Media & Invasion of Privacy

LAGOS STATE UNIVERSITY SCHOOL OF COMMUNICATION A TERM PAPER SUBMITTED IN PARTIAL FULFILLMENT OF THE COURSE: ETHICS AND PROFESSIONAL PRACTISE (MAC 854) LECTURER: DR. JIMI KAYODE TITLE: MEDIA AND THE INVASION OF PRIVACY BY AKANDE ADEFEYISAYO ADEBOLARINWA †¢ SUBMITTED ON 30th JANUARY, 2010 INTRODUCTION Media practitioners possess the function of gathering, processing and disseminating news item to a heterogeneous large audience which often times not done with sound moral judgement in mind lands them into pool of troubled waters. Celebrities, politicians and other sought-after sources of news have over time expressed justifiable anguish over the diminishing aspects of their lives that are no longer free from prying eyes and publication from the press. They routinely assert that members of the media violates their privacy based strictly on their need to publish any news story that comes their way for the main purpose of profit and simply can not distinguish what type of information is private, public or newsworthy. Journalists, however, often possess diverse concepts of privacy and newsworthiness, and know that the issue is more complicated based on the fact that reporting news stories in a way that serves and informs the public will often require publicizing details or displaying images that will mortify or anger someone. To make privacy issues even more complicated for journalists, courts constantly redefine what is private based upon interpretations of the elusive legal standard of a â€Å"reasonable expectation of privacy. ( www. winning-newsmedia. com/privacy) â€Å"The U. S. Supreme Courts scolding of the media in the 1999 â€Å"ride along† cases for a perceived inattention to the privacy rights of the people featured in the news most likely reflects the current attitude of many judges and lawmakers and, thus, underscores the importance for journalists to be aware of general privacy principles. † (www. associatedcontent. com/topic) The intrusion and publication of private images can expose journalists to overwhelming financial liability if a court determines that a news organization has invaded a person’s privacy. The invasion of another’s privacy is a tort, meaning a civil wrong against another that results in injury. A privacy tort occurs when a person or entity breaches the duty to leave another person alone. When reporters intrude on a person’s privacy and cause emotional or monetary injury, they may be forced to pay damages. To avoid lawsuits, journalists must know how the law operates while seeking to balance the competing interests of the press and the public against the privacy interests of the subjects of the reports. Journalists often run contrary of this tort through the process of gathering information. Actions that may violate this privacy right include intrusion onto private property, concealed observation and the deceptive access into private areas. Conduct that invades privacy may also violate the criminal law. In general, courts have held that journalists must obey all relevant laws. In Cox Broadcasting Corp. v. Cohn, 420 U. S. 469 (1975) â€Å"the U. S. Supreme Court noted that in privacy tort, claims of privacy most directly confront the constitutional freedoms of speech and press†. www. definitions. uslegal. com) This study provides a universal explanation of each privacy tort and related causes of action. The privacy facts tort presents the unsettling circumstances in which journalists may be liable for monetary damages for coverage of news item. In several cases the Supreme Court has held that â€Å"where a newspaper publishes truthful information which it has lawfully obtaine d, punishment may lawfully be imposed, if at all, only when narrowly tailored to a state interest of the highest order. Florida Star v. B. J. F. , 491 U. S. 524, 541 (1989). Although the Supreme Court has prevented states from punishing journalists who published legally obtained names of juvenile offenders and rape victims, the Court has not absolutely rejected the private facts tort in this context. Although crimes such as rape are newsworthy and newsworthiness is a defence to a private facts suit, not all courts have agreed that the identity of a rape victim is newsworthy. Apart from news story either in the broadcast or in the print medium, photography has also been observed as posing some inimitable problems in privacy law, broadly, the legal analysis for invasion of privacy through images parallels the analysis for invasions through words. Essentially, the scope of this study is simply to analysis the fundamental nature of privacy laws, the various types that a mass media practitioner can run afoul of in the course of his or her duty and its implication for the society as a whole. Emergence of Privacy Laws: Concerns about intrusive newspaper reporting were mainly the beginning of the law of privacy. At that time, metropolitan daily newspapers used a variety of sensational information to attract potential readers. Media practitioners often played out the lives of the affluent and famous on the pages of their newspaper, permitting their readers to vicariously enjoy the wealth and the status of the celebrity. It was the kind of journalism now commonly referred to as â€Å"yellow journalism† that drove two Boston lawyers, Samuel D. Warren and Louis Brandeis to use the pages of the Harvard Law Review to recommend an officially documented right to privacy titled â€Å"The Right to Privacy† in 1890. Thus, their enterprise can be justifiably referred to as the source from which the law of privacy sprouted from. In their words as cited in Pember & Calvert, 2006: To satisfy a prurient taste the details of sexual relations are spread broad-cast in the columns of the daily papers. To occupy the indolent, column upon column is filled with idle gossip, which can only be procured by intrusion upon the domestic circle†¦Ã¢â‚¬ ¦.. The common law has always recognised a man’s house as his castle, impregnable, often, even to its own officers engaged in the execution of its commands. Shall the courts close the front entrance to constituted authority, and open wide the back door to idle or prurient curiosity? Warren and Brandeis strongly proposed that people should be able to go to courts to stop such unwarranted intrusions and also to secure monetary damages for the hardship or emotional distress they suffered from prying and from publication of private materials about them. The question of when the coverage and reporting of news became an invasion of privacy is a difficult one, especially for photographers and videographers. Consequently, the combination of a lack of clear definitions of privacy standards and an acceptance of degree of privacy puts media practitioners in a precarious position. In Sanders v. American Broadcasting Cos. , Inc. , 978 P. 2d 67 Cal. 1999, â€Å"the California Supreme Court held in 1999 that even an employee who holds a conversation in an open office space and overheard by co-workers can pursue an invasion of privacy claim if that conversation is recorded by a reporter’s hidden camera. The court rejected the notion of privacy as an â€Å"all-or-nothing† concept and described an â€Å"expectation of limited privacy† as follows: †¢ A subjective expectation of privacy is an opinion of a person that a certain place or situation is private. †¢ An objective, legitimate or reasonable expectation of privacy is an expectation of privacy recognized by society Under different circumstances, however, courts have established that news media are justified in doing what their subjects may feel is invasive. ( wikipedia: 2002) Definitions: According to the United Nations’ Universal Declaration of Human Rights Resolution 219A (III), Article 12 of 10 December 1948 as cited in Malemi (2002: 163): No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks. Privacy refers primarily to a person’s right to be left alone by the media, not necessarily a physical intrusion into one's private property or personal space. Invasion of privacy charges are usually presented in a civil lawsuit against media outlets that have crossed a perceived line into a celebrity or other public figure's private life, or have used his or her likeness or name in an unauthorized public manner Privacy law is the area of law concerned with the protection and preservation of the privacy rights of individuals. Increasingly, governments and other publics as well as private organizations collect vast amounts of personal information about individuals for a variety of purposes. The law of privacy regulates the type of information which may be collected and how the information may be used. The Right to Privacy: According to the 1999 Constitution of the Federal Republic of Nigeria, chapter IV, Section 37 on the right to private and family life says: â€Å"Citizens have right to privacy of themselves, their homes, correspondence, telephone and telegraphic communications. † A violation of this rights amounts to invasion of privacy. Remedies can then be pursued in the courts when anyone goes contrary to the above provisions. The right of privacy is a common-law cause of action that is a recent legal development. The U. S. Constitution contains no direct references to the right of privacy, although the Fourth Amendment states: â€Å"The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated†¦ † The right of privacy competes with the freedom of the press as well as the interest of the public in the free dissemination of news and information, and these permanent public interests must be considered when placing the necessary limitations upon the right of privacy. The First Amendment states: â€Å"Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech or of the press†¦ † â€Å"[pic][pic]Invasion of privacy, then is the intrusion into the personal life of another, without just cause, which can give the person whose privacy has been invaded a right to bring a lawsuit for damages against the person or entity that intruded. It encompasses workplace monitoring, Internet privacy, data collection, and other means of disseminating private information†. Photographers’ guide to Privacy, 2003). The wrongful intrusion into a person's private activities by other individuals, the media or by the government has generally been defined as invasion of privacy. Privacy is invaded when one intentionally intrudes, physically or otherwise, upon a person's solitude or into his private area or affairs. Invasion of privacy is considered a violation of to rt law and can be litigated inside the civil courts for monetary damages. Recently, invasion of privacy has taken on even greater meaning with recent technological advances. Bussian & Levine 2004 opine that: Whether an article or broadcast is newsworthy, whether the information was gathered in an objectionable fashion, whether truthful information is nonetheless highly offensive — all are considerations in weighing individuals' claims against the news media. Invasion of privacy is a tort, a civil wrong, which can lead to jury trials and potential claims for compensatory and punitive damages. It also places judges in the unfamiliar and uncomfortable role as â€Å"editors† of last resort. Celebrities are not protected in most situations, since they have voluntarily placed themselves already within the public eye, and their activities are considered newsworthy. Categorically, invasion of privacy or the intrusion into the personal life of another, without just cause, can give the person whose privacy has been invaded a right to bring a lawsuit for damages against the person or entity that intruded. Folarin, 2005:155 also agrees that the right to privacy is a legal means by which consumers can control media content through suits instituted against the media in defence of their right relating to invasion of privacy which includes insulation from needless publication of private matters. Also that people can sue any media that uses their names falsely. He asserts that the people who have little or no chance of winning most of the suits are acknowledged public figures who are generally assumed to have lost their to privacy by taking up public office or otherwise become public by being involved in a newsworthy act or incident. In distinguishing invasion of privacy among other claims facing the media, unusual situations involving crime victims and witnesses and also photographs of virtually anything visible in a public place do not give rise to actions for publication of private facts. Also facts that give rise to a false light claim may support a defamation claim while injury to reputation is not required for a false light claim. The false light tort aims primarily to protect against emotional distress rather than to protect one’s reputation. Based on First Amendment of the US constitution concerns, and the similarity between the claims, some states have not been persuaded to recognize the false light tort. However, public personalities are not protected in most situations, since they have placed themselves already within the public eye, and their activities (even personal and sometimes intimate) are considered newsworthy and are perceived to be of legitimate public interest. Dimensions of Invasion of Privacy: ) Intrusion on one's solitude or into one's private affairs includes: †¢ The Home: A person's home gets the highest protection from the courts. Entering a house or apartment without permission of the occupant or, in some circumstances, the police, can be considered as an unlawful intrusion. †¢ Photographs and Tape Recording: Taking photographs of a person or his property in a private place may be an invasion of privacy. Tape recording a person without his consent may also provoke damage awards. ) Public di sclosure of embarrassing private information such as: †¢ Personal Matters: Details about a private person's sexual relationships, the contents of personal letters, private facts about an individual, or other intensely personal matters are off-limits to the news media unless they are considered as absolutely newsworthy. †¢ Newsworthiness: Even truthful accounts are actionable if they contain highly offensive details which are not of legitimate concern to the public. ) Publicity which puts him/her in a false light to the public: †¢ Fabrication: Ascribing quotes or fictionalizing actual events can lead to invasion if a person is portrayed in a false light before the public. †¢ Photographs: Using photographs or films to illustrate a story that implies falsely that a person is involved in a disreputable incident. d) Appropriation of one's name or picture for personal or commercial advantage such as: †¢ Advertising: The unauthorized use of a person's name or photo graph in an advertisement is another immense subject in nvading people’s privacy. †¢ Property Rights: This happens when the press offers to give away unauthorized broadcasts or photographs of a performance. The Supreme Court in the United States has ruled that there is a limited constitutional right of privacy based on a number of provisions in the Bill of Rights and subsequent amendments. This includes a right to privacy from media surveillance into an area where a person has a â€Å"reasonable expectation of privacy† and also in matters relating to marriage, procreation, contraception, family relationships, child rearing and education. However, records held by third parties such as financial records or telephone call records are generally not protected unless a specific federal law applies. The court has also recognized a right of anonymity and the right of groups to not have to disclose their members' names to media agencies. (www. answers. com) Generally, it’s been considered that one ought to have a reasonable â€Å"expectation of privacy†, meaning: i. A place where a reasonable person would believe that he or she could disrobe in privacy, without being concerned that his or her undressing was being photographed or filmed by another; or ii. A place where one may reasonably expect to be safe from casual or hostile intrusion or surveillance. Given the similarity to voyeurism, an adjudicator might find that placing a hidden camera in a certain location may amount to the torts of indignation or deliberate infliction of emotional distress. Invasion of privacy laws are usually broken into four separate categories highlighted earlier including intrusion, appropriation, false light and public disclosure of embarrassing facts. Intrusion of Solitude: Intrusion of solitude, seclusion or into private affairs is an arm of invasion of privacy done by spying on or intruding upon another person where that person has the expectation of privacy. Places that a person ought to have an expectation of privacy are usually in a home or business setting. Consequently, people who have become public figures do not have the same expectation of privacy. A media practitioner, who intentionally intrudes, physically or otherwise, upon the solitude or seclusion of another or his private affairs or concerns, is subject to liability for invasion of privacy, if the intrusion would be highly offensive to a reasonable person. To be liable for intrusion upon seclusion or solitude, the plaintiff must prove the following elements: Invasion of a secluded place or privacy: this happens when the defendant is alleged to have invaded the plaintiff's personal or private space. This could be determined by: Physical intrusion into a place where the plaintiff has secluded himself. ) Use of the defendant's senses to eavesdrop or spy in order to oversee or overhear the plaintiff's private affairs or b) Some other form of investigation or examination into plaintiff's private concerns. Objectionable intrusion: this is the type of intrusion that would be highly offensive to the ordinary reasonable person. †¢ Invasion of private affairs or matters: the i nterference with the plaintiff's privacy must be substantial (however, if the event reported occurs in public, there is no expectation of privacy). Other examples of intrusion upon privacy include placing microphones or cameras in someone's bedroom or hacking into their computer. Society does not expect a journalist to place wiretaps on a private individual’s telephone without his or her consent. Opening someone's mail is also considered to be intrusion of solitude, seclusion or private affairs. The information gathered by this form of intrusion need not be published in order for an invasion of privacy claim to succeed. Trespass is closely related to the intrusion tort and may be claimed simultaneously. Intrusion claims against the media often centre on some aspect of the newsgathering process. This tort may involve the wrongful use of tape recorders, cameras or other intrusive equipment. Trespass also can be a form of intrusion. An actionable claim for intrusion may arise whether or not a news story is published or aired. (A photographer’s guide to privacy, 2003) Appropriation of Name, Likeness or Identity: The appropriation of a private person's name, likeness or identity by a person or company for commercial gain is prohibited under the invasion of privacy laws. However, this law pertains to a private figure and not a public figure or celebrities, who have fewer and different privacy rights. The Restatement (Second) of Torts Section 652C (1977) defines appropriation of name or likeness as follows: â€Å"One who appropriates to his own use or benefit the name or likeness of another is subject to liability to the other for invasion of his privacy. † (Bussian & Levine, 2004) Appropriation of name or likeness occurs when someone uses the name or likeness of another for their own advantage. Action for misappropriation of right of publicity protects against commercial loss caused by appropriation of an individual's personality for commercial exploitation. It gives the individual exclusive right to control the commercial value of his or her name and likeness to prevent others from exploiting that value without permission. It is similar to a trademark action with the person's likeness, rather than the trademark, being the subject of the protection. The appropriation category of invasion of privacy prevents others from using a person's name or identity for commercial gain. Ordinarily, the news media do not run afoul of this form of tort. However, seemingly harmless news coverage or advertisements can lead to lawsuits. This law came into existence from a couple of court decisions in the early 1900's where a private person's photograph was being used without consent for advertising purposes and without them receiving any monetary reward for using their pictures in print. The court recognized that the common law right to privacy including a person's identity had been violated by the unauthorized commercial use. In later cases, a person's voice was also included. Public figures, especially politicians do not have the same right to privacy as regards to appropriation of name, likeness or identity since there is much less expectation of privacy for public figures. Celebrities may sue for the appropriation of name, likeness or identity not on grounds of invasion of privacy, but rather on owning their own right to publicity and the monetary rewards (or damages) that come from using their likeness. False Light: As cited in Bussian , (2004) The Restatement (Second) of Torts Section 652E (1977) provides that: One who gives publicity to a matter concerning another that places the other before the public in a false light is subject to liability to the other for invasion of his privacy, if the false light in which the other was placed would be highly offensive to a reasonable person, and the actor had knowledge of or acted in reckless disregard as to the falsity of the publicized matter and the false light in which the other would be placed. Creating a false image for an individual may constitute an invasion of privacy. This is an aspect of invasion of privacy that deals with untruthful publication. In this instance, the offended person is placed in a false light through misleading descriptions, confusion of the person's identity with another, fictionalization of actual events, or photographs taken out of context. Its features are: It gives an individual unreasonable and highly objectionable publicity that attributes false characteristics, conduct or beliefs to him or her. The said material must be published to a third person or publicised to a large audience or to so many persons that the matter must be regarded as substantially certain to become one of public knowledge. The invasion of privacy tort of false light is upheld in court when the plaintiff can prove that the defendant publicize the plaintiff in such as way that it would be highly offensive to a reasonable person. However, it is pertinent to note that this tort shares many similarities with libel and many courts have trouble separating the two. Public Disclosure of Embarrassing Private Facts: Public disclosure of embarrassing private facts becomes an invasion of privacy tort when the disclosure is so despicable that it becomes a matter of public concern and it outrages the public sense of decency. In this invasion of privacy tort, the information may be truthful and yet still be considered an invasion if it is not newsworthy, if the event took place in private and there was no consent to reveal the information. The Restatement (Second) of Torts Section 652D (1977) provides that: One who gives ublicity to a matter concerning the private life of another is subject to liability to the other for invasion of his privacy, if the matter publicized is of a kind that (a) would be highly offensive to a reasonable person, and (b) is not of legitimate concern to the public. (ibid) The media can also be held accountable for damages for truthful publication. It is considered that the antisocial article or broadcast exposes to public view certain highly offensive matters that are not considered newsworthy. In order for an offended plaintiff to prevail, he must prove that the publication was: a) Extremely offensive to a reasonable person, b) And that the matters were not of legitimate concern to the public. The latter requirement may give the news media what might be called the newsworthiness defence. Though, the legal concern of the public in a matter is not presumed by the matter's publication. Thus, a plaintiff may prove that an article is lacking in newsworthiness despite its publication. Below is a good example: Case study: Publication of Embarrassing Private Facts Nollywood actress and 2005 Gulder Ultimate Search star, Anita Hogan, was reported to have lost a three-month-old pregnancy following the shock caused by the publication of her nude pictures in Daily Sun, an evening newspaper in 2006. Anita, according to her lawyer, was engaged to be married to a white man whose nude pictures were published along with hers in the Friday, August 11th edition of the newspaper. Police detectives in Lagos eventually arrested one Emeka Nwankwo, a computer engineer who allegedly circulated the shocking pictures to the media, after the actress rebuffed his alleged bid to blackmail and extort money from her over the lurid shots. The actress through her counsel explained that the computer where the controversial photos were saved developed a fault and had to be taken for repairs, from where they were allegedly stolen. The shots were said to have been taken by Anita’s fiance and stored on her personal computer. Emeka allegedly approached her to pay him N500, 000 or risk getting her pornographic pictures with the white man published in newspapers. The actress was said to have turned down the request, which she regarded as blackmail, and Emeka allegedly went ahead with his threat to circulate the pictures to media houses. A petition written by Anita’s lawyer, Mr Tony Dania of Dania and Associates, to the Deputy Commissioner of Police SCID, Lagos, actually admitted that the pictures in circulation were those of the actress but stressed that they were Anita’s private pictures with her fiance, stolen and doctored to suit the purpose of blackmail. The aforesaid publication is a criminal invasion of our client’s privacy. From the story the suspects published, it was obvious that there was blackmail and attempts to extort money from our client. They stole some of our clients’ pictures, used the computer to improvise and superimpose further images on them, called our clie nt and demanded for money. â€Å"The white man in the published pictures is a true resemblance of Anita’s fiance who works in a very decent organisation. In fact, they have done the pre-marriage formal introduction. Anita, who lost her dad recently, was actually carrying the baby of the white man, but the shock of the aforesaid inglorious publications made her to lose her pregnancy between Saturday/Sunday, August, 12, 13, 2006,† the petition alleged. CONSTITUTIONAL PROVISIONS Misappropriation: There are statutes that govern the right of publicity. These laws have two purposes: 1) To protect ordinary individuals from the mental anguish that may accompany the undesired commercial use of their name or image, and 2) To protect the property interest that celebrities develop in their identities. Under these laws the use of a relevant picture to illustrate a newsworthy article will generally not lead to liability. The unauthorized use of a celebrity’s picture in an advertisement often will. False Light: A photograph or videotape by itself will rarely place a subject in a false light. Rather, the accompanying text, caption, or voice-over could be misleading and portray the person in a false context. However, an accurate depiction of a person in a publication the person finds offensive does not, in itself, state a false light claim. Private Facts: The private facts tort presents unsettling scenario in which media practitioners may be iable for money damages for reporting the truth. In several cases the US Supreme Court has held that â€Å"where a newspaper publishes truthful information which it has lawfully obtained, punishment may lawfully be imposed, if at all, only when narrowly tailored to a state interest of the highest order. † Florida Star v. B. J. F. , 49 1 U. S. 524, 541 (1989) as cited in Bussian & Levine 2004. Although the Supreme Court has prevented states from punishing journalists who published legally obtained names of juvenile offenders and rape victims, the Court has not absolutely rejected the private facts tort in this context. Although crimes such as rape are newsworthy not all courts have agreed that the identity of a rape victim is newsworthy. Intrusion: Intrusion always comes into play through the process of gathering information. Here, the subsequent publication of the information is not required. Actions that may violate this privacy right include trespass onto private property, hidden surveillance, and the fraudulent entry into private areas. Conduct that invades privacy may also violate the criminal law. In general, courts have held that journalists must obey generally applicable laws. Trespass is the illegal entry onto private property. If the owner or person in charge of private property orders a photographer to leave, the photographer should leave or be prepared to face a trespass charge. Photographers who accompany police onto private property are not necessarily immune from liability. Camera operators should also be aware of federal and state laws that govern the taping of oral communications. The federal wiretap statute prohibits the interception of oral communications unless one party such as the journalist consents to the recording. And there have been instances where barring the taping of oral communications exist unless all parties consent to the taping. Privacy and the Internet: â€Å"The US Congress and its state legislatures across the nation have considered or are considering scores of bills aimed at reducing public concern about the ability of Internet users to protect their private lives as they surf the World Wide Web. † (Pember & Calvert, 2006). Despite the positive usage of the internet, the have been growing concern among users about the technology considering the ease with which third parties can collect data bout users and what the data collectors can do with the material they have gathered. However, the Nigerian Government have not woken from its slumber towards the direction of giving adequate protection to its citizens, properties and of course, rights. Defences available to Privacy Suits: Several defences are available to photographers and news organizations accused of invasion of privac y: Legitimate concern: defendant in a disclosure can challenge the plaintiff's proof of the basic elements of intrusion. For example, the defendant may be able to show that the facts that the defendant disclosed were matters of legitimate public concern. If a person is involved in a matter of legitimate public concern, a â€Å"newsworthy† event, the person becomes a public figure with respect to that event, regardless of the person's intentions or desires. If a person is a public official or public figure, his or her reasonable expectations of privacy are dramatically reduced. As a practical matter, a public official or public figure cannot successfully sue unless the invasion of privacy is outrageous or done with actual malice. Consent: it is a voluntary agreement to a publication or permission to enter a private place to gather information. It could be expressed or implied. Allis (2009) opines that a person who accepts money or other considerations in exchange for the invasion of privacy is said to have sold his or her â€Å"rights. † Though some defendants, such as prosecutors and government officials do have immunity if they are acting within the scope of their authority. Anything to be used in a commercial context, whether it is a photo taken in public or in private, must have consent, usually in the form of a model release. Consent must be obtained from someone who can validly give it. Consent to enter a home may not be consent to photograph it. Consent exceeded can be the same as no consent at all. Although oral consent may protect the press from liability for invasion of privacy, written consent is more likely to foreclose the possibility of a lawsuit. However, a subject’s subsequent withdrawal of consent does not bar the publication of the photograph. It simply means that the journalist may not assert consent as a defence if the subject later files suit. Cornwell (2008) sums it by saying â€Å"the more explicit the consent, the better the protection for the press. † Newsworthiness: Is generally defined as what the public is interested in. According to Wulfemeyer (2003), if a story that includes legally obtained private information that is embarrassing to the plaintiff but the subject matter is of public concern, it would be difficult for the plaintiff to win the law suit because courts give wide latitude to the newsworthiness defence. Photographs taken in public places generally are not actionable. Photographs of crimes, arrests and accidents usually are considered newsworthy and immune from privacy claims. Public places: if an event occurs in public view, they are almost always considered public and not private. Though public places defence have been considered not absolute. Public proceedings: Information obtained during public meetings, hearings or trials can be reported by a news organization. Public records: if information has been obtained from a document that is of a public record, it can not be deemed private. ETHICAL OBLIGATION Momoh (2004) opines that as a rule a journalist should respect the privacy of individuals and their families unless it affects public interest in the following ways: †¢ Information on the private life of an individual or his family should only be published if it impinges on public interest, †¢ Publishing of such information about an individual as mentioned above should be deemed justifiable only if it is directed at: 1. Exposing crime or serious misdemeanour; 2. Exposing anti – social conduct; 3. Protecting public health, morality and safety; 4. Preventing the public from being misled by some statement or action of the individual concerned. SUMMING UP The Right of Privacy is a good measure to check media practitioners on inappropriate media content so a news medium while carrying out its function must at all time be concerned with the welfare of its consumer. A media practitioner must ensure the accuracy of his or her information and must be ready to make corrections and clarifications when necessary after publishing or broadcasting untrue information. A media practitioner must at all time uphold the dignity of his or her profession comply with his or her professional codes and respect the human rights. A media expert must also recognise that gathering and reporting information may sometimes cause discomfort, so must seek ways to minimise the hurt. (Kayode, 2009). REFERENCES Allis. (2009). Invasion of Privacy—Appropriation. Retrieved September 19, 2009, from Lexis-Nexis database. Bussian & Levine. (2004). Invasion of Privacy: The Right â€Å"to be left alone† Retieved September 18, 2009, from Lexis-Nexis database. Cornwell, C. N. (2008). Freedom of the Press: Rights and liberties under the law. Retrieved September 18, 2009, from http://www. abc. clio. com Expectation of privacy (2002). Retrieved September 18, 2009, From http://www. wikipedia. com Folarin , B. (2005). Theories of Mass Communication: An Introductory Text. Abeokuta: Bakinfol Publication Invasion of Privacy (2003). Retrieved September 18, 2009, From http://www. winningnewsmedia. com/privacy Kayode, J. (2009). Ethics and professional practise [Record] . Lagos. Malemi, E. (2002). Mass Media Law: Cases and materials Lagos: Grace Publishing Incorporation Momoh, T . (2004). Nigerian Media Laws & Ethics Lagos : Efua Media Associates. Pember & Calvert. (2006). Mass Media Law Boston: McGraw Hill. Phtographers’ giude to Privacy (2003), Retrieved September 18, 2009, From http://www. rcfp. org Wulfemeyer, K. T. (2003). Radio & TV Newswriting: A workbook Retrieved September 19, 2009, from Lexis-Nexis database.

Pressure Management on a Supercritical Airfoil

Pressure Management on a supercritical aerofoil in transonic flow Abstract-At transonic speeds an aerofoil will have flow accelerate onwards from the leading edge to sonic speeds and produce a shockwave over the surface of its body. One factor that determines the shockwave location is the flow speed. However, the shape of an aerofoil also has an influence. The experiment conducted compared Mach flow over a supercritical aerofoil (flattened upper surface) and a naca0012 aerofoil (symmetrical).Despite discrepancies, the experiment confirmed the aerodynamic performance of a supercritical aerofoil being superior to a conventional aerofoil. A comparison of the graphical distributions demonstrates the more even pressure distribution on a supercritical aerofoil and a longer delay in shockwave formation. All of which, reflects the theory. Table of Contents Introduction3 Apparatus3 Induction Wind Tunnel with Transonic Test Section3 Mercury Manometer4 Procedure4 Theory and Equations5 Results6 Discussion10 Theory of Transonic Flight10 Relating the Theory to the Experiment11Effectiveness of Supercritical aerofoils†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 11 Limitations and Improvements12 Appendix13 References14 Introduction For any object travelling through a fluid such as air, a pressure distribution over all of its surface exists which helps generate the necessary lift. Lift is an aerodynamic force which is perpendicular to the direction of the aerofoil. Transonic speeds result in the formation of shockwaves over the top surface of the aerofoil. This is due to accelerated flow over the surface region. We say this region is approximately between 0. 8-0. . Since the flow must accelerate and then will lose velocity following the shockwave the aerofoil will have a subsonic and sonic region. For the majority of commercial airlines this is not a desired region to cruise at given the instantaneous pressure distribution which passengers would otherwise experience. Particularly, the formation of shock induced boundary layer separation. Supercritical aerofoils are more efficient designed for higher Mach speeds and drag reduction. They are distinct from conventional aerofoils by their flattened upper surface and asymmetrical design.The main advantage of this type of aerofoil is the development of shockwaves further away then traditional aerofoils and thus greatly reducing the shock induced boundary layer separation. In order to truly understand the effectiveness of a supercritical aerofoil an experiment gathering supercritical aerofoil performance and raw data of a naca0012 aerofoil will be extensively analysed and compared. Following the calculation and procedureit will be assessed whether a supercritical aerofoil is more effective. ApparatusA wind tunnel with a transonic test section was used in this experiment to study transonic flow around an aerofoil. The test section consists of liners which, after the initial contraction, are nominally parallel apart from a slight divergence to compensate for growth of the boundary layers on the wall. In order to reduce interference and blockage at transonic speeds, the top and bottom liners are ventilated by longitudinal slots backed by plenum chambers. The working section has a height and width of 178mm and 89mm respectively. The stagnation pressure, p0? in the tunnel is close to atmospheric pressure, and therefore it can be taken to be equal to the settling-chamber pressure as the errors are only small. To minimise the disturbance due to the model itself, the reference stagnation pressure, p? , is taken from a pressure tapping in the floor of the working-section, well upstream of the model. The nominal ‘free-stream’ Mach number, M? , in the tunnel can be calculated from the ratio p? /p0?. The Mach number in the tunnel can be controlled by varying the pressure of the injected air, pj. The maximum Mach number that the tunnel can achieve is about 0. 8 Mercury Manometer A multi-tube manometer with mercury was used to measure the pressure at stagnation, the aerofoil tappings and atmosphere. The manometer is equipped with a locking mechanism which allows the mercury levels to be ‘frozen’ so that readings can be taken once the flow has been stopped. Also, the angle of the manometer can be adjusted. For this experiment, it was set to 45 degrees (Motellebi, F. ,2012). Procedure Before conducting the experiment, the barometric pressure, Pat, was recorded, in inches of mercury and the atmospheric temperature, in degrees Celsius, was also recorded.For a range of  values of Pj from 10 – 110 lb/in2, in intervals of 20lb/in2, Pj was then recorded along with the manometer readings corresponding to stagnation pressure (I0? ), the reference static pressure (I? ), airfoil pressure tappings (In, n=1 to 8 and 3a ) and the atmospheric pressure (Iat), all in inches of mercury (Motellebi, F. ,2012). Results- Raw data in appendix x/c Figure 1b Cp against x/c at M= 0. 85 Figure 1a -Cp against x/c at M=0. 85 The experimental data was converted to absolute pressure values using Equation x ( units are inches of mercury).For a given value of the pressure injector (Pinjector) we can find the value of the Mach number using Equation y. Also Equation Z calculates Cp( or pressure coefficents) which reflect the measurements of the surface of the aerofoil. These results are displayed in figure x. This was done for both the supercritical aerofoil and the NACCA 0012 aerofoil. What follows is a comparison and analysis of the data. ( Figure 2b Cp against x/c at Mach speed 0. 8 Figure 2a -Cp against x/c at Mach speed 0. 81 x/c x/c Figure 3b- -Cp against x/c at Mach speed 0. 72 Figure 3a –Cp against x/c at Mach speed 0. 3 Figure 4b –Cp against x/c at Mach speed 0. 61 Figure 4a –Cp against x/ c at Mach speed 0. 61 Figure 5a- -Cp against x/c at Mach speed 0. 45 Figure 5b- -Cp against x/c at Mach speed 0. 44 Note that for both supercritical and naca0012 aerofoils the supercritical cases ( where M is equal to 0. 77, 0. 83 and 0. 840) the approximate value of x/c % where the shock occurs over the aerofoil is shown in red line. For the point below where Cp and the Cpcritical and hence the drop in Cp is greatest gives the location of where the shockwave occurs on the surface of the aerofoil. Cp and Cp* vs M? naca0012 aerofoil) Cp and Cp* vs M? (supercritical aerofoil) It is worth noting that for both the supercritical and Naca0012 aerofoil the results are somewhat similar. That is the critical Mach numbers for both are around 0. 72. Therefore the Minimum Mach number for a local shockwaves on both the supercritical and conventional aerofoil can be assumed to be the same. It is worth noting that Mach number 0. 41 for the supercritical aerofoil does not produce a shockwave, where as the Naca0012 aerofoil does. Mach number| Supercritical Aerofoil Approx position of shock| naca0012 Approx position of shock| 0. 5| -| -| 0. 61| -| -| 0. 72-0. 73| -| 0. 25x/c%| 0. 85-0. 86| 0. 70x/c%| 0. 40x/c%| Basic transonic theory An aerofoil or any object for that matter travelling through a medium (air) at low Mach numbers ( typically between 0. 30-0. 40) has flow is subsonic and can be considered incompressible. This means that any change in pressure or density is significant. The speed of sound (a) is dependent on the altitude of the aerofoil/object and the Mach number M is the ratio of velocity: M=va , a=? RT ?is a specific heat ratio, T is thel absolute temperature and R is the gas constant.The combination of these two equations above leads to: M=v? RT Sound is essentially a series of consecutive weak pressure waves emitted from a given source. These waves travel at the local speed of sound. If we assume the aerofoil is travelling towards the source, the source can noti ce the disturbances beforehand giving enough time for flow to adjust around the object. When the source begins to approach near the speed of sound, pressure waves move closer together in front of the object, therefore inadequate information from the source/disturbance is propagated upstream and the flow will not be able to react in time.The pressure waves merge together to produce a shockwave in front of the object. The flow encountering the shockwave will experience changes in temperature, static pressure and gas density as well as a lower Mach number. The transonic region is special because although flight speed is below sonic speed as the information is propagated upstream on the surface of the aerofoil the flow accelerated to the speed of sound. Thus forming a shockwave over the aerofoil. The position of this shockwave depends on the initial entry speed to the aerofoil.Therefore what we have in the transonic region is an aerofoil which has sonic speeds early upstream and subsoni c speed towards the end of the aerofoil or downstream. This means it is complicated to accurately analyse transonic flow over an aerofoil as a different set of equations must be used on the leading edge, upper surface and trailing edge. The critical upstream Mach number is the minimum value of a given Mach number for which a shockwave will be produced on the surface of an aerofoil. In other words, supersonic flow.Below this threshold a shockwave will not appear. Drag or the aerodynamic force in the transonic region again depends on the speed of the object travelling. At subsonic speeds the main component of drag are Skin friction, pressure drag and lift induced drag. At sonic speeds (approaching or exceeding) there is the addition of wave drag. The drag increases dramatically, and as a result a higher thrust is needed to sustain acceleration. Also, at this point the shockwave will interact with the boundary layer, thus causing it to separate upstream of the shock.Figure 6Demonstrati on of transonic flight-(Scott, J. , 2000) The aerofoils The two aerofoils Naca0012 and Supercritical aerofoil are different in design and purpose. The Naca0012 is a basic symmetrical aerofoil used primarily for rudder and elevator movements. Aerodynamic performance is not taken into consideration and is thus reflected by the simple aerodynamic design. It is worth noting that there are better aerofoils. The Supercritical aerofoil is a performance aerofoil designed for higher Mach speeds and drag reduction.They are distinct from conventional aerofoils by their flattened upper surface and asymmetrical design. The main advantage of this type of aerofoil is the development of shockwaves further away then traditional aerofoils and thus greatly reducing the shock induced boundary layer separation. Relating the Theory to the Experiment The critical Mach number for both the supercritical aerofoil and NACA0012 aerofoil was found to be in the region of 0,72. There is a difference to the neares t 10th but for all intents and purposes we can assume they are the same.This indicates that the minimum Mach number for a shockwave to be produced on the surface of the aerofoils is equal and not influenced via the shape. The pressure distributions of the supercritical aerofoil ( especially at Higher Mach) in comparison to the Naca0012 are more evenly distributed. The experiment confirms the theory that the supercritical aerofoil in comparison ro a conventional aerofoil generates more lift due to an even distribution of pressure over the upper surface. (http://en. wikipedia. org/wiki/Supercritical_airfoil) Effectiveness of Supercritical aerofoils.At a Mach number of 0. 45 both aerofoils do not display a shockwave. This is evident from the fact the Cp and Cp* graphs do not intersect at all. We already know this because the critical Mach number is 0. 72 for both. This indicates that either a shockwave was not produced (unlikely), or that the shockwave was produced beyond the trailing edge This means we cannot assess the effectiveness of the supercritical aerofoil at Mach speeds 0,45 and 0. 61. The supercritical Mach numbers show varying results. When the experiment took place at Mach ) 0. 72-0. 3 ( the critical Mach number) the supercritical aerofoil did not produce a shockwave ( Cp and Cp* do not intersect) whereas the naca0012 aerofoil did. The lack of a shockwave formation indicates either the critical Mach number for the supercritical aerofoil is higher then the conventional aerofoil experimental accuracy is lacking. At the supercritical mach numbers ( 0. 81-0. 86) in both the naca0012 aerofoil and the supercritical aerofoil Cp and Cp* intersect. The large drop in pressure coefficient is evidence of the formation of a shockwave.However, the pressure drop in the supercritical aerofoil is occurring at a pressure tapping further downstream. This confirms the theory that a shockwave is produced further downstream in a supercritical aerofoil This seems to confirm the theory that a supercritical aerofoils design does allow for development of shockwaves further away then traditional aerofoils and thus greater reduction in the shock induced boundary layer separation. In regards to the amount of drag (aerodynamic force) acting on the aerofoils it is worth noting that the pressure distribution at 0. 5 Mach for the supercritical aerofoil is more evenly distributed and ‘flatter’ then the naca0012 aerofoil. There is no indication of a large instantaneous increase in drag taking over. This would therefore confirm the theory that a supercritical aerofoil is effective in greatly reducing the shock induced boundary layer separation. Notes for limitations The experiment is a success since results obtained confirm the capabilities of supercritical aerofoils and their advantages over conventional aerofoils. However, there are a few discrepancies which regarding experimental error and the different aerofoils.First of all the mach numbers teste d at 0. 72 and 0. 73 created an inaccurate experiment. Normally, this would not be a problem. However, since the critical mach numbers for both aerofoil’s were in the vicinity of 0. 72 it was expected this was the minimum threshold for a shockwave to be produced over the aerofoil. A shockwave was not produced for the supercritical aerofoil despite the critical mach number value. Therefore, we can conclude that at this speed there are too many inaccuracies to understand what is really going on.We also did not really see a difference in performance at subsonic flow. Granted, the supercritical aerofoil was primarily designed for supercritical mach speed. No useful information was obtained from here. The fact the pressure tappings have different coordinates means that each aerofoil is showing the pressure distribution at a different set of coordinates. This of course, is not as accurate if the aerofoils had the same pressure tappings. For instance, the naca0012 has a pressure tap ping at 6. 5% of the aerofoil section and the last ends 75% the rest is unaccounted for.Since the supercritical aerofoil has different pressure tappings it means both aerofoils have different areas which are unaccounted for. This means it is not certain whether or not the graphs are a reliable source of information, yet alone to compare. A digital meter should also be connected that displays the pressure in the two tappings so the aerofoil can be appropriately adjusted to bring it to zero incidence. This digital meter can also be used to display the value of the mercury levels for other pressure tappings, reducing any human errors.In order to increase the accuracy of the pressure distribution over the aerofoil surface, more pressure tappings can be made on the aerofoil. These will improve the pressure coefficient graphs by allowing more points to be plotted, in turn, yielding better information for the position of the shockwave in the supercritical cases and also the critical Mach n umber for a shock to occur. References 1) http://www. southampton. ac. uk/~jps7/Aircraft%20Design%20Resources/aerodynamics/supercritical%20aerofoils. pdf 2) http://www. nasa. gov/centers/dryden/pdf/89232main_TF-2004-13-DFRC. pdf 3)

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New Doha International Airport Design and Construction - Research Paper Example Area 3 includes airport terminal facilities, while Area 4 includes landscaping and support buildings for the airport. The New Doha International Airport is designed to cover more than 22 square kilometers of land, which amounts to about one quarter the size of the old city of Doha, and about 3 times the size of the existing airport in Doha. The airport is designed to cater to as many as 50 million people, 2 million tones of luggage, and also handle as many as 320,000 aircraft takeoffs and landings per year. â€Å"By opening day, as many as 8,700 passengers can go through the terminal complex in a single hour. The airport’s eastern runway will be 4,850 meters long, only150 meters shorter than the longest commercial runway in the world at Ulyanovsk-Vostochny International Airport in Russia. By opening day, the 350,000+ square meter passenger terminal facility will be the largest building in Doha, covering an area equivalent to 50 full size football pitches. As such, it will be bigger than Doha’s City Center Plaza which has an internal area of 290,000 m2. Flights and passenger processin g facilities will be organized in a way to minimize walking distances for various travelers. Moving walkways will also help to shorten the distances to the contact gates. The new airport check-in and retail areas alone will be big enough to squeeze in ten wide body aircraft. When completed, this area will be about 12 times bigger than the retail and check-in areas at the existing facility, making the journey through check-in much quicker, and the shopping experience more varied.† (Airport Technology - New Doha International Airport, Qatar). The New Doha International Airport is designed to be one of the most advanced airports in the world, and will serve as home to Qatar Airways, which is a leading airline worldwide. The airport is designed to be able to handle operations of some of the biggest passenger planes in the

Dracula Essay Example for Free

Dracula Essay Good vs. Evil has long been expressed through movies and books throughout history. Batman beating the Joker, Spiderman banishing the Green Goblin, and Arthur and the guys defeating Dracula are all examples of literature based on the theme Good vs. Evil. In Bram Stokers, Dracula, Jonathan Harker represents the good, while the vampire, Dracula, represents the evil antagonist. One thing these four pieces share is that evil never fully overcomes good. They all start off as regular human beings, or on the good side, until their spirit and soul becomes taken over by a sense of evil. Gothic elements, such as, an atmosphere of mystery and suspense, supernatural events, gloom and horror, the tyrannical male, and the woman in distress are all present in these stories. The movie Interview with a Vampire, The Singing Springing Lark, and the story Interview with a Vampire can relate to Dracula because of their themes and gothic elements. The movie Interview with a Vampire is very similar to the story Dracula. It starts off in a dark night scene filled with dull and heavy music. Also, during the fight scene, the setting included thunderstorms and pouring rain. This shows metonymy because the dark and heavy music represents death and terror and the thunderstorms and rain were used to create a setting of darkness and fear. Other gothic elements shown in this movie were Lucy’s pale skin, the castle setting, and the exchanging of blood. In the Lindauer 2 story Dracula, Lucy’s skin starts to become very pale because she has been bitten by Dracula, which is what happened in the movie. This represents the gothic element tyrannical male, because of Dracula’s presentation of overpowering the other characters, more specifically Mina and Lucy. This directly relates to the gothic element women in distress because the women in both stories were treated poorly and were taken advantage of due to their weaknesses. In the story, The Singing Springing Lark, there are also many similarities to Dracula. For example, as in Interview with a Vampire also, most of the scenes take place in a castle. This shows the gothic element setting in a castle. As in most stories, a castle usually represents evil spirits and terror, which Dracula and the Beast both represent. Another gothic element shown is an atmosphere of mystery and suspense. In the story, the prince was hesitant to meet the girl’s family because â€Å"for if a ray from a burning light were to fall on him there, he would be transformed into a dove, and would have to fly with doves for seven years.† This is an important quote because in the story Dracula, the boys had figured out that Dracula’s evil spirit was weakest during the times of sunrise and sunset. If they didn’t get to him before the sun set, his powers were going to be restored. In other words, the change from dark to light represents a change from evil to good. In the story Interview with a Vampire, the plot line is almost exactly the same. For example, â€Å"The mere sight of a bared throat could bring about in me such a taste of arousal that I became like an animal, incapable of language or restraint.† This quote shows tyrannical male because it compares how Armand and Dracula are both similar in the way they kill their prey. They both attack where the blood is rich just like animals do and dominate their prey. It also Lindauer 3 shows a sexual side because the mere fact of killing got both of these characters aroused. For example, â€Å"With his left hand he held both Mrs. Harkers hands, keeping them away with her arms at full tension; his right hand gripped her by the back of the neck, forcing her face down on his bosom. Her white nightdress was smeared with blood, and a thin stream trickled down the mans bare breast which was shown by his torn-open dress.†(Stoker 283) This quote shows women in distress because it describes how Mina, in a sense, was raped. Just Armand, Dracula finds pleasure in killing, and transforming good into evil. One thing that all of these pieces share is that evil never overcomes good. Although evil makes its presence known and dominates at first, good prevails in the end. The movie Interview with a Vampire, The Singing Springing Lark, and the story Interview with a Vampire can relate to Dracula because of their themes and gothic elements. As Theodore Roosevelts once said, The forces that tend for evil are great and terrible, but the forces of truth and love and courage and honesty and generosity and sympathy are stronger than any before.

Law of Partnership Fiduciary Duty Analysis

Law of Partnership Fiduciary Duty Analysis Analyse within the Law of Partnership Fiduciary Duty Definition Partnership is a longstanding legal concept which has become regulated by statute. Recently, the introduction of Limited Liability Partnerships has added a new species of partnership to the legal lexicon and demands a dramatic reworking of the way in which partnerships are viewed. The classic definition of partnership is provided by s.1 of the Partnership Act 1890: â€Å"Partnership is the relation which subsists between persons carrying on a business in common with a view to profit.† The relationship between partners must be contrasted with the relationship between employer and employee. The latter may also be said to be â€Å"carrying on a business etc.† but one is subordinate to the authority of the other. Partners possess a number of co-existent rights: To be involved in decisions affecting the business; To share in the profits and losses; To examine the accounts; To be entitled to the good faith of the other partner(s); To veto the introduction of a new partner. Traditionally, a definition of partnership would involve a contrast with a company drawing the distinction that, unlike a company, a partnership could not benefit from the protection of limited liability. However, as will be seen below, such a distinction is no longer universally valid following the Limited Liability Partnerships Act 2000. Fiduciary Duty Partnership is a particular type of contract (albeit governed by the partnership legislation). There is therefore considerable involvement of the common law and equitable principles. The major consequence of entering into a partnership is that the partners owe a fiduciary duty to one another. Since the law of fiduciaries and constructive trusts is a creature of equity and the categories of equity are never closed it is impossible to provide a comprehensive and definitive list of such duties but a number of clear principles have emerged. The partners owe one another a duty of good faith. For example, in Floydd v Cheney[1], an architect engaged an assistant with a view to partnership. The assistant removed certain documents and photographed others in the absence of the architect who then sued for the return of the documents and negatives and sought an injunction restraining the use of confidential information. There was a dispute as to whether this was a partnership or a master/servant relationship. However, Megarry J held that even if this was a partnership, there existed a duty of good faith which prevented the assistant from acting as he did. A partnership relationship is one of ’utmost trust’ (uberrimae fidei). Therefore each partner must deal honestly and openly with his fellows and disclose all relevant information to them. A failure to disclose is a breach of this duty; there is no need to establish fraud. This is also partly embodied in statute. Section 28 of the Partnership Act 1980 provides: â€Å"Partners are bound to render true accounts and full information of all things affecting the partnership to any partner or his legal representatives.† A trustee must not profit from his trust and this applies to partners as fiduciaries. This a partner must not make unauthorised personal profit. This principle is also embodied in s.29 of the Act which requires a partner to account to the firm for any benefit derived by him without the consent of the other partners from any transaction concerning the partnership or involving the use of partnership property. Thus the rule in Keech v Sandford[2] (which provided that where a trustee of a trust which holds a lease obtained a renewal of the lease for his own benefit, he held the lease as a constructive trustee for the beneficiaries) applies to partners where they obtain such a benefit as a result of their position as a partner. A partner must not put himself in a position of conflict of interest and duty toward his partners. This is codified by s.30 of the Act which provides that where a partner has carried on a business of the same nature and in competition with the partnership, he must account to the other partners for the profits of that business. Because, as has been seen, partnership is a species of contract, the written terms of the partnership deed (if any) and indeed those imposed by the Act can be varied by express or implied agreement. Limited Liability Partnerships For many years pressure had been growing in the commercial world and particularly among those providing professional services for the introduction of a form of partnership that would provide a limitation of liability akin to that enjoyed by directors of a limited company. This was driven in particular by an increase in litigation and the consequent threat to firms and therefore to their partners personally. This led to the passage of the Limited Liability Partnerships Act 2000 and the creation of Limited Liability Partnerships. LLPs are therefore entirely a creature of statute and a new form of legal entity. They continue to enjoy the organisational flexibility of partnerships. In matters relating to taxation (partners are Schedule D as before) they are similar to traditional partnerships but in many other respects it is appropriate to think of them in terms of the company model. Indeed the only way in which an LLP can be created is by submitting an incorporation document to Companie s House. While there is no need to submit a partnership deed (contrast the filing of Articles of Association in respect of companies), partners in LLPs are well advised to subscribe to a deed which will regulate the operation of the partnership and protect their interests in the event of a dispute. An LLP is therefore a corporate body with a separate identity from the partners. In general, partners in an LLP will have full entitlement to limited liability. (There is an exception in circumstances in which an LLP continues to trade after being reduced to only one â€Å"designated member† such that, after a prescribed interval, the remaining partner will become jointly and severally liable with the LLP.) Similarly, in the event of insolvency, partners are not in most circumstances personally liable to any extent over and above the aggregate of their capital share in the LLP and any contribution they have agreed to make. An LLP is analogous to a limited company in that it has no existence until the formalities of incorporation are complete. However, many of the restrictions upon the freedom of action of company directors particularly interaction with the corporate body do not apply. Nonetheless, unlike partnerships, Companies House imposes a number of formal requirements such as the filing of an annual return and audited accounts. Both partnerships and LLPs involve a venture for profit. There is no restriction upon the type of venture to be undertaken (although LLPs are not suitable for use by charities). In a traditional partnership, the central feature is the relationship between the members whereas with an LLP it is the act of association that creates the entity. This can be seen from the fact that in a partnership every member is an agent of the partnership and an agent of the other partners whereas in an LLP every partner is an agent of the LLP itself but not of the other partners. This has led commentators[3] to conclude: â€Å"Overall, LLPs are a curious mix of the law of partnership and the law of companies.† Those authors (at p.165) speculate as to the operation of duties within the new form of partnership: â€Å"Partners will owe a duty to the LLP as a body corporate in common law but it seems unclear whether they owe a duty of good faith to each other.† LLPs and Fiduciary Duty The fiduciary duties of a partner to an LLP are helpfully explored by Whittaker and Machell[4]. They observe that â€Å"the core obligation of a fiduciary is that of single-minded loyalty to his principal†. This core obligation is represented by several separate duties or restrictions including but not limited to the following: To act at all times in good faith; Not to misapply the money or property of the LLP; Not to put himself in a position of conflict of interest with the LLP; To disclose all relevant information (including any material breach by him of his fiduciary duties to the LLP; Not to compete with the LLP; Not to misuse his position in the LLP for his own advantage. The authors suggest (at p.137): â€Å"that the fiduciary obligations set out above will exist unless they are expressly (and properly) excluded by the LLP agreement or it is clear from a consideration of all the circumstances that particular duties are inapplicable.† The Act contains a number of â€Å"default rules† which specify such duties and, regulate, for example, the circumstances in which a member may be expelled from an LLP but it should be noted that these rules are not a comprehensive statement of a member’s fiduciary duties which will continue in their totality to be regulated by equitable principles where any partnership deed does not make express provision. Partnerships in Other Jurisdictions Partnership is recognised as a legal relationship throughout Europe and, provided that it has been formed in accordance with the laws of a member state and has its registered office (in the case of LLPs) or principal place of business (in respect of traditional partnerships) within the EC, a partnership will be treated for the purposes of European law in the same way as a natural person who is a national of a member state. In most European jurisdictions there are three basic types of commercial partnership: the undisclosed or â€Å"secret† partnership; the general partnership and the limited partnership. In France, partners in a secret partnership can authorise each other to disclose their partnership relationship to third parties thus rendering it a socià ¯Ã†â€™Ã‚ ©tà ¯Ã†â€™Ã‚ © en participation ostensible with the result that they become jointly and severally liable for the firm’s obligations. By contrast, in Austria, where the partnership will consist of a principa l and a single dormant partner, the latter will not be liable even if he manages the business. The formalities for creation of general partnerships vary according to jurisdiction. In countries such as Belgium, Bulgaria and Greece, it is necessary to have a written agreement for registration purposes whereas in other countries an oral agreement will suffice. In France and Belgium, there are two types of limited partnership (socià ¯Ã†â€™Ã‚ ©tà ¯Ã†â€™Ã‚ © en commandite simple and socià ¯Ã†â€™Ã‚ ©tà ¯Ã†â€™Ã‚ © en commandite par actions). The latter is more analogous to a limited company. In the former, the limited partners may not participate in the management of the partnership on pain of losing their limited status. This contrasts sharply with the operation of English LLPs discussed above which is more akin to that in Austria which allows limited partners to participate in internal management. Proposals for Reform Finally, it should be noted that the Limited Liability Partnerships Act 2000 created an additional category of partnership rather than reforming the existing rules. In the Preface to the First Edition of Partnership Law, Geoffrey Morse observed: â€Å"It is to the everlasting credit of the Victorian judges that they created a business form which has proved to be both strong and flexible enough to adapt itself to EEC-wide firms of accountants when it was designed for small parochial businesses in Victorian England.† Nonetheless, as has been seen by the need to develop LLPs, modern circumstances demand continual evolution. In November 2003, the Law Commission and the Scottish Law Commission published a report on such reform accompanied by a detailed draft Partnership Bill. Central to their proposals is a redefinition of partnership which moves away from the relationship between persons carrying on business together to â€Å"an association formed when two or more persons start to carry on business together under a partnership agreement [emphasis supplied]†. This gives primacy to the existence of an agreement. A written agreement has never been an essential prerequisite of a partnership (even under the 2000 Act) and the Commissions shied away from imposing a statutory model agreement but it is nonetheless proposed to abolish partnerships at will providing that there should at the very least be express agreement. Bibliography Adams, T. et al, Business Law and Practice 2004-2005 Banks, R., Lindley Banks on Partnership, (18th Ed., 2002) Morse G. et al, Palmer’s Limited Liability Partnership Law (2002) Morse, G., Partnership Law, (5th Ed., 2001) Whittaker, J. Machell, J., The Law of Limited Liability Partnerships, (2nd Ed., 2004) Encyclopaedia of Forms Precedents, Partnership, Volume 30(1) 1 Footnotes [1] [1970] Ch 602 [2] (1726) Sel Cas t King 61 [3] For example, Adams, T. et al, Business Law and Practice 2004-2005, p. 166 [4] The Law of Limited Liability Partnerships, (2nd Ed., 2004) p.134 et seq

Gay Marriages Essay -- Same Sex Marriage Essays

In today’s society there are many factors that contribute to the ever-continuing social inequality of people through out Canada. It is no wonder as to why there are so many stereotypes of what is socially ‘acceptable’ and what isn’t when the media is forcing these ‘norms’ into our minds. What is ‘ideal’ with in today’s expectations isn’t always attainable due the fact that everyone is different. One of the most controversial topics being discussed today is view on same sex marriage. This notorious topic is nothing new, however, there is an ongoing debate as to whether or not make it legal for couples of the same sex to engage in a marital status. Although the bond between two homosexuals is ‘different’ from two heterosexuals, the idea is the same: a union between two people. This is just one of the ways in which society is continuously participating in the failure to establish equality.   Ã‚  Ã‚  Ã‚  Ã‚  Gay and lesbian activist are hoping for legalized same-sex marriages so that both of the partners can receive federal benefits as those of heterosexuals with in their marriage. As of right now, homosexual couples do no receive social security. According to Hector Vargas â€Å"Separate is not equal and same-sex couples deserve the same as heterosexual couples†. Many people fear that if same sex couples are granted the same rights to unite under the term â€Å"marriage† there will be nothing distinguishing the difference between the two marriages and for many, there is a hu... Gay Marriages Essay -- Same Sex Marriage Essays In today’s society there are many factors that contribute to the ever-continuing social inequality of people through out Canada. It is no wonder as to why there are so many stereotypes of what is socially ‘acceptable’ and what isn’t when the media is forcing these ‘norms’ into our minds. What is ‘ideal’ with in today’s expectations isn’t always attainable due the fact that everyone is different. One of the most controversial topics being discussed today is view on same sex marriage. This notorious topic is nothing new, however, there is an ongoing debate as to whether or not make it legal for couples of the same sex to engage in a marital status. Although the bond between two homosexuals is ‘different’ from two heterosexuals, the idea is the same: a union between two people. This is just one of the ways in which society is continuously participating in the failure to establish equality.   Ã‚  Ã‚  Ã‚  Ã‚  Gay and lesbian activist are hoping for legalized same-sex marriages so that both of the partners can receive federal benefits as those of heterosexuals with in their marriage. As of right now, homosexual couples do no receive social security. According to Hector Vargas â€Å"Separate is not equal and same-sex couples deserve the same as heterosexual couples†. Many people fear that if same sex couples are granted the same rights to unite under the term â€Å"marriage† there will be nothing distinguishing the difference between the two marriages and for many, there is a hu...

DJ Scratch Info :: essays research papers

Turntablism - The art of manipulating/restructuring previously existing phonograph recordings to produce new, musically creative combinations of sounds using turntables and a mixer. Hamster Style - Normally a DJ setup would be configured with the right turntable playing on the right channel of the mixer and the left turntable playing on the left channel of the mixer. With a hamster style setup, however, the opposite is true. The right turntable plays through the left channel, and the left turntable plays through the right channel. Many DJs find it more comfortable to scratch hamster style since to do many moves it is easier to bounce the fader off of the side of the fader slot using your multiple fingers rather than your thumb. Personally I think that hamster style seems more conducive to flaring and doing continuous crabs. DJ members of the Bullet Proof Scratch Hamsters/Space Travellers crew are most commonly recognized as the first DJs to practice/demonstrate this style thus giving it the nickname "hamster" style. There are two ways to achieve this mixer configuration. One is to physically hook your turntables up to the opposite channels where they c ome into the back of your mixer, and the other is with a hamster switch. Normally a hamster switch only reverses your crossfader's configuration, while physically reversing your turntable cables reverses the crossfader and volume faders' configuration. Hamster Switch - A switch on a mixer that reverses the crossfader without reversing the volume faders so that you can scratch hamster style without physically hooking up the turntables to different channels on the back of the mixer. Baby Scratch - The simplest of scratches, the baby scratch is performed without the use of the crossfader by simple moving the record back and forth. A simple example would be one forward stroke, and one backward stroke (or vice versa) in sequence. Forward and Backward Scratches - Forward and backward scratches are also fairly simple scratches but unlike the baby scratch they are performed using the fader to cut the sound in and out. As an example, to perform 2 forward scratches you would just do two baby scratches with your record hand using your fader hand to cut the sound in when you move the record forward both times and out while you're pulling the record back both times so that all you hear are the 2 forward strokes.

Essay --

The film Kinsley was an interesting film to say the least. I must admit that I was a little uncomfortable at times while watching this movie. The study that was conducted by Alfred Kinsey was something that I believe the people of society are interested in but are conditioned to pretend like we are not. His finding in Sexual Behavior in the Human Male put many people at ease because I think inside everyone is very curious about what everyone else is doing. This is because we all have the desire to be normal and fit in with society. But as Kinsey found the sexual behaviors of males could not be further from what society thinks is normal. But what is normal really? I myself had this certain view about sexual behavior and there were certain things that I believed to be normal. But because of this movie my eyes are now open to the truth about sex. I think that for society sex is a very touchy subject and because of this people are oblivious to everything about sex. Different cultures have different views on sex and how it is suppose to be done. From the time we are young the culture tha...

Paper Chromatography

The Hydrogen Atom Spectrum Evan J. Collins C. N. Peck June 16, 2009 INTRODUCTION MATERIALS _Emission Spectra an the Electronic Structure of Atoms_ Spectroscope Black Ink Pen Graphite Pencil Notebook Mercury Spectrum Hydrogen Spectrum PROCEDURE Calibration of the Spectroscope: Using the spectroscope the four most visible lines on the scale were measured. Violet, blue, green, and yellow were all visible. With the ink pen the measurements were recorded. A known wavelength (nm) vs. measured lines (cm) graph was then drawn from the measurements. Observation and Measurements of the Hydrogen Spectrum: Using the calibrated spectroscope the scale position of the observable lines of the hydrogen emission spectrum were measured. Red, turquoise, violet, and purple were all visible. Using the measurements and the calibration graph the wavelength of the lines were determined. The relative error was calculated using: Accepted Value Values of wavelength for the hydrogen atom spectrum were converted to kJ/mol. Using a form of the Rydberg equation, the Rydberg constant was calculated for each of the lines measured. This constant was used to then calculate percentage error. Data Calibration of the Spectroscope Observations and Measurements of the Hydrogen Spectrum CALCULATIONS (Convert wavelength values to corresponding energy in kJ/mol) 680 x 10^-9 2. 92 x 10^-19 J x (6. 022 x 10^23) / (1000 J) = 176 kJ/mol (Calculate the value of the Rydberg constant) (1/680)/(. 25-. 30) = . 00147059/(. 25000-. 11111)= 0. 0105042 x 10^-7 = Rh= 105,040 cm ^-1 (Calculate Percentage Error) 105040 – 109678 X 100 = 4. 23% Error 109678 DISCUSSION/CONCLUSION

Disney’s Expedition Everest Essay

Walt Disney World wanted to celebrate its 50th anniversary in a big way. So in 2006 Walt Disney Company introduced Expedition Everest in Disney’s Animal Kingdom Park at Lake Buena Vista, Florida. This is more than your average roller coaster. The roller coaster not only has the unexpected twist and turns we all love, but also an incredible attention to detail. This roller coaster really took some impressive management skills. This roller is based off of Mount Everest in Nepal. The ride contains 18 mountains with the tallest one (Everest) peaking at just under 200 feet. The rollers coaster contains nearly a mile of track and also has a robotic 10 foot tall Yeti. Surrounding this roller coaster in 900 bamboo plants, 10 species of trees, and 110 species of shrubs was planted to give the feel of the lowlands in the Himalayas. The Disney Imaginers actually went to the Himalayas in Nepal to study the lands, architecture, colors, ecology, and culture. They actually got more than 2000 handcrafted item for Asia to use as props and ornamentation. This is actually the most expensive roller coaster in the world. Disney’s approach to the management of project such as Expedition Everest is to combine careful planning, including schedule and budgeting preparation, with the imagination and vision for which the company is so well known. Prioritizing the needs for project success took discipline and creativity. Disney seemed to spare no expense when creating their new ride. The budget must have been astronomical. Wanting the new ride open for their 50th anniversary, each step of the project had to be met with strict deadlines taking over 2 years to develop. The approach to the management of the project displays the embodiment of the Disney spirit: a ride that combines Disney’s trademark thrills, and impressive project management.