Writing a 5 paragraph essay
Hci Research Paper Topics
Thursday, August 27, 2020
How to Write a Business Proposal Free Essays
A strategic agreement is maybe one of the most basic reports you have to figure out how to compose. It is the thing that spells the contrast among progress and disappointment, regardless of whether youââ¬â¢re a specialist or you have your very own organization. In todayââ¬â¢s relentless business world, business visionaries end up going through a long time submitting strategic plans to likely customers, and not get any outcomes. We will compose a custom article test on Instructions to Write a Business Proposal or on the other hand any comparable theme just for you Request Now Then again, there are those that resemble sharpshooters, ready to get the agreement after simply submitting one strategic plan. So how would they do it? All things considered, this article will train you tell you the best way to do only that. The Basics of a Business Proposal Before you even proceed to begin composing that strategic agreement, you should initially comprehend what it is and realize the nuts and bolts. A strategic agreement is a composed report that offers a specific item or administration to a possible purchaser or customer. There are commonly two sorts of strategic agreements: requested strategic plans (which are submitted in light of a promotion distributed by the purchaser or customer) and spontaneous proposition (submitted or offered out to possible purchasers or customers despite the fact that they are not mentioning for one). Strategic plan versus Marketable strategy Regularly, the terms ââ¬Å"business proposalâ⬠and ââ¬Å"business planâ⬠are utilized conversely, giving you the feeling that they are very much the same. Be that as it may, they are definitely not. A strategic plan is made to offer an item or administration to a purchaser or customer. Then again, a field-tested strategy is a ââ¬Å"formal explanation of a lot of business goalsâ⬠and how these would be accomplished. The last is just piece of what is remembered for a strategic plan. 3 Ps of a Winning Business Proposal The mystery behind composing a triumphant strategic plan and one that will simply be put aside is the nearness of what I call the 3 Ps: issue explanation, proposed arrangement, and evaluating data. Issue Statement An effective strategic plan must be one that can depict to the customer what their needs are in a straightforward way. This is extremelyâ vital on the grounds that how might you anticipate that the customer should accept that you can assist them with taking care of their issues on the off chance that you donââ¬â¢t even know are these issues? Hereââ¬â¢s a case of an elegantly composed issue articulation of a strategic plan: With the nearness of online life in todayââ¬â¢s propelling world, Puffin Media Inc. wavered to make the jump from conventional promoting to online life advertising. Their advertising strategies appear to lose viability and the organization feels as though they are passing up a huge section of their market. Likewise, their opposition has started procuring most of the business in the market and have brought Puffin Mediaââ¬â¢s developing incomes to an end. Proposed Solution The primary goal of presenting a strategic agreement is to offer an answer for an issue looked by an imminent customer. This part ought to be as nitty gritty as could be expected under the circumstances, and ready to address every single need you have found. Hereââ¬â¢s a model: The arrangement that is suggested for Puffin Media Inc. is to send their organization on the entirety of the significant online life channels; be that as it may, there is a significant contrast in making web-based social networking stages as opposed to making a brand you can advance on those stages. A promoting effort must be made using these media channels and making prompt commitment with your crowd. With the end goal for this to be effective, you realize how to make deals. At first, gain a few fans, devotees, endorsers, and associations and welcome them to go along with you specifically conversation or go to a particular occasion. The motivation behind this isn't just to advance Puffin Media Inc, yet additionally to request input from the intended interest group. Evaluating Information For some customers, the evaluating data is the thing that will cause them to choose whether they would offer you the agreement or not. The most effective method to compose this part enormously relies upon the arrangement or arrangements you remembered for the past fragment. On the off chance that the arrangement proposed will just involve a brief timeframe, a Fee Summary will do the trick. For longer tasks, section these installments to explicit achievements in a Fee Schedule list. Things to Remember When Writing a Business Proposal Since you know the basics of a triumphant strategic plan, itââ¬â¢s time to feel free to begin composing, isn't that so? All things considered, not actually. The following part is to have the option to discover what to put under the 3 Ps with the goal that you can build up a strategic plan that stands out enough to be noticed and grants you that agreement. Do Your Research Not all customers and purchasers will give you the unequivocal subtleties of their needs and needs, particularly if youââ¬â¢re presenting a spontaneous strategic plan. Stretch out your examination to incorporate the contenders of your expected customer, and their clients too. This will guarantee that your strategic plan will be as thorough and as itemized as could reasonably be expected. Come at the situation from their Perspective. Something else to recollect when composing a strategic plan is to consistently placed yourself in the shoes of your expected customers. Doing this will assist you with giving data on things that they would in all probability ask, for example, ââ¬Å"Why would it be advisable for us to pay you this much sum for the arrangements youââ¬â¢re offeringâ⬠and ââ¬Å"How can these progressions advantage me?â⬠Why You? On the off chance that you confirmed that an organization or customer has certain requirements, odds are others would have done likewise. That implies that there will be others that have presented their individual proposition to the organization or customer. That being stated, it is critical to make a point to feature your gifts, understanding and different capabilities to persuade the customer why they ought to pick you or your organization. Composing that Business Proposal At the point when you got these, at that point youââ¬â¢re at long last ready to begin composing your strategic plan. Probably the most ideal ways on the best way to compose a powerful strategic plan is to utilize a strategic plan programming. Strategic plan programming programs encourages you compose your strategic agreement without stressing over how they ought to be assembled and the substance that you have to incorporate. These projects contain two sorts of proposition formats that you can utilize and re-use, contingent upon which one you have to compose. Notwithstanding the put away formats, you can make your own proposition layouts through these projects dependent on past recommendations youââ¬â¢ve made, making it even moreâ convenient for you and your business. A Final Wordâ⬠¦ In spite of the fact that strategic agreements present a similar data and have a similar design, itââ¬â¢s critical to require significant investment and make every one interesting. Each venture is extraordinary, regardless of whether itââ¬â¢s with a similar organization. Keep in mind, a strategic plan must show how you or your organization can support an expected customer. The most effective method to refer to How to Write a Business Proposal, Papers
Saturday, August 22, 2020
Gene Therapy Essay -- Genetics Science Essays
Quality Therapy The Human Genome Project started around 1986. The primary objective of the venture is to find and arrangement all qualities found in human DNA. The destinations for this driven exertion are to become familiar with heredity of illness and to find the qualities that would help in quality treatment. Advances in quality treatment endeavor to treat genetic ailments and conceivably kill sickness from the genome. The meaning of quality treatment is the presentation of qualities into existing cells to forestall or fix a wide scope of infections (Jaroff, 1996). Quality treatment has two prospects of infection treatment, physical quality treatment and germline quality treatment. Physical quality treatment includes the control of quality articulation in cells that will be remedial to the patient yet not acquired to the people to come. Germline quality treatment includes the hereditary alteration of germ cells, which give the change to the people to come (Wilson, 1998). Physical quality treatment is right now being looked into all the more forcefully because of moral and specialized confusions with germline quality treatment. Specialized Aspects Quality treatment started with the Human Genome Project. The Human Genome Project has discovered quality areas for some illnesses. Among the illnesses that have been found Huntingtonââ¬â¢s infection, cystic fibrosis, ADA inadequacy, and two qualities for bosom malignant growth are only a couple of models. After an infection causing quality is discovered, amending it is the following consistent advance. This can be accomplished through different techniques. One of the primary tried techniques was to acquire the defective quality from the patient, bring the rectified quality into cells, lastly infuse the adjusted cells once more into a vein. Blood is taken from the influenced individual to acquire cells with DNA carryi... ...imit our capacity to adjust to natural and ecological changes. Notwithstanding this, I am excited about quality treatment. I need to carry on with a sound life and I need my youngsters to have the option to live cheerful, solid lives. With quality treatment, the utilization of human cells to treat sickness looks encouraging. Who knows, when the earth changes, quality treatment might be progressed to such an extent that a straightforward infusion could cause us to adjust to this change. References Elmer-Dewitt, Philip. The Genetic Revolution. Time. January 17, 1994. V 143. N 3. P (46-44). Beauty, Eric S. Better Health Through Gene Therapy. The Futurist. Jan-Feb 1998. V 32. N 1. P (39-43). Jaroff, Leon. Keys to the Kingdom. Time. Fall 1996. V 148. N14. P (24-29). Wilson, Jim. The Institute for Human Gene Therapy. Gotten from the WWW November 1, 1998:http://www.med.upenn.edu/~ihgt/data/whatisgt.html
Friday, August 21, 2020
What Can Be Done With Samples of Lyrical Essay?
What Can Be Done With Samples of Lyrical Essay?Have you noticed that a lot of songs that are in the charts these days have samples of lyric essays in them? Have you wondered what that is all about? You may not think about lyrics that much but there are actually quite a number of samples of lyric essays that are out there, which you can easily access using the Internet.If you have written a song that has a sample of a lyric essay or other type of music, then you can certainly use those samples. The samples are often used for commercials and advertising campaigns so they have to be very good. That is why a lot of people enjoy using samples.Even if you are just writing a short article about music or songs, you can use these samples as well. The samples will enable you to write about something completely different from your own experiences. You will discover that the samples of lyric essays and songs are indeed quite helpful when you need to bring a bit of freshness into your writing.Whe n you go to school, you would hear all about lyric essays. They are certainly useful tools that students can use when they are writing their papers. These are usually written by songwriters and they offer insights into how they came up with their songs. The samples of lyric essays could possibly help you in the process of writing your own papers.All songwriters have their versions of the samples. This is because the samples are there to assist them in understanding how their work comes about. They are there to ensure that the songwriter is making the best use of the time that he has and he is able to express his true thoughts in the composition of the song. The samples are also great for helping the songwriter keep things simple, as well as he is able to bring the best out of his instrument.If you really want to write about a sample of a lyric essay, then you will be doing yourself a disservice. It is rather easy to compose something that is unique and captivating. You should rememb er that the more innovative and interesting your articles are, the better chance you have of getting people interested in the content of your pieces.When you see someone who is having trouble understanding the meaning of a sample of a lyric essay, you will want to help him out. That is why you can always bring your own thoughts and inspirations to the project. You will be able to offer your own interpretation to the piece of music that you are writing about. You will be able to do this with the samples of lyric essays that you are familiar with.You will find that many online websites will allow you to upload your own samples of lyric essays. You will find that you are able to take advantage of these opportunities in order to enhance your writing skills and knowledge. You will also be able to write something that is very different from other writers. It is always good to have samples of lyric essays in order to contribute to the development of the art form that is songwriting.
Monday, May 25, 2020
Technology Transfers Developing Renewable Energy Sources...
Technology Transfers: Putting Theory into Practice Climate change is an increasingly demanding issue as global population continues to grow, energy sources are being depleted and cooperation between actors to take action is often difficult to enforce. Renewable energy is a growing technology. With the depletion of fossil fuels as well as increased greenhouse gases in the atmosphere due to fossil fuel burning, energy dependency will have to shift to renewable technologies such as solar photovoltaic, wind, hydroelectric and geothermal. Unfortunately, these technologies are expensive and building new or altering old plants to allow for their use is costly. Because developing countries are in transition and have a growing energy demand,â⬠¦show more contentâ⬠¦These projects must transfer cleaner technology as well as foster sustainable development in Non Annex I countries. In Joint Implementation, both countries participating are committed to reductions under the Protocol (Cullet, 175). Flexible mechanisms lessen the financial burden of lowering emissions for Annex I countries and also involve developing nations in the international effort to reduce greenhouse gases in the atmosphere. Non- Annex I countries must be begin to adhere to the emission regulations of the Kyoto Protocol. In theory, technology transfers through Cleaner Development Mechanisms and Joint Implementations are an effective way to introduce cleaner technology, aiding both developing and developed countries; developing countries gain new knowledge and different techniques to shift their dependency away from nonrenewable energy sources and developed countries adhere to Kyoto provisions. This exchange is necessary and appears to be flawless, yet such transfers must be closely regulated to ensure the livelihoods of the people in developing nations rather than the economic benefits such actions will have for private corporations. Economic and social security must be granted to the developing countries in order for this mechanism to be followed and agreed upon. Technology transfers under the Kyoto Protocol further define the division between the North and the South and mayShow MoreRelatedRenewable Energy As A Means Of Reducing The Use Of Fossil Fuels1412 Words à |à 6 Pagesdevelopments in renewable energy as a means of reducing the use of fossil fuels OUTLINE Thesis statement: benefits of renewable energy decreaseing the consumption of fossil fuels outweighs its disadvantages. Topic sentences: 1. First of all, renewable energy is more governable than nuclear power. 2. Furthermore, renewable energy is benefit to human in two ways, in particular environmentally friendly, and reducing the consumption of fossil fuels. 3. To some extent, developments in renewable energy need toRead MoreBureaucratic And Government Organizations : Policies And Bottlenecks1586 Words à |à 7 PagesPolicies and Bottlenecks in clean energy investments. VIKAS PATEL, 1402207, NITIE Mumbai EXECUTIVE SUMMARY Developing countries needs huge investment in energy sector to achieve development goals Deployment of new clean technology can help meet two objective in energy sector: to improve access to and reliability on modern energy services and to help shift to sustainable energy development. Modern era technology has the potential to increase the availability of cleaner energy at low cost and maintainingRead MoreGlobal Dependence On Fossil Fuel1485 Words à |à 6 Pagesproportion of Renewables must increase to around 50% of the energy mix in most countries and is expected to be over 70% in countries Brazil and Africa. Energy efficiencies and low carbon energy carriers for heating and cooling can decarbonize electricity, significantly reducing the share of fossil fuels to less than 50% in the total energy requirement. Sharing best practices across borders can help transfer innovative technologies and support energy transition plans for many of the developing countriesRead MoreThe Transition Of Energy Systems1677 Words à |à 7 PagesThe energy systems seen in the present day a re vastly different from those seen in the past two decades amid the ongoing transition of energy systems. The issue of climate change and the alarmingly high levels of Global Greenhouse Gas (GCG) emissions have meant there has been a transition in energy systems as countries worldwide continuingly proceed into a post-carbon world. Developing energy systems of the future is one of the central challenges to policy makers, a challenge which is ââ¬Å"complex andRead MoreImplementation Of Geothermal Energy As An Alternative Energy1459 Words à |à 6 PagesTitle : Implementation Of Geothermal Energy As An Alternative Energy AHMAD HAFIZUDDIN BIN ISMAIL (EC15132) FIRDAUS BIN MAT SHUKRI (EC15133) MUHAMMAD SUHAIMI BIN MOKHTAH (EC) AMAR FAISSAL BIN KAMARUDDIN (EC15134) Faculty of Electrical and Electronic Engineering UNIVERSITI MALAYSIA PAHANG (UMP), 26600 PEKAN, PAHANG, MALAYSIA Abstract This report presents an alternative energy is any energy source that from fossil fuel. We need to turn to alternative energy in general. Firstly, we were in dangerRead MoreSaudi Arabi A Large Amount Of Energy1388 Words à |à 6 PagesAbstract There has been an increasing growth in the development of new energy resources that can compete with the energy demands of the growing population of the world. In this manner, a number of steps have been taken in the major parts of the world. Solar power is been in use since a long time. With the increasing demands of oil and gas there is a rapid decrease in the supply of these natural resources, and hence, the authorities are looking for alternative ways to supply the power to the exceedingRead MoreSolar Energy Technology And Its Policies1385 Words à |à 6 PagesSolar Energy Technology and its Policies Increased energy consumption in the world today is a growing concern. Most of the energy consumption today comes from fossil fuels. Fossil fuels mainly consist of oil, coal, and natural gas as the most commonly used ones. These products are non-renewable sources meaning that one day it will be all used up. But the issues with fossil fuels extend past its eventual finish, the burning of them leads to greenhouse gas emissions and in non-producing countries thereRead MorePolicy Brief On Sustainable Energy And Green Industry Puerto Rico1703 Words à |à 7 PagesPolicy brief on sustainable energy/green industry Puerto Rico Purpose section According to United Nations Industrial Development Organization (UNIDO) the term green industry is defined as an industry that ensures sustainable and viable future with no harm on our environment (UNIDO 2016). In Puerto Rico, manufacturing industry accounts for about 46.3 percent of Gross Domestic Product (GDP). This indicates that Puerto Rico is highly dependent on different manufacturing industries for its revenue. SimilarlyRead MoreChina Has Increased Its Installed Wind Energy Capacity878 Words à |à 4 Pagesits renewable energy profile. China has increased its installed wind energy capacity from 1.260 GW to 62.36 GW from 2005 to 2011. This can be compared with the United States that saw an increased wind energy capacity from 8.7 GW to 45.98 GW in the same time period. This is a 10.2\% increase annually versus 6.2\% in the United States. As shown in figure ef{AC_Sys_Voltages}, China installed 45.6\% of the total wind energy installed around the world in 2013. In addition to the Renewable Energy LawRead MoreSustainable Development And Energy Development : The G8 Summit Declaration Of 7 August 20071372 Words à |à 6 PagesThe ongoing demand and patterns of industrial energy production and consumption are highly unsustainable which may lead to face multiple challenges like global warming, greenhouse gas emissions, geopolitical conflicts, consecutive fuel price rises and at last fossil fuel reserves depletion. Worldwide all the developing countries are working to make a vibrant industrial sector where entrepreneurs will make investments and thus opportunities will be created for new jobs. To achieve sustainable development
Thursday, May 14, 2020
Colleges and Universities in Vancouver, Canada Pursuing Online and Campus-based Education in Vancouver, Canada 2019
With its mild winters, nearby mountains, and harbor views, Vancouver has consistently ranked as one of the top 3 livable cities in the world. Vancouver is the largest city on the Pacific coast of Canada. Colleges and universities serve a diverse local population. As businesses thrive, Vancouver college graduates find a large selection of employment opportunities. Considering all that the area has to offer, it is easy to see why Vancouver is such a rapidly growing city. Colleges and universities in Vancouver accommodate the varying needs of its students. Both new and returning Vancouver college students find degree programs that fit their education and lifestyle needs through schools, such as: University of Phoenix: Vancouver College Campus and Online Degree Programs. Kaplan University: Online Degree Programs. Capella University: Online Degree Programs. Everest College: Online and Campus Colleges Graduates of Vancouver Colleges and Universities Pursue Careers in Diverse Local Industries Vancouvers income has historically been generated from forestry, mining, fishing, and agriculture. However, a growing economy has led to more diverse industries in recent years. Vancouver college graduates are now securing positions in exciting industries, such as: Vancouver Film Production. Vancouver Biotechnology. Vancouver Software Development. Vancouver Tourism. .ud306844a5d02e4cf7a7901bd2110d45c { padding:0px; margin: 0; padding-top:1em!important; padding-bottom:1em!important; width:100%; display: block; font-weight:bold; background-color:#eaeaea; border:0!important; border-left:4px solid #34495E!important; box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); -moz-box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); -o-box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); -webkit-box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); text-decoration:none; } .ud306844a5d02e4cf7a7901bd2110d45c:active, .ud306844a5d02e4cf7a7901bd2110d45c:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; text-decoration:none; } .ud306844a5d02e4cf7a7901bd2110d45c { transition: background-color 250ms; webkit-transition: background-color 250ms; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; } .ud306844a5d02e4cf7a7901bd2110d45c .ctaText { font-weight:bold; color:inherit; text-decoration:none; font-size: 16px; } .ud306844a5d02e4cf7a7901bd2110d45c .post Title { color:#000000; text-decoration: underline!important; font-size: 16px; } .ud306844a5d02e4cf7a7901bd2110d45c:hover .postTitle { text-decoration: underline!important; } READ Minnesota Colleges and Universities Pursuing Online and Campus Based Education in MinnesotaVancouver Companies Look to Hire Graduates of Vancouver Universities and Colleges Although some businesses have moved to Alberta in recent years, several prominent companies maintain their corporate headquarters in Vancouver. Colleges and universities in Vancouver are training students to compete for the best positions in these Vancouver-based companies: Jim Pattison Group, the 3rd largest private company in Canada. TELUS, a Canadian communications provider. Electronic Arts Canada. Ballard Power Systems, headquartered in Vancouver. Sierra Wireless, based in Vancouver. Goldcorp, operated from Vancouver. Vancouver college graduates will have some of the best job opportunities in Vancouver over the coming years. Training programs are available in business, criminal justice, nursing, engineering, and more. To request more information about degree programs from any Vancouver school, prospective students may click on the above Vancouver college of choice. For an extensive list of degree programs in Vancouver, students are encouraged to visit College-Pages.com, the leading education and career resource website. Related ArticlesColleges and Universities in British Columbia Pursuing Campus Based and Online Education in British ColumbiaWest Virginia Colleges and Universities Pursuing Online and Campus Based EducationColleges and Universities in Alberta, Canada Pursuing Online and Campus-based Education in Alberta, CanadaMontana Colleges and Universities Pursuing Online and Campus Based Education in Montana, the Treasure StateNorth Dakota Colleges and Universities Pursuing Online and Campus Based Education in North DakotaYour Home Business and Accounting .u82f80fffe4fa1ce90d2b775118eedcd8 { padding:0px; margin: 0; padding-top:1em!important; padding-bottom:1em!important; width:100%; display: block; font-weight:bold; background-color:#eaeaea; border:0!important; border-left:4px solid #34495E!important; box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); -moz-box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); -o-box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); -webkit-box-shadow: 0 1px 2px rgba(0, 0, 0, 0.17); text-deco ration:none; } .u82f80fffe4fa1ce90d2b775118eedcd8:active, .u82f80fffe4fa1ce90d2b775118eedcd8:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; text-decoration:none; } .u82f80fffe4fa1ce90d2b775118eedcd8 { transition: background-color 250ms; webkit-transition: background-color 250ms; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; } .u82f80fffe4fa1ce90d2b775118eedcd8 .ctaText { font-weight:bold; color:inherit; text-decoration:none; font-size: 16px; } .u82f80fffe4fa1ce90d2b775118eedcd8 .postTitle { color:#000000; text-decoration: underline!important; font-size: 16px; } .u82f80fffe4fa1ce90d2b775118eedcd8:hover .postTitle { text-decoration: underline!important; } READ Getting an Associate's Degree in Paralegal Studies
Wednesday, May 6, 2020
Fast Food And Its Effect On Society - 2059 Words
Fast food has came to be very popular in today s society even with all of the negative affects that it carries with it. In 1970, there were about 30,000 fast-food restaurants in the United States; that number increased to 222,000 by 2001 (Therien,1). With the increase in fast food restaurants the number of people that are obese has also increased and fast food options provide a quick, effortless meal (Sharkly, Johnson, Dean, and Horel,1). Many people like convenience after a long day of work even if they know that fast food is highly processed and contains large amounts of carbohydrates, added sugar, unhealthy fats and salt (Carey,4). Fast food doesnââ¬â¢t just affect a personââ¬â¢s body weight, it also has the possibility to affect academic performance (Woodhouse,1). Fast food often contains too many calories and not enough nutrition (Pietrangelo,1). If fast food is consumed on a daily basis, obesity will come to be a factor in someoneââ¬â¢s health history. Many diff erent contributors have lead to the fast growth of the fast food industry. Will people learn how horrible fast food is for themselves? What has caused this fast food revolution to grow at such a speedy rate, and what could be done to amend some of the issues that have surfaced with it? The intriguing, cheap price of McDonaldââ¬â¢s and other fast food chains is very tempting. Therefore, it is important for everyone to be more aware of oneââ¬â¢s own choices and set a better example for others. Correspondingly, fast foodShow MoreRelatedFast Food And Its Effect On Our Society1761 Words à |à 8 PagesStop the Increasing Weight of the People? Fast food, the highly addictive food that many people can not go a day without eating. In our society today fast food has become the ââ¬Å"normâ⬠when we are looking for something to eat, causing our society to accept it as something to be eaten ALL the time. Fast food can affect our bodies more than most people comprehend. According to the United States Healthful Food Council, they say 8 out of 10 people eat fast food monthly and half say they even eat it weeklyRead MoreThe Fast Food Industry Has a Harmful Effect on Society1211 Words à |à 5 PagesThesis: The fast food industry has a harmful affect on society. Topic Sentence 1: Fast food causes Coronary Artery Disease. Topic Sentence 2: Fast food is popular among our nation. Topic Sentence 3: The environment is affected by the fast food industry. We provide food that customers love, day after day after day. People just want more of itâ⬠(Ray Kroc, Founder of McDonaldââ¬â¢s). Coronary Artery Disease is a type of heart disease and the most common cause of heart attacks. Plaque from eating unhealthyRead MoreAnalysis of David Zinczenkos Dont Blame the Eater: Fast Food and Its Effect on the Contemporary Society838 Words à |à 3 Pagesthe Eater fast food and its effect on the contemporary society David Zinczenkos article Dont Blame the Eater discuses with regard to a series of health-related topics involving food that most people and, particularly, young individuals eat today. The article is meant to raise public awareness concerning the risks associated with consuming particular foods. These respective risks are generally ignored because companies selling the products refrain from emphasizing the exact effects that consumingRead MoreEssay about Fast Food is Destroying America1477 Words à |à 6 Pagesprovide food that customers love, day after day after day. People just want more of itâ⬠(Ray Kroc, Founder of McDonaldââ¬â¢s). Coronary Artery Disease is a type of heart disease and the most common cause of heart attacks. Plaque from eating unhealthy foods, builds up in the arteries, the arteries harden and begin to become narrow and can cause chest pain and heart attacks. ââ¬Å"Obesity is a medical condition in which excess body fat has accumulated to the extent tha t it may have a negative effect on healthRead MoreFast Food Is An Integral Part Of Our Society Essay1455 Words à |à 6 Pages Fast food has become an integral part of our society by providing the option for a cheap and quick meal and on-the-go dining. In 1954, Ray Kroc, a seller of milkshake machines, took interest in the hamburger shop owned by the McDonaldââ¬â¢s brothers. From there, Kroc suggested that the brothers ââ¬Å"franchiseâ⬠their restaurants and after skepticism from the brothers, Kroc took on most of the responsibility for making the chain national venture. Today, McDonaldââ¬â¢s is a global phenomenon and a billion-dollarRead MoreFast Food Nation Essay862 Words à |à 4 PagesFast food is very popular amongst todayââ¬â¢s society. Fast Food Nation has reasons for the explosion in popularity of fast food restaurants in the mid-1900ââ¬â¢s. It also explains negative effects on American Culture in todayââ¬â¢s society. The fast-food industry has multip lied across America and changed the food industry. Eric Schlosser describes in Fast Food Nation the way people think about what they eat and what people think of the fast food industry, and also its impact on society. 2 ND There are manyRead MoreFood Nation : The Dark Side Of The All American Meal1299 Words à |à 6 PagesIMPLICATIONS OF PROCESSED FOODS TO HUMAN HEALTH Processed foods, refers to any deliberate alteration or modification of foodstuff before its availability for consumption. These alterations ranges from simple undertakings such as drying or freezing food for nutrients and freshness preservation to complex undertakings such as formulation of a frozen meal with the correct balance of ingredients and nutrients. Nowadays, processed foods have become a large part of the human food industry and this has beenRead MoreAre We Taking It Too Far by Blaming Fast Food Restaurant for Obesity?1285 Words à |à 6 PagesAre we taking it too far by blaming fast food restaurant for obesity? Although throughout the years many people have claimed that obesity is a genetic disorder for the most part; results of recent studies strongly indicate that lifestyles rather than genetics are what are causing an obese society, because people choose to not exercise, not watch their diet, and eat fast food. For the past few decades, food companies had aimed their marketing at single meals, pushing to inflate portion sizes. ThatRead MoreFast Food Nation By Eric Schlosser848 Words à |à 4 PagesLAST THREE DECADES, fast food has infiltrated every nook and cranny of American societyâ⬠, Schlosser writes. Fast Food Nation, written by Eric Schlosser, includes topics about fast food chains impact on the community, jobs relating to fast food, and health issues. Fast Food Nation uses logic to appeal to the aspects of fast food chains by giving relatable examples from the devastating effects on the communities to the millions of jobs offered for our country. Moreover, fast food chains have contributedRead MoreUnderstanding The Impact Of Junk Food Essay1510 Words à |à 7 Pages: Understanding the Impact of Junk Food INTRODUCTION Junk Food is that type of food which doesnââ¬â¢t contain nutritional value. It do not contain high level of calories and has little protein, vitamins and minerals. Such foods are also not good for health and has negative effects after consuming them. Why there is a More Demand of Junk Food? There are following reasons which shows that why people are attracted towards junk food:- â ¦ Preparation of junk food doesnââ¬â¢t take so much time and it is
Tuesday, May 5, 2020
International Commercial Law Convention Deals
Question: Discuss about the Case Study for International Commercial Law for Convention Deals. Answer: Introduction It is regardless to say that the very nature of future is uncertain. When there exists long term contracts between the parties, there may be situations where prices are suddenly increasing, inflating rising and thereby performance becoming onerous due to changing economic conditions around the globe. However, all such conditions are required to be foreseen by the parties. Contracts can be framed in such a manner by giving provision for the future uncertainties, like by fixing the price and defining performance. Thus, only except of unforeseen situations, the contract shall yield and guarantee performance. One of the paramount features in law of contract is most considerably, the sanctity of contract. The Latin phrase clearly says that the contract must be respected. Parties are mandated to adhere and abide by the terms of the contract agreed between them, as a matter of principle. Thus, this explains the reason as to why international sales remain unaffected by economic hardship as per the Vienna Convention on International Sales[1]. Under international law, it has become a rule for the arbitrators to consider the terms of contract agreed between the parties as supreme. The contract terms are mandated to be respected by the arbitrator as stated under the Arbitration treaty law[2], arbitration rules[3] and arbitration statutes[4]. Further, the sanctity of contract principle has also been confirmed by the arbitrators. This main objective of this paper is to critically evaluate the statement [] the principle of sanctity of contracts (pacta sunt servanda) as the leading maxim of contract law generally has priority over changes in the surrounding economic conditions.[5] For this purpose, the paper has been divided into various sections. The first section deals with the principle of sanctity of contract and seeks to analyze the principle in detail with respect to case laws. The second section deals with a principle, which stands contract to that of sanctity, which is flexibility of contract and also examines the grounds for defending the principle of flexibility. In further sections, the paper seeks to examine the interaction between changed circumstances and sanctity of contract and thus focuses on hardship clause, which is provided as a remedy for any change in circumstances. In the last sections, the main discussion shall be regarding the remedies, which the arbitrators or parties may avail in rega rds to changed circumstances. The principle of sanctity of contract pacta sunt servanda Pacta sunt servanda is a Latin phrase, which in English means that the pact or the agreement must be respected. It is a basic principle of civil and international law, which governs contractual relationship between parties. Article 26 of the Vienna Convention on the Law of Treaties also provides for the principle of pacta sunt servanda and states that every treaty in force is binding upon the parties to it and must be performed by them in good faith. In west, two significant principles, namely, pacta sunt servanda and the contract is the law of the parties protects the fundamental right relating to conclusion of contract between the parties. It is important for the parties to abide by the agreement in all the circumstances. These principles of contract law are not only applicable to contracts governing private persons but also governing state parties. These principles are recognized are eminent rules of private law, which govern the aspects of agreement between the parties and also as rules of law of treaties, which govern the aspects of arbitration among states.[6] Analysis of various commercial arbitration cases show that in addition to the legal issues raised before the arbitral tribunal, the objective of discussion between the parties is to establish the primacy of the principle of sanctity in commercial arbitration contracts over principle of flexibility as followed in the Western culture. The tribunal while giving Sapphire[7] award stated that the principle of sanctity is fundamental principle, which the international courts constantly proclaim by holding that it is pertinent to respect every contractual obligation undertaken by the party. Further, the rule of pacta sunt servanda governs the basis of each and every contractual relationship in the private international law. [8] Earlier award of Aramco[9] and of Sapphire were referred in the Topcos case[10] and it was states that international jurisdiction has never doubted on the existence and implementation of the rule of pacta sunt servanda in international law and thus this maximum must be viewed as a fundamental principle governing the international law. Further, the sole arbitrator in the case of Liamco[11], upheld this principle by stating that international law and practice have widely accepted that unilateral termination of contract is survived by the arbitration clause, which is inserted in the agreement by the parties and this clause continues even after the contract terminates. [12] The principle of sanctity of contract found its application to equal parties but jurists and scholars have extended the applicability of this principle of the contracts governing relations of states as well as private persons. The principle has been integrated and well extended to the international commercial arbitration contracts. Such contracts are now considered binding on the parties and none of the parties have the right to abrogate, modify or nullify the contract unilaterally.[13] The Flexibility Contract Principle It has been observed above that the principle of sanctity is well observed by the international law. However, scholars have countered the aspects of absolute sanctity while stressing on the requirement of brining flexibility in terms of legal implications and performance of international commercial contracts. They have generally pointed out on the very nature of such contracts, which influences the scope of national economic development and governmental functions. Most common arguments raised and their respective defenses and discussions in respect of flexibility of the contract principle of sanctity in international commercial arbitration have been analyzed in the sections below: The argument relating to public interests To defend the flexibility contract principle it has been argued that in reference to international commercial contracts relating to natural resources, these are closely associated with economic development and are underlying instruments of public policy. Thus, in such contracts of natural resources various countries cannot bind themselves in regards to economic welfare of the country since the relationship formed under the contract might derogate with time and affect welfare. Thus, for contracts relating to public interest or welfare, it is pertinent to ensure flexibility principle in application. The argument relating to denial of international status Another argument that defends the principle of flexibility, states that international contracts should not be governed by the public international law rather the law of the host state. Since, individuals were not considered subjects of international law; therefore it was valid to deny the status of international to commercial contracts. This argument was raised in the Anglo-Iranian Oil Company Case by The Permanent Court of International Justice.[14] However, the above argument was countered[15] by stating the view that if state contracts are modified or abrogated, then that shall refer to breach of the international law. It was further stated that the doctrine of flexibility has a fundamental error, which would have been removed if the lawyers of public international law would have give due regard and significance to the teachings, character and role of private international law. In cases where there is no scope for any problem to arise under the customary public international law, it is not possible for any breach of contract to factually occur and thus the principle of pacta sunt servanda goes un-infringed. The private international law of the respective forum governs the contracts. Such law not only has the power to sustain the contract but also modify or abrogate the contractual bond in its entirety. The argument relating to changed circumstances To defend the principle of flexibility, it has been argued that if pacta sunt servanda being the principle of public international law applies to international contract then there are other principles of international law, particular the principles of changed circumstances, which comprise of expectations to the former principle. Principle of changed circumstances as defined under Article 62 of the Vienna Convention on the Law of Treaties as clausal rebus sic stantibus states that in regards to the inter-state agreements, there is not absoluteness in the principle of sanctity of contract. [16] Various international jurists have the view that the principle of changed circumstances can be considered as an exception or reservation to the principle of pacta sunt servanda in international law. This view of jurists has now come to be accepted generally in the international law. Contractual Provisions on Changed Circumstances Parties may agree to implement a hardship clause in their agreement, when there are any chances that future situations may change. Some of the hardship clauses state that the on occurrence of certain specified situation or circumstance, the contract shall be terminated. However, there are other clauses also, namely the price revision clause or the indexation clause, which state that in change of circumstances even the terms of contract shall change. Further, clauses like that of adaptation clause provide that the parties are ordered to adapt to new circumstances as per the contract terms. Various authors have argued that hardship clause in a contract pertaining to long-term relations between the parties must be dealt like a custom. In other words, such a clause of hardship must be implied in long term contracts even when not expressly agreed to between the parties. However, if in contractual terms, parties specifically include a clause of hardship, it shall help in proving that no such general customary principle relating to hardship clause exists.[17] Further, the scope and implication of hardship clause varies in various types of such clauses. The application, scope and remedy of each of hardship clauses are different and thus a customary principle cannot be easily based on such varied and diverse hardship clause. Considering this situation, arbitrators have refused to consider hardship clause as customary in long term contracts rather they have focused on strict interpretation of such clauses as per the facts and circumstance of each case. This means that if there is a clause in the contract that mentions specific changes then such clause must be interpreted in a manner that no other change could be considered or taken into account while dealing with the contract. However, it cannot be said that mere presence of hardship clause shall exclude the entire application of general law relating to changed circumstances. This is so because it is almost impossible for the parties to negotiate and thereafter draft such hardship clause that is capable of covering all possible effects from which performance is likely to be affected. Thus, such changes which cannot be covered under the hardship clause may be applied by integrating the general law on changed circumstances. The arbitrators in the Arbitration Court of the Japan Shipping Exchange[18] stated as follows while recognizing this principle: The relation between this Article (renegotiation clause) and the principle of change in situation is such that the present article does not exclude the said principle, but provides for either one of the parties to request the other for consultation to amend the price, even in the instances where the principle of the change in situation does not need to be applied. Thus, in case of special circumstances, parties may instruct the tribunal to consider such circumstances that have changed post the dispute between the parties. The Iran-US Claims Tribunal [19]also stated that it is the very duty of the tribunal to consider and taking into account any change in circumstances between the contracting parties. Relationship between Pacta Sunt Servanda Rebus Sic Stantibus Most national legal systems have a rule that the binding force of the contract may get affected due to change circumstances. The maximum rebus sic stantibus: when things remain same even the contract remains binding, ensures possibility of such situations. Restricted interpretation of the maxim rebus sic stantibus shall be done to limit the huge scope of its analysis. Such expressed contractual terms are excluded that could not be satisfied, like changes relating to failure to perform as per the contractual conditions. Also, the act of God or Force Majeure, is excluded, since it makes the performance of contract completely impossible[20]. The main of this paper shall be to consider and analyze such changes, which make the performance erroneous rather than impossible. Various legal systems have incorporated the principle of rebus sic stantibus and it is also an important principle of international law. Even the judges of Iran-US Claim Tribunal recognized this principle under the Vienna Convention. Further, the judges stated that with wide implementation of this principle in the national legal systems, it shall not be unreasonable to regard it as a general principle of law.[21] International Law International treaty law defines the principle of Rebus sic stantibus. The Vienna Convention on the law of treaties, 1969 in its Article 62 defines and explains this principle of rebus sic stantibus. The Article 62 states as follows: A fundamental change of circumstances which has occurred with regard to those existing at the time of the conclusion of a treaty, and which was not foreseen by the parties, may not be invoked as a ground for terminating or withdrawing from the treaty unless: (a) the existence of those circumstances constituted an essential basis of the consent of the parties to be bound by the treaty; and (b) the effect of the change is radically to transform the extent of the obligations still to be performed under the treaty. The exception nature of this rebus sic stantibus has been demonstrated by the wording of Article 62. It ensures that this principle is considered subordinate to that of pacta sunt servanda and the same has been clearly stated under Article 26 of the Vienna Convention. It is pertinent for the change in circumstances to be fundamental in nature. The change must be such that the survival of State has been jeopardized entirely. Change cannot be in nature of mere currency reforms or loss in matters of economic interest. In the case of Fisheries Jurisdiction[22], the International Court stated that change must be vital in nature: it should be such that it imperils or prevents the vital development or existence of either of the parties. Further, the change should be such that none of the parties to the contract could reasonable foresee the same. However, it must be noted that even when the principle of rebus sic stantibus is indentified as a rule of international law by arbitrators and invoked by various parties, relief on such ground has not been granted to the parties. Tribunals and even the International Court of Justice have refused to consider the principle of rebus sic stantibus as a treaty.[23] National Law Performance when circumstances of contract change are excused under English Law, as per the doctrine of frustration of purpose. However, the party who demands excuse in performance under this doctrine must prove that the circumstances have changed radically due to which the performance undertaken as per the contract could not be fulfilled. But, the English judges have shown reluctance in implementing this doctrine to state that the contract has been frustrated.[24] Arbitration Practice In regards to international arbitration, implementation and impact of rebus sic stantibus has not been explored. Generally, arbitrators have been strict in implementing this principle to international contracts. Further, arbitrators have concluded that in any case where the mutual convent ants become impossible to perform, the contract shall be rendered impossible. This vitiates the very essence of contract. Thus, in only handful of cases, this doctrine has been actually implemented into the legal scenario relating to change in circumstances. Rather, arbitrators and tribunals have relied on renegotiation between parties in case of change in circumstances as an effective remedy to such problem. Such renegotiation may be included as a part of contract and state that parties may renegotiate in case of any change in circumstances.[25] Also, on successful renegotiations, rearrangement of contractual relationship may be done. However, it is equally important to identify the situation if such renegotiation fails. The clause dealing with renegotiation must be framed in such a manner that it provides solution to all possible situations. Conclusion The above analysis has critically discussed various aspects of the principle of sanctity of contracts. In international contracts, arbitration is the remedy to solve disputes between the parties. Thus, it is important to understand various complexities and rules of international law, which are considered by the arbitrators, tribunals and international courts. The principle of sanctity of contract or pacta sunt servanda states that the parties must serve the agreement or must fulfill the agreement, which leads to contractual relationship. In other words, it can be stated that the parties in no way can derogate from the agreement and ensure every action with the objective to fulfill contractual obligations agreed. It can be analyzed that this principle is a leading maxim under contract of law, which is also agreed by the arbitrators and used while dealing with international law. However, it is needless to say that parties under contract may face change in situations, due to which performance of contract gets affected. From the above discussion, it can be concluded that even when arbitrators have accepted the principle of rebus sic stantibus under international law, it has not been implemented into practical situations dealing with contracts. This principle is also considered as subordinate to pacta sunt servanda. Since, it imposes an obligation on the parties to perform. Further, as a remedy to changed circumstances, arbitrators have opted for the remedy of renegotiation between the parties. This remedy also seeks to fulfill the objective of pacta sunt servanda because it holds that in change of circumstances, parties may renegotiate to new agreement but must fulfill their obligations as per the agreement. Thus, it can be finally concluded that principle of sanctity of contract is the leading principle of contract law and is given priority even in change of circumstances or over the principle of flexibility of contract. References Article 79 of the Vienna Convention deals with force majeure, excludes economic hardship. European Convention on International Commercial Arbitration, 1961, Article VII. C.C. Arbitration Rules, Article 13.5; UNCITRAL Rules, Article 33.3. UNCITRAL Model Law, Article 28(4) already incorporated in many countries. Klaus Peter Berger, Renegotiation and Adaption of International Investment Contracts: The Role of Contract Drafters and Arbitrators, Vanderbilt Journal of Transnational Law, (2003) 36, 1347, 1353. Hamid Reza Nikbakht Fini, State Contract and Abitration, (1990, unpublished thesis, p. 26) Sapphire Intl Petroleums Ltd. v National Iranian Oil Co.,[1967]. George R. Delaume, State Contract and Transnational Arbitration, The American Journal of International Law. (1981) 75, 11. Arabia v Arabian American Oil Company (Aramco), 27 I.L.R. 117, 168 (1958). Texaco Overseas Petroleum Co. v Libya (Topco/Calasiatic Case), 53 I.L.R. 389 (1977). Libyan American Oil Company (LIAMCO) v Government of the Libyan Arab Republic, 17 I.L.M. 3 (1978). Doak Bishop, International arbitration of Petroleum Disputes: the development of a Lex Petrolea, Cepmlp Journal, (2000). Wehberg, Pacta sunt Servanda, American Journal of International Law, 1959, p.775; J. F. Lalive, Contracts Between a State or a State agency and a Foreign company, 13 International and Comparative Law Quarterly, 1964, p.987 Oxford Journal vol. 13 No. 3. Bing B. Tia, The regime of straits in international law, Oxford University Press, (1998). A. Mann, England Rejects Delocalised Contract and Arbitration, International and Comparative Law Quarterly, (1983) vol. 33. p. 194-195. Geiger, The Unilateral Changes of Economic Development Agreements, International and Comparative Law Quarterly, (1974), p. 100. C.C. award No. 5953 (1989), J.D.I., 1990, 1056 at 1059. Arbitration Court of the Japan Shipping Exchange, award September 20, 1975, Yb. Comm. Arb., 153 at 154. Questech decision 9 Iran-US C.T.R., 122-123. Court of Arbitration at the Polish Chamber of Foreign Trade, award February 11, 1958, Comm. Arb., 1981, 147 at 148. Questechdecision, 9Iran - US C.T.R., 122-123. International Court of Justice,Fisheries Jurisdiction case, ICJ Reports, 1973, 4 at 20. Yearbook ILC, 1963, II, 208;Yearbook ILC, 1966, II, 257; R. VAN MEHREN and P. KOURIDES, "International arbitrations between state and foreign private parties: the Libyan nationalisation cases",J.I.L., 1981, 475 at 532. Lauritzen A.S. v. Wijsmuller B.V., "The Super Servant Two",1 Lloyd's Rep., 1990, 1. C.C. award No. 4761 (1987),J.D.I., 1987, 1012. [1] Article 79 of the Vienna Convention deals with force majeure, excludes economic hardship. [2] European Convention on International Commercial Arbitration, 1961, Article VII. [3] Eg: I.C.C. Arbitration Rules, Article 13.5; UNCITRAL Rules, Article 33.3. [4] Eg. UNCITRAL Model Law, Article 28(4) already incorporated in many countries. [5] Klaus Peter Berger, Renegotiation and Adaption of International Investment Contracts: The Role of Contract Drafters and Arbitrators, Vanderbilt Journal of Transnational Law, (2003) 36, 1347, 1353. [6] Hamid Reza Nikbakht Fini, State Contract and Abitration, (1990, unpublished thesis, p. 26) [7] Sapphire Intl Petroleums Ltd. v National Iranian Oil Co.,[1967]. [8] George R. Delaume, State Contract and Transnational Arbitration, The American Journal of International Law. (1981) 75, 11. [9] Arabia v Arabian American Oil Company (Aramco), 27 I.L.R. 117, 168 (1958). [10] Texaco Overseas Petroleum Co. v Libya (Topco/Calasiatic Case), 53 I.L.R. 389 (1977). [11] Libyan American Oil Company (LIAMCO) v Government of the Libyan Arab Republic, 17 I.L.M. 3 (1978). [12] R. Doak Bishop, International arbitration of Petroleum Disputes: the development of a Lex Petrolea, Cepmlp Journal, (2000). [13] H. Wehberg, Pacta sunt Servanda, American Journal of International Law, 1959, p.775; J. F. Lalive, Contracts Between a State or a State agency and a Foreign company, 13 International and Comparative Law Quarterly, 1964, p.987 Oxford Journal vol. 13 No. 3. [14] Bing B. Tia, The regime of straits in international law, Oxford University Press, (1998). [15] F. A. Mann, England Rejects Delocalised Contract and Arbitration, International and Comparative Law Quarterly, (1983) vol. 33. p. 194-195. [16] R. Geiger, The Unilateral Changes of Economic Development Agreements, International and Comparative Law Quarterly, (1974), p. 100. [17] I.C.C. award No. 5953 (1989), J.D.I., 1990, 1056 at 1059. [18] Arbitration Court of the Japan Shipping Exchange, award September 20, 1975, Yb. Comm. Arb., 153 at 154. [19] Questech decision 9 Iran-US C.T.R., 122-123. [20] However arbitrators sometimes bring the former also under the heading of "changed circumstances - rebus sic stantibus".E.g.Court of Arbitration at the Polish Chamber of Foreign Trade, award February 11, 1958,Yb. Comm. Arb., 1981, 147 at 148. [21] Questechdecision, 9Iran - US C.T.R., 122-123. [22] International Court of Justice,Fisheries Jurisdiction case, ICJ Reports, 1973, 4 at 20. [23] Yearbook ILC, 1963, II, 208;Yearbook ILC, 1966, II, 257; R. VAN MEHREN and P. KOURIDES, "International arbitrations between state and foreign private parties: the Libyan nationalisation cases",A.J.I.L., 1981, 475 at 532. [24] J. Lauritzen A.S. v. Wijsmuller B.V., "The Super Servant Two",1 Lloyd's Rep., 1990, 1. [25] I.C.C. award No. 4761 (1987),J.D.I., 1987, 1012.
Subscribe to:
Posts (Atom)