Digital Fortress Chapter 47 Free Essays

â€Å"A billion-dollar code?† Midge snickered, accompanying Brinkerhoff back up the hallway. â€Å"That’s a good one.† â€Å"I swear it,† he said. We will write a custom essay sample on Digital Fortress Chapter 47 or any similar topic only for you Order Now She eyed him askance. â€Å"This better not be some ploy to get me out of this dress.† â€Å"Midge, I would never-† he said self-righteously. â€Å"I know, Chad. Don’t remind me.† Thirty seconds later, Midge was sitting in Brinkerhoff’s chair and studying the Crypto report. â€Å"See?† he said, leaning over her and pointing to the figure in question. â€Å"This MCD? A billion dollars!† Midge chuckled. â€Å"It does appear to be a touch on the high side, doesn’t it?† â€Å"Yeah.† He groaned. â€Å"Just a touch.† â€Å"Looks like a divide-by-zero.† â€Å"A who?† â€Å"A divide-by-zero,† she said, scanning the rest of the data. â€Å"The MCD’s calculated as a fraction-total expense divided by number of decryptions.† â€Å"Of course.† Brinkerhoff nodded blankly and tried not to peer down the front of her dress. â€Å"When the denominator’s zero,† Midge explained, â€Å"the quotient goes to infinity. Computers hate infinity, so they type all nines.† She pointed to a different column. â€Å"See this?† â€Å"Yeah.† Brinkerhoff refocused on the paper. â€Å"It’s today’s raw production data. Take a look at the number of decryptions.† Brinkerhoff dutifully followed her finger down the column. NUMBER OF DECRYPTIONS = 0 Midge tapped on the figure. â€Å"It’s just as I suspected. Divide-by-zero.† Brinkerhoff arched his eyebrows. â€Å"So everything’s okay?† She shrugged. â€Å"Just means we haven’t broken any codes today. TRANSLTR must be taking a break.† â€Å"A break?† Brinkerhoff looked doubtful. He’d been with the director long enough to know that â€Å"breaks† were not part of his preferred modus operandi-particularly with respect to TRANSLTR. Fontaine had paid $2 billion for the code-breaking behemoth, and he wanted his money’s worth. Every second TRANSLTR sat idle was money down the toilet. â€Å"Ah†¦ Midge?† Brinkerhoff said. â€Å"TRANSLTR doesn’t take any breaks. It runs day and night. You know that.† She shrugged. â€Å"Maybe Strathmore didn’t feel like hanging out last night to prepare the weekend run. He probably knew Fontaine was away and ducked out early to go fishing.† â€Å"Come on, Midge.† Brinkerhoff gave her disgusted look. â€Å"Give the guy a break.† It was no secret Midge Milken didn’t like Trevor Strathmore. Strathmore had attempted a cunning maneuver rewriting Skipjack, but he’d been caught. Despite Strathmore’s bold intentions, the NSA had paid dearly. The EFF had gained strength, Fontaine had lost credibility with Congress, and worst of all, the agency had lost a lot of its anonymity. There were suddenly housewives in Minnesota complaining to America Online and Prodigy that the NSA might be reading their E-mail-like the NSA gave a damn about a secret recipe for candied yams. Strathmore’s blunder had cost the NSA, and Midge felt responsible-not that she could have anticipated the commander’s stunt, but the bottom line was that an unauthorized action had taken place behind Director Fontaine’s back, a back Midge was paid to cover. Fontaine’s hands-off attitude made him susceptible; and it made Midge nervous. But the director had learned long ago to stand back and let smart people do their jobs; that’s exactly how he handled Trevor Strathmore. â€Å"Midge, you know damn well Strathmore’s not slacking,† Brinkerhoff argued. â€Å"He runs TRANSLTR like a fiend.† Midge nodded. Deep down, she knew that accusing Strathmore of shirking was absurd. The commander was as dedicated as they came-dedicated to a fault. He bore the evils of the world as his own personal cross. The NSA’s Skipjack plan had been Strathmore’s brainchild-a bold attempt to change the world. Unfortunately, like so many divine quests, this crusade ended in crucifixion. â€Å"Okay,† she admitted, â€Å"so I’m being a little harsh.† â€Å"A little?† Brinkerhoff eyes narrowed. â€Å"Strathmore’s got a backlog of files a mile long. He’s not about to let TRANSLTR sit idle for a whole weekend.† â€Å"Okay, okay.† Midge sighed. â€Å"My mistake.† She furrowed her brow and puzzled why TRANSLTR hadn’t broken any codes all day. â€Å"Let me double-check something,† she said, and began flipping through the report. She located what she was looking for and scanned the figures. After a moment she nodded. â€Å"You’re right, Chad. TRANSLTR’s been running full force. Raw consumables are even a little on the high side; we’re at over half a million kilowatt-hours since midnight last night.† â€Å"So where does that leave us?† Midge was puzzled. â€Å"I’m not sure. It’s odd.† â€Å"You want to rerun the data?† She gave him a disapproving stare. There were two things one never questioned about Midge Milken. One of them was her data. Brinkerhoff waited while Midge studied the figures. â€Å"Huh.† She finally grunted. â€Å"Yesterday’s stats look fine: 237 codes broken. MCD, $874. Average time per code, a little over six minutes. Raw consumables, average. Last code entering TRANSLTR-† She stopped. â€Å"What is it?† â€Å"That’s funny,† she said. â€Å"Last file on yesterday’s queue log ran at 11:37 p.m.† â€Å"So?† â€Å"So, TRANSLTR breaks codes every six minutes or so. The last file of the day usually runs closer to midnight. It sure doesn’t look like-† Midge suddenly stopped short and gasped. Brinkerhoff jumped. â€Å"What!† Midge was staring at the readout in disbelief. â€Å"This file? The one that entered TRANSLTR last night?† â€Å"Yeah?† â€Å"It hasn’t broken yet. It’s queue time was 23:37:08-but it lists no decrypt time.† Midge fumbled with the sheets. â€Å"Yesterday or today!† Brinkerhoff shrugged. â€Å"Maybe those guys are running a tough diagnostic.† Midge shook her head. â€Å"Eighteen hours tough?† She paused. â€Å"Not likely. Besides, the queue data says it’s an outside file. We should call Strathmore.† â€Å"At home?† Brinkerhoff swallowed. â€Å"On a Saturday night?† â€Å"No,† Midge said. â€Å"If I know Strathmore, he’s on top of this. I’ll bet good money he’s here. Just a hunch.† Midge’s hunches were the other thing one never questioned. â€Å"Come on,† she said, standing up. â€Å"Let’s see if I’m right.† Brinkerhoff followed Midge to her office, where she sat down and began to work Big Brother’s keypads like a virtuoso pipe organist. Brinkerhoff gazed up at the array of closed-caption video monitors on her wall, their screens all freeze frames of the NSA seal. â€Å"You’re gonna snoop Crypto?† he asked nervously. â€Å"Nope,† Midge replied. â€Å"Wish I could, but Crypto’s a sealed deal. It’s got no video. No sound. No nothing. Strathmore’s orders. All I’ve got is approach stats and basic TRANSLTR stuff. We’re lucky we’ve even got that. Strathmore wanted total isolation, but Fontaine insisted on the basics.† Brinkerhoff looked puzzled. â€Å"Crypto hasn’t got video?† â€Å"Why?† she asked, without turning from her monitor. â€Å"You and Carmen looking for a little more privacy?† Brinkerhoff grumbled something inaudible. Midge typed some more keys. â€Å"I’m pulling Strathmore’s elevator log.† She studied her monitor a moment and then rapped her knuckle on the desk. â€Å"He’s here,† she said matter-of-factly. â€Å"He’s in Crypto right now. Look at this. Talk about long hours-he went in yesterday morning bright and early, and his elevator hasn’t budged since. I’m showing no magno-card use for him on the main door. So he’s definitely in there.† Brinkerhoff breathed a slight sigh of relief. â€Å"So, if Strathmore’s in there, everything’s okay, right?† Midge thought a moment. â€Å"Maybe,† she finally decided. â€Å"Maybe?† â€Å"We should call him and double-check.† Brinkerhoff groaned. â€Å"Midge, he’s the deputy director. I’m sure he has everything under control. Let’s not second-guess-â€Å" â€Å"Oh, come on, Chad-don’t be such a child. We’re just doing our job. We’ve got a snag in the stats, and we’re following up. Besides,† she added, â€Å"I’d like to remind Strathmore that Big Brother’s watching. Make him think twice before planning any more of his hare-brained stunts to save the world.† Midge picked up the phone and began dialing. Brinkerhoff looked uneasy. â€Å"You really think you should bother him?† â€Å"I’m not bothering him,† Midge said, tossing him the receiver. â€Å"You are.† How to cite Digital Fortress Chapter 47, Essay examples

Electroplating Essay Example For Students

Electroplating Essay ELECTROPLATINGThe problem was to discover which electrolyte is the best. An electrolyte is a liquid you electroplate in. Water, vinegar, and vinegar with salt stirred in it were the three electrolytes used. Which is the best electrolyte for copperplating a nickel? Is there a difference between these electrolytes or are they all the same?Electroplating is the process of coating with metal by means of electric current. When electroplating is really used it is more complicated than the process used in this experiment. In a real plating tank the cathode, or metal to be plated, is negatively charged. The anode, or plating metal, is charged positively. Then some of the atoms on the anode come off with the electric current and on to the cathode. The cathodes old atoms are taken off with the electric current, leaving room for the anodes atoms (Ammen 38-39). Electroplating is used to keep an old metal looking new. It can also be used to make one metal look like another. Electroplating is used in a lot of cases. A very well known use is on cars. This keeps a car looking shiny and attractive. Copperplating is most commonly used to prevent metal from hardening. Silverplating is mainly used on tableware and electric contacts. Goldplating may be found on jewelry and watchcases. Zinc is often used to prevent corrosion of steel objects. A nickel or chromium plating may be found on cars or household appliances (?Electroplating?). Some coating procedures may have begun in early times. Modern electroplating did not start until the early 1800s. After the invention of the battery at this time period, large amounts of current electricity became available. It also could deposit lead, copper, and silver. With the discovery of cyanide solution, deposits of gold, silver, copper and brass could be directly deposited on steel or iron. This increased the commercial use of electroplating. The electroplating industry has grown and has developed many requirements in the electroplating process. Some commonly used metals today are iron, brass, silver, copper, cobalt, zinc, gold, lead, and chromium. Chromium is a very useful metal in this industry. Chromium is very bright and stays this way for a very long time. Automobiles are the main items electroplated with this metal. That is what keeps a car bright. Hard-chromium is used to improve wear resistance of machine parts (Barrow). My hypothesis was that vinegar and salt would work the best for copperplating a nickel since it is the densest electrolyte of the three. When this liquid is used more copper will come off the penny at a time. The process also goes the fastest in this solution. I thought that the water would go the slowest and would not work as well. This is because it is least dense of the three electrolytes. One 6-volt battery was needed to hook up to the coins. Three nickels and three pennies are needed as the cathode and anode. Vinegar, water, and vinegar with salt mixed in it were used as the three electrolytes. Two different colored wires were needed to hook the coins to the battery. The nickel, or cathode, was hooked up to the negative part of the battery. The penny, or anode, was hooked to the positive end. When they connected they were put in to the water filled jar. Then they were put in the vinegar and after that in the vinegar with salt in it (Gibson 177-179). All three electrolytes gave different results. In water, the nickel did not appear to be plated at all, but there were bubbles surrounding both of the metals. In vinegar, the process was not as quick as in the vinegar with salt, but it electroplated perfectly fine. In the vinegar mixed with salt, the results were great. It took only a couple of minutes for the nickel to be plated. The finished product was well coated. I also found out if you keep the coins in there for too long the penny becomes corroded and the nickel is totally plated. In conclusion, when an electrolyte is more dense it is better for electroplating. .u274c5d38482f89afae687d7454e4c3e4 , .u274c5d38482f89afae687d7454e4c3e4 .postImageUrl , .u274c5d38482f89afae687d7454e4c3e4 .centered-text-area { min-height: 80px; position: relative; } .u274c5d38482f89afae687d7454e4c3e4 , .u274c5d38482f89afae687d7454e4c3e4:hover , .u274c5d38482f89afae687d7454e4c3e4:visited , .u274c5d38482f89afae687d7454e4c3e4:active { border:0!important; } .u274c5d38482f89afae687d7454e4c3e4 .clearfix:after { content: ""; display: table; clear: both; } .u274c5d38482f89afae687d7454e4c3e4 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u274c5d38482f89afae687d7454e4c3e4:active , .u274c5d38482f89afae687d7454e4c3e4:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u274c5d38482f89afae687d7454e4c3e4 .centered-text-area { width: 100%; position: relative ; } .u274c5d38482f89afae687d7454e4c3e4 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u274c5d38482f89afae687d7454e4c3e4 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u274c5d38482f89afae687d7454e4c3e4 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u274c5d38482f89afae687d7454e4c3e4:hover .ctaButton { background-color: #34495E!important; } .u274c5d38482f89afae687d7454e4c3e4 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u274c5d38482f89afae687d7454e4c3e4 .u274c5d38482f89afae687d7454e4c3e4-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u274c5d38482f89afae687d7454e4c3e4:after { content: ""; display: block; clear: both; } READ: International Relations Of Asia EssayScience

The Book Theif Movie Review Essay Example

The Book Theif Movie Review Essay The Book Thief Movie Review BY Burglar,98 The Book Thief It all started with a train, some snow and my brother A man with an accordion heart and a woman cloaked In thunder, lathing their new daughters arrival on a street named after Heaven. From the beloved, best-selling novel by Markus Sack, comes the Oscar-winning film directed by Brian Percival, The Book Thief, starring Geoffrey Rush, Emily Watson and Sophie NÂ ©else. Set in 1938 (shortly after the rise of Adolph Hitler), a mysterious narrator (voiced by Robert Alum) tells the story of a young girl named Lease Melange (Sophie NÂ ©else) who steals The Gravediggers Handbook from a young grave digger, thus starting her love affair with books the beginning to an illustrious career; a career that will end with Lilies defying the society and sparking courage in the hearts of those around her. Meanwhile in the basement of her home a Jewish refugee (Max) is being sheltered by her adoptive parents. The mysterious narrator of the film who we later discover Is Death (or the Grim Repaper expresses the themes of Darkness and The Power of Words through the harassers such as Rudy Steiner, Max Vandenberg (portrayed by Ben Schnauzer) and Hans Hibernate (Geoffrey Rush) in the film, as well as the actions. Death is merely an invisible presence in the film, who finds himself captured in the beauty of Lilies Engineer. Death has a darkly witty and sardonic nature in The Book Thief, as well as his gentler, nourishing side, which we see when he tells of the sadness he feels as he collects the many souls who pass through his arms during the film. We will write a custom essay sample on The Book Theif Movie Review specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on The Book Theif Movie Review specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on The Book Theif Movie Review specifically for you FOR ONLY $16.38 $13.9/page Hire Writer All 3 characters who embody the themes of Darkness and The Power of Words also demonstrate the trudge of an individual against the prevailing ideology of his/her constricted society. We start with Rudy, Lisles first friend in the town of Mulching, Germany. With his blonde hair and blue eyes and his athletic and Intellectual genius, he makes for the perfect Nazi soldier. But because of his naivety and obliviousness to the real horrors of World War II, he truly does not see the harm in wanting to be the fastest man alive like his favorite Olympic relay champion, Jesse Owens (who happened to be an African American man). This proves to be the struggle for Rudy Steiner as he tries to discover his identity in the midst of the chaos and ongoing sadness In Mulching. He goes against his society by demonstrating his love for Jesse Owens, despite the fact that his father tries to explain to him how Wanting to be black Is bad news. Near the end of the movie, he is signed up for a training camp for young Nazi soldiers, and in an attempt to escape the training, runs away into the forest with Lilies for a while, expressing their hatred for Hitler before returning home. When Lilies finally confesses to Rudy that her family is hiding a Jewish person in their basement, Rudy remains faithful to her and stays silent. Story tells us, Mans father sacrificed himself to save Lisles adopted father Hans from the first World War, and therefore owed Mans father a favor; in this case, keeping Max in their basement as refuge from the Jewish concentration camps. The symbol of darkness that we see in the film reflects the most in Mans character; Max hides in the Hibernates house for several years to escape Nazi soldiers, but all the while still managing to stay alive in the darkness of the basement. The darkness of the story in this circumstance represents both fear and safety simultaneously. Max is also the second person (along with Hans Hibernate) who inspires Lilies to read and write in fact, he paints over every page in his copy of Mien Kampala (which initially saved his life) so that Lilies would have a book to write in. He inspires Lilies to speak with her eyes when she writes, and helps to create a unique new sense as she discovers the wonders of how powerful words can be. Last but not least, we introduce Hans Hibernate, the lovable foster father of Lilies with the accordion heart. He is the first person to show compassion towards Lilies upon her arrival in Mulching, by being kind-hearted and gentle, nicknaming her your majesty on her first day with him and his wife, Rosa. He discovers her copy of The Grave-Diggers handbook on her third night at the house, and he insists on bonding with her by proposing that they read the book together. After they finish the first book, she secretly steals another one from a large pile of burning books a symbol of he destruction of the books that ruined the minds of children in the Nazi party. After the two book-lovers finish the second book, Hans surprises Lilies with a gift: A blackboard dictionary, so she can write down all the words shes learnt. This is significant in the way that he almost creates an alternate reality for her to live in, which is somehow illegal because of the laws against specific books. Its also significant in the reflection that he creates the dictionary in the basement, where Max is set to be refugee later in the film. This creates a deeper meaning to both themes in he film, in the sense that it weaves the basement and its darkness further into the meaning of the story, as well as the power of the words that Lilies introduces to Max when he does take refuge downstairs. l have seen a great many things. Eve attended all the worlds worst disasters. And worked for the greatest of villains. And Eve seen the greatest of wonders. But its still like I said it was. No one lives forever. When I finally came for Lilies, I took self- pleasure in the knowledge that she had lived her 90 years so wisely. By then, her Tories had touched many souls; some of them I came to know in passing. Max, whose friendship lasted almost as long as Lilies Almost. In her final thoughts, she saw the long list of loves that merged with hers: Her three children, her grandchildren, her husband Among them, lit like lanterns, were Hans and Rosa, her brother, and the boy whose hair remained the color of lemons forever. I wanted to tell The Book Thief she was one of the few souls that made me wonder what it was to live. But in the end, there were no words. Only peace. The only truth I know is that I am haunted by humans

The Mexican-American War

The Mexican-American War From 1846 to 1848, the United States of America and Mexico went to war. There were several reasons why they did so, but the most important ones were the US annexation of Texas and the Americans desire for California and other Mexican territories. The Americans took the offensive, invading Mexico on three fronts: from the north through Texas, from the east through the port of Veracruz and into the west (present-day California and New Mexico). The Americans won every major battle of the war, mostly thanks to superior artillery and officers. In September  1847, American General Winfield Scott captured Mexico City: this was the final straw for the Mexicans, who finally sat down to negotiate. The war was disastrous for Mexico, as it was forced to sign away nearly half of its national territory, including California, New Mexico, Nevada, Utah, and parts of several other current US states. The Western War American President James K. Polk intended to invade and hold the territories he wanted, so he sent General Stephen Kearny west from Fort Leavenworth with 1,700 men to invade and hold New Mexico and California. Kearny captured Santa Fe and then divided his forces, sending a large contingent south under Alexander Doniphan. Doniphan would eventually take the city of Chihuahua. Meanwhile, the war had already begun in California. Captain John C. Frà ©mont had been in the region with 60 men: they organized American settlers in California to revolt against the Mexican authorities there. He had the support of some US navy vessels in the area. The struggle between these men and the Mexicans went back and forth for a few months until Kearny arrived with what was left of his army. Although he was down to fewer than 200 men, Kearny made the difference: by January of 1847 the Mexican northwest was in American hands. General Taylors Invasion American General Zachary Taylor was already in Texas with his army waiting for hostilities to break out. There was already a large Mexican army on the border as well: Taylor routed it twice in early May of 1846 at the Battle of Palo Alto and the Battle of Resaca de la Palma. During both battles, superior American artillery units proved the difference. The losses forced the Mexicans to retreat to Monterrey: Taylor followed and took the city in September of 1846. Taylor moved to the south and was engaged by a massive Mexican army under the command of General Santa Anna at the Battle of Buena Vista on February 23, 1847: Taylor once again prevailed. The Americans hoped that they had proved their point: Taylors invasion had gone well and California was already securely under control. They sent envoys to Mexico in the hopes of ending the war and gaining the land they desired: Mexico would have none of it. Polk and his advisors decided to send yet another army into Mexico and General Winfield Scott was selected to lead it. General Scotts Invasion The best route to get to Mexico City was to go through the Atlantic port of Veracruz. In March of 1847, Scott began landing his troops near Veracruz. After a short siege, the city surrendered. Scott marched inland, defeating Santa Anna at the Battle of Cerro Gordo on April 17-18 along the way. By August Scott was at the gates of Mexico City itself. He defeated the Mexicans at the Battles of Contreras and Churubusco on August 20, gaining a toehold into the city. The two sides agreed to a brief armistice, during which time Scott hoped the Mexicans would finally negotiate, but Mexico still refused to sign away its territories to the north. In September of 1847, Scott attacked once again, crushing the Mexican fortification at Molino del Rey before assaulting the Chapultepec Fortress, which was also the Mexican Military Academy. Chapultepec guarded the entrance to the city: once it fell the Americans were able to take and hold Mexico City. General Santa Anna, seeing that the city had fallen, retreated with what troops he had left to unsuccessfully try and cut the American supply lines near Puebla. The major combat phase of the war had ended. The Treaty of Guadalupe Hidalgo The Mexican politicians and diplomats were finally forced to negotiate in earnest. For the next few months, they met with American diplomat Nicholas Trist, who had been ordered by Polk to secure all of the Mexican northwest in any peace settlement. In February of 1848, the two sides agreed on the Treaty of Guadalupe Hidalgo. Mexico was forced to sign over all of California, Utah, and Nevada as well as parts of New Mexico, Arizona, Wyoming and Colorado in exchange for $15 million dollars and exoneration of about $3 million more in previous liability. The Rio Grande was established as the border of Texas. People living in these territories, including several tribes of Native Americans, reserved their properties and rights and were to be given US citizenship after a year. Lastly, future disagreements between the US and Mexico would be settled by mediation, not warfare. Legacy of the Mexican-American War Although it is often overlooked in comparison with the American Civil War, which broke out about 12 years later, the Mexican-American War was just as important to American History. The massive territories gained during the war make up a large percentage of present-day United States. As an added bonus, gold was discovered shortly thereafter in California which made the newly acquired lands even more valuable. The Mexican-American War was in many ways a precursor to the Civil War. Most of the important Civil War Generals fought in the Mexican-American War, including Robert E. Lee, Ulysses S. Grant, William Tecumseh Sherman, George Meade, George McClellan, Stonewall Jackson and many others. The tension between the slave states of the southern USA and the free states of the north was made worse by the addition of so much new territory: this hastened the onset of the Civil War. The Mexican-American War made the reputations of future US Presidents. Ulysses S. Grant, Zachary Taylor, and Franklin Pierce all fought in the war, and James Buchanan was Polks Secretary of State during the war. A Congressman named Abraham Lincoln made a name for himself in Washington by vocally opposing the war. Jefferson Davis, who would become President of the Confederate States of America, also distinguished himself during the war. If the war was a bonanza for the United States of America, it was a disaster for Mexico. If Texas is included, Mexico lost more than half of its national territory to the USA between 1836 and 1848. After the bloody war, Mexico was in ruins physically, economically, politically and socially. Many peasant groups took advantage of the chaos of war to lead uprisings all over the country: the worst was in Yucatan, where hundreds of thousands of people were killed. Although Americans have forgotten about the war, for the most part, many Mexicans are still irate about the theft of so much land and the humiliation of the Treaty of Guadalupe Hidalgo. Even though there is no realistic chance of Mexico ever reclaiming those lands, many Mexicans feel they still belong to them. Because of the war, there was much bad blood between the USA and Mexico for decades: relations did not begin to improve until World War Two, when Mexico decided to join the Allies and make common cause with the USA. Sources: Eisenhower, John S.D. So Far from God: the U.S. War with Mexico, 1846-1848. Norman: the University of Oklahoma Press, 1989 Henderson, Timothy J. A Glorious Defeat: Mexico and its War with the United States.New York: Hill and Wang, 2007. Wheelan, Joseph. Invading Mexico: Americas Continental Dream and the Mexican War, 1846-1848. New York: Carroll and Graf, 2007.

Essay Example | Topics and Well Written Essays - 1000 words - 48

Essay Example The risks and benefits, the rights and wrongs, or the pros and cons of genetically modified food and science are global concerns in both public and private arenas (Adolphs, Hamilton and Nerlich, 58). In today’s technological world however, GM crops and products play an important role in driving modernization and as such they are here to stay; as long as focus is not placed on future technological advancement instead of today’s risks and disadvantages, and if research, assessment, controls and policies are adequately and stringently evidenced then the benefits, will eventually negate the risks. Martin Teitel, in his article entitled ‘Unsafe at any Seed?’ argues against GM food claiming the argument that GM foods are better for the environment, farmers and consumers â€Å"should be taken with a grain of salt† (1). He further purports that this new technology has grown too quickly with insufficient testing, has entered supermarket shelves too soon, and necessitates further research and an objective commission to verify and validate the safety of such foods prior to entering the market. This paper will argue in agreement of Teitel’s paper in some respects but will not concur with others. Although Teitel has put forward some pertinent points that are significant if biotechnology is to continue and develop, his argument falls short in that he fails to consider the debate from two perspectives – that of the opponent and that of the advocate of GM foods – and has remained steadfast on the side of opponents at the risk of sounding dogmatic and ill informed. The situation is not as black and white as Teitel paints it; within the developed world scientists are at odds in their convictions on measurement of risk, both for health and the environment. Many are convinced that assessments are not necessary or are too harsh, while

Separation of Powers between the Three Branches of Government Essay

Separation of Powers between the Three Branches of Government - Essay Example It was, however, Charles Louis de Montesquieu who clearly defined the three branches of government and laid down the basics of the concept of separation of powers. Some countries being underpinned by the concept of separation of powers, like the United States, have written constitutions that clearly laid out and allocated the various powers and functions of the government to the different branches (Barnett pp. 105-106). This is not so in the United Kingdom. The UK Constitution does not consist of a single, written document but rather of various uncodified laws scattered in several documents like statutes, court decisions and treaties and unwritten ones like customs and conventions. A strict separation of powers normally divides separate powers and functions and allows them to the three branches government: the executive; Parliament, and; the judiciary. In the UK, the components of the three branches of governments usually share powers held by other branches in a mixed government fash ion. Eric Barendt, however, author of the book Separation of Powers does not believe that the UK necessarily has a weaker constitution because of this disparity. He believes that â€Å"the separation of powers should not be explained in terms of a strict distribution of functions between the three branches of government, but in terms of a network of rules and principles which ensure that power is not concentrated in the hands of one branch.† The UK government, like other democratic governments, has three major institutions, all exercising various functions and powers and sometimes sharing the powers of the other branches: the executive, the legislative and the judiciary. The executive department is made up the Crown and the central government, the latter of which is composed of the Prime Minister and his/her Cabinet Ministers. The central government is accountable to Parliament, which can choose to dissolve it and force a new election of a new set of officials if it believes that circumstances warrant it.  

Chirnside v Fay

Chirnside v Fay I Introduction On 6 September 2006 the Supreme Court released its important and controversial judgment in Chirnside v Fay . Elias CJ and Tipping and Blanchard JJ took very different approaches to the issue of whether or not to grant an equitable allowance to the defendant. This essays primary aim is to provide a detailed description of their Honours differing opinions as to that issue and also outline the authors own opinion as to what approach should be adopted. This essay starts with a brief description of the fact situation and the general law behind equitable allowances. It then describes the differing approaches taken in Chirnside . Next, the author makes a principled argument that the broad approach should be preferred when considering whether or not to grant an allowance. II Analysis of Chirnside v Fay A Fact Situation The plaintiff, Mr Fay (MF), and the defendant, Mr Chirnside (MC), were both property developers. They had known each other since the early 1980s and in 1997 decided to enter into a project together in respect of an old building. They had Harvey Norman (HN) in mind as the potential anchor tenant. Although MF made the initial contact with HN MC became almost solely responsible for dealing with them and entered into a conditional contract in his name only. HN made the final commitment to the project on 7 July 2000. By that time MC had gone cold on MF, largely due to his limited involvement. Instead of telling MF this MC intended to complete all the transactions through Rattray Ltd while convincing MF that he himself was no longer involved. MF argued that there had been a partnership and that he was entitled to proceeds, which was denied by MC. The project was ultimately completed. MF sued. By the time this case got to the Supreme Court the only viable cause of action that MF had was breach of fiduciary duty. The Supreme Court was unanimous in finding that MC had breached his fiduciary obligations. B Equitable Allowance There is a presumptive requirement that once a breach of fiduciary duty has been established the errant fiduciary must disgorge all profits made by dint of the breach. That is commonly referred to as the no-profit rule. There are two main exceptions to that rule. The first is where there has been some antecedent agreement for profit sharing. The second is where the court decides to exercise its discretion to grant the errant fiduciary an allowance for their skill, labour or expertise in making the profits. The onus is on the defendant to satisfy the court that an allowance should be made. In Chirnside there was an antecedent profit-sharing arrangement between the parties. Because of that agreement MC was entitled to a deduction of 50 per cent to the amount he had to account to MF. In addition to that, MC argued that he was entitled to an allowance due to the effort he exerted in gaining the profit from the joint venture. There were two different approaches taken to this issue both in regards to the actual law itself and the application of it. 1 Elias CJ Elias CJ took a strict approach to the issue of when an allowance should be granted. Her Honours main point was that allowances should remain exceptional, as Lord Templeman and Lord Goff in Guinness Plc v Saunders suggested they should be. She expressed the view that an allowance should generally only be permitted if the fiduciarys breach was wholly innocent and the beneficiary was-wholly undeserving, as in Boardman v Phipps . She accepted, however, that there had been cases where allowances had been granted despite the fiduciary not being blameless. She was of the opinion that the allowances were granted in such cases due to the fiduciary creating extraordinary profits outside the scope of what was envisaged in the fiduciary relationship while not having committed any significant wrongdoing. To evidence this point she analysed the cases of OSullivan v Management Agency , Estate Realties v Wignall , Badfinger Music v Evans , and Say-Dee v Farah Constructions . She suggested that in t hose cases the fiduciary had created substantial and unexpected profits and in most of them the wrongdoing was mere non-disclosure, which supported her proposition. Thus, she was of the view that an allowance could only be granted here if MC could show that he was wholly innocent and MF was-wholly undeserving or that he created extraordinary profits, essentially outside the scope of the fiduciary undertaking, while not having committed any significant wrongdoing. She then applied that reasoning to the facts. She held that MC had committed significant wrongdoing because by actively concealing his breach of duty at a vital time he had directly undermined the obligation of loyalty which is the cornerstone fiduciary obligation. Moreover, she was of the opinion that the work which MC had done was expected of him and thus was within the scope of the joint venture giving rise to the fiduciary obligations. Based on those two findings she denied MC an allowance. She did, however, make two additional points. Firstly, she saw no significance in the fact that MCs work had been undertaken before he had committed the breach because he was required to account for all profits made through the opportunities he obtained as a fiduciary which covered the whole joint venture. Secondly, the fact that MC was entitled to a 50 per cent deduction by dint of the antecedent agreement was important to her because she felt that if an allowance were to be granted he would essentially be receiving the full benefit he might have expected had he been wholly loyal which would significantly undermine the obligation of loyalty. 2 Tipping and Blanchard JJ Tipping and Blanchard JJ took a broad approach to the issue of when an allowance should be granted. They expressed the view that what a court should consider is whether, on the overall balance of the equities between the parties, it is fair and just to grant an allowance. In considering that, all the relevant circumstances must be taken into account. The essence of this exercise was to come to a fair conclusion as to what the fiduciary had to account. Thus, unlike Elias CJ they were of the opinion that the significance of the defendants breach and the personal input that they put into creating the profits were only factors to be taken into account rather than criteria that had to be satisfied. However, they did emphasise the need for restraint when calculating the amount of an allowance. That is, they expressed the view that the amount of allowances should generally not be liberal in order to deter others from committing breaches of fiduciary duty. Their main authority for this appro ach was OSullivan , Warman International , Estate Realities , and Murad v Al-Saraj . They analysed Saunders , which was a crucial case for Elias CJ, and distinguished it based on the finding that the obligations in that case were expressly accepted whereas in this case the obligations were imposed. They stated that it would be unfair and conflict with the pillars of equity to apply such a strict approach as was done in Saunders in a case such as this. They then applied that reasoning to the facts. There were four key factors which led to them ruling that it was fair and just to grant MC an allowance. Firstly, they held that MCs breach was not significant because it was not fraudulent or dishonest and MC genuinely believed he was entitled to act as he did. Secondly, they held that most of MCs work was done prior to his breach of duty and as such the breach did not facilitate in any way the making of the relevant profit. This was relevant to them because due to that ruling there could be no suggestion in their minds that by granting an allowance the fiduciary relationship would be undermined by encouraging fiduciaries to act in breach of duty. Thirdly, they held that MC had contributed far more effort in bringing the joint venture to profit than MF. In particular, MC had incurred all legal and financial liability and engaged in most of the negotiations with HN on his own. Fourthly, had the project been completed with MF then it was clear that he would have agreed to recognise MCs disproportionate contribution in a reasonable way which would have probably included an element of disproportionate profit sharing. Having found that an allowance was suitable they then exercised restraint in calculating the amount of the allowance, which they ultimately considered to-be $100,000. 3 Conclusion Thus, the key distinction between these two approaches is that while Elias CJ believed it was necessary to keep allowances exceptional by adopting a strict approach based on general elements Tipping and Blanchard JJ considered the issue by asking a much broader question based on notions of fairness. III Authors Opinion as to the Appropriate Approach to Allowances Every court of equity has the broad aim of doing justice between the parties. Indeed, equity was originally developed in order to address the injustices that resulted from the strict application of common law rules and since then it has been consistently stated that equitable remedies must be fashioned to fit the nature of the case and its particular facts. It would be more consistent with these broad goals for the decision of whether to grant an allowance to not be based on general rules but rather on an overall assessment of the particular facts and the merits and claims of the defendant. That is because a court is much more able to come to a decision that is fair between the parties if it is able to take account of all the circumstances of the case and not be limited to discussing a couple of general issues as courts that adopt the strict approach are. While the major issues in deciding whether to grant an allowance will often be the moral blameworthiness of the defendant and the personal input that they put into creating the profits, which are the two issues addressed under the strict approach, there are other important issues that can only be properly taken into account under a broad approach. For example, the circumstances in which the breach occurred , the circumstances in which the gains or profits were derived , the beneficiarys reliance on the fiduciarys involvement in the arrangement , and the extent to which the defendant has already been compensated through professional fees . The case of Chirnside illustrates this point that in taking a broad approach the court is more likely to come to a decision that is fair and just. In Chirnside it was clear that although the plaintiff had breached his fiduciary obligations it would be unfair if he was not granted an allowance. That was because the defendant had almost singlehandedly brought the joint venture to profit and the plaintiff was originally going to compensate him for his significant efforts. Elias CJ took a strict approach to the case and due to its rigid nature she was unable to do justice between the parties. However, in taking a broad approach the main judgment was able to take account of all the circumstances and reach a fair and just decision. Thus, courts should use the broad approach because they will be more able to reach fair and just decisions and be more in line with foundational aspects of equity. Furthermore, a broad approach is more consistent with the important equitable maxim of he who seeks equity must do equity. That is, under a broad approach the court will always be able to recognise whether the profits to which the beneficiary is entitled are in the nature of a windfall and as such rule that the beneficiary should provide some recompense for the work that has produced it because equity is not in the business of unjustly enriching plaintiffs. Furthermore, the broad approach is a lot more flexible than the stricter approach and as Tipping J stated in Chirnside it is undesirable to adopt rigid equitable approaches unless the justification for such an approach is compelling. The reason for that is that one of the foundational aspects of equity was its remedial flexibility in that it was first developed to address the rigour and rigidity of the common law. The way in which one typically makes such an argument is to suggest that the rigidity of the stricter approach tends towards much greater certainty, which is particularly desirable due to the significant vulnerability and broad liability involved in the application of the approach, and as such it is necessary in the overall interests of justice to adopt a rigid approach. In this case, while adopting the stricter approach would create more certainty it is not particularly important to do so here because the burden of proof is on defendants who will have breached some of thei r obligations and allowances are usually modest. Accordingly, there is no compelling reason in this regard to adopt a stricter approach. An argument that is frequently postulated in favour of a stricter approach is that such an approach will be more effective in deterring fiduciaries from acting in breach of their duties. It seems farfetched to suggest that a defaulting fiduciary will not engage in certain behaviour for fear that it will be unremunerated. Indeed, many cases show that a fiduciary will engage in conduct in breach of duty regardless of the potential sanction. Moreover, if equitys true goal was deterrence then a defaulting trustee would not be allowed to retain a proportion of the profit made from acquiring an asset with mixed funds. Also, courts that adopt the broad approach still pay regard to this concern by exercising restraint when they calculate the allowance. Thus, it seems unsound to not adopt a broad approach based on notions of deterrence. It is sometimes argued that allowances should never be granted because the making of an allowance means that there is no sanction for the defendants conduct. This argument is ill-conceived. The purpose of an allowance is to properly fix compensation or damages on the basis of disgorgement of profits properly analysed, not to apply a sanction or punishment for the breach of duty. Conclusion In conclusion, it is clear that the approaches taken by Elias CJ and Tipping and Blanchard JJ are very distinct and will reasonably frequently lead to differing results, as in Chirnside itself. It is this authors opinion that the broad approach used by Tipping and Blanchard JJ is the more appropriate approach because it is more in line with foundational aspects of equity and the arguments in favour of the strict approach are not compelling enough to go against that. Given the main judgment in Chirnside , and Estate Realities , it is likely that the broad approach will be used in New Zealand for the foreseeable future.