research designs to be employed in this research are Quantitative and Qualitative. According to Belinda in a Quantitative research design, the Descriptive Model would be most favorable since it describes phenomena as they exist (45). This model makes use of raw data for research. This data is collected through administering questionnaires, carrying out observations and interviews. The people to participate in the interviews will be sampled using Random Sampling techniques. This research may refer to research that relates to this current research to get good information from it. Based on the information collected from the research, evaluation and analysis shall be carried out. The results from the analysis shall be used to create patterns from which decisions will be made to state whether the research was successful or futile. Dr. Belinda Biscoe, presented an article that shows the different types of research designs that can be used in any research. They have been broken down such that the reader may understand the differences put into gathering of information for the

Genre analysis Essay Example | Topics and Well Written Essays - 750 words - 1

Genre analysis - Essay Example At the same time it has made my reflexes so much better, I can feel the difference for myself. Earlier, I was really slow and my reflexes were extremely slow but thanks to the game, I have become much faster now. My hand-eye coordination has also improved tremendously. In addition to this playing online has helped me a lot, I have made so many friends and I constantly play against them to see how good I really am. We also meet outside and spend time together. I became excessively involved and that was when I asked myself some really important questions? Questions like what is the future on gaming and how can I benefit from it? I am investing so much time into it what will I get out of it? These were some extremely important questions that I asked myself and it was very important for me to ask myself these questions and I am delighted I asked these questions just at the right time. â€Å"To narrow my analysis I stumbled upon the Virgin Gaming website.† (Virgin Gaming) The Virgin Gaming website has been developed by the Virgin group and it provides an ideal platform for gamers to grow and develop. I also came across twitch TV website. The Twitch TV website allows gamers to stream gaming videos and attract audience. That was when I started believing that one can make a career out of gaming and I started working towards it. There are so many gamers who have made a career out of gaming and this is certainly possible. So many of them have already been immensely successful. Twitch TV is similar to Youtube and they pay content producers for involving more and more people, this is very similar to Youtube partner program. The audience can contribute greatly, they can chip in with their comments and the types of series they would want to see and the content producers can produce exactly what is required and demanded by the audience. Virgin Gaming is a different ball game altogether. It involves competitive game

Money Is Not Everything Case Essay Example for Free

Money Is Not Everything Case Essay 1. According to C.S. Lewis there are three things morality is concerned about , what are those things? Explain each one. Morality, then, seems to be concerned with three things. First, with fair play and harmony between individuals. Second, with what might be called tidying up or harmonizing the things inside each individual. Third, with the general purpose of human life as a whole: what man was made for: what course the whole fleet ought to be one: what tune the conductor of the band wants it to play a. Personal – What’s the use of thinking and just drawing up rules if we don’t think that the courage and unselfishness of individuals is ever going to make any system work b. Communal – Kindness and fair play between nation, classes and individuals c. Purpose – the thinking that every individual lives on forever. This means that we are more valuable than anything in the world which will come to an end. 2. What are the 4 Cardinal Virtues? (Give a definition of cardinal and each of the virtues)? Cardinal virtues are virtues which are common to all people, Christian or not. It is derived from a Latin word meaning ‘the hinge of a door’ because they are pivotal d. Prudence – practical common sense; harmless as doves but also as wise as serpents e. Temperance – putting a limit to one’s â€Å"addictions† f. Justice – â€Å"fairness† g. Fortitude – 2 kinds of courage, faces danger and sticks it under pain; guts 3. What does it mean for commitment to be â€Å"elusive?† Breaking a commitment for a â€Å"higher† commitment; Breaking a commitment is considered bad by society; the less you think about your commitment, the deeper it is 4. What is the meaning of the statement â€Å"Commitment is a choice and a promise?† And how does it relate to freedom? Though we have a choice, people allow themselves to be afflicted with the voluntary slavery of indetermination. The promise is a particular kind of choice. Unlike every other choice we make, what is unique about a promise is that it describes something we intend to do in the future, whereas any other choice is a formal determination about the present. By giving my word, I am assuming an obligation, but I do more than that. I yield to another, or others, a claim over myself by creating an expectation in them concerning what I say I will do for them. Since we are given choices, it means that we have freedom. As more choices are given to us, we feel that there is more freedom. Also, choosing a commitment means that you are doing what you want. You would never deliberately choose something that you don’t want. In the end, you will feel more free with your commitment because you are doing something that you like doing. 5. Explain the meaning of conscience having both a subjective and objective aspect. Subjective: It is ours, we are responsible for how we decide Objective: it transcends our individualistic, private notions and â€Å"bind† us, calling us ur of ourselves into relation with others and before God 6. What is the difference of â€Å"fear conscience and philosophical-ethical conscience?† Fear conscience: â€Å"Baka mahuli ako† Philosophical: â€Å"Hindi magandang magnakaw† 7. What are the two axial commitments according to Haughey? Explain at least one of them? (note: you can decide just to give one or two examples for each axial commitment) h. The first is the commitment of God to His Son i. Self-donation as a general description 1. I am not growing this relationship. Should I end it? 2. Is self-donation opposed to freedom? ii. Complete commitment to the other in love is at the heart and core of the internal life of God Himself iii. Commitment is an essential part of existence iv. Commitment generates communion v. Commitment is compatible to freedom (self-donation) i. The other is Jesus’ commitment vi. Commitment is a process (Not a single act) vii. Commitment is motivated by love 3. Love one another as I have loved you viii. Commitment is about communion 4. As the Father has loved me, so have I loved you. Abide in my love ix. Commitment has a clear direction 5. No one comes to the Father except through me x. Commitment involves freedom 6. No one takes it from me, but I lay it down of my own accord 8. What does it mean for Jesus’ commitment to be totally free? j. For this reason, the Father loves me, because I lay down my life that I may take it up again. No one takes it from me, but I lay it down of my own accord. I have authority to lay it down, and I have authority to take it up again. This charge I have received from my Father. 9. What is the meaning of this statement, â€Å"The purity of the commitment means you dont just make it, you yield to it—(freely, gladly made)†? 10. What is the meaning of this statement, â€Å"The commitment that is rooted in mutual presence of oneself and God more likely will be preserved?†

Technology Innovation And Competition In Gaming Industry Media Essay

Technology Innovation And Competition In Gaming Industry Media Essay The purpose of this paper is to explain the effect of technology innovation on the competition in a global industry. After presenting some theoretical understanding on this issue, it is further illustrated thoroughly by the example of Gaming Industry and innovations done by the major players in it and how in these days the latest technology innovation by Nintendo altered the terms of competition in the whole industry. Innovation can have radical or drastic effects. Usually innovation is seen as the method of applying technical or specific progress to the market. In this sense innovation can be in relation to processes (i.e. a new method of making something better or cheaper or both) or products (i.e. a new or considerably better product of some kind), or may be a mixture of the two. Product innovation can generate new markets or modify the segmentation of already existing markets while Process innovation have an effect on the competitive balance in existing markets. Innovation brings productivity gains, product diversity and better quality product at fewer prices. With such clear consumer benefits, it also gives innovator competitive advantage by giving the ability to present entirely new products or processes or greater competence in existing techniques. For such competitive advantage it is not necessary to be permanent and other consequence is that it encourages other competitors also And the benefits may be widespread, arising from their distribution through networks. (Peter Freeman, 2004). In other words, by innovation the incremental profits may increase the competition and thus promote RD investments aimed at escaping competition. (Philippe Aghion, et, al, 2002) Many innovations utilize technology. May be an innovation is high technology from the suppliers point of view, but if it is not apparent to the customer as improving and altering their business functions, that is radical innovation. Technological innovations are generally complex products, possessing attributes with which the potential adopting unit may be unfamiliar. Generally high technology innovations have high switching cost and costly in monetary terms. The concern is how this technology innovation alters the terms of competition in the global industry. These technology innovations may reduce cost of production or distribution and also helps in producing higher quality or innovative products that offer new benefits for the consumers. In technology markets, products of new generation often include new features instead of more core capabilities. The acceptance of technology innovation is positively associated with competition. (Thomas and Hubert, 1986). In fact, Abernathy and Utt erback (1978) have suggested that as competition increases, the type of innovations adopted changes from major product innovations to process innovations. The accessibility to innovation is most pronounced if the strategy for preempting new entry requires new technologies for cost reduction or for gaining new segments. Therefore, the conditions for a positive effect of demand uncertainty on the rate of diffusion of innovation are: when existing competition uses cost as a barrier to entry and there is a potential for price reductions and when the preempting strategy is to fill the gaps in satisfying the heterogeneous needs of the market, given that the new products or segments require a technological innovation. There have been many management practices and demonstrations in todays modern times on the requirements for companies to be innovative. It is also usually believed that without innovation companies will immediately lose their charm of competitive edge. Competitiveness of an industry is generally assessed by the number of competitors it has and also competition has reached such a level that only companies who can provide steady stream of innovative processes and products are successful in both domestic as well as international markets. The aim of technology innovation can either be to target new customers or the need of existing customers. This can be explained by taking the example of gaming industry, as gaming industry made a lot of technology innovations in memory and graphic components of gaming consoles since many years. The important feature of gaming industry is rapid and sustained technical innovation. INDUSTRY: Since 70s the gaming industry being a only factor in a short time period. It took them only few years to make their place in the market and people started becoming familiar with the gaming companies. Types of games where we stomped turtles and ate mushrooms are gone now. That time gaming industry was really successful and became a billion dollar industry, those were the days when Nintendo started launching games every month. In the early 1980s their use to be a huge increase in demand for video games and has continued with constant increases in the following years. And then in 2000s, the gaming industries supported US market of nearly $13 billion  [1]  and worldwide market of almost $24.5 billion. Right now, in the industry every firm is following different Business Model and the most successful is Nintendos Business Model as the price of their console is less and instead of following others, they are doing something innovative and this time they targeted the non-gamers in the ma rket which the other two competitors could not even think of. The gaming industry tries to improve by releasing new games one after the other. To increase the sales and beat the competition every firm in the industry is trying to improve marketing techniques and games. They launch more powerful consoles with bigger game worlds, new graphics and better soundtracks. Over the last couple of years there is a direct connection between the introduction of next-generation video game hardware and the rise in demand. Through technological upgrading, Video game console manufacturers have gradually moved from 8-bit to 16-bit to 32-bit to 64-bit, resulting in continuous improvement in performance and quality of games. As Sony and Microsoft concentrated on improving their consoles, Nintendo came up with new technology that allows the player to play physically with proper moves unlike the other consoles. The introduction of new product by Nintendo that is Nintendo Wii, game console is an easier to use interface that targets at current non-gamers where as Microsofts Xbox 360, another console is introduced as high definition gaming. So Microsofts behavior is accelerating the technology treadmill and when the new feature has an alternate presentation aspect to attract new customers as in Nintendos case, so this is referred as stepping off the technology treadm ill. So, to alter the terms of competition in the gaming industry, Nintendo came up with technology innovation and launched Nintendo Wii, console in which a motion sensitive controller is used and adopted totally different strategy and with its technology innovation altered the terms of competition in the global industry. Sales and marketing vice-president of Nintendo described the strategy of his firm by citing two popular managerial books, the Blue Ocean Strategy (Kim and Mauborgne 2005) and The Innovators Dilemma (Cristensen 1997): Looking at the current state of the video game market, we believe there is a strong argument for expanding the audience beyond the current core players, attracting players by rethinking what a videogame means, and delivering our entertaining in a more convenient and affordable fashion (Casamassina 2005). The video game market is strongly subject to changes and is highly dynamic. THE 3 GIANTS PLAYERS: The gaming industry is dominated and contested by 3 giant players, namely: MICROSOFT XBOX NINTENDO Wii SONY Play Station Once the definite global leader of the video game industry, Nintendo now for the number-one spot in the industry has to compete with Sony. For its home video game systems as well as the hand-held Nintendo DS, Nintendo itself manufactures and markets hardware and software. Nintendo DS has controlled around 90% of the U.S. hand-held market in 2003, the 16-bit Super Nintendo. In the history Entertainment System (SNES), and the performance-driven Game Cube was the fastest-selling video game system. The superior 3-D graphics of Game Cubes and well-known games (Nintendos 50% profits are derived from software) have enabled it to retain itself in the video game competition. In 2005, US gaming consoles has highest market share from Sony with 56.4% share which is followed by 24.9% share of Microsoft and then third one was Nintendo with 18.7% as shown in the figure given below: March (2005) NINTENDOs INNOVATION: Motion Controller Because of the introduction of the innovative motion controller, The Wii has been on fire since it hit the market and US unit, sales have increased to 20 million, making it the highest selling video game console in history and ushering in unique family gameplay with some of the titles such as Mario Kart Wii and WiiPlay. As Microsoft and Sony continued to improve their games, Nintendo tries its best to change the technology. They decided that rather than enhancing their cars, they would considerably build a new vehicle, which would reform the industry. Sony and Microsoft target the older players of human population with their games and consoles, instead of young people. Nintendo instead tried to bring technology innovation to the table and win over the adolescent generations, which are the future. The fact behind the Nintendo Wiis success is that its a cool technology and parents can see their kids exercise. Basically Nintendo did not introduce Wii with the HDTV where as its competito rs did with their latest consoles. This seems relatively a sensible step as the bulk of homes do not have HDTV and the acceptance rate of TV will comparatively slow because non HD TVs do a flawlessly good job. Even elder people like this console, especially if sometimes they prefer to change their inactive lifestyle, or if they are interested to lose some weight. This is why when Nintendo comes to race with its other two competitors, Microsoft and Sony it has the advantage over them. Like Sony some companies depends mostly on their reputation, whereas the ones who wins the race in the long run are those who innovate. The advantages to Nintendo are that, firstly it makes their console low-priced to manufacture, which means that they can sell the console base at a profit while their competitors have to invest in the retail price. Another advantage is that games are a lot cheaper, quicker and easier to develop. This, obviously, has immense effect on what appears generally and when it a ppears on the game shop shelf. (Peter Freeman, 2004) According to the NPD Group (which track retail sale), in November 2008, the company sold 2 million Wii players more than twice the number of PlayStation 3s and Xbox 36Os combined. And in the same month it sold 700000-plus Wii-fit exercise boards. But Nintendos success isnt limited to the Wii. Its portable DS system is the top seller in its category too. In March Nintendo sold 601,000 Wii consoles in the U.S that are more machines than Microsoft and Sony Corp. llustration The couch-potato world of video gamers was dazed when the Wii, was launched with its motion-sensitive remote control. Users can play Wii Golf, tennis and lot more games for instance, by swinging the remote like a golf club, or like a racket in the air. In September, Nintendo added one more accessory in its collection that is a $20 remote-control accessory called Wii Motion Plus that was introduced to add more accuracy to game motions, it make the Wiis motions feel more realistic. But it works only with Wii Motion Plus Games. Wii also encourages users to walk around in more ways than just playing with a remote: Its Wii Balance Board, works like a digital exercise step, which is included in the Wii Fit Plus game in a $100 bundle, It records changes in the bodys weight and all the moves for activities from wake boarding to yoga. The Internet access is included in Wii and users can compete against each other online. Around 655 packaged games are accessible for between $30 and $50. MICROSOFT PROJECT NATAL: Microsoft Corp. developed the worlds first sensor to combine multi-array microphone, an RGB camera and custom processor that allows players to control games with the movement of their bodies, this was an attempt to magnetize the casual players who have fueled Nintendos recent success. The device of Microsoft is a bend on Nintendos smash hit Wii game console, which allows users to swing a racket of tennis or other games equipment by just holding a wand of plastic in their hands. The Microsoft camera doesnt require gamers to hold any thing in their hands to control on-screen action. The camera sits near the television and captures when players move their hands, legs or head. The camera represents another attempt by the gaming industry to get to consumers with more instinctive playing methods than usual game controllers, with their range of joysticks and buttons. To give players more perfect control over games than earlier game cameras actually did. Microsofts camera uses 3-D technology SONY PS-3 MOTION CONTROL: Sony Computer Entertainment, on the other hand, will be competing with Nintendo head-on via a new PS3 motion-control technology set to launch in spring 2010. The PlayStation Eye, Sonys proprietary digital camera that detects the slightest hand gesture, reads movement on the device. On-screen, the controller can then become anything from a bow and arrow to a novelty baseball bat that opens up a wealth of possibilities for PS3 game designers. Sony is also going head-to-head with the current twin handheld device of choice, the Nintendo DS. Sony Corp. plans to upgrade its PlayStation 3 console for 3-D games with a free software upgrade, but for that consumers will have to buy a new TV and glasses. NINTENDO 3-D: Nintendo Co. is planning to sell a new 3-D gaming device without the requirement of wearing glasses while playing as everyone doesnt like to wear glasses. The device will succeed as the DS; which is the best-selling hand-held videogame till date, with more than 125 million units sold since its launch in late 2004. Especially among casual videogame fans, Apple Inc.s iPhone (Smart phones) have started to come forward as a threat to gaming stuff such as the DS. The new system will also play current Nintendo DS games. From TV sets to digital cameras, electronics companies are turning to 3-D as a way to produce better products. Source: Flurry Analytics Conclusion: The history of the video game industry belongs to Nintendo. But in 1990s, Nintendos market share was reduced completely as the preferences of video game players shifted from uncomplicated fun games to technical and superior video games offered by Sony and Microsoft, which entered the market in 2001 with the Xbox. It was basically the technological prowess of Sony and Microsoft, which stole the whole market from Nintendo. When the company was almost falling like a house of cards and it seemed that the competition in the gaming industry was only between Sony Play Station 3 and Microsoft Xbox360. Nintendo launched Wii, a console that had unconventional design. Though Wii was not in direct competition with Microsofts Xbox and Sonys PlayStation, but it managed to steal and fans of both the players and substantial market shares. The Nintendo Wii wiped the sales floor with its competitors. As a response to the massive success of the Nintendo Wii, Microsoft came up with Project Natal, ditching physical peripherals and controllers completely with the worlds first sensor to combine multi-array microphone, custom processor and RGB camera. Sony also did not lag behind as it launched a new PS3 motion-control technology to meet the competition head-on. These innovative devices again disturbed the sales of Nintendo and aiming to revive sales of portable game machines, Nintendo Co. brought about a new 3-D gaming device known as the Nintendo 3DS. So, this can be seen that through a series of innovations and technological advancements, each of the three companies has altered the terms of competition in the gaming industry. Every company is trying to capture the largest market share by bringing about innovative gaming consoles. So, in case of the gaming industry, Innovation is the main mover of the market and it helps in altering the terms of competition in any industry to a great extent.

Munchausen Syndrome Essay -- Disease/Disorders Health

Munchausen Syndrome History Munchausen Syndrome, an illness of psychiatric nature, was first introduced by Richard Asher in 1951 (Zibis et al., 2010). Although Munchausen Syndrome had been described in 1931 by Karl Menninger in medical publications it wasn’t until 1951 that Richard Asher published three case reports and the disorder gained interest (Turner, Reid 2002).The syndrome, as described by the Merck Manual for Healthcare Professionals (2008), is a severe form of a factitious disorder in which the patient tends to feign some kind of illness (physical or mental) without an external reason. Richard Asher was a renowned British endocrinologist and hematologist who is said to have named the syndrome after the fictionalized accounts of Baron Karl Friederich Munchausen (1720-1791) a German soldier who was famous for the adventurous tales about his life (Murray, 1997). Consequently because of the extensive traveling, peculiar stories and refractory treatment, as more cases appeared the syndrome took on various names such as the following: pathologic malingering, chronic factitious illness, and peregrinating problem patients (Justus, Kreutziger, Kitchens 1980). Diagnosis Patenaude, Zitsch, and Hirschi (2006) define a factitious disease as one in which the patient consciously and purposely injures themselves in order for a physician or caretaker to make a wrongful diagnosis and thus be submitted to treatment. Munchausen Syndrome is characterized by the patients’ continuous attempt for admittance at hospitals after a dramatic show of physical symptoms (Zibis et al., 2010). The disorder is associated with severe emotional problems specifically in patients with histrionic or borderline personalities; these ten... ... http://www.merckmanuals.com/professional/print/psychiatric_disorders/somatoform_and_factiti ous_disorders/munchausen_syndrome.htm Murray, J. (1997). Munchausen Syndrome/Munchausen Syndrome by Proxy. The Journal Of Psychology: Interdisciplinary And Applied, 131(3), 343-352. Patenaude, B., Zitsch III, R., & Hirschi, S. D. (2006). Blood-but not bleeding-at a tracheotomy site: A case of Munchausen's syndrome. ENT: Ear, Nose & Throat Journal,85(10), 677-679. Turner, J., & Reid, S. (2002). Munchausen's syndrome. The Lancet (Sciencedirect),359(9303), 346-349. Zibis, A. H., Dailiana, Z. H., Papaliaga, M. N., Vrangalas, V. A., Mouzas, O. D., & Malizos, K. N. (2010). Munchausen syndrome: A differential diagnostic trap for hand surgeons. Journal Of Plastic Surgery And Hand Surgery, 44(4-5), 222-224.

Simplicity in a Clean Well Lighted Place Essay -- essays research pa

Ernest Hemingway is known as one of the best writers of our time. He has a unique writing style in which he manipulates the English language to use the minimum amount of words and maximize the impression on the reader. A Clean, Well-Lighted Place is a prime example of this. Here, Ernest Hemingway uses his writing style to reinforce the theme of â€Å"Nada†. The setting is simple, the characters are plain, and the dialogues among them are short and to the point. It is with the absence of similes and metaphors that the reader is able to appreciate the work for what it is. Ernest Hemingway does not feel the need to give much detail on the setting. The reader knows that it is late and that these men are in a cafà ©. The main character is sitting in the shadow and he is drinking brandy. Hemingway leaves out details from the setting but does make it clear that this cafà © is, like the title suggest, clean and well-lighted. He only states important aspects of the setting demonstrating that details are nothing: nada. Through his writing Hemingway implies that this old man feels that little details in the world mean nothing. When the older waiter asks the younger waiter why this drunken man had tried to commit suicide a week before, the younger waiter simply answers â€Å"Nothing. He has plenty of money.† In the young waiters mind this old man has everything. Obviously, this old man feels that things like money are nothing and thus not worth living over. Ernest Hemingway, through the lack of deta...

Reardon v. U.S. Essay

Lien on real property created by CERCLA when Environmental Protection Agency (EPA) determines that property owners may be liable for cleanup costs amounts to deprivation of a significant property interest within meaning of the due process clause. Comprehensive Environmental Response, Compensation, and Liability Act of 1980,  § 107(l ), as amended, 42 U.S.C.A.  § 9607(l ); U.S.C.A. Const.Amend. 5. Absence of notice and hearing may be justified by exigent circumstances. U.S.C.A. Const.Amend. 5. 92k251.5 k. Procedural Due Process in General. Most Cited Cases Constitution allows the process due to be tailored to fit realities of the situation. U.S.C.A. Const.Amend. 5. *1510 Lynn Wright, with whom Robin F. Price and Edwards and Angell, New York City, were on supplemental brief, for plaintiffs, appellants. George W. Van Cleve, Deputy Asst. Atty. Gen., with whom Barry Hartman, Asst. Atty. Gen., Washington, D.C., Wayne A. Budd, U.S. Atty., George B. Henderson, II, Asst. U.S. Atty., Boston, Mass., Stephen L. Samuels, Steve C. Gold, Jacques B. Gelin, Attys., Dept. of Justice, Charles Openschowski, Office of Gen. Counsel, E.P.A. and Luis Rodriguez, Asst. Regional Counsel, E.P.A., Washington, D.C., were on supplemental brief, for defendants, appellees. OPINION EN BANC TORRUELLA, Circuit Judge. After removing hazardous substances from property belonging to the Reardons, EPA filed a notice of lien on the property for the amount spent. See 42 U.S.C.  § 9607(l ). The Reardons sued to have the notice of lien removed, arguing that they were not liable for the cleanup costs, that the lien was  overextensive in that it covered parcels not involved in the clean-up, and that the filing of the lien notice without a hearing deprived them of property without due process. The district court, in Reardon v. United States, 731 F.Supp. 558 (D.Mass.1990), decided that it did not have jurisdiction to hear the Reardons’ two statutory claims. It ruled that although jurisdiction existed to hear the constitutional claim, the filing of a lien did not amount to a taking of a significant property interest protected by the due process clause. It therefore denied the Reardons’ motion for a preliminary injunction, and dismissed their complaint. The Reardons appealed and a panel of this court ruled in their favor on statutory grounds. Reardon v. United States, 922 F.2d 28 (1st Cir.1990) (withdrawn). We now consider the appeal en banc. After closely considering applicable law, including most notably the recent case of Connecticut v. Doehr, 501 U.S. 1, 111 S.Ct. 2105, 115 L.Ed.2d 1 (1991), we conclude that the district court correctly decided that it did not have jurisdiction to consider the Reardons’ statutory claims, but we find that the CERCLA lien provisions do violate the fifth amendment due process clause. I. BACKGROUND A. Facts. In 1979, Paul and John Reardon purchased a 16-acre parcel in Norwood, Massachusetts, adjacent to an electric equipment manufacturing plant site *1511 known as the â€Å"Grant Gear† site, and named it â€Å"Kerry Place.† In 1983, the Massachusetts Department of Environmental Quality Engineering, responding to a report of a nearby resident, tested soil samples from both properties and discovered extremely high levels of polychlorinated biphenyls (â€Å"PCBs†) on the Grant Gear site and on Kerry Place where it bordered Grant Gear. EPA then investigated the site. Finding the same high levels of PCBs, it authorized an immediate clean-up of the contaminated areas. Between June 25 and August 1, 1983, EPA removed 518 tons of contaminated soil from the two properties. It then notified the Reardons that it had removed all soil with concentrations of PCBs known to be above the safe limit, but informed them that additional areas of contamination might exist, in whi ch case EPA might undertake additional clean-up work. In 1984, the Reardons subdivided Kerry Place into a number of parcels; they sold five of those parcels and retained ownership of the others. In October 1985, EPA notified the Reardons that, as current owners of Kerry Place, they might be liable under  §Ã‚ § 106  and 107 of the Comprehensive Environmental Response, Compensation, and Liability Act (â€Å"CERCLA†), 42 U.S.C.  §Ã‚ § 9606 & 9607, along with ten other present and prior owners of the properties, for the clean-up costs. In August 1987, EPA again investigated the properties to assess the feasibility of a long-term remedy for any remaining contamination. New testing showed that soil in several areas on Kerry Place was still contaminated with PCBs. In April 1988, EPA informed the Reardons of these results. The Reardons told EPA that they intended to clean up their property themselves. EPA advised the Reardons to coordinate any offsite disposal plans with EPA and to obtain EPA’s approval of a treatment or disposal facility. In January 1989, the Reardons informed EPA that they had completed their own clean-up of Kerry Place, without having attempted coordination with or sought the approval of EPA. On March 23, 1989, EPA filed a notice of lien with the Norfolk County Registry of Deeds pursuant to  § 107(l ) of CERCLA, 42 U.S.C.  § 9607(l ), on all of the Kerry Place parcels still owned by the Reardons. The lien was for an unspecified amount, as it secured payment of â€Å"all costs and damages covered by† 42 U.S.C.  § 9607(l ) for which the Reardons were liable under  § 107(a) of CERCLA, 42 U.S.C.  § 9607(a). Five days later, EPA notified the Reardons that it had filed the notice of lien. On July 12, 1989, EPA informed the Reardons that they could settle EPA’s claims against them for $336,709, but noted that this amount did not limit the Reardons’ potential liability. On September 29, 1989, EPA selected a long-term remedy for the Kerry Place and Grant Gear sites estimated to cost $16,100,000. B. Procedural History. The Reardons filed a complaint and a motion for preliminary injunction in the United States District Court for the District of Massachusetts. They argued that they were entitled to have the notice of lien removed for three reasons. First, the Reardons maintained that they qualified as â€Å"innocent landowners† under  § 107(b) of CERCLA, 42 U.S.C.  § 9607(b), and therefore were not liable for any clean-up costs. Second, 42 U.S.C.  § 9607(l ) provides for a lien on only that property â€Å"subject to or affected by a removal or remedial action,† 42 U.S.C.  § 9607(l )(1)(B); the Reardons claim that since some of their Kerry Place parcels were not â€Å"subject to or affected by† the clean-up, EPA erred in filing a notice of lien covering all of those parcels. Third, they asserted that EPA’s imposition of the lien without a hearing violated the due process clause of  the fifth amendment to the United States Constitution. The district court held that  § 113(h) of CERCLA, 42 U.S.C.  § 9613(h), divested it of jurisdiction to hear the Reardons’ â€Å"innocent landowner† and â€Å"overbroad lien† claims. It found that the same section also purported to divest it of jurisdiction to hear the due process claim, but held that Congress was without power to place such a limitation on its jurisdiction. Turning to the merits of the due process claim, the *1512 district court held that the lien imposed by  § 107(l ) did not amount to a taking of a â€Å"significant property interest† protected by the due process clause. The court therefore denied the motion for a preliminary injunction and dismissed the complaint. The Reardons appealed, and a panel of this court found in their favor. The panel opinion construed  § 9613(h) so as to permit judicial review of the statutory challenges to the lien, and did not reach the due process issue. In response to EPA’s petition for rehearing, however, a majority of the court voted to grant a rehearing en banc. Although the court en banc finds for the plaintiffs, as did the panel, we do so on constitutional rather than statutory grounds. II. JURISDICTION [1] We turn first to the question of jurisdiction. The district court, as we have noted, held that 42 U.S.C.  § 9613(h) purported to divest it of jurisdiction over all three of the Reardons’ claims. We agree that  § 9613(h) bars review of the â€Å"innocent landowner† and â€Å"overbroad lien† claims, prior to the commencement of an enforcement or recovery action, but we conclude that this section does not bar review of the due process claim. Section 9613(h), entitled â€Å"Timing of review,† explicitly limits the jurisdiction of the federal courts to hear certain cases arising under CERCLA. The section states, in part: No federal court shall have jurisdiction under Federal law †¦ to review any challenges to removal or remedial action selected under section 9604 of this title, or to review any order issued under section 9606(a) of this title, in any action except one of the following: [listing 5 enumerated types of actions] 42 U.S.C.  § 9613(h). The five exceptions to the jurisdictional bar are all actions filed by the government or by a private citizen seeking to enforce or recover costs for the enforcement of CERCLA; for this reason, the district court described  § 9613(h) as barring â€Å"judicial review of EPA actions prior to the time that the EPA or a third  party undertakes a legal action to enforce an order or to seek recovery of costs for the cleanup of a hazardous waste site.† Reardon v. United States, 731 F.Supp. at 564 n. 8. As a convenient shorthand, we will say that  § 9613(h) bars â€Å"pre-enforcement review† of certain claims. The district court framed the question of jurisdiction as whether the filing of a lien constituted a â€Å"removal or remedial action selected under section 9604 of this title.† As the district court noted, the terms â€Å"removal† and â€Å"remedial action† are defined terms under the CERCLA statute. 42 U.S.C.  §Ã‚ § 9601(23), (24). Another C ERCLA provision says that these terms â€Å"include enforcement activities related thereto.† 42 U.S.C.  § 9601(25) (emphasis added). The court found that placing a lien on property from which hazardous substances had been removed was a type of enforcement activity. It therefore concluded that any challenge the Reardons could make, whether statutory or constitutional, was a â€Å"challenge[ ] to [a] removal or remedial action† over which Congress intended it not to have jurisdiction unless and until EPA brought an enforcement action. Reardon v. United States, 731 F.Supp. at 569. A. Jurisdiction over the â€Å"innocent landowner† and â€Å"overbroad lien† claims. We agree with the district court that filing a lien notice is a type of â€Å"enforcement activity† related to a removal or remedial action. And we agree that  § 9613(h) bars the federal courts from hearing pre-enforcement challenges to the merits of any particular lien–challenges, for example, to the liability which a lien secures, or to the conformity of that lien to the CERCLA lien provisions. Several considerations l ead to these conclusions. First, we think that the language of the statute, read for its ordinary meaning, supports such an interpretation. Central to the entire CERCLA scheme is a provision that makes certain parties liable for the cost of removal and remedial actions. See 42 U.S.C.  § 9607(a). When the government files a lien on property to secure payment of that liability, it can reasonably be described as seeking to enforce the liability *1513 provision. Thus, the activity of filing liens is, in ordinary language, an â€Å"enforcement activity.† Second, we believe that allowing challenges to the merits of particular liens would defeat some of the purposes of barring pre-enforcement review under  § 9613(h). Congress was no doubt concerned, first and foremost, that clean-up of substances that endanger public health would be delayed if EPA were forced to litigate each detail of its removal  and remedial plans before implementing them. Thus, the Senate Judiciary Committee Report stated that  § 9613(h) barred pre-enforcement review because such review would be a significant obstacle to the implementation of response actions and the use of administrative orders. Pre-enforcement review would lead to considerable delay in providing cleanups, would increase response costs, and would discourage settlement and voluntary cleanups. S.Rep. No. 11, 99th Cong., 1st Sess. 58 (1985). As long as the remedy upon review of a lien was limited to the invalidation or modification of the lien, of course, such review would not directly delay clean-up of hazardous substances. However, we do not believe that avoiding delay was the only purpose of postponing review. As the Fifth Circuit stated in a similar case: Although review in the case at hand would not delay actual cleanup of hazardous wastes, it would force the EPA–against the wishes of Congress–to engage in â€Å"piecemeal† litigation and use its resources to protect its rights to recover from any [potentially responsible party] filing such a[n] action. . . . . . Moreover, the crazy-quilt litigation that could result from allowing [potentially responsible parties] to file declaratory judgment actions prior to the initiation of government cost recovery actions could force the EPA to confront inconsistent results. Voluntary Purchasing Groups, Inc. v. Reilly, 889 F.2d 1380, 1390 (5th Cir.1989). The same practical considerations weigh against allowing pre-enforcement review in this case. And we add to these reasons one more: information needed to decide legal challenges to liens may not be available at the time such challenges are made. To decide, for example, the Reardons’ claim that they are innocent landowners, a court must determine whether the contamination pre-dated their ownership; whether they had any knowledge or reason to know of the contamination; whether they had exercised due care with respect to the hazardous substances; and whether they took precautions to prevent releases by foreseeable acts of third parties. See 42 U.S.C.  § 9607(a), (b)(3), EPA Supplemental Brief, at 16-17 (stressing complexity of resolving innocent landowner claim). Notices of liens are likely to be filed early in the history of a response action–shortly after EPA has begun to spend money on waste removal and the  landowner has been notified of potential responsibility. See 42 U.S.C.  § 9607(l ) (providing for creation and filing of liens). At that point, EPA is likely not yet to know the full extent of the contamination, let alone when that contamination occurred, or whether it is likely that the owner exercised due care or took reasonable precautions. One purpose of  § 9613(h), we believe, is to delay review until enough is known to decide these issues. Third, legislative history supports the view that  § 9613(h) is intended to bar challenges to liability, such as the Reardons seek to make by attacking the lien filing, as well as challenges to the remedy EPA has chosen. During floor debate on this section, Senator Thurmond, Chairman of the Judiciary Committee, which drafted the section, explained: Citizens, including potentially responsible parties, cannot seek review of the response action or their potential liability for a response action –other than in a suit for contribution–unless the suit falls within one of the categories in this section†¦. 132 Cong.Rec. S14929 (daily ed. Oct. 3, 1986) (emphasis added). Senator Stafford, *1514 Chairman of the Conference Committee, stated: â€Å"When the essence of a lawsuit involves the contesting [of] the liability of the plaintiff for cleanup costs, the courts are to apply the provisions of section 113(h), delaying such challenges until the Government has filed a suit.† 132 Cong.Rec. S14898 (daily ed. Oct. 3, 1986) (emphasis added). It is certainly possible that Congress inadvertently rather than purposefully included lien challenges in the judicial review bar. Congress amended the scope of â€Å"removal† and â€Å"remedial† actions to include â€Å"enforcement activities related thereto† primarily to ensure that EPA could â€Å"recover costs for enforcement actions taken against responsible parties.† H.R.Rep. No. 253(I), 99th Cong., 2d Sess. 66-67, reprinted in 1986 U.S.Code Cong. & Admin.News 2835, 2848-49; see H.R.Conf.Rep. No. 962, 99th Cong., 2d Sess. 185, reprinted in 1986 U.S.Code Cong. & Admin.News 3276, 3278 (â€Å"This amendment clarifies and confirms that [enforcement activity] costs are recoverable from responsible parties.†). Perhaps Congress did not realize that other provisions referring to removal and remedial actions–such as the judicial review bar–would also be affected. But even if this were so, we do not see how our conclusion is altered. First, as outlined above, reading the statute to bar review of pre- enforcement challenges to liens is consistent with the language and the purpose of the judicial bar. Second, and more importantly,  Congress amended a definitional section, thus changing the meaning of â€Å"removal† and â€Å"remedial† wherever they appear in CERCLA. We cannot give the definition inconsistent readings within the statute. As the above-quoted legislative history makes clear, the 1986 amendment was certainly intended to allow the government to collect attorney’s fees in cost recovery actions. See United States v. Ottati & Goss, 694 F.Supp. 977, 997 (D.N.H.1988) (allowing attorney’s fees to United States under  § 9607(a)(4)(A)), aff’d in part, vacated in part, 900 F.2d 429 (1st Cir.1990). If liens to ensure the government’s complete recovery of its remedial costs are not â€Å"enforcement activities† related to the removal or remedial action–the view suggested by the dissent–then we do not see how a suit to recover the government’s clean up costs is an â€Å"enforcement activit[y]† either. And if â€Å"enforcement activities† in  § 9601(25) is interpreted to exclude the expenses of cost recovery actions, this would have the effect of denying the government significant amounts of attorney’s fees– which was certainly not the intent of Congress. We therefore conclude, as did the district court, that  § 9613(h) precludes judicial review of the imposition of a lien until EPA commences an enforcement action. [2] B. Jurisdiction over the due process claim. Unlike the district court, however, we do not believe that  § 9613(h) precludes federal court jurisdiction over the Reardons’ due process claim. First, such a challenge does not fit into the literal language of  § 9613(h). That section refers to â€Å"challenges to removal or remedial action selected under section 9604 of this title.† Under our reading, it divests federal courts of jurisdiction over challenges to EPA’s administration of the statute–claims that EPA did not â€Å"select[ ] † the proper â€Å"removal or remedial action,† in light of the standards and constraints established by the CERCLA statutes. The Reardons’ due process claim is not a challenge to the way in which EPA is administering the statute; it does not concern the merits of any particular removal or remedial action. Rather, it is a challenge to the CERCLA statute itself–to a statutory scheme under which the government is authorized to file lien notices without any hearing on the validity of the lien. Second, we read  § 9613(h) in light of the Supreme Court’s oft-repeated pronouncement that â€Å"where Congress intends to preclude judicial review of constitutional  claims its intent to do so must be clear.† Webster v. Doe, 486 U.S. 592, 603, 108 S.Ct. 2047, 2053-54, 100 L.Ed.2d 632 (1988); see Weinberger v. Salfi, 422 U.S. 749, 95 S.Ct. 2457, 45 L.Ed.2d 522 (1975); *1515 Johnson v. Robison, 415 U.S. 361, 94 S.Ct. 1160, 39 L.Ed.2d 389 (1974). [FN1] We do not believe that the statute expresses a clear congressional intent to preclude the type of constitutional claim the Reardons are making–a challenge to several statutory provisions which form part of CERCLA. However, it is important to make clear that we are not holding that all constitutional challenges involving CERCLA fall outside the scope of  § 9613(h). A constitutional challenge to EPA administration of the statute may be subject to  § 9613(h)’s strictures. Such a claim may well be a â€Å"challenge[ ] to removal or remedial action selected under section 9604 of this title,† and may thus fall within  § 9613(h)’s bar. We find only that a constitutional challenge to the CERCLA statute is not covered by  § 9613(h). FN1. Of course,  § 9613(h) is styled as a provision that merely delays review, rather than precludes it–indeed, it is titled â€Å"Timing of review.† However, the only available review of the lien notice is in an enforcement action brought by EPA; and the judgment in that enforcement action will render moot the Reardons’ due-process-based request for injunctive relief against the filing of the lien, since it will decide whether or not the Reardons are liable under CERCLA. Hence, the effect of  § 9613(h) is to preclude review altogether. Third, extending jurisdiction to the Reardons’ due process claim does not necessarily run counter to the purposes underlying  § 9613(h). For example, resolution of the due process issue does not require any information that is not likely to be available until clean-up of a site is finished. Because it is a purely legal issue, its resolution in a pre-enforcement proceeding does not have the potential to force EPA to confront inconsistent results (as would a finding, for example, that a particular spill was caused by an act of God). Of course, if we decide that filing a notice of a CERCLA lien without any pre- enforcement review does violate due process, EPA’s collection efforts will no doubt be hampered. However, we do not lightly assume that Congress intended to ease EPA’s path even at the expense of  violating the Constitution. Fourth, although the two courts that have considered this issue have reached a different conclusion, see Barmet Aluminum Corp. v. Re illy, 927 F.2d 289, 293 (6th Cir.1991); South Macomb Disposal Authority v. U.S.E.P.A., 681 F.Supp. 1244, 1249-51 (E.D.Mich.1988), we are unpersuaded by the reasoning of those cases. Our disagreement commences with the phrasing of the issue to be decided. Both courts frame the question as whether  § 9613(h) â€Å"prohibits constitutional as well as statutory challenges until the time pr[e]scribed by the statute.† South Macomb, 681 F.Supp. at 1249-50; see Barmet, 927 F.2d at 292. We think that this question fails to make the distinction we have noted above, see pp. 1514-1515, supra, between two types of constitutional challenges–challenges to EPA’s administration of CERCLA, and challenges to CERCLA itself. Once we recognize this distinction, the reasoning of these two courts becomes less convincing. First, says the South Macomb court, Reading the language of  § 9613(h) for its everyday meaning supports the notion that this subsection prohibits constitutional as well as statutory challenges until the time pr[e]scribed by the statute. The provision explicitly states that federal courts shall not have jurisdiction to review â€Å"any challenge† except for those enumerated. South Macomb, 681 F.Supp. at 1249- 50. But, the statute does not bar â€Å"any challenge,† without qualification; rather, it delays federal court review of â€Å"any challenges to removal or remedial action selected under section 9604 of this title.† 42 U.S.C.  § 9613(h). Because a due process challenge to the CERCLA lien provisions is not, we believe, a challenge to â€Å"removal or remedial action selected under section 9604 of this title,† we do not find that the â€Å"everyday meaning† of  § 9613(h) divests the federal courts of jurisdiction to hear such a challenge. Both the Barmet and South Macomb courts contend that legislative history–House and Senate Reports, and House Judiciary Committee Hearings– suggests that Congress intended  § 9613(h) to bar all pre-enforcement challenges, including all *1516 constitutional challenges. Upon examination, we find these materials unconvincing as well. The Senate Report states, in part: As several courts have noted, the scheme and purposes of CERCLA would be disrupted by affording review of orders or response actions prior to commencement of a government enforcement or cost recovery action. See, e.g., Lone Pine Steering Committee v. EPA, [600 F.Supp. 1487 (D.N.J.1985) ]. These cases  correctly interpret CERCLA with regard to the unavailability of pre-enforcement review. This amendment [ § 9613(h) ] is to expressly recognize that pre-enforcement review would be a significant obstacle to the implementation of response actions and the use of administrative orders. Pre- enforcement review would lead to considerable delay in providing cleanups, would increase response costs, and would discourage settlements and voluntary cleanups. S.Rep. No. 11, 99th Cong., 1st Sess. 58 (1985). We see nothing in this discussion which would indicate an intent to divest federal courts of jurisdiction to consider a claim that the provisions of CERCLA itself authorize deprivations of property without due process of law. On the contrary, the reference to â€Å"review of orders or response actions† suggests that the writers of the Senate Report focused their concern on the problems that would arise if courts reviewed the merits of particular EPA actions. Both Barmet and South Macomb attach great weight to the Senate Report’s citation â€Å"with approval† of Lone Pine, a case decided before  § 9613(h) was enacted, which they say held that CERCLA did not allow pre- enforcement review even of constitutional challenges. We think there are good reasons to discount this citation. For one thing, the 13-page opinion in Lone Pine contains no discussion of the question whether constitutional challenges to the statute as well as challenges to administrative action are barred; one can only infer that the Lone Pine court held this view from the facts that (1) the plaintiff’s complaint had one constitutional count alongside six statutory counts, and (2) the court dismissed the entire complaint. In fact, Lone Pine cites Aminoil, Inc. v. EPA, 599 F.Supp. 69, 72 (C.D.Cal.1984), the leading case holding that CERCLA did not bar jurisdiction to review constitutional challenges to the statute; and it does so, not to indicate any disagreement with that holding, but simply to agree with its holding that CERCLA does bar pre-enforcement review of administrative orders. See Lone Pine, 600 F.Supp. at 1497. For another thing, the Senate Report does not cite Lone Pine for the proposition that federal courts have no jurisdiction to hear constitutional challenges; rather, it cites it solely as an example of a group of cases, sub silentio holding that review â€Å"of orders or response actions† would disrupt the purposes of CERCLA. We do not see why this should indicate agreement with Lone Pine’s purported holding regarding constitutional challenges,  particularly since cases such as Aminoil would seem to fit just as easily into the group of cases described in the Report. We do not find the House Report any more convincing. The pertinent passage in that Report, according to Barmet and South Macomb, is a statement that â€Å"there is no right of judicial review of the Administrator’s selection and implementation of response actions until after the response action[s] have been completed†¦.† H.R.Rep. No. 253(I), 99th Cong., 2d Sess. 81, reprinted in 1986 U.S.Code Cong. & Admin.News 2835, 2863. See Barmet, 927 F.2d at 293 (quoting this passage); South Macomb, 681 F.Supp. at 1250 (same). This statement says nothing about judicial review of the CERCLA statute itself. South Macomb also cites testimony of EPA and Justice Department officials during hearings on the bill that contained  § 9613(h). In response to a query from Representative Glickman as to whether EPA and the Justice Department â€Å"might accept some form of accelerated [pre-enforcement] review,† Mr. Habicht, the Assistant Attorney General for Land and Natural Resources, replied: Mr. Chairman, briefly, this issue has been litigated under the 1980 statute *1517 quite extensively, and there have been a number of decisions over the last several months that address the fundamental questions of the constitutionality of the procedures set forth in that law. Virtually across the board now the courts are finding that the scheme is constitutional as currently constituted. Superfund Reauthorization: Judicial and Legal Issues, Hearings before the Subcomm. on Admin. Law and Governmental Relations, H. of Rep. Judiciary Comm., 99th Cong., 1st Sess. at 226 (July 17, 1985); see South Macomb, 681 F.Supp. at 1250 (quoting this passage). The South Macomb court comments: â€Å"Our reading of this exchange is that the EPA and the Department of Justice took the position that because the courts had already upheld the constitutionality of CERCLA, constitutional challenges could also await EPA enforcement actions.† Id. We do not find this passage quite so clear. It would appear to be an expression of hope by EPA and the Department of Justice rather than a statement of congressional intent, particularly in light of the fact that Congress passed a provision,  § 9613(h), that by its language does not bar constitutional challenges to the CERCLA statute. Finally, the Supreme Court recently examined a statute with a judicial review provision not unlike the CERCLA section analyzed here. At issue in McNary v. Haitian Refugee Center, Inc., 498 U.S. 479, 111 S.Ct. 888, 112  L.Ed.2d 1005 (1991), was a provision of the Immigration and Nationality Act barring judicial review of a denial of â€Å"Special Agriculture Worker† (â€Å"SAW†) status except in the context of a deportation order. The statute states: â€Å"There shall be no administrative or judicial review of a determination respecting an application for adjustment of status under this section except in accordance with this subsection.† 8 U.S.C.  § 1160(e) (as amended by the Immigration Reform and Control Act of 1986). The Court held that this bar did not preclude review of â€Å"general collateral challenges to unconstitutional practices and policies used by the agency in processing applications.† McNary, 111 S.Ct. at 896. Rather, it only barred review of individual denials of SAW status. Id. The statute in McNary resembles the CERCLA provision at issue here in two respects. First, as here, judicial review of an administrative event is withheld until the agency instigates a second, independent proceeding. More significantly, the immigration statute is phrased so as to bar review of the agency’s determination of SAW status in an individual action–an event comparable to EPA’s selection of a removal or remedial action, which is the focus of the CERCLA bar. Neither statute mentions the availability of review of a constitutional challenge to the statute itself (as here) or to the agency’s execution of the statute (as in McNary ). Insofar as the Immigration and Nationality Act compares to CERCLA, we think that the holding in McNary supports our conclusion here. See also Johnson v. Robinson, 415 U.S. 361, 367, 94 S.Ct. 1160, 1165-66, 39 L.Ed.2d 389 (1974) (holding that similar jurisdictional bar precluded review only of administration of statute, not of challenge to statute itself); cf. Weinberger v. Salfi, 422 U.S. 749, 762, 95 S.Ct. 2457, 2465, 45 L.Ed.2d 522 (1975) (holding that more expansive language barred all challenges related to statute). Thus, we conclude that we have jurisdiction to consider the Reardons’ due process claim: that the CERCLA statutory scheme under which liens may be imposed on property without opportunity for a hearing violates the fifth amendment due process clause. III. THE DUE PROCESS CLAIM [4] The Supreme Court has established a two-part analysis of due process challenges to statutes which, like this one, involve property rather than liberty interests. One must first ask whether the statute authorizes the taking of a â€Å"significant property interest† protected by the fifth  amendment. E.g., Fuentes v. Shevin, 407 U.S. 67, 86, 92 S.Ct. 1983, 1997, 32 L.Ed.2d 556 (1972). If there is no significant property interest involved, the inquiry is at an end. If there is, one proceeds to examine what process is due in the particular circumstances. *1518 E.g., id.; Mathews v. Eldridge, 424 U.S. 319, 335, 96 S.Ct. 893, 903, 47 L.Ed.2d 18 (1976). We shall address each issue in turn. A. The Deprivation. The district court, relying primarily on Spielman- Fond, Inc. v. Hanson’s, Inc., 379 F.Supp. 997 (D.Ariz.1973) (three judge panel), aff’d mem., 417 U.S. 901, 94 S.Ct. 2596, 41 L.Ed.2d 208 (1974), found that the filing of a federal lien under 42 U.S.C.  § 96 07(l ) did not amount to a deprivation of a significant property interest; thus, the court did not reach the second step of the analysis. However, a Supreme Court case decided after the district court had issued its decision (indeed, after oral argument at the en banc rehearing of this appeal) has clarified the law in this area considerably, and has precluded continued reliance on the Court’s summary affirmance in Spielman-Fond. In Connecticut v. Doehr, 501 U.S. 1, 111 S.Ct. 2105, 115 L.Ed.2d 1 (1991), a unanimous Court held that a Connecticut attachment statute violated the due process clause. The Court held that the attachment lien on plaintiff Doehr’s real property deprived him of a significant property interest within the meaning of the due process clause. The Court stated: For a property owner like Doehr, attachment ordinarily clouds title; impairs the ability to sell or otherwise alienate the property; taints any credit rating; reduces the chance of obtaining a home equity loan or additional mortgage; and can even place an existing mortgage in technical default where there is an insecurity clause. Doehr, 501 U.S. at —-, 111 S.Ct. at 2113. It concluded that â€Å"even the temporary or partial impairments to property rights that attachments, liens, and similar encumbrances entail are sufficient to merit due process protection.† Id. (emphasis added). And, in a footnote, it disposed of its summary affirmance in Spielman-Fond by noting that â€Å"[a] summary disposition does not enjoy the full precedential value of a case argued on the merits and disposed of by a written opinion.† Id. at —- n. 4, 111 S.Ct. at 2113 n. 4 (citing Edelman v. Jordan, 415 U.S. 651, 671, 94 S.Ct. 1347, 1359-60, 39 L.Ed.2d 662 (1974)). See also id. at —-, 111 S.Ct. at 2113 (Rehnquist, C.J., concurring) (Spielman-Fond should not be read to mean that the imposition of a lien is not a deprivation of a significant interest in property). Whether the response costs were incurred consistently with the national contingency plan is an issue which may be highly factual, but it is usually a matter of the amount, and not the existence, of liability. More likely to be â€Å"highly factual† is the determination whether certain of the owner’s parcels of land are â€Å"subject to or affected by† EPA’s response action. Similarly, on the issue of the landowner’s liability, EPA admits in its brief that the â€Å"concepts of due care, foreseeability, objective and subjective knowledge, some of which are unique in CERCLA to the innocent landowner defense, are extremely fact-intensive.† EPA Supplementary Brief at 16-17. Second, we must consider what procedural safeguards, if any, CERCLA provides against erroneous filing of a lien. a. The right to a judicial hearing. CERCLA provides no such safeguards. It provides for no pre-deprivation proceedings at all–not even the ex parte â€Å"probable cause† hearing judged insufficient in Doehr. See Doehr at —-, 111 S.Ct. at 2108 (describing Connecticut attachment procedure). Nor does CERCLA provide for an immediate post-deprivation hearing. [FN2] The first hearing the property owner is likely to get is at the enforcement proceeding, or cost recovery action, brought by EPA. This action may be brought several years after the notice of lien is filed; it is limited only by a rather complicated statute of  limitations, see 42 U.S.C.  § 9613(g)(2), which gives EPA three years after a removal action is completed or six years after a remedial action is commenced to bring such a suit. The running of the statute of limitations is entirely within EPA’s control. Since the government may take its own sweet time before suing, and since the removal or remedial action may itself take years to complete, the lien may be in place for a considerable time without an opportunity for a hearing. FN2. The Connecticut statute at issue in Doehr provided â€Å"expeditious† post-attachment review, see 501 U.S. at —-, 111 S.Ct. at 2115, but the Court nonetheless found the statute constitutionally deficient. Even under Doehr, though, post-attachment process is not always inadequate. Doehr notes the factors leading to the Court’s  approval, in Mitchell v. W.T. Grant Co., 416 U.S. 600, 94 S.Ct. 1895 (1974), of a sequestration statute with no pre-deprivation review: â€Å"the plaintiff had a vendor’s lien to protect, the risk of error was minimal because the likelihood of recovery involved uncomplicated matters that lent themselves to documentary proof, and plaintiff was required to put up a bond.† Doehr, 501 U.S. at —-, 111 S.Ct. at 2114. â€Å"[M]ere postponement of judicial enquiry is not a denial of due process if the opportunity given for ultimate judicial determination of liability is adequate.† *1520 Phillips v. Commissioner, 283 U.S. 589, 596, 51 S.Ct. 608, 611, 75 L.Ed. 1289 (1931). But the CERCLA statute of limitations on liens throws the â€Å"ultimate judicial determination† so far into the future as to render it inadequate. Indeed, in this respect the CERCLA scheme resembles the replevin statutes in Fuentes v. Shevin, where the Court held that the debtor may not be â€Å"left in limbo to await a hearing that might or might not ‘eventually’ occur.† Mitchell v. W.T. Grant Co., 416 U.S. at 618, 94 S.Ct. at 1905 (discussing Fuentes v. Shevin ). b. Posting of a Bond. The Court has recognized that requiring the filing party to post a bond may provide the property owner important protection against wrongful filing; in Doehr, four members of the Court suggested that due process always requires a plaintiff’s bond in the context of an attachment. See Doehr, 501 U.S. at  Ã¢â‚¬â€-, 111 S.Ct. at 2116 (plurality). CERCLA does not require EPA to post a bond when filing the notice of federal lien. c. Action for damages. In Doehr, the State of Connecticut argued that the availability of a double damages remedy for suits that are commenced without probable cause was an important protection against misuse of the attachment provisions; however, four members of the Court did not find the availability of such a suit to be an adequate procedural safeguard. Four members of the court explained in detail why an action for damages would never prove adequate: The necessity for at least a prompt postattachment hearing is self-evident because the right to be compensated at the end of the case, if the plaintiff loses, for all provable injuries caused by the attachment is inadequate to redress the harm inflicted, harm that could have been avoided had an early hearing been held. An individual with an immediate need or opportunity to sell a property can neither do so, nor otherwise satisfy that need or recreate the opportunity. The same applies to a parent in need of a home equity loan for a child’s education, an entrepreneur seeking to start a business on the strength of an otherwise strong credit rating, or simply a homeowner who might face the disruption of having a mortgage placed in technical default. Doehr, 501 U.S. at —-, 111 S.Ct. at 2118 (plurality).