Healthy Body, Healthy Mind Essay

Many people believe that â€Å"A healthy body makes a healthy mind†. I hesitate on the word â€Å"make† — Assuming a healthy mind means something like integrity, happiness and optimistic attitude, I believe that people who have a healthy body usually also have a healthy mind, but a healthy body is not necessarily for a healthy mind. The players in professional sports leagues are probably the most physically healthy people in the world; however it’s not uncommon to hear news of their troubles, such as crimes or family violences. A healthy body shares some common causes with a healthy mind. The process of pursuing a healthy body requires good discipline. It’s easy to exercise for one day, but one must endeavor to keep exercising to stay in a physically healthy condition. Long distance running is a well known way of having a healthy body. To prepare to run a full marathon, one has to repeat many moderate or long distance running practices. It’s such a painful process that one likely to give up if he/she doesn’t have strong will power. If a person has such will power, it’s no surprise that this person can be successful at other things. A person achieves many life goals is likely to have a healthy mind. A healthy body can be a factor of a healthy mind: physically healthy people usually have more energy to work on things they care about, therefore have a better chance to enjoy their lives. In contrast, physically unhealthy people may be disturbed by their health issues. Their concerns can distract them from doing things that would make them happy. A scientific study also tried to discover the secret relation between exercise and the mind. Scientists found a chemical substance called endorphins [1], which can be reproduced by human body during exercise, excitement, spicy food tasting, etc. It can interact with some other substances in the human body to generate a feeling of well-being. A well-known effect of endorphins is â€Å"runners high,† which is said to occur when people exercise so strenuously that their bodies reach the threshold of endorphin release. Scientists are still not sure of the amount of endorphins the human body can generate or how much it impacts a human’s mind. But at least most of the running enthusiasts I know are all very nice people. The ex-Google VP, the founder of Google China, a role model of many Chinese  young students and entrepreneurs, Kaifu Lee, was recently diagnosed with cancer. He said he should have spent less time on work and more time on doing things that would have kept him healthy, especially sufficient sleep and exercise. This tells us that at the end of the day, fame and wealthy will not make people happy if they don’t have a healthy body. We should get away from the chair and the computer some time everyday to exercise. It might not make us better people, but it’ll make us lead longer and happier life.

A Book Review on Eckhart Tolle’s

A New Earth talks about being present in the moment of one’s life. It also talks about being in contact with one’s consciousness while looking deeper into life’s meaning.The author, Eckhart Tolle, experienced a spiritual transformation that has delivered him from extensive periods of depression. Deeply inclined by Buddhism, Hinduism, and other Indian schools of thought, the author emphasizes living in the current moment, the now. A new Earth is a book that puts ahead a number of sensible solutions to ways of thoughts that have caused a great deal of hurt and dysfunction in society. One must try reading A New Earth to experience a positive shift of his/her consciousness.The first part of the book talks about being still for the awakening of the consciousness through nature, specifically through a flower. The chapter also explained the pathway to Heaven, which the author describes as not being a place but is within the consciousness. Tolle is also reinstating the s ignificance of now.The author discussed the concept of awakening as being a vital part of recognizing the unawakened part of a person. The mind is easily fooled into thinking that it’s the ego, which is not the real being of a person. The ego will trick one to identify with it over and over again. The author also talked about one’s thoughts and the dysfunctions of man’s way of thinking.The first thing that one may become aware of in this book is that the author uses stipulations like the human consciousness’ evolution and enlightenment. Tolle however failed to define these terms clearly and would make it hard for a reader to understand what the author is trying to say. Reading the first chapter may pose quite a challenge for the unawakened person’s understanding.This book needs more facts rather than assumptions. The author also stated some things that are contradictory with the bible. For example, Tolle talks about a creature growing some wings an d evolving into a bird. The bible says that God created the birds of the air, and not that it evolved.Tolle also explained that the Holy Spirit, which was being signified by the dove, has provided a means for a reflective alteration in planetary consciousness. The reader personally doesn’t agree with this New Age teaching as the Holy Spirit leads people to salvation and not into a transferring of planetary consciousness.

Einstein's Ideas on Science and Religion Term Paper

Einstein's Ideas on Science and Religion - Term Paper Example The story begins thus, "I tell myself I am not looking for God. I am looking for an elision that is nevertheless a contour." (175) He travels to the desert, a solely deserted place devote of significant life to find the only sole God that all people and religions have believed in, to this the author says, "I have come to the Holy Land because the God of the Jews, Christians, and Muslims-a common God revealed Himself in the desert." (176) this is indeed a logical reasoning that the author believes that there is some religion truth in this place. Quite contrastingly, this land that is supposed to be holy is marred by blood and no human life. Einstein critically presents his arguments and points out the limitations of the human intellectual ability as individuals entangled in ‘religion fear’ (1) to secure favor in solving the human miseries. In Einstein’s Personal god, religion beliefs and science are presented as antagonists, but he further suggests that serious sci entific workers are also the most profoundly the most religious people. The most outstanding feature of Einstein’s characteristics is his language about religion and science. The desire to experience the cosmos as a single whole sprouts from human’s perspective of the world as some kind of prison to him. This thought already brings forth the idea of cosmic religion which emanates from mans fear of uncertainty. To limit dogma and lots of theology, Einstein does not rule out the prospects of a future cosmic religion. He foresees a religion that goes beyond personal God. This religion majorly based on sense of emanating from the encounter of all spiritual and natural things that when combined form an ideal and meaningful unity. From his perspective, science brings to life religion and those who accept it internalize it. Einstein argues that humans are usually driven by some sort of internal needs as they seek religious interpretation. The main force for human would be in most instances for a ‘feeling and longing’. (1) It is the fear of these that tend to provoke human emotions throughout religious life. This religion concept where one fears sickness, death or hunger is what Einstein describes as a ‘religion fear’ by constantly using the word ‘religion fear’ the author implies that human beings do not go to church to seek spiritual guidance but rather they attend church from the fears that emanate deep within. The author generally groups these religion fears into hunger, pain or comfort. Moreover, Einstein describes a second type of religion belief that emanates from social impulses. He attempts to justify that ‘the desire for guidance, love, and support prompts men to form social conception of God.’ (3) God who the human race believes to provide, protect and even offer rewards and punishments; this ‘personal god’ as the author describes is able to even provide ‘life and offer com fort during difficult times of sadness and ‘unsatisfied longing’ and ‘he who is also able to preserve the soul of the dead.’ (3) A common religious orientation with the above types of religion is what Einstein describes as ‘anthropomorphic character of their conception of God’ (4) exhibited by low level individuals. It is therefore based on these two low level of human understanding and belief about religion that Einstein expunges a new religion dimension which he also admits is ‘rarely found in pure form’ (4) this is what he calls ‘Cosmic religion’ (4) which is characterized by human desires and personal quest to ‘reveal themselves both in nature and in the world of thought.’ By using the word â€Å"Anthropomorphic cha

Understanding International Relations (IR) Essay

Understanding International Relations (IR) - Essay Example This essay stresses that the globalisation concept explains international relations better than the sovereignty concept. For one, almost all the aspects of the modern day society seem to have been influenced either directly or indirectly by globalisation. In addition, globalisation in its entirety is all about intensifying cross-border relations/interactions. Moreover, it looks at the interdependence between countries; consequently, this has a major impact on the international system. This paper makes a conclusion that globalisation concept demonstrates interconnectedness of different states in the modern international system. The interconnectedness includes bodies such as the International Federation of Stock Exchange whose decisions have, in one way or another, impacted states all over the globe and the world economy. Even more importantly, globalisation has facilitated the opening of national borders and the subsequent implementation of free trade. The consequence of this is cohesion between states and reduction of conflicts. In a nutshell, therefore, it can be argued that the globalisation concept is quite explicit in as much as international relations is concerned. The increase in the level of dependence among states and their interconnectedness that are key to understanding international relations are captured well globalisation. Globalisation has equally contributed towards the solving of international problems.

Slanket Case from Harvard Business Review by John Deighton Essay

Slanket Case from Harvard Business Review by John Deighton - Essay Example A slanket’s body length makes it convenient to use in the comfort of a sofa or even while studying. Some customers send slankets to their loved ones as gifts during feasts and festivals, such as Christmas and Halloween. It saves money that could otherwise be spent on thermostats during winter. Its use is further promoted by consumers when watching movies and during long car journeys. Distribution Situation Gary Clegg ensured the effective delivery of the product to customers’ doorsteps. Every time an online order was made, the details of the client were noted and responded to online. Gary accompanied these deliveries with a personal note, thanking the customer for purchasing the product. He also built a supply chain that helped source the product from China, in partnership with a North Carolina company. Competitive Situation The main competitor of the Slanket Organization came in October, 2008, by the name Allstar Marketing Group (AMG). Based in Hawthorne, New York, the firm was a Direct-Response Television (DRTV). This was a highly successful marketing firm that was previously credited with the production of Aqua Globe, a self-watering system for house plants, and Big City Sliders, a device that produced miniature hamburgers. As an infomercial marketer, the Allstar Marketing Group produced a cheaper version of the Slanket, dubbed â€Å"snuggie†. ... However, there is uncertainty in this industry as it is not known whether other consumer trends may occur or which other company may enter and invest in the industry. SWOT Analysis of the Slanket Business Strengths To begin with, the Slanket Business had quite a diligent and industrious pair of managers. Gary Clegg researched on patents, found a textiles supplier and oversaw production. Despite the discouragement from lawyers concerning the impossibility of obtaining a patent of their work, due to the difficulty in distinguishing the design from a bathrobe, hospital gown, stylized shawl or poncho, Gary persisted and would not let go of the business. Gary’s elder brother, Jeff Clegg, was also important in the success of the business in its earlier years. He set up the infrastructure for a web-based business. On day one of their business, he worked tirelessly for 14 hours on the screen, answering emails and filling orders. These two brothers further cooperated in effectively man aging the staff and the transaction operations of the Slanket Organization. The Slanket Business had an upper hand in ensuring product awareness. The on-line word of mouth promotion was also strength to the business. At Digg.com and the Daily Candy, an email newsletter and insider guide that appeared in one million subscribers’ inboxes daily, Gary and Jeff could reach over a vast proportion of potential clients each day. Exclusive contracts went as far as having Gary host live sales for the slanket on the QVC Channel, a televised home-shopping network. This was an added strength in getting more customers, ensuring more sales. For instance, by the end of 2007, QVC had sold over 30 000 units (Deighton & Kornfeld, 2010). Another contract was made with an airline

Reflective summary Essay Example | Topics and Well Written Essays - 250 words

Reflective summary - Essay Example This is obviously important not only professionally, but practically (Zala 2007). When examining evidence, there might be only one opportunity to insure that every facet of the material is properly analysed in order to get accurate readings on a whole host of foreign bodies that might be present (Gonzalez 2013). With that in mind, I also now realise that I need to be more analytical in my observation skills as it is essential that I visualise what might have happened, or infer the significance of a particular piece of evidence, even it at first my eyes might not catch on. In performing that practical experiments, I did notice that I have difficult discerning the relevance of particular bits of evidence at first and that it took more discussion before I caught on as to what I was actually observing. Naturally, this will likely come with more practice and I look forward to competing many more practicals in order to become more skilled at being to observe every facet of the evidence tha t is placed under

Analysis of AT & T Organization Essay Example | Topics and Well Written Essays - 3250 words

Analysis of AT & T Organization - Essay Example This organization is originally a company of Alexander Graham Bell, the inventor of telephone services, and has their headquarters in Boston. The organization is a previous monopoly business that serves the population in the telecommunications and information technology sector (Keidel, 2005). It involves itself in the development and sale of telecommunication services in the country and across the entire globe (Verzuh, 2007). The organization has recently been experiencing problems in the loss of customers to their competitor, Verizon Corporation. This is because their competitor’s did introduce a similar product to their iphone. They are also able to offer better pacts than the organization (Green, 2006). For example, Verizon Corporation offers no limitations on data transfers and still charges a set price. The organization is currently unable to provide their customers with the satisfaction they require from the network capabilities on offer. This results in the company maki ng big losses in terms of customers leaving the organization for their competitors. The organization has not been able to keep their customers to the business (Valikangas, 2010). I would like to suggest that the company develops a project to explore into these issues. They should form teams comprising of experts and some technical staff to address this issue across their various branches. The organization will expect to improve their products and increase the number of customers to their business (Valikangas, 2010). Analysis of the Current Situation This organization offers telephone communication services across twenty-two states in America. The company also offers internet facilities, data transfers and phone services. Financial analysts in the company suggest that the organization is likely to make profits in the next few years. The organization is also currently enjoying great revenues from their wireless trade (Estabrooks, 2005). The organizations debt currently stands at $1.4 billion, which is below EBITDA standards by 1.6 periods. Their pensions are hard to approximate and it finds difficulties in their cash flows since they have many debt to repay and dividends to pay to the shareholders. The dividends they pay out amount to more than ten billion dollars (Temin and Galambos, 2007). The organization intends to acquire another company by the name of T-Mobile USA. These activities are likely to affect the organizations capital composition though the financial analysts believe that the company’s performance will remain constant. The company has to cut the costs they incur to ensure that their performances remains relevant to the current market conditions (Hodges, 2002). The disadvantage that the organization currently encounters on limitations in their network will get their solutions after the organization acquires the additional firm. The management of AT&T expects that the additional organization will come with the networking resources they requi re. The organization’s provision of wireless services is far beyond their competitors abilities. The organizations leadership focuses their cash on the repayment of their debts (Ellis, 2009). This move did come into play over the past few years with the aim of reducing their debts. This act enables the company to cut their costs to the current value of 65 billion dollars. Their investment formation remains the most traditional in their industry. This gives the company the advantage of quickly adjusting to changes in the economic conditions the country experiences (Temin and Galambos, 2007). The organization’s main competitor in the provision of Iphones, Verizon, has a customer base of more than ninety four million people and makes over a

Alexander McQueen Savage Beauty Exhibition Research Paper

Alexander McQueen Savage Beauty Exhibition - Research Paper Example The exhibition serves both as a source of education and a source of inspiration for the contemporary fashion designers. In addition to that, the exhibition was also a very informative and entertaining show for the students of Fashion Designing. The exhibition exhibited more than 70 accessories and about 100 ensembles from the prolific career of McQueen from his career ranged over 19 years (â€Å"About the Exhibition†). The audience leaves the show confused because the fashion that reflected from the models’ outfits represented McQueen’s varying states of mind at different points in time. Such exhibitions are hard to watch because of the conflict between the overt expression of such sensitive themes as vulgarity and the cultural conservatism of the audiences. Despite all their absurdity, one thing that adds to their appeal of the clothes displayed in the exhibition is that they have been designed keeping the different kinds of weather and seasons into consideration. For example, there are clothes made in net to be worn during the summer season whereas there is a whole furry range for the winter season. One theme that was commonly observed in all of his outfits was that they were inspired by birds; pigeon , peacock, and hen to name a few. While watching the show, it is hard for the audiences to predict what is coming up next or even how they feel about it. I chose this topic because McQueen’s fashion show stands out from the queue of traditional fashion shows because of a number of reasons. I have personally never found a fashion show so dramatic, appealing, and at the same time, controversial. It was something very unusual so I wanted to share it with others. If I was in charge, one thing that I would like to change is nudity. I would at least cover up all the private parts of the models in respect of our cultural values of modesty and conservatism.  

Missouri Compromise 1820 Essay Example for Free

Missouri Compromise 1820 Essay Northerners finally were receiving the outcome that they had wished for with slavery slowly declining at the end of the 18th century. Southern economilcal dependancy on slavery was slowly withering away due to the Act of 1808, stating that by that time slavery would not be allowed. Due to this Southerners were forced to change their means of production and the use of slaves. When the 19th century arrived it brought the invention of the Cotton Gin. This invention, created by Eli Whitney, assisted in speeding the picking of cotton by removing the seed. The only flaw in this was that it relied on even more unskilled labor. Slaves were found perfect for the handlying of this machine: it was easy to manufactor and as easy to work.. From this, Southerners found it now more than ever nessesary to hault the abolition of slavery do to the economic prosperity that lied ahead because of the Cotton Gin. In Southern eyes, slavery was a better choice than free labor. IN the case of using free labor Southerners couldnt be totally dependent on the person because they might demand things such as higher wages. If free laborors were refused what they asked, Southerners faced the risk of them stop working. Because you owned a slave Southerners would never have to worry about such a situation. This threat of prolonging slavery enabled the major conflict between The North and South arise. The Southern view of this conflict was that due to the economical advantages that slavery rbought and the economical disadvantages that an abolition with bring to the states, that the issue of slavery should be considered a nessasary evil. Not only this, but some even believed that slavery was doing blacks a favor. They believed that even in Africa balcks had owners, that they are always fed, and are treated better as slaves then they would be as free blacks. Northerners disreguarded any attempt in justifying such a matter and stood by there point that slavery was not right. Northern abolishnists fought back and said that slavery went again the fundamental priciple on which America was built on; Equality and freeddon. Not only immoral and sinful but went again the Declaration of Independece which clearly states that all men were created equal with no exceptions. The Norths morality and Souths Economic self-interest, and both sides refusal to compromise left the issue in a stalemate. By the North fueling the fire with such articles like The Liberator, inspiring slaves to revolt, and other abolitionist moves, the North forced the south to fight back in order to protect themselved from future revolts and incidence fueled by enraged slaves. The Missouri Compromise made the divide between the North and the South more evident that it had ever been. This compromised, proposed by Henry Clay, declared that Missouri would enter the union as a slave state, but every other state that was North of the Ohio river and Mason-Dixon line. Though this did stop slavery it gradually decreased it. In additon to this another factor was the that all states would be admitted into the union in pairs in order to balance the slave states as well as the free states. Still enraged, Northerners demanded the instant abolishment owed to the moral breach that slavery incompassed. They believed that slaves were being treated and stripped of there rights as a humane being. In American Slavery As It Is the author, Theodore Weld, describes his view on how it really is for the slaves of the south and the treatment they are force to endure by their slaveowners. That their ears are often cut off, their eyes knocked out, their bones broken, their flesh branded with red-hot irons; that they are maimed, mutilated and burned to death over slow firesthat self interest would prompt them to treat their slaved with kindness By writing such things, Weld just encouraged abolitionists to fight harder and harder for their cause. Such cases as the ones he mention cant be said never happened but are surely rare if so. Due to the tone in writng that is used though, wel makes his words harsh and strong which justly, the Southerners take their place to fight back at. In actuality most southerners were not as Weld describe because they realized that the better you treated a slave and healthier it was the more work that it could accomplish for you. Not only this, but due to the harsh rigid tone of his words, Weld, gives whoever is reading this no option towards working out some sort of compromise between North and South but instead just relies on getting thing s done. Abolitionist works, such as The Liberato,r aided in aggravating the South. William Loyd Garrisons The Liberator, was printed as a Boston proabolitionist newspaper in which Garrison referrs to Southerners to being sinners and that slaves should do anything to get out of the miserable situation that they are in, even if that means blacks revolting against their. He as well brings up the issue of blacks being equals with whites. : Assenting to the self-evident truth, and endowed by their Creator with certain enalienable rights-among which are life, liberty, and persuit of happiness. Garrison, here, clearly explicates how by having slaves not be free we are going against everything that the declaration stands for and represents. Some say that Garrisons The Liberator might have even sparked the rebellion led by Nat Turner in which Turner gathers up a group of slaves and killed over fifty white southerners. Southerners were so fearful of more rebellion that it led them to create even harsher rules for slaves. In Federick Douglass Independence Day Speech at Rochester Douglass writes of how white southerners are fearful of blacks and that is the reason why there are such harsh laws against them reading and writing. What is this but the awknowledgment that the slave is amoral, itellectual, and responsible being? Douglasss Articular only further depicts that Southerners were in fear or the capability that blacks would have if they were learned. By keeping slaves ignorant they prevented slaves from reading such abolitionist articles which could fuel an angry mob. Due to a fear of angry mobs and revolts Southerners were foreced to lay stricter rules as Civil Codes and the restriction on abolitionist literature. In Thomas Dews Review of the Debate in the Virginia Legislature Dew discusses how the white race and black race could never coencide because if blacks were free there would just be an array of massacres led by angry blacks. Southerners Spent more time on the issue of protecting themselved from a threat of slave rebellions due to abolitionsit literature sparking rebellions than any other matter. In George Fitzhughs Slavery Justified he discusses further on the matter of slave rebellions and how if black werent slaves their anger would just lead to more crimes and violent incidencs. In the matter of slave abuse he stats that its ridiculous; His feeling for his slave never permits him to stint him in old age. The slaves are all well fed, well clas, have plenty of fuel, and are happy. In response to the accusation of slave owners abusing their slaves, other Southerners replied by saying that incidents such as the ones which Weld discusses are isolated and uncommon. In fact it most cases it is the opposite of circumstances. In Solon Robinsons De Bows Review Robinson takes the opposite stance that Weld takes and says on the contrary that slave owners would never do such abuse to there slaves because they were too valuable to them. Robinson says The Two things that are most despised and hated in the South are masters that abuse and starve and ill-treat their slaves, and abolistionists, who sieze upon every isolated case of the kind As stated before, abolitionist kept on exagerateing the slave situation in order to attempt to speed up the process of getting rid of slavery when they were only furthering it because of Southerners needing to defend themselves against false accusations. Finally besides the matter of slave abuse and the morality of the situation, the South argues that due to the mass production of cotton that slaves help produce, if we abolish slavery America would be in an economic crisis. Because of the low production of cotton that there would be after an emacipation, labor woul be inconsistent, because free workers would be inconsistent and require more and we wouldnt be able to forfill our internation al demand for cotton. In William Harpers Source Problems in the United States History Harper says The cultivation of the grat crops cannot be carried on in any portion of our own country where there are no slavesAnd what would be the eefect of putting an end to the cultivationannihilating,at a blow,two thrids or three fourths of our foreign commerce? From this we can see that slavery was no easy matter and that it too more economic thinking to get rid of Slaves. Perhaps more than the North thought. Though both the South and the North make legitimate reason for their not wanting or wanting the emancipation of slaves, it seems that due to the North the process or reaching compromise was delayed unneccesarily. Instead of thinking about the economical blow emancipation would cause the North ruthlessly kept attacking the Souths morality. The South realized that without slaves for a bit longer they wouldnt be able to make a full economic recovery once emancipation was inacted. But because of the attacks and harsh literature being published by abolitionists, the South spent more time in trying to protect themselves from slaves getting ideas from these works than trying to figure out a plan to resolve the issue with the North. It seems as if the issue could have been quickend if the North hadnt made such quick and damaging attacks.

Euthanasia Essay Example for Free

Euthanasia Essay In his accounts, Gay-Williams raised important arguments with regard to euthanasia. Being a serious point of debate for many decades now, there are people who approve of it claiming it provides humane death for someone otherwise not capable of living a normal life anymore. On the other hand, there are others who stay conservative and disapprove of euthanasia believing that in no way can people decide should another person is already bound for death or not. One point of contention is the differentiation between active and passive euthanasia, which further segments the population. Gay-Williams assert that active euthanasia is illegal yet passive euthanasia can be morally favored. Some do not believe on the differentiation and say that whether it is active or passive, euthanasia should be regarded as illegal. Gay-Williams also argued that euthanasia takes out the hope in a patient. This further proves the negative notion on euthanasia. This along with the argument that euthanasia is a practical choice for medical practitioners is raised by the author and was explained in detail. This paper aims to discuss these arguments and evaluate their strength, which may prove or otherwise disprove the motions of Gay-Williams. In developing the paper, it hopes to evaluate euthanasia in light of its moral viability; the distinction cited between active and passive euthanasia and their moral statures, and two arguments that embody mercy killing: the argument that states how euthanasia affects the will to live and survive as well as how it may be used for practical applications—rather surprising conclusions that were taken by Gay-Williams which are worth a lengthy point of discussion, evaluation, and comparison. Passive and active euthanasia Gay-Williams stated that there is a big difference between passive and active euthanasia. In phrases, passive euthanasia is letting die while active euthanasia is killing. It should be noted that passive euthanasia happens when a person was not given relief from a certainly fatal situation which is otherwise medically alterable. For instance, a person with extreme difficulty in breathing who can still be resuscitated but was not given an apparatus or aid for the purpose may die under the circumstance of passive euthanasia. This is often done when there is an order by the patient or the family that the patient should not be resuscitated. Alternatively, the situation can be the other way around. The patient may be in a dying situation, but still technically alive. For some circumstance such as the thought that the patient is constantly in pain, hopeless, or if the patient himself can no longer bear the pain, there may become a request or a suggestion for the pain to be stopped—rather permanently. At this point poison may be intravenously given to end the suffering of the patient. According to Gay-Williams, this big difference between the two is obvious in light of their moral statures. The first one which let the patient die without medical intervention is acceptable as there was no effort in ending the life of the patient. Divinely, the patient may still be saved. On the other hand, the latter-described procedure deliberately put an effort in ending the suffering and the life of the patient. The author stated that this is killing even if the purpose of the act is to save someone from a lengthy and costly suffering. The thought of euthanasia Every one of us is gifted with survival instincts. When the going gets tough, they say the tough gets going. And so when an illness hits someone and he is tough enough, he finds hope rather than despair. He focuses on the positive rather than the negative and strives to find a way to battle the sickness and eventually win it. Thus, when the mind says that it wants to live, the body and the person will most likely follow. (How to live a longer and healthier life, 2007) This is the same argument raised by Gay-Williams as an issue of euthanasia. He states: knowing that we can take out our life at anytime (or ask another to take it) might well incline us to give up too easily. The will to live is strong in all of us, but it can be weakened by pain and suffering and feelings of hopelessness. This will to live is essential as many doctors have proven. Gay-Williams himself stated that there are many miraculous survivals that occur which even medicine cannot fully explain. Many shows, testimonials, and books have discussed how people in the brink of death were able to miraculously survive. Some were from serious illnesses or were declared in comatose. Some claimed to be back from dying. This relationship between the will to live and getting well has been the premise of many studies. Doctors started incorporating psychological therapies to their patients’ treatment plans hoping to get better results. Often, the results even exceed their expectations. This led many doctors to adapt the concept, to the relief and advantage of thousands and maybe even millions of patients around the world. As Gay-Williams says: The very presence of the possibility of euthanasia may keep us from surviving when we might. Euthanasia and practical effects Gay-Williams state that doctors and nurses’ main thrust and aim in their professions is to save lives, and that when a patient dies in their care it becomes a personal failure which may not be too easy to accept. Thus it is not surprising if the author argued that euthanasia is a practical way for practitioners to avoid this quicksand. If they endorse or support euthanasia, any impending deaths in their care can be pre-empted—no one will ever die in their responsibility again. Euthanasia is a product of free will. It takes the patient and/or his family into a higher level of decision-making whereby they choose whether to prolong the patient’s illness and let live or end the suffering and let the patient die in peace. Its proponents agree that approving euthanasia as a social policy lets the people exercise the freedom of will that was given to them by the divine and the constitution. This is true in that even if euthanasia becomes a social policy, it still boils down to the decision of the person if euthanasia should be chosen or not as a way of getting out of one’s suffering. If a patient or his family does not want to exercise it, it is also for them to decline. However, Gay-Williams claim that euthanasia will bring an all new low in the quality of healthcare where euthanasia is acceptable. The quality will be sacrificed because if practitioners know an easier way out of an untreatable disease rather than letting the patient die naturally in their hands, the process may be taken in non-serious cases as well. In connection, Gay-Williams stress that as a social policy euthanasia will bring worse concerns. For one, it can permit authorities to eliminate those who are hopelessly ill, the way those who are mentally ill are sent in mental hospitals—a comparison Gay-Williams was clever in making. Conclusion So did Gay-Williams’ argument win or lose? The argument revolved around the innate willingness to live by people, especially the sick. It played up the fact that the will to live is a fragile characteristic inherent to everyone. It further stated that euthanasia blotted onto this inherent character; that the provision of a choice to end life gave people the reason to end life; that giving patients, their families, and the doctors an easy route out of the situation gave them the authority to take this easy route out as well. With these arguments, Gay-Williams reiterated that whether as a social policy or an open option for patients, families, and medical practitioners, euthanasia is a slippery slope where no one wins. Gay-Williams, theoretically speaking, was able to deliver his points well. It is true that euthanasia is an exercise of free will, but the fact that free will is given and thus the idea of euthanasia is suggested to a patient is already initially detrimental to the patient. It entails responsible choices to be made by the patient, the family, and the doctors. It requires a full understanding of life, and the willingness to allow life to take its course. The doctors can suggest this graceful exit option to the patient or the family but if the patient or the family’s will to live or let live is stronger than the will to end everything, euthanasia becomes out of the options and medication can continue. But if the patient or the doctors already have the way out it will be too tempting to resist. (A plea for beneficent euthanasia, n. d. ) Even if euthanasia is unwise for conservatives, it is a matter of choice and conscience. For the unbelievers, they can go through life without considering it. For modernists, it is an available choice. In the end, one should never and can never decide for another. Gay-Williams failed to include this in his distinctions. It is true that it can be used by doctors as a practical way out of a medical case, or disillusion patients, but it should still be a choice given for all.

Movement of Goods and Freedom of Establishment Policies

Movement of Goods and Freedom of Establishment Policies INTRODUCTION In an examination of the various freedoms that are protected by the European Convention (EC), there are two that have provoked at different times praise and criticism, champions and conquerors. This paper will analyse that the roadmap that has been followed by the European Court of Justice[1] while interpreting EC Article 28[2] and EC A43[3]. Before splitting the discussion between free movement of goods and establishment, it is important to lay the foundation by an overview of the federalism debate that is natural to the EC and to Europe in general. The federalism question concerns the division of jurisdiction, power, and authority, between the central body (in this case the EC) and the individual states that are part of the central body. As the EC has developed, various autonomies have diminished. The ECJ is acknowledged as supreme, and Woods[4] notes that the court has expanded the Treaty into areas that were not envisaged originally, for example in Commission v Council[5]. The purpose of this paper then is to analyse the relationship between establishing a common market and respecting the autonomy and policies of individual states in the context of movement of goods and freedom of establishment. LEGISLATION? Craig[6] raises and interesting point with regards to the litigation on these points. In an effort to get true harmony, the simple solution would have been to issue Commission legislation which would have compelled the states to harmonise their laws. Craig blames the lack of speed in the Community for this failure, a situation which raises the question of the effectiveness of the courts as an adjudicator in this battle. While the ECJ do have jurisdiction, the decisions which will be examined presently have fluctuated as different times bring different concerns. The case-by-case approach is one that should surely be addressed by a legislative rather than a judicial body. Regardless of the lines that the courts have developed, there is surely a strong argument that they were not the right body for this job. It is important to understand what the individuals would be interested in gaining from the relationship. It is fair to say that the goals enumerated in the EC Treaty indicate that the Commission would want the maximum control in order to establish a common market, free of barriers. For the state, it cannot be expected that they will retain full autonomy; that would have been a sacrifice made when signing the treaty. The ideal situation though would be sufficient autonomy to be able to regulate so as to protect the interests of their constituency. WPJ Wils[7] summed this up in his article as â€Å"partial integration† which was described by him as the â€Å"pragmatic approach reconciling the desire for integration with the desire for government intervention†. The best alternative would be a clear and concise set of rules from the ECJ which would enable them to know for certain what they are and are not permitted to do; though this would be a poor substitute for the previous scenario. FREE MOVEMENT OF GOODS The EC Treaty is based in a large part around the development of a concept of a common market. A crucial aspect of this is the free movement of goods, with the apex being a market where there are no barriers and goods are sold in exactly the same conditions and situations in states a, b, and c. On the other hand, the states argue that to further the individual causes of their state, the national government must have the power to regulate, at least to a certain degree, the movement of goods. This section will deal first with Article 28 which sets out the boundaries of the intervention; it will then proceed to deal with Article 30 which addresses the interests of the member states. Intervention of the federal government. Article 28 states that: Quantative restrictions on imports and all measures having equivalent effect shall be prohibited between Member States. By itself this Article poses more questions than it answers; as such the interpretation of the ECJ is crucial. The attitude of the ECJ has been inconsistent when drawing the federalist line, although on certain points they have remained consistently pro central governance. The limited consistencies In Geddo v Ente Nazionale Risi[8] the ECJ took a broad view as to the nature of a quantative restriction, including â€Å"measures which amount to a total or partial restraint† of trade. Since Geddo[9], this has not been questioned, and it remains a firm foundation against the influence of national governance. Likewise, it has never been seriously doubted that the second part of Article 28 addressed measures that had equivalent results (MEQRs) and that national intervention could be struck down if the court deemed them to be an MEQR. The only question has been what constitutes an MEQR and this was largely resolved by Directive 70/50 which in Article 2 outlined the possible legislation that might constitute an MEQR. Discriminatory measures: national intervention rejected. On one point, it can be stated that the ECJ has awarded an overwhelming victory to the central government. This is where the restriction has a discriminatory element to it; for example in Commission v Italy[10] imported cars were compelled to go through a rigorous registration procedure. This was struck down as being a discriminatory restraint of trade. Likewise the court has struck down attempts by a state to promote domestic goods or efforts at price fixing. Indeed this analysis of the strict application to discrimination is included for three purposes only. First, to emphasise the first victory against state intervention. Second because of Commission v Ireland[11] where the court were content to ignore the prima facie pleadings of Ireland and examine the substantive result of their self interest promotions. Craig[12] points out that this is the theme which the ECJ have followed. The third reason is the indication that, not content with giving the central government a points decision, the ECJ have attempted to land a knockout punch. In Openbaar Ministere v Van Tiggele[13] the ECJ said that if a non-discriminatory attempt to fix prices affected even a single product adversely, the law would breach Article 28. The effect of this case is to throw down the gauntlet to states and make the dedication to an open market even more convincing. There is one way for the state to save a measure; by utilising Article 30. This provides that prohibitions can be saved on the grounds of public morality, public policy, public security, health and life, protection of national treasures, and protection of industrial and commercial property. On the face of this article, it seems to belay the earlier statement of victory for the common market. States have found though that utilising the article has major difficulties. Firstly, the courts have declared that the state has the burden of proof (Openbaar[14]). Secondly, as a general principle the list is exhaustive and cannot be added to over time Non-discriminatory measures In reality, it is hardly surprising that the ECJ has reacted strongly against discriminatory measures; the real battle ground has been measures that are applicable to both domestic and foreign goods. While A28 makes no mention of any requirement of discrimination, the Dassonville case obiter noted in paragraph 5 that there should be no need for discrimination in order to be caught by A28. Far from being simple, this field has been where the battle has been most fiercely fought. Cassis de Dijon In Rewe-Zentrale AG v Bundesmonopolverwaltung fur Branntwein[15] Germany invoked a rule that liqueurs were required to have a certain alcoholic content (regardless of nationality). The ECJ developed the Dassonville obiter to apply A28 to national rules that do not discriminate. Fundamentally, the ECJ summed up the approach in paragraph 14(4) by stating the principle of mutual recognition. Once a good is lawfully marketed in state x, it should be lawful to market it in any state in the bloc. This is a huge leap from Dassonville, a leap which on its face renders a national power helpless in the face of potential consequences. Craig notes[16] that in one step the ECJ places the states â€Å"on the defensive†. It can even be stated, and this paper contends, that this does not reflect the extreme state of affairs. An analogy can be drawn with company law in the United States. With no federal control, the states engaged in a race to attract companies to their shores. Delaware prevailed by offering such laws as provide minimum governance and convenient laws. The result has been that the companies have flocked to Delaware. The result of Cassis is that were one state to create a lenient set of laws, any product that passes muster should be accepted in every other member state. This ‘Cassis control’ leaves states not on the defensive, rather defenceless. Is there no limit to the ‘Cassis control’? This bleak state of affairs is not though one of total disaster. Cassis applies only so far as the ECJ rules that the boundary extends. The crucial term is what â€Å"affects the free movement of goods†? Weatherill and Beaumont[17] emphasised the potential for domination by listing a number of hypothetical situations where irrelevant regulations could be viewed as having a marginal effect on trade. The path the court has taken has been to draw a distinction between dual-burden rules where a product has to satisfy the rules of both state a and b, and equal-burden rules which apply to all goods after they have entered the country and so would not have been applied to the goods before. Cassis clearly governs the former; the crucial question is whether it also applies to the latter, for if it does then the national legislatures may as well take a white flag to the next European summit for their battle will be truly lost. The difficulty is that the court has been ambivalent on the issue with the court in Obel[18] stating that the cases were outside A28, while in Cinetheque SA v Federation Natioanle des Cinemas Francais[19] the court ruled that such a regulation could be within A28. The court it seems has resolved the matter in Criminal Proceedings against Keck and Mithouard[20]. The ECJ followed the initial article by E White[21], who contended that under the application of the article and to retain needed autonomy for the national legislatures, all equal-burden regulations should be outside the ambit of A28. On the face of it, this appears to be a boost for the states. Indeed, this would appear to grant back to the states the freedom and autonomy to regulate in this area, so long as the regulation applies to the characteristics of the goods and is not a regulation of the type that the goods would have had to satisfy in their original state. This though is not the complete story. The first point is that the decision in Keck[22] received a great deal of criticism, from scholars, practitioners and judges alike. While this doesn’t affect the decision, it has led to uncertainty in applying Keck[23]. The result has been that a new question has been raised as to what the courts meant when permitting regulation as to sale arrangements. A typical example comes from Societe d’Importation Edouard Leclerc-Siplec v TFI Publicite SA[24] where advertising was seen as a method of sales promotion and so outside the article. Meanwhile, in Vereinigte Familiapress Zeitungsverlags- und Vertreibs GmbH v Heinrich Bauer Verlag[25] the court held that because there was an effect on the product, it was within the ambit of A28. The opening section considered the range of scenarios from the perspective of the state, from ideal to least desirable. It is clear that the current jurisprudence provides the tae with neither the autonomy that it needs to protect the interests of the state, nor the certainty which would be needed in order to determine what the state may and may not regulate. Conclusion In conclusion what can be said about the line drawn by the courts? There is no doubt that the courts have used Dassonville as a launching pad for an assault on the autonomy of the member states. The only beacons of light for the state are the Keck authority, which has already been weakened by Gourmet and by academic criticism, and the policy exemptions which as has been discussed above will be interpreted strictly by the courts. The overwhelming conclusion must be that the line has been drawn in favour of the common market. FREEDOM OF ESTABLISHMENT The second element of the EC Treaty is the section concerning the freedom of establishment pursuant to Article 43. This goes hand in hand with freedom of movement, with the distinction that it applies to the right of individuals to maintain a permanent or settled place of business. Once again, the dispute at issue here is the battle between policies and a common market. It is conceivable that individual states may have concerns about allowing free establishment. Issues such as promotion of domestic small businesses and potential concerns about lack of qualifications are all issues which states may wish to regulate. This section will determine how the ECJ has reconciled these rights with the goal of a common market. In many regards there are parallels with free movement of goods and A28, as the crucial battle lines have been drawn over measures and regulations that are non-discriminatory. However, as before, the starting point must be those regulations that discriminate against new arrivals. Discriminatory tactics: any point at all? Unlike free movement of goods, the answer to this question is implicit within A43. The second paragraph clearly and explicitly states that an individual has the right of establishment â€Å"under the conditions laid down†. This was confirmed by the General Programme[26] which detailed the requirement that restrictive laws be removed. The point therefore is clear; the state may not discriminate against individuals entering the state for the purpose of to establish themselves as a company or in self-employment. Non-discriminatory measures? On a first reading of the article, the implication seems to be that non-discriminatory measures will pass muster. Indeed, the second paragraph states that the right must be acknowledged â€Å"under the conditions laid down for its own nationals†. Given the strict approach that the courts have taken in other cases though, it is worth examining whether they have held true to this definition or have developed it, much as they did with Dassonville in the area of free movement of goods. The early authorities appeared to bode well for the national authorities; in Commission v Belgium[27] the Advocate General stated that there was no need to analyse the question of proportionality because the law was non-discriminatory. A close analysis of this decision is not needed to iterate the importance of it. As long as a state could convince the ECJ that their law applied to everyone, they would still be able to control the establishment within their country. While they would be restricted, they would at least have a wide range of options open to them, and could exercise these options while retaining their autonomy and moulding them based on the needs of their constituency. The fight however, soon began to turn, at least with regards to the initial intervention of the ECJ. In Ordre des Avocats v Klopp[28] the court struck down a French law which applied to nationals and non-nationals alike. This could be excused, as the French law prevented the lawyer from holding a second office within the Community, which provided another ground to strike the law down. Nonetheless, the decision would have been troubling for the defenders of states rights and policies. The volte face was confirmed in Gullung v Conseil de l’Ordre des Avocats[29] when the ECJ ruled that a non-discriminatory law could be struck down if not sufficiently objective. Just as the Belgium case was significant for the states, so this was for the common market. Regardless of the overall result following a determining of objectivity and state policy, the decision meant that the court would investigate the reasons for the regulation. This by itself was a strike against the states autonomy and ability to self-govern. The hits just keep on coming for state’s rights. In the next section, there will be a discussion on the defences that a state can raise, indeed they are similar to those discussed for free movement of goods. Before that though, the ECJ has provided one last marker to further encroach on the states right to regulate. In Van Binsbergen v Bestuur van de Bedrijfsverenigning voor de Metaalnijverheif[30] the court ruled that upon finding a non-discriminatory restriction to fall within A43/59 (the test was originally used in the context of free movement of services but has been extended to establishment) the state will have to show that it can be objectively justified in pursuance of a public interest. On the one hand this is a positive step for the states as the ECJ is recognising their right to regulate under certain circumstances. The difficulty is that not only is an objective standard required, a standard that will judge the state not merely on what is best for that state, but also that the ECJ was prepared in Van Binsbergen[31] to hold that the measure was not sufficiently tailored to the particular aim of the regulation. For a state attempting to hold on to autonomy, this is arguably the worst possible result, to have the ECJ making recommendations about internal legislative functions. The other complication with this proportionality test arises from the complications for a state in assessing the likelihood of prevailing at the ECJ. Even on the question of what constitutes proportionality, the case law has mushroomed into a determination of the various factors that need to be taken into account. In Criminal Proceedings against Webb[32] the court made a list of factors that would be taken into account, including whether or not a similar test existed in the individuals home state. The re-claiming of territory lost As with free movement of goods, there are exceptions which the states can attempt to fit their regulations into. Once again, the enumeration of these in the Treaty (Articles 46 and 56) is both a blessing and a curse. On the one hand the court can at worse apply them strictly; they cannot remove the right to a defence from the members. On the other hand, the ECJ have used the enumeration to state that the at least for discriminatory measures, only those enumerated defences may be utilised (Bond van Adverteerders v Netherlands([33]. There is one area that the ECJ has deemed sacrosanct. A55 states that the rules on establishment are null and void when related to â€Å"the exercise of official authority†. In Reyners v Belgium[34] the ECJ held that this had to be related to sovereignty and† majesty† of the States. Unsurprisingly the states have seized on this to try and hit a metaphorical home run by forcing as many measures through this loop-hole. It is possibly because of Luxembourg’s wide ranging approach to the Reynors[35] case that the ECJ drew the narrowest possible interpretation emphasising that simply because a profession exercised some official duties, the entire profession could not be exempt. The official purpose exception may still be invoked but it will be an exception rather than the rule. In passing it should also be noted that the states do have some rights reserved to the. Under A43 there is express mention of the non-appliance of the article to citizens of that nation. Although the ECJ have wavered on this point, in Ministere Public v Auer[36] the ECJ held that the ‘foreign’ qualification was crucial. Thus there is nothing to prevent state a denying rights to their own citizens that to any other states citizen would be in breach of the article. This is likely to be a pyrrhic victory given that few states will have any desire to hinder their own citizens. Last chance saloon The final chance for the national authorities to claim some of the territory in this battle is with the ability to derogate that is contained in A46(1). The texts, in particular Barnard and Craig, set out the individual case law for each of the exceptions. This section simply focuses on the general approach in an effort to ascertain how helpful the derogation powers are to the national authorities. The first benefit that the states have is that it is not merely the ECJ who have commented on the derogations. Directive 64/221 Article 2 sets out the guidelines that must be followed. While the states may have hoped for more sympathy from the Commission than they received from the ECJ, they will have been disappointed. The articles merely set out a number of restrictions, including the point that the states cannot use it merely to further their own economic agendas. Indeed, the situation for the States is so unappealing that Craig emphasises (at788) that there is â€Å"little scope for manoeuvre†¦by the Member States†. Possibly the most illustrative case in this area is Van Duyn v Home Office[37] where the UK convinced the ECJ that they should be allowed to derogate in the case of an individual who was entering to work for the Church of Scientology. The ECJ ruled that it was irrelevant that the practice of this religion was not universally condemned. While this might encourage states, they would have been concerned by a later part of the judgement where the court emphasised that had she merely been a member the derogation would not have been permitted. In many ways this was typical of the ECJ’s approach to these case; advancing the cause of the States one step and with the same movement moving them two steps back. Equally illustrative was Bonsignore v Oberstadtdirektor der Stadt Koln[38] where the court took the sizeable stride of stating that past criminal convictions may not be enough to derogate from the articles. It I fair to say that this would frustrate any official in a State who would find that their hands were being tied, not on n integral international level, but on the basic and fundamental needs of national security. CONCLUSION The first conclusion is, and has to be that no definite answer can be given. As long as the federalism debate is answered by the ECJ and not the Commission, the answer will depend on the date of the cases and the environment at that particular time. It can be said though that regarding both free movement of goods and freedom of establishment, any regulations that are deemed to be discriminatory will be prima facie void and that it will be exceedingly difficult to persuade the court of the need for the regulation. Regarding non-discriminatory regulations, the situation also looks bleak for national policies with Cassis in particular emphasising central dominance. There are chinks of light within the Treaty itself and within parts of the ECJ jurisprudence. Overall though the path that the ECJ is taking leads in one direction only, and either they or the Commission will eventually minimise national policies to the point of virtual insignificance. Possibly the most clinical analysis can be found in Usher at 83 when he writes: It can hardly be denied that the Community now exercises considerable substantive powers which the Member States no longer exercise or lay claim to exercise- the exceptional cases being so infrequent as to be regarded as a major crises. BIBLIOGRAPHY BOOKS Barnard C‘The Substantive Law of the EU’ The Four Freedoms 1st Edition Published by Oxford Press Burrows F‘Free Movement in EC Law’ Published by Oxford Press Craig P /De Burca C‘EU Law, Text, Cases, and Materials’ 2nd Edition Published by Oxford Press Levasseur A‘The Law o the EU, A new Constitutional Order’ Published by Carolina Academic Press Rometsch D (edited)‘The EU and member states. Towards institutional fusion?’ Published by European Policy Research Unit Series Usher J‘EC Law and National Law. The Irreversible Transfer?’ Published by George Allen Woods L‘Free Movement of Goods and Services within the EC’ Published by European Business Law Library ARTICLES- GOODS Dirks K‘The Market Citizen: Economic Integration and Citizenship in the European Union’ Columbia University, 2005, http://www.columbia.edu/cu/polisci/pdf-files/dirks.pdf Gormley LW ‘Cassis de Dijon and the Communication from the Commission’ (1981) 6 ELev 454 Pitiyasak S‘Free Movement of Goods Within EU’ (17/12/2005) http://members.tripod.com/asialaw/articles/saravuth.html Steiner J‘Drawing the Line: Uses and Abuses of Article 30 EEC’ (1992) 29 CMLRev 749 Weatherill S‘After Keck: Some Thoughts on how to Clarify the Clarification’ (1996) 33 CML Rev 885 White E‘In Search of the Limits to Article 30 of the EEC Treaty’ (1989) 26 CMLRev 235 Wils WPJ‘The Search for the Rule in Article 30 EEC: Much Ado About Nothing?’ (1993) 18 ELRev. 475 ARTICLES- ESTABLISHMENT Lonbay J‘Picking over the bones: Rights of Establishment Reviewed’ (1991) 16 ELRev 507 The General Programme (1961) OJ Spec. Ed. Second Series IX O’Keefe D‘Practical Difficulties in the Application of Article 48 of the EEC Treaty’ (1982) 19 CMLRev 35 CASES- GOODS Case 22/70 Commission v Council [1971] ECR 263 Case 2/73 Geddo v Ente Nazionale Risi (1973) ECR 865 Case 154/85 Commission v Italy (1987) ECR 2717 Case 249/81 Commission v Ireland (1982) ECR 2717 Case 82/77 Openbaar Ministere v Van Tiggele (1978) ECR 25 Case 120/78, Rewe-Zentrale AG v Bundesmonopolverwaltung fur Branntwein (1979) ECR 649 Case 155/80 Obel (1981) ECR 1993 Cases 60 and 61/84 Cinetheque SA v Federation Natioanle des Cinemas Francais (1986) ECR 2605 Cases C-267 and 268/91- Criminal Proceedings against Keck and Mithouard (1993) ECR I-6097 Case 412/93, Societe d’Importation Edouard Leclerc-Siplec v TFI Publicite SA (1995) ECR I-179 Case C-368/95, Vereinigte Familiapress Zeitungsverlags- und Vertreibs GmbH v Heinrich Bauer Verlag (1997) 3 CMLR 1329 CASES- ESTABLISHMENT Case 352/85, Bond van Adverteerders v Netherlands (1988) ECR 2085 Case 2/74, Reyners v Belgium (1974) ECR 631 Case 221/85, Commission v Belgium (1987) ECR 719 Case 107/83, Ordre des Avocats v Klopp (1984) ECR 2971 Case 292/86, Gullung v Conseil de l’Ordre des Avocats (1988) ECR 111 Case 136/78, Ministere Public v Auer (1979) ECR 437 Case 33/74, Van Binsbergen v Bestuur van de Bedrijfsverenigning voor de Metaalnijverheif (1974) ECR 1299 Case 279/80 Criminal Proceedings against Webb (1981) ECR 3305 Case 41/74, Van Duyn v Home Office (1974) ECR 1337 Case 67/74, Bonsignore v Oberstadtdirektor der Stadt Koln (1975) ECR 297 1 Footnotes [1] ECJ [2] Formerly A30 [3] Formerly A52 [4] ‘Free Movement of Goods and Services within the EC’ at 2 [5] Case 22/70 [1971] [6] ‘EU Law, Text, Cases, and Materials’ at 582 [7] ‘The Search for the Rule in Article 30 EEC: Much Ado About Nothing? [8] Case 2/73 (1973) [9] ibid [10] Case 154/85 (1987) [11] Case 249/81 (1982) [12] ibid n4 at 588 [13] Case 82/77 (1978) [14] ibid [15] Case 120/78 (1979) [16] ibid n4 at 607 [17] ‘After Keck: Some Thoughts on how to Clarify the Clarification’ [18] Case 155/80 (1981) [19] Cases 60 and 61.94 (1986) [20] Cases C-267 and 268/91 (1993) [21] ‘In Search of the Limits to Article 30 of the EEC Treaty’ [22] ibid n20 [23] ibid [24] Case 412/93 (1995) [25] Case C-368/95 (1997) [26] (1961) [27] Case 221/85 (1987)

Malcolm X Essay -- essays research papers

Malcolm Little was born May 19, 1925 in Omaha, Nebraska. He grew up around eight siblings. His mother was a mixed woman because her mother was raped by a white man. His father was a very outspoken black Baptist church minister, who preached that blacks should go back to Africa. Due to death threats by white supremacist his family had to relocate to different places to live. After all that time his father was murdered when police found his body on the trolley tracks. The mother new it was by white supremacist. After his death his mother was committed to an insane asylum. Malcolm and his brother and sisters were split up and sent to foster homes and orphanages.   Ã‚  Ã‚  Ã‚  Ã‚  Malcolm graduated at the top of his junior high class. He then located to Harlem, New York. He then ...

Dinner is Served :: Technology Food Papers

Dinner is Served I ran into the kitchen to perform some last minute preparations for the night’s joyous festivities. I could smell the inviting aroma of the freshly smoked salmon which I had smothered in a light cabernet sauce and topped with dill to complete the presentation. I must admit that I was quite nervous in regards to the night that lay ahead. I quickly set the table because dinner was to be served in fifteen minutes. I could see the look of anxiety on my face through the reflection of the recently polished silver and stemware. I decided that Ben and Bill would sit across the table from Tim and myself. I knew I was taking a chance inviting the three of them back to my home considering what had happened the last time, but I was in the mood to engage myself into some stimulating conversation. The doorbell rang as I was pouring the last of the Pinot Grigio and my nervousness quickly ceased the moment that I opened the door. I said a little prayer that the night would go smoot hly and proceeded to twist the doorknob, opening myself to the world of luddites and fetishists. Bill Henderson was the first to arrive. He walked into my house with his head held high and placed his cane next to his seat. Bill was in his late 60s and was sure to add his own spice into the dinner party. I asked to take his knee length, brown suede jacket but he looked at me and mumbled, â€Å"I think that I can do it myself. You do realize that I can sufficiently run my life without an absurd amount of help that others seem to need.† "I'm sorry." I said. "I just thought it might be easier for me to take it.""That seems to be the only thing that concerns you people these days! Why must everything be so easy? I actually enjoy taking my coat and putting it behind my chair like the good old days." His breath permeated the smell of aged whiskey throughout the dining room. I led him to his predetermined seat and pushed start on the CD Player. He reached for his glass of wine as Beethoven’s String Quartet in C sharp minor gently entered the room.

Marketing Channel Analysis

The furniture industry is a very lucrative business that spans domestic and international markets. With that fact in mind, it goes without saying that different channels of distribution exist with regards to delivery of furniture from manufacturer to consumer. Furniture manufacturers who target the domestic market segment have three (3) major marketing distribution channels: (1 ) Through online shopping portals, (2) through public showrooms in malls, and (3) through prouder by catalogue. Online shopping portals.With the rise of the digital age, the use of the net is to just limited to advertisements, but has transcended to become a means of direct shopping via the Internet. Online shopping portals like Amazon . Com, Testamentary. Com, and Alabama. Com are just some of the mediums widely used by consumers to buy an assortment of products suitable to their needs. The success of online shopping portals can be attributed primarily to its wide reach of consumers and its ease of access-?on e click away as long as internet is available.However, this also means that a lot of choices are available for consumers to choose from prompting companies to always try to innovate ND improve on product designs and concept. Also, customer feedback and satisfaction is difficult to track. Internet traffic and thousands of mail per day are difficult are problems to be addressed. Public showrooms in malls and buildings. Public showrooms are one of the most known venues for selling furniture.It is very effective for selling because it exhibits the products in actual with tasteful arrangements while you sell. Customers are able to see for themselves the quality of the product and be active in choosing process before buying. However, public showrooms tap sees consumers than online shopping portals. This goes without saying that people in the immediate area are the primary consumers of the furniture. Prouder via Catalogues.Some companies use catalogues in selling their products wherein con sumer choose a product of their choice and place an order by giving the item name of what they are going to buy. It is then delivered to them after a time at their doorstep.

Psychoactive Drugs and Their Effects

Psychology Psychoactive Drugs and their Effects Medications that effect people psychologically are called psychoactive drugs. They are often helpful in treating depression, anxiety, insomnia, and other psychological complications. Psychoactive drugs don’t affect the underlying causes of these disorders, but they can provide symptomatic relief to allow people to live more normal lives. Anxiety can be defined as persistent nervousness, tension, or panic caused by stress or other psychological causes. Anti-anxiety drugs (also know as minor tranquilizers) are used to promote relaxation or reduce the physical symptoms of anxiety. Everyone feels depressed at times, but when it is prolonged and starts interfering with daily life, support, professional help, and psychoactive medications may be appropriate. Insomnia has many causes, including anxiety and depression. When the cause is known and can be treated, sleep patterns generally return to normal. When the insomnia is persistent, sleeping drugs may be appropriate. Drugs are classified according to their effects and actions on the mind and body. Example: Depressants, Hallucinogens, opiates and stimulants. Depressants (sometimes called downers) are a class of drugs that slow normal brain function. It acts on the central nervous system because of this effect on GABA activity that produces a drowsy or calming effect. GABA works to decrease brain activity. Depressants also carry high addictive potential. The withdrawal effects from long-term depressant use can be life- threatening and produce some of the worst consequences of any other drug classifications. Examples: alcohol, Valium, Xanax, Librium, and barbiturates. Hallucinogens (commonly referred to as Psychedelics) are drugs which cause altered perception and feeling. Hallucinogens have powerful mind –altering effects and can change how the brain perceives times, everyday reality, and the surrounding environment. They affect regions of the brain that are responsible for coordination, thought processes, hearing and sight. They can cause sensory or perceptual distortions in people to hear voices, see things, and feel sensations that do not exist. Hallucinogens change the way the brain works by changing the way nerve cells communicate with one another. Hallucinogens possess a moderate potential for addiction with very high potential for tolerance, moderate level of psychological dependence and low potential for physical dependence. Examples: LSD, PCP, MDMA,(Ecstasy), marijuana, mescaline, and psilocybin. Opiates (or narcotics) are powerful painkillers. They are made from opium, a white liquid in the poppy plant. Opiates produce a quick, intense feeling of pleasure followed by a sense of well being and calm. Long-term opiate use changes the way the brain works by changing the way nerve cells communicate with one another. If opiates are taken away from opiate-dependant brain cells, many of them will become overactive. As with many other drugs, opiates possess very addictive potential. Examples: heroin, morphine, codeine, Oxycontin. Stimulants (uppers) are a class of drugs that elevate mood, increase feelings of well-being, and increase energy and alertness. Stimulants can cause the heart to beat faster and will also cause blood pressure and breathing to evaluate. Repeated use of stimulants can result in paranoia and hostility. As with other drugs, stimulants possess very high addictive potential. Examples: cocaine, methamphetamine, amphetamine, MDMA (Ecstasy), nicotine and caffeine. Drug Abuse generally refers to drug taking that cause emotional or physical harm to one self or others example, operating machinery or driving a vehicle, while â€Å"under the influence† of alcohol. Addiction is a broad term referring to a condition in which a person feels compelled to use a specific drug. Drug addiction can be psychological, physical or both. Drug addiction is not the same as substance abuse or drug abuse. A Individual who abuse drugs are not necessarily drug dependent, people who are addicted to drugs, conversely are also called drug abusers.

Biovail Case Essay

In the case when ownership changes hands upon receipt of the product at the distributor’s facility (FOB destination), the second condition for revenue recognition under SAB101 has not been met. In this case the company would not recognize revenue because delivery did not occur. Part 3: The shipment left Biovail on September 30, 2003, which is in the 3rd quarter. Under FOB shipping point guidelines it would be correct to recognize revenue for the shipment in the Q3 report. Assuming revenue associated with this shipment was included in Q3 earnings as originally stated, no further impact. Under the FOB destination guidelines it would be incorrect to recognize revenue. In that scenario the truck does not reach it’s destination in the 3rd quarter and thus no shipment is made and revenue should not be recorded. Assuming that this shipment would take longer than 1 day to reach the distributor, based on the fact that it is in Chicago on 10/1, this shipment shouldn’t have been planned as revenue in quarter three anyway. The accident will have an impact on Q4 revenue. Part 4: Biovail’s treatment of analysts who cover their stock is concerning. It is still unclear whether Treppel was correct or too harsh, but Biovail’s fierce retaliation against Treppel highlights their willingness to go to great lengths to suppress any negative analyst reports. This combined with, the lack of clarity around their accounting practices and conflicting arguments from their distributor lends us to question their integrity. This would create a difficult environment for an analyst to create a unbiased report and significantly discourages us to be an analyst covering this company.

Falcon Computer Essay

Falcon managers documented that the company’s communications is an open kind of communication, but why did they always hold a meeting with an executive panel. Quality was said to be the most important of all, in a sense that they delivered damaged-free computers to customers; in contrast, two out of four defective computers were used in one of their trainings. Despite the fact that the employees, like Peter Richards, knows about the inconsistency between their values and behavior, they choose to behave. Because normally when we talk of our values, these are the things that we strongly feel about. These are the things we are either for or against. And it’s often easier to think of what we are for rather than what we are against. This is because we feel positive energy when we are working on what we are for. Even if our values are negative, we can be stronger and more focused by expressing it positively. The way Falcon values formulated is a technique involving the advocacy of a behavior that is opposite to the one existing with the expectation that this approach will encourage the employees of the persuasion to believe that they are working in an ideal environment against the existing reality. With this, executives possibly would like to hide the flaws of the company. They would want the employees to be positively motivated by satisfying themselves to a blind belief that there are no problems at all. And when the company closed, the employee will just have thought that this is something they have seen before and have not done anything because of the hope that a positive change might happen in between.

Categories of Evasion Techniques

Categories of Evasion Techniques Evasion techniques The term evasion technique groups all the methods used by malware to avoid detection, analysis, and understanding. The evasion techniques can be classified into three broad categories, namely, anti-security techniques, anti-sandbox techniques and anti-analyst techniques. Anti-security techniques These techniques are used to avoid detection by antimalware engines, firewalls, application containment, or other tools that protect the environment. Anti-sandbox techniques These techniques are used to detect automatic analysis and avoid engines that report on the behavior of malware. Detecting registry keys, files, or processes related to virtual environments lets malware know if it is running in a sandbox. Anti-analyst techniques These techniques are used to detect and fool malware analysts, for example, by spotting monitoring tools such as Process Explorer or Wireshark, as well as some process-monitoring tricks, packers, or obfuscation to avoid reverse engineering. Some advanced malware samples employ two or three of these techniques together. For example, malware can use a technique like RunPE (which runs another process of itself in memory) to evade antimalware software, a sandbox, or an analyst. Some malware detects a specific registry key related to a virtual environment, allowing the threat to evade an automatic sandbox as well as an analyst attempting to dynamically run the suspected malware binary in a virtual machine. It is important for security researchers to understand these evasion techniques to ensure that security technologies remain viable. Malware detection on mobile devices The basic differences between a PC and mobile device are constrained in terms of computation power, memory and limited battery resources. The targeted exploits of mobile malware are also significantly different from those on PC due to the differences in operating systems and hardware. For e.g. Majority of mobile devices are based on the ARM architecture. Hence, we need to provide due consideration when using the PC based methods for mobile devices. The detection method must use memory and computational resources efficiently and not drain the device battery. The detection method must be cost-efficient to update over the wireless network. There are two general ways of protecting the mobile device. One is to offer protection at the device level and the other is to offer protection at the network level by inspecting packets destined for the device. Device based protection detects and cleans malware including viruses, Trojans and spyware that are installed on the device whereas network based protection looks to detect and prevent intrusions in the network. Malware Analysis Classification All classification approaches taken in the literature can basically be categorized into two types: (i) based on features drawn from an unpacked static version of the executable file and (ii) based on dynamic features of the packed executable file. These approaches are further classified into signature based, behavior based, hybrid based and machine learning based approaches. Signature based approaches are simple and capable to operate online in real time. They detect only known malwares and are not useful for detecting new, unknown and stealthy malwares. They are less powerful with respect to evasion techniques (i.e) obfuscation transformations can easily defeat signature-based detection mechanisms. A signature matching algorithm is well suited for use in mobile device scanning due to its low memory requirements. Behavior based approaches are designed for analyzing the malwares dynamically, thereby allowing it to detect unknown malwares efficiently. They rely on system call sequences/graphs to model a malicious specification/pattern. Behavior-based methods and machine learning methods are dynamic approaches. Anomaly-based approaches, also known as profile-based approaches, profile the statistical features of normal traffic. Any deviation from the profile will be treated as suspicious. They detect previously unknown attacks, but they showed high false-positive ratios when the normal activities are diverse and unpredictable. Specification-based approaches are similar to anomaly detection, but they are based on manually developed specifications that capture legitimate (rather than previously seen) system behaviors. They avoid high false alarm rates caused by legitimate but unseen behavior in the anomaly detection approach. Their drawback lies in more time-consumption as they develop detailed specifications. Thus, one has to trade off specification development effort for increased false negatives (i.e., likelihood that some attacks may be missed). Heuristic approaches for detection in PCs include semantics-based, visualization-based, social network based, entropy based, cryptographic based, difference equation based, kernel based detection approaches. For detection in mobile, immune system-based, memory acquisition-based, suspicious API call patterns, differential fault analysis approach, Intercomponent communications are the approaches that comes under heuristic category. Much research has been conducted on developing automatic malware classification systems using data mining and machine-learning approaches. However, due to various stealth techniques designed by malware authors, most malwares remain undetectable. Organization This paper presents a detailed insight on malware analysis in both the Personal Computer (PC) domain and the mobile domain, based on literature survey done from 1987. First, the various forms of malware and the impact of malware in PC and mobile phones are discussed. Also, their prevalence in most used operating systems such as Windows (for PCs) and Android (for mobile) is focused. Second, the literature survey explaining the contemporary detection approaches are compared with the ancient approaches and their advantages and disadvantages are discussed. Finally, research questions and findings are discussed, giving key ideas for malware researchers to develop a more robust and efficient detection approach, to improve protection and reduce risks, applicable to real-world scenario.

A Relationship between Followers and Leaders Thesis

A Relationship between Followers and Leaders - Thesis Example Leadership is one of the most discussed topics in the contexts of scholarly domain, the work and organizational environment. Most authors have delved into research that is aimed at shedding light on the various leadership styles, basing their arguments on leadership theories that were earlier developed by scholars such as Conger and Kanungo, Weber, Bass and Lewin among others. Leadership in itself gives a sense of positive direction to the involvement of human resources and brings out the best from the employees thus meeting the organizational goals. Charismatic leadership, transformational leadership, autocratic leadership, and bureaucratic leadership are just but a few examples of leaderships that are applicable cross several organizations. Some leadership styles are rigid whereas some flexible to change of any sort that is inevitable in any organization.Demographic change makes leadership an aspect of critical necessity because the war of talents is getting harder than ever before . Most people are getting educated on leadership, making it necessary for the leaders to change their styles of leadership to those that are effective in meeting the organizational objectives. The best leadership style will not only be able to make a company or organizations realize its objectives but also change the face of the organization. Additionally there are also changes that are bound to take place in the organization

Netflix Essay Example | Topics and Well Written Essays - 1000 words

Netflix - Essay Example The first part of this paper will analyse Netflix products, its competitors, the company’s competitive strategy as well as its value chain. Part two of the paper will evaluate how Netflix applied art and science through various information communication technologies to boost its operations. Netflix products Netflix has more than 33 million subscribers in 40 countries that can rent DVDs or download movies for a monthly fee through Netflix.com. The company also has mail delivery services where movie deliveries takes place through the US Postal services from distribution centers that are located in the major cities in the country. More so, the movies streaming reaches800 devices that include PCs, TVs, and mobile application (Nelson and Quick, 2012). This means that the company’s products and services are DVD vending, and selling physically and through the internet, mail delivery services and video demand services online. ... The other competitors Amazon prime, who freely ships on millions of items and rented eBooks. The problem that Amazon prime has is that customers are required to purchase an entire year of prime for $ 79; hence discouraging customers (Nelson and Quick, 2012). To add up the competitor list is HBO GO owned by Time Warner, who offers unlimited access via website login. In spite of HBO Go great web interface, it still tethers to the cable networks. Vudu, Wal-Mart partner has also joined the industry, adding up the competitor list and it allows subscribers to stream instantly on Walmart.com. What is Netflix competitive strategy? The main competitive strategy that Netflix uses to beat competitors is product differentiation. This is the case because the company offers old products (movies) in new modernized ways. For instance, the company still mixes the old mail delivery and online streaming in movie delivery, which helps it target diverse customers (Nelson and Quick, 2012). This is excepti onal because no other company in the industry uses the old mail delivery; hence creating a differentiation. This strategy not only creates a differentiation to the customers but also eases customer’s delivery of movies because most customers get the movies at the comfort of their homes through mail and still return them through the same mail. This convenience is a great attraction to customers who end up becoming loyal to Netflix. Netflix value chain analysis Every business should look forward to reducing logistical costs as well as perceptive sales, which eventually keep the company viable. Netflix has strategically organized its value chain because it is cable to accurately, forecast demand given that

Margaret Thatcher Essay Example | Topics and Well Written Essays - 1000 words

Margaret Thatcher - Essay Example Five years later, she strongly supported Keith Joseph in his mission to become Conservative Party leader but unfortunately he couldn't remain in the election. After gaining great experience she became the leader of the Conservative party in 1975. Thatcher entered the contest herself and became leader of the Conservative Party. It was 1979 when Margaret Thatcher became England's first female Prime Minister. (Thatcher, 1993, pp-27) In the Conservative manifesto of 1979, she had written about the feeling of helplessness that a nation which was once called a great nation has fallen behind with time. Thatcher entered ten determined to reverse the national decline of the country, which was characterized by a combination of high unemployment, high inflation and stagnant growth. The political philosophy and the economic policies of Thatcher emphasized on the financial sector, selling off of state owned companies and flexible labor markets. (Thatcher, 1993, pp-32) Because of high unemployment and recession her popularity amongst people decreased, with the help of economic recovery and the success of Falklands War which brought a great support for her and in the election of 1983 she was elected again. During her leadership she been through very hard times for example, Brighton hotel bombing which was the attempt to assassinate her, but she survived. Margaret also took a hard line against all the trade unions. Because of her hard words and tough talking she was also know as the Iron Lady. In 1987 she was again elected for the third term. The same year was not good for her and it proved difficult as the Poll tax plan became unpopular and her views about the European Community were also not shared in the Cabinet. (Thatcher, 1997, pp-17) In the November of 1990 she resigned as the Prime Minister. Her period as Prime minister proved longest after the record of Lord Salisbury and she also had a record of spending continuous longest period after Lord Liverpool. She also became the first lady to lead a political party in the England. Thatcher is also the first of only five women to have the four great offices of a state. She also has a peerage as Baroness Thatcher, in the County of Lincolnshire; this made her eligible to sit in the House of Lords. (Thatcher, 1997, pp-34) Thatcher's economic and political philosophy focused on entrepreneurialism and free market. She tried her best to end what she thought was excessive government interference in the economic policies, and therefore she decided to privatized many nationally owned companies and made a policy of selling public housing to tenants at reduced prices. Thatcher was deeply influenced by monetarist thinking as exposed by Milton Friedman, Thatcher started her economic reforms by focusing on increasing interest rates to try lower inflation. Thatcher also ordered to place limits on the printing of money and she thought that legal restrictions on trade unions should be there, in her battle to handle inflation and settle the disputes among trade union she found it very difficult. UK's economy was not good during the whole 1970s. In pursuit of her anti interventionist views Thatcher introduced the system of cash limits on public spending, and tried to reduce expenditures on social services such as edu cation and housing un till 1988. In the same period

Ethics in research Essay Example | Topics and Well Written Essays - 500 words

Ethics in research - Essay Example Two: Do voluntary participation, informed consent, risk of harm, confidentiality, and anonymity (Trochim) pretty much cover the bases for ethical research on human subjects? Whether quantitative or qualitative research approaches are employed to study human phenomena, the knowledge quest rests on the thing of the quest--the object of study. Whether researchers, ethics committees, the public, or others like it or not, human subjects become objects in the service of discovering, confirming, or advancing knowledge. Objectification comes with all that is the research enterprise. If, however, in a clinical or confidential study, a subject, or we can now say object, is not treated per proper procedure and respect, there may be cause for complaint. Any ethics violation may then have to be determined by those closest to what was actually proposed and done. Davidsons question seems more philosophical than practical. It may not be nice or politically correct to objectify people in some ideal world or in some contexts, but in the end for research we do it, just as we do it elsewhere in our lives (e.g., picture the finals in a body building competition). Voluntary participation, informed consent, risk of harm, confidentiality, and anonymity are not the only matters for care in planning and conducting research involving human subjects. No doubt any ethics committee or listing of standards, rules, or procedures would specify these and others, and in some detail. However, there is at least one additional base to cover regardless of the group to be satisfied or the expectations to be met. The expectation or standard should be articulated that ethics should be addressed whenever researching human subjects. This may seem redundant, but if not stated in whatever fashion the governing or advisory body wishes to, not having some self-referential language about the

Typography in Business & Bauhaus Manifesto Dissertation

Typography in Business & Bauhaus Manifesto - Dissertation Example The document; ‘Using styles Training’ could appear as illustrated below after the effect of topography on it: How to Format Your Word Document Using â€Å"Styles† Microsoft Word has a tool known as styles, which help in formatting a document. Where is Styles found? The styles tool is in the Home ribbon of Microsoft Word. Styles functions. It allows the user to classify certain formatting characteristics as a specific â€Å"style†. How to use Styles. For example, if one wishes to have all Headers in a document to be Arial, size 18, and bold, one could create a style which encompasses these formatting characteristics. This style can then be applied to any other words in the document with one click, rather than having to manually format each word. Design entails making an assemblage of concepts and creating a format that reflects a visual solution that depicts functional and artistic usefulness. Design is more about transformation of ideas and words to achieve a desired result in the mind of an audience. The principles of design offer vast possibilities in crafting creative solutions. Good design would be flexible and reflect content so as to give an effective visual communication. The Bauhaus manifesto expressed the opinion of design as primarily involving industry and mass production as opposed to individual craftsmanship. That the definitive aim of all creativity is building. The manifesto refutes the existence of professional art. Bauhaus philosophy maintains that design is relevant only when someone is using it.

Relief o choking in victims one year of age and older Essay

Relief o choking in victims one year of age and older - Essay Example When there is plenty of nasal secretion in the airways of a child, breathing difficulties may arise during feeding and in the periods between meals, because some children are unable to open their mouths wide enough once their noses are bunged up. As a child in new born, inhalation difficulties are likely to arise, if there is a mechanical obstruction in the airways. Problems with both inhalation and exhalation can indicate cardiac dyspnea in children. Yet, the most common reasons for choking in children aged one year or older include breathing in a small object, a part of a toy, food or some other object that might block airways, i.e. throat and windpipe. It is also possible that children breathe in vomited material, while being asleep/unconscious. Generally, choking in children aged one year and older is caused by the obstruction of a child’s airways, which can be divided into two main kinds – mild and severe airway obstruction (Blair-Harmon). Naturally, handling different kinds of choking depends greatly on recognition of them and knowledge of symptoms. The signs indicating mild airway obstruction are the following: there is a good air exchange in a child’s airways; the child is responsive and coughs forcefully; the child might wheeze between coughs (Blair-Harmon). This type of obstruction is easy to get rid of as there is a good air exchange and apnea is virtually impossible. Thus, it is important to encourage breathing efforts and coughing in children until the foreign object is removed. Moreover, one mustn’t interfere with the attempts to remove the foreign object or perform first aid, yet it is necessary to stay with the child and monitor the situation – the need to call 911 may arise, if mild airway obstruction still persists. Another – and more serious type of mechanical obstruction is severe airway obstruction that is crucial to be recognized promptly. In this case, there is no