Modules on skills and materials Essay

Well prep ard teachers contribute a large repertoire of activities for their course of actiones. They cornerstone organise preparation and controlled come onput work emerge they burn d give birth direct pupils in the acquiring of receptive skills and organise sure-enough(prenominal)ly communicative activities. This repertoire of activities enables them to have varied plans and achieve an activities balance.The Practice of slope Language Teaching HarmerWhich of the techniques turn uplined in this module, and elsewhere in the modules on skills and materials, would you employ in order to achieve veridical colloquy in the trendroom?This task should refer to other atomic number 18as of the course. You should aim to write just well-nighwhat 750 words.The ultimate aim of teaching English to speakers of other languages is to achieve genuine chat by limiting teacher talking clipping and maximizing schoolchild participation. Simply standing in front of a severalise an d telling things to the assimilators does not guarantee they go expose learn them. Students need to be actively involved in the lessons. A vital step in raiseing a partition of active learners is varianceroom management. There are legion(predicate) an(prenominal) techniques which dope be implemented in order to achieve genuine communication within the classroom. Communication should tax return place the minute the class begins. acquire into the habit of chatting to the students at the start of a lesson gives them the chance to take part in natural discourse. This tummy be achieved by salutation the students and offering five minutes to go around asking what people did at the weekend, for example. This gets students intercommunicate before they have had a chance to worry more than or less getting involved. In order to throw an open learning purlieu and aid the flow of communication, the furniture in the classroom should be place appropriately.Ideally, the furnit ure should be arranged in a circle as it allows all the students to be involved and creates a sense of equality. However, if this is not possible, a semi-circle or some form of group arrangement is best. A semi-circle ensures the students are able to see any visual aids clearly and as many students as possible have eye contact with the teacher. A group arrangement allows for a huge degree of interaction and squeeze out be utilizeful in pranceed- index classes, where groups of students can concentrate on assorted communication tasks according to their ability. another(prenominal) great government agency of rousing communication is to show interest in the students by getting to know about their interests and backgrounds. This allows teachers to make conversation before and after class using person-to-person information. How is your new cat? Is your husband feeling better? It is encouraging for the students and they are more apt(predicate) to want to speak about themselves, their families, etc.Getting to know the students also allows teachers to personalise lessons and set up relevant discussions. This ontogenys student involvement by allowing them to express opinions about their environment and personal experiences. A similar technique is to talk about current affairs or news stories. These are subjects that the students are likely to have knowledge of and will be able to discuss amongst themselves. This will supercharge students to find enkindle stories or anecdotes they can share with the class or to keep themselves cognizant so they can have meaningful input in class activities. Current newspaper and magazine articles can be cut out and used to prompt discussions. These techniques can allow the students to take control of the conversation, trim back teacher talk time and consequently further their learning. Relevant and down-to-earth practise of language is classic in spurring meaningful communication from students.Teachers should focus on e lements of language and communication that are necessary for the students goals or are of personal interest. The types of activities expendd in a lesson can give more or less opportunities for communication. The most obvious way to get someone talking is to ask them questions, but teachers should authentically think about the kinds of questions they ask. Closed questions are simple direct questions that can be useful for checking understanding or reviewing language, whereas open questions do not always have a single or right solving and get the students thinking. Both types of questions are useful in the classroom and teachers should establish a good balance between the two. Furthermore, questions should be directed to the social unit class initially, rather than a named individual, as this ensures all students are zippy and thinking about the answer should they be chosen to respond. Another technique to keep students focused is avoiding asking questions in a fixed order. Teachers should mix it up by darting around the classroom, keeping the students on their toes.Asking questions can be rather limiting in the degree of communication it fosters and it involves a lot of initial input by the teacher. In order to encourage genuine communication between students so they get the most out of the experience, teacher talking time needs to be limited. Group or pair-work activities are a great way to do this. They generate conversation and communication flows more naturally. Well prepared group or pair-work activities should wait students to maintain communication in order to complete the task. They dramatically increase the amount of speaking time each student gets in the class and allow students to interact independently without guidance of the teacher. This promotes learner independence and more spontaneous communication. region-plays, dialogues, sketches, etc. can be a great way to reduce anxiety about speaking. Students may be embarrassed at first, but b ecome less self-conscious as they concentrate on the character or situation they are required to carry out, indeed produce more natural language. In addition, prompts, such as role cards and realia can be provided as an aid for the students to use during their performance. It is important for the teacher to continue monitoring groups during fluency tasks to ensure English is creation spoken.It is imperative that the use of the mother tongue language is limited in the class. If the class are of differing nationalities, this aids communication as the students have no choice but to use English to communicate. Thus, there are many techniques that can be adopted to ensure genuine communication is achieved in every lesson. It is important for teachers to really think about all aspects of the lesson, including the introduction, seats arrangement, the delivery of activities, materials used, etc. prior to teaching in order to tap student talk time so that each individual gains the most o ut of their experience within the classroom. depute FOR SUBMISSION TO YOUR TUTORTASK 2You are working in an ESOL school with class sizes of 14-18.Your emboss does not like your schools current way of exam spoken English. At the moment it is riseed in a one-on-one, 2 minute speaking test at the end of course with a mark from 0-10. It does not seem to be working well and takes up a whole lesson from the course. He has asked for suggestions as to how to mixed bag the system.With reference to what you have studied in this and other modules, and to your own experience and reading, make some suggestions to your boss as to how the school could assess the spoken English of the students in a more accurate and less pressurized way.You should write about four hundred 500 words to send as an email setting out your ideas.Dear ______,In light of your recent request for ideas as to how to change the current way of examination spoken English, I would like to constitute the following suggestio ns. Rather than a one-on-one end of year speaking test, we could adopt a task undertake and assess the students speaking ability in a variety of ways throughout the duration of the course. We could create tasks that require the students to use the language in real-life communicative performances. This type of testing is advantageous as it can be conducted with more than one student at a time, reducing the amount of time dedicated to the testing. It allows the students to use their language knowledge and competence in real-life communications with their peers. It is a more realistic and accurate measure of their abilities. Not only do these tasks test accuracy and fluency, they also test how creatively the students are able to use language and whether they are able to communicate effectively with each other.It is likely to reduce the pressure they feel about a single query with the teacher, particularly if they get to perform the tasks with other students so the focus isnt sole ly on them. Adopting this kind of testing approach will allow us to carry out a image of different ad-lib tests throughout the course, assessing a variety of skills. There are a number of different tasks that could be used such as role plays, reckons and presentations. Role Plays We can give them a particularised situation and roles to play that utilise the language they have learnt. Role plays can be used colloquially throughout the course so the students get lots of time to course session for a schematic assessment. Debates We could tell apart the classes into groups and have each group debate an argument relating to different topics they have studied.Each group would be split into two smaller groups, one to represent each side of the argument. The students can be given time in or out of class to prepare their side of the debate. Each side could be allocated a specific time for giving their initial argument in which each student has to contribute the same amount of time. A gain, debates can be used conversationally throughout the course to practice language, allowing students ample of practice before the formal assessment. Class Presentation We could assign group projects for the students to carry out in or out of class. The students will have a deadline to complete the project, at the end of which they will be asked to give a group presentation. We can provide them with guidelines of what to include and what skills they will be individually tested on.Another way to test students individually that takes away the pressure of performing in front of the class is to ask them to make a recording. In a previous school, we had students read a short story and then asked them to theorize they were one of the characters. They had to record themselves giving an account of what happened according to their the characters personal experience. The students were allowed time to think about what they wanted to say before making the recording. afterward assessment, th e students listened to each others recordings and gave constructive feedback to their classmates. This type of assessment was carried out a number of times throughout the course, with notable improvements across the board. Although this approach is less realistic, it gives the students a chance to hear themselves speaking and pinpoint their own mistakes which they can work on in the future.I hope these suggestions are of use and we are able to implement a more booming way of testing the oral skills of the students.

Haefren Baum Business Analysis Essay

Haefren Baum is a furniture retailer, established in 1965 and was incorporated in 1970. Haefren Baum receives its merchandise from Wiegandt GmbH Cologne, a nearby manufacturer, whose commercial enterprise relationship equals over xxvii years. The company has one retail location in Cologne, Germany and three of late constructed topic stores in nearby suburban areas. Demand and overlap gross gross sales are influenced by consumer discretionary income. In 1993, an economic bust in the German economy passed in a major dip in GDP. Demand for the industry is cyclical and is influenced by the overall economy. There is no evidence of seasonality. In response to the German economic down minute in 1993, the company began to open outlets with wide selections and lower prices to maintain sales volume.This was a trend used by all in the industry, further sales volumes were not affected and remained flat. As the German economy recovered, Haefren Baums business began to see fierce compe tition from European furniture retailers. This was a engage for the Wiegandt, who saw its retailers losing market share, and began aggressively advertising its brand. The strategies involving aggressive branding and oblation wider selections at lower prices proved to be unsuccessful, mainly ascribable to the influx of competition.Operations AnalysisHaefren Baum being a retailer needs a large amount of memorial and additions in order to generate sales. To turn profits, the company needs to be effective in both memorandum management and asset turnover. Recently, the Haefren Baum is showing very extravagantly determine for inventory years, and an overall decline in its TAT and FAT ratios. Figures for total and unconquerable asset turnover steadily decline from 1993-1995. These figures could be a result of the expansion and create of outlet stores, as well as sluggish sales. Total assets turnover equals 2.1 in 1993 to 1.5 in 1995. As for fixed asset turnover, 1993 equals 6.9 8 to 5.39 in 1995. Haefren Baums land investment has remained constant over this period, but buildings and equipment investments confine changed, again a result from the building of the three outlet stores. Inventory days show and increase from 103 in 1993 to 129 in 1995. much(prenominal) a dramatic change shows that the fuddled is getting less efficient in managing its inventory, which could be a result of increasing competition throughout the industry. The average collection period has also shown significant increases, going from 53 days in 1993 to 77 days in 1994 and 1995. It seems that Haefren Baum has had difficulty obtaining enceinte due from customers. The overall operations of the company seem to be missing proper efficiency due to the increase in inventory days and average collection period. The negative values for net income and results from the previous denounce conclude why the firm has seen a decrease and negative values for ROE and ROA.Financial AnalysisHaefre n Baums strategy of selling product at lower prices seems to be ineffective in generating profits. The firms operating activities can be misleading, although it seems that its improving, the net figures are lock away negative. The increase in investing activities is explained by the recent construction of outlets, and is shown in the buildings and equipment account. The recent buyout from the other investors is shown in the payables from stockholders. Financing activities seem to be the reference work of funding for the firm. Haefren Baums liquidity has been mildly volatile. The current ratios for the firm have changed from 2.26 in 1993 to 2.53 in 1995. Accounts payable days saw a major increase going from 49 days in 93, to 65 days in 94.Although Wiegandt has been flexible with credit terms, Baum is far exceeding the net 30 terms and is not taking advantage of any discounts. Haefren Baum is showing high leverage risk with its debt to equity ratio of 5.84%, this is a problem due to the large debt compared to equity owned. The NPM of the company is zero, due to the failure to generate profits. The GPM, though positive, shows a steady decline in profitability. Haefren Baum is primarily using finance activities to maintain operations of the business. They are basically staying alive by debt, and impart need to re-evaluate its processes to stay in business.SummaryHaefren Baum has been severely impacted by competition and the value of its inventory stemming from the economic downturn in 1993. The firm is producing negative cash flows and in turn producing zero profits. The construction and building of the impudently outlet stores have no sales support and are eating profits with staggering mortgage cost. The firm needs to be more effective and efficient with inventory and credit lines. Arranging new credit terms in order to receive discounts and improve margins are in order for the firm to generate profits.

Capacity Contract Law

header 1(i) Phing, 17 divisions non get along withnarian daughter of a wealthy businessman is currently studying at a University College at Kelana Jaya. She bought a luxury railway railroad automobile Audi R8 worth RM 900,000. The auto has straightway been delivered entirely she is un equal to breakfor it. Firstly, Phing is a 17 twelvemonths venerable teenager which besides cognise as underage. Minor is a soulfulness who leg exclusivelyy underage who has non yet achieve the age of bulk, and which ar denied the ability to bounteousy and freely scram. In Capacity of incision 11 sic a psyche who is of the age of majority, sound mind and is non disqualified from developing under any law.Age of majority is recognized as above 18 eld of age as stated in theAge of Majority Act 1971. Below argon similar with the field, which graphic symbol 1 Ryder v. Wombwell (1868), the def breakant, an sister, having an income of nonetheless 500 Pounds per year was supplied a pair of crystal, carmine and diamond solitaries and an antique silver goblet. It was held that these things could not be considered to be necessaries. It was notice that certain things deal ear rings for a antheral, spectacles for a blind person, or a wild animal, fundamentnot be considered as necessaries.For an another(prenominal)(a)(prenominal) gaffe which fortune 2 Mohori Bibee v. Dharmodas Ghose (1903) the plaintiff, Dharmodas Ghose, while he was a minor, owe his property in opt of the defendant, Brahmo Dutt, who was a bullionlender to secure a bring of Rs. 20,000. The deportual amount of loan presumption was less than Rs. 20,000. At the prison term of the deed the attorney, who acted on behalf of the gold lender, had the knowledge that the plaintiff is a minor. The plaintiff brought an action against the defendant stating that he was a minor when the owe was executed by him.Held mortgage was void and inoperative and the same should be cancelled. In the Phing study, she is unable to pay for luxury car Audi R8 which is already delivered to her. downstairs the trade of Goods Act (1979) Phing is against the section 32 of the Act goes on to allege that unless otherwise agree, delivery of the practiseds and payment of the price are concurrent bosom-outs. This m everywhere that the seller shall be ready and pull up s namesing to give possession of the goods to the buyer in exchange for the price, and the buyer shall be ready and willing to pay the price in exchange for possession of the goods.However, before look on the section 32 of the Act we in addition institute to refer the member 3(2) of the Act. Under this section, necessaries are defined as the goods are suitable to the school in life of the minor or other person touch on and to his actual requirements at the time of sale and delivery. Necessaries are things which are inbred to the existence and reasonable comfort of the baby. Luxurious articles are excluded. Thus, wh at may be termed as necessaries depends on the nature of goods supplied as well as the infants actual needs.In the next case which case 3 Fawcett v Smthurst (1914) the coquet ruled that a minor is not flinch by a fetch for the hire of a car, although it was a necessary service, as the rationalize acceptd the terms which make him liable for damage to the car in any event, whether or not the damage in his fault. Where thither is a binding demand for necessaries, the minor is and bound to pay a reasonable price for them. Next case is pertinent with luxury cases, case 4 Chapple v. Cooper (1844) a minor whose economize had recently died leted with undertakers for his funeral.She later ref utilise to pay the cost of the funeral, shooting her in capacity to contract. The royal court held her liable to pay the bill. The funeral was for her private benefit and was a necessary as she had an obvious obligation to bury her dead married man. In the next, case 5 Nash v Inman (1908) a Cambridge undergraduate, the son of an architect, was supplied with clothes, including 11 fancy waistcoats, to the value of $122. The cloth could be appropriate to the station in life of the undergraduate, exclusively the contract was not enforceable because the minor was already adequately supplied with clothes.Therefore clothes supplied by the tailor could not be naval divisionified as necessaries. As conclusion, in the Phing case, she is only a minor and not has any income when she was studying, on that pointfore, the luxury car may not be the necessaries for her. In conclusion, Phing buy luxury car Audi R8 contract is void, she is not stimulate to accept and pay any damages. Question 1(ii) In this case, Phing is a 17 year one-time(a) student bought a Myvi as a transport to travel back and forth from the college. In the element of contract, Phing is already against with the capacity section 11.In section 11 of capacity say that Every person is competent to contract who is of age of majority according to law to which he is subject, and who is of sound mind, and is not disqualified from contracting by any law to which he is subject. It means that the following collar categories of persons are not competent to contract. The target of a minor is a person who has not attained the age of majority is a minor. naval division 4 of the age of majority, the minority of all males and females shall cease and determine at bottom Malaysia at the age of 18 years and every much(prenominal) male and female attaining that age shall be of the age of majority.However, slightly contracts of capacity make by infants are not void in that location are contract for necessaries, contract for scholarships and contract for insurance. In the case of Phing bought a Myvi may be necessaries for her to travel back and forth from the college. According the section 69 of decoct Act (1950) say that the necessaries supplied to a minor should be suited to his destine life it do es not mean the food, clothing, shelter and schooling, but much(prenominal) things which may be necessary to maintain a person according to his condition in life.Below is the cases that related with contract for necessaries, which case 1 Kunwarlal v. Surajmal (1963) It has held that the dramatics given to a minor on rent for living and continuing his studies is deemed to be supply of necessaries suited to the minors conditions of life, and the rent for the fellowship can be rec everyplaceed. For another(prenominal) good summary case is case 2 Chapple v Cooper (1844) where the court ruled that the funeral service of her economise was a necessary service for the young widow in this case, so she was obliged to pay. In the case of case 3 Clowes v.Brook (1739) where, though the plaintiff Farriers claim for work done on an infants horse failed on technical appeal grounds, it would come on clearly to guide been accepted by the Court that a horse could be a necessary in certain cas es. In the case 4 Mohori Bibee v. Dharmodas Ghose (1903) case, the Privy Council did not consider it necessary to mold whether fraction 115, Indian Evidence Act was applicable to the present case, because the money lender was not misled by the false statement made by the minor as has was aware of the real age of the borrower .Under the Section 3(2) of the Sale of Good Act (1979), provides that if goods are sold and delivered to minorsor those genially incapacitatedthe minor will be liable to pay a reasonable price if the goods are necessaries. The case more suitable for demonstrate this section is case 5 Roberts v. Gray (1913), in this case a minor was held liable for his failure to perform a contract for a tour with the plaintiff, a noted billiards player. It was a contract for the instruction of the minor. The contract was wholly executory and but it was held that the contract was binding on him from its formation. In conclusion, in Phing case to purchasedMyvi, Myvi car is her necessaries good for her to travel back and forth from the college and she is able to afford it, so the contract for her to purchased Myvi car is reasoned. Question 1(iii) Phing is 17 year old, she is a student which studying at a University College at Kelana Jaya. She now has to take a state loan of RM 20,000 for her studies in the college. 17 year old is not attained the age of majority, for another countersign Phing is also call as minor. In capacity section 11 define that a person who legally underage who has not yet attained the age of majority, and which are denied the ability to full moony and freely contract.The similar case that related which case 1 Burnard v. Haggis (1863), there a minor employ a mare. It was expressly agreed that the mare will be used only for riding and not for climb uping and larking. The mare was made to jump over a fence she was impaled on it and killed. It was held that the minor was liable for negligently killing the mare as his act was total ly in mutualist of the contract made by him. For another similar case, which case 2 Ballett v. Mingay (1943), there a minor hired a microphone and an antiophthalmic factorliphier. Instead of move the same to the owner the minor passed it on to his friend.It was held that the minors act of passing it on was alto numberher outside the purview of bailment and, therefore, the minor could be made liable for detinue. In the Phing case, she unable to work the contract to get the scholarship, but Under the Section 69 of Contract Act 1950, it is utter that if a person, incapable of entering into a contract, or anyone whom he is legally bound to support, is supplied by another person with necessaries suited to his condition in life, the person who has furnished such supplies is entitled to be reimbursed from the property of such incapable person. Under necessaries a minor can enter into valid contract if only it is the basic need of the minor and suitable of his or her station in life or lifestyle. The similar cases that related with, which case 3 Mohori Bibee v. Dharmodas Ghose (1903) case, the minor misrepresented his age while taking loan, but the fact that the person taking the loan is a minor was known to the money lender.The Privy Council did not consider it necessary to decide whether Section 115, Indian Evidence Act was applicable to the present case, because the money lender was not misled by the false statement made by the minor as has was aware of the real age of the borrower. Contract of Scholarship amid a minor and the government or non government organization is also under Section 4 (a) Contracts (Amendment) Act 1976 the scholar entering into such agreement is not of the age of majority. Next similar case, which case 4 Government of Malaysia v.Gurcharansingh & ors (1971) say that when the award, bursary, loan or scholarships granted by the federal or state government, a statutory authority, or an educational institution such as a university. This is a good example case to show the contract of scholarship, in this case Gurchran is a student who had legitimate a government scholarship to undergo t separatelyer training and was bonded to serve the government. However, Gurcharan left the service before completing his 5 years bond. When the Government sued Gurcharan for breach of contract, he contended that he had no capacity to contract.The court, never the less, held that education was a necessary. For another good case is case 5 Harnedy v National Greyhound Racing Co. Ltd, where the contract does not appear to flummox had any connection, whether by way of analogy or otherwise, with contracts for the education or employment of children or contacts for personal services. The distinction among employment contracts and contracts for apprenticeship and education and analogous contracts may often be difficult to draw. Treitel has commented that, an infant haulage contractor is a trader, but probably an infant number one wood wo uld not be.An infant house painter probably be regarded as a trader, but not an infant portrait painter. In conclusion, Phing have to take loan of scholarship to continue her study, so the scholarship will be the necessaries for Phing, so the contract for her to get scholarship is valid. Question 1(b) maverick is an old man. He has children, Joe and capital of Seychelles. knot has informed everyone that when he dies, the property is to be selld equally among Joe and Victoria. He stays with Victoria and is totally dependent on her to look subsequently him. knot loves Victoria and does whatever she tells him to do.Two months ago, Johnny transferred all his property to Victoria. In this case, Victoria take care of her make is her responsibility, but Johnny should not transfer all property to Victoria although he loves Victoria so much. Johnny should be fair for Joe too. On the other situation, Victoria maybe said something or persuades her bring, Johnny to transfer all property to her. If this situation become true, Victoria is against vitiating factors, Section 10 Contracts must be entered into with free consent of the parties and Section 10(1) all agreements are contracts if they are made by the free consent of parties competent to contract.Section 14 Consent is free when it is not caused by Section 16(1) wild regulate unwarrantable entrance occur where there is a relationship between the parties and one troupe is in the position to dominate the will of the other. The plethoric part uses that position to obtain an unfair advantage over the other. The word unfounded influence has the tendency to make people feel that it would include situations where one party is about to persuade the other through some kind of influence in a general sense ands. Undue influence can divide into actual extravagant influence and presumed unjustifiable influence.Actual undue influence as the name suggests, requires proof that the contract was entered into as a res ult of actual influence exerted. The claimant must plead and march the acts which they assert amounted to undue influence. This may include such acts as threats to enda relationship, continuing to badger the party where they have refused consent until they finally give in. For presumed undue influence is no automatic presumption arising as a matter of law. Here it must be established that there is a relationship of such a kind that one party in fact dimensiond their trust and confidence in the other to safeguard their interest.Any relationship is capable of amounting to this examples include hubby and wife, cohabitees, employer and employee. In Section 16(2) person is in a position to dominate the will of another where he holds a real/apparent authority over the other, or where he stands in a fiduciary relation to the other, he makes a contract with a person whose mental capacity is temporarily or permanently affected by reason of age, illness or mental bodily distress. Next, i n Section 16(3) where a person who is in a position to dominate the will of another, enters into a contract ith him, and the transaction appears, on the face of it or on the evidence adduced, to be unconscionable, the burden of proving that the contract was not induced by undue influence shall lie upon the person in a position to dominate the will of the other as the case 1 Re Craig (1971) C, an old man of 84 years whose wife had died, employed Mrs M as secretary/companion. From the beginning she employed a position of trust, and in addition to running the house she took a confidential part in running Cs affairs.From the time of Mrs Ms employment and Cs oddment (January 1959 August 1964) he gave her enables worth ? 28,000 from his total assets of ? 40,000. It was held by the Chancery cleavage that All the gifts complained of where such as to remunerate the requirements to raise the presumption of undue influence, namely, that they could not be accounted for on the ground of t he habitual motives on which ordinary men act, and secondly, that the relationship between C and Mrs M involved such confidence by C in Mrs M as to place her in a position to exercise undue influence over him.Mrs M failed to discharge the onus on her of establishing that the gifts were only made after full, free and informed discussion so as to rebut the presumption of undue influence. The gifts would, therefore, be set forth. Other similar cases, which case 2 Williams v Bailey (1866) A son forged his fathers ghost on promissory notes and gave them to their cashboxers. At a meeting of all the parties at the bevel, one of the bankers said to the father If the bills are yours we are all right if they are not, we have only one course to pursue we cannot be parties to compounding a felony. The banks scrutineer said it was a serious matter and the fathers own solicitor added, a case of transportation for life. After gain ground discussion as to the sons fiscal liability the banks solicitor said that they could only look to the father. The father wherefore agreed to make an equitable mortgage to the bank in amity of the return of the promissory notes. The father succeeded in an action for cancellation of the agreement.It was held by captain Westbury that the security given for the debt of the son by the father under such circumstances was not the security of a man who acted with that freedom and power of deliberation that must be considered as necessary to validate a contract to give security for the debt of another. Besides that, in the Singapore mettlesome Court case, which case 3 che Som bte. Yip & Ors. V. Maha Pte. Ltd. & Ors. ( Maha Pte. Ltd. & Anor. , Third Parties) a mortgage deed was set aside in so far as it affected the plaintiff over whom undue influence was exercised.In this case the relationship was that of brothers. This relationship does not per se (That is, on the face of it) give rise to a presumption of undue influence. However , the court found as a fact that undue influence was therefore exercised. In the next similar case, which case 4 Inche Noriah v. Shaik Allie Bin Omar (1929) case, an old and illiterate Malay woman executed a deed of gift of a landed property in Singapore in favour of her nephew who had been managing her affairs. Before executing the deed the donor had independent advice from a attorney who acted in good faith.However, he was unaware that the gift constituted a lot he whole of her property and did not impress upon her that she could prudently, and equally effectively, have benefited the done by bestowing the property upon him by a will. Held the gift should be set aside as the presumption of undue influence, which is raised by the relationship proved to have been in existence between the parties, was not rebutted. A plea of undue influence can only be raised by a party to the contract and not by a third party, this have been show in the case, which case 5 Malaysian Freach verify B hd. V. Abdullah bin Mohd Yusof & Ors.It was held that in tack to establish undue influence, the defendants have to prove that the plaintiff was in a position to dominate their will and thus obtained an unfair advantage by apply that position. In this case, there is undue influence involving family members or friends. Often cases airlift that involve family and friends who become parties to a contract. In general, family relationships, such as between husband and wife or parent and child, are confidential relationships. These relationships, like fiduciary relationships, have at their crux a history of versed trust and confidential dealings.In cases that arise where a family member gains a arrive at or distinct advantage through dealing with a weaker party, the courts have looked to see if the weaker party is very old, mentally incapacitated, suffering from debilitating sickness, or otherwise physically or psychologically impaired. Such physical or psychological impairment com bined with a lack of independent advice and a contract giving an obvious advantage to a family member would force the stronger party to prove the contracts fairness. The cases of undue influence, which case6 Allcard v.Skinner Miss Allcard was introduced by the Revd Mr Nihill to Miss Skinner, a lady superior of a religious order named Protestant Sisters of the Poor. She had to observe vows of poverty and obedience. Three days after becoming a member, Miss Allcard made a will bequeathing all property to Miss Skinner, and passed on railway stock that she came into possession of in 1872 and 1874. She then claimed the money back after she left the sisterhood. Held Lindley LJ, held that she was unduly influenced but barred by laches from getting restitution.And in any case she would only have been able to recover as much of the gift as remained in the defendants hands after some of it had been exhausted in accordance with her wishes. Another next case, which case 7 In Royal Bank of Scot land v Etridge 2001, the House of Lord indicates that, in average circumstances, a wifes agreement to charge the matrimonial billet as security for her husbands business debts is not a transaction that calls for explanation. Undue influence connotes impropriety, and should only be found where the husbands influence has been misused .Then, the other case, which case 8 Lloyds Bank Ltd v Bundy(1974) Herbert James Bundy was a farmer. His son, Michael, formed a MJB Plant subscribe Ltd and it was in financial ado. Mr Bundy had already guaranteed the business with a ? 7,500 charge over his only asset to Lloyds. This was his farmhouse at Yew Tree Farm,Broadchalke, and Wiltshire. Michaels caller-out got into more trouble still, and needed more money. Bundys solicitor said not to put on any more money, but they went up to ? 11,000.The assistant manager of Lloyds, Mr calculate explained the companys position to Bundy (i. e. a conflict of interest) but neglected to say the company was in serious trouble. Bundy signed the guarantee and charge form. Lloyds foreclosed on the house when the money was not paid, and Bundy had a heart attack in the happen box. The question was whether the contract leading to the repossession of the house was voidable for some immoral pressure. The held is that the contract was voidable due to the unequal bargaining position in which Mr Bundy had found himself.He held that undue influence was a category of a wider class where the balance of power between the parties was such as to merit the mental disorder of the court. It was apparent that Mr Bundy had, without independent advice entered the contract and it was very unfair and pressures were brought to bear by the bank. Another similar case, which case 9 National Westminster Bank v. Morgan (1985) Mrs Morgan together with owned the family home with her husband. As a result of his business problems, their mortgage payments fell into arrears, and the bank started to seek possession.Mr Mo rgan approached the bank to arrange a refinancing loan (this work as follows if Mr Morgans original mortgage was for ? 50,000, and he owed arrears of ? 5,000, he could replace the mortgage with a refinancing loan of ? 55,000, and start afresh). Mrs Morgans signature was required to use the house as security for the extended loans. The bank manager went to see her, in the presence of Mr Morgan she made it clear that she had slight confidence in her husbands business and wanted to address to the manager alone, but this did not happen, and she eventually signed to prevent the house being repossessed.The loan was not repaid, and Mr Morgan later died. When the bank tried to take possession of the house, Mrs Morgan pleaded undue influence. Next, the case which case10 CIBC Mortgages v Pitt(1994) Mr Pitt wished to purchase some shares on the stock market. He pressured his wife into signing a mortgage of ? 150,000 securing the family home. The stated purpose of the loan was to purchase a pass home and pay off the existing mortgage. The husband used the money to purchase shares and then used those shares as collateral to purchase further shares.For a time the shares did very well and he was a millionaire on paper. The wife saw no benefit from these shares as any income was ever so used to purchase more shares. In 1987 the stock market crashed. The bank seek to enforce the security under the mortgage which at the time exceeded the value of the home. The wife raised actual undue influence in defence. The judged is the Overruling BBCI v Aboody it is not necessary for a claimant to demonstrate bare hurt where a defence is based on actual undue influence.However, as the transaction on its face did not seem to the manifest disadvantage of the wife, because the stated purpose was to purchase a pass home, the bank was not put on enquiry and therefore could not be doctor with constructive notice. In the case11 Bank of Credit and medico International v Aboody(1990) A h usband exerted actual undue influence over his wife in order to get her to sign a charge securing the family home on the debts owed by the company in which the husband and wife owned shares. The couples were unable to repay the mortgage and the bank sought to repossess the home.The wife sought to have the mortgage set aside on the grounds that it was procured by actual undue influence of the husband. Held the husband had exerted actual undue influence on the wife. However, the transaction was not to the manifest disadvantage of the wife since she owned shares in the company. In considering whether a transaction was to the manifest disadvantage the court was to have regard to any benefits received in addition to the risks undertaken. Therefore the banks were granted possession. Furthermore, in case12 Credit Lyonnais Bank Nederland NV v Burch(1997) Miss Burch started working for her employer at the age of 18.She became close to the director, Mr Pelosi, who was an Italian business man 10 years erstwhile(a) and trusted him implicitly. She often visited his home to do babysitting and went on holiday with the family to Italy. At the age of 21 she purchased a flat. 5 years later, she was still working for him but the company was experiencing financial difficulty. Mr Pelosi asked her to put her flat up as security for a loan taken out by the company. He told her that his home and villa in Italy were also secured on the debt but they would not accept 100% mortgage on these properties and needed another ? 0,000. She agreed to allow her home to be used as security accept that it was only ? 20,000 and that Mr Pelosis properties would first be sold which would release the debt so that there was no risk to her. The bank had written to her and informed her that the charge was boundless in amount and time and advised her to seek independent advice. She at no time was told of the extent of the companys borrowings which stood at ? 270,000 neither did the bank satisfy themselv es that she had in fact received independent advice.In the case 13 UCB v Williams(2002) The Williams family (Mr & Mrs Jack Williams and their three grown up children) ran a garage business as a federation with the benefit of a prerogative from Toyota. Toyota threatened to withdraw the franchise unless the showrooms were extended and improved. The cost for this was ? 500,000. The Williams approached the bank for a loan which asked for security by way of a charge on the three showrooms in addition to a charge on each of the partners home. The defendant, Mrs Williams, was the wife of one of the sons.She had signed the charge without having been told the full extent of the liability. The signature was executed in the presence of all the other partners and witnessed by Mr. Howells, the solicitor of the partnership. The charge secured all debts present and future of the partnership and provided for joint and several liabilities of all the partners. The business was unable to repay t he loan and became bankrupt. UCB sought to enforce the charge and Mrs Williams raised undue influence and disproof in her defence. The trial judge, HHJ Hickinbottom, held that undue influence and misrepresentation were established.However, he held that Mrs Williams would have signed the charge in any event had she known the full facts and also that UCB were not fixed with constructive notice as a solicitor had witnessed the signature therefore they could assume Mrs Williams had been advised accordingly. Mrs Williams appealed to the Court of Appeal. Held Mrs Williams was thriving on both grounds. In conclusion, Joe still can voidable the contract about the Johnny transferred all his property to Victoria. If the contract is void, property Johnny will use back the contract in early to share equally among for Joe and Victoria.

Role and Functions of Hr Managers

Role and moulds of HR Managers Introduction The gracious beings vision part deals with reignment of people within the government. There be a payoff of responsibilities that come along with this title. First of completely, the Department is liable for hiring members of supply this allow for mean attracting put singlees, keeping them in their positions and ensuring that they perform to expectation. Besides, the benevolent mental imagery Department to a fault clarifies and sets mean solar day to day goals for the organisation. It is responsible for organisation of people in the ideal go with and plans for future ventures and neutrals involving people in the troupe. Handy, 1999) Research has stressn that the human medical checkup prognosis of resources within an organisation contributes approximately octonaryy percent of the organisations economic value. This implies that if people atomic number 18 non managed properly, the organisation faces a serious f ind oneself of falling apart. The forgiving Resource Departments main objective is to bring come out the best in their employees and hence contribute to the succeeder of the phoner. These roles come with real positive and negative purviews. However, the negative aspects lavatory be minimised by dislodgements to their roles and functions.These issues shall be examined in detail in the subsequent sections of the seek with reference to case warnings of businesses in current operation. Positive aspects of Roles and Functions of the Human Resource Department Recruitment of Employees This is one of the most fundamental roles of the HR plane section. This is because this function tells that the society chthonic consideration selects the most skilful and competent mortal from a sea of appli flowerpotts at that time. This function involves military rank of ability and susceptibility of potential employees in relation to what the social club needs.This role falls under the Staffing role of management. If this function is performed vigorous, thusly the organisation entrust increase value consequently being on the righteousness pathway to achieve its organisational and departmental goals and objectives. (Hyde, 2004) Effective recordment can be done finished a way out of ways. First of all the Company can conduct educational and psychological measurements. This t involve pass on involve assessment of abilities, skills and character evaluation of applicants. Through psychometric evaluation, the Company can ensure that employees start the right attitude necessary to fit into the organisation.Another method Companies use to recruit members of rung is through interviews. Here, the Human Resource Department can ask applicants questions that evaluate their decision making abilities and how they would deal with certain situations if presented with them. The Department can a ilk employ the use of written interviews where applicants answer questions a ddressing key issues in the organisation. Through these channels, the Department contributes towards organisational performance. An example of a Company that performs this role swell is Tesco Ireland.The Company notifies the public about vacancies. It then posts a questionnaire online and interested parties execute it at that time. This is then evaluated and those who fall within their minimum requirements atomic number 18 invited for an interview. In the interview, applicants are asked a number of questions and those who did extremely well are yet analysed and retained. Those who did moderately well are not immediately eliminated instead, their interview questions are kept on file then these are reviewed after sextet months.By so doing, the Tesco Ireland makes sure that its employees are highly capable and that they exit enrich the organisation. (Hyde, 2004) Improvement of Compensation Packages One of the major functions of the HR department is to strike employees. This can be done through rewards curiously for those who piss done well. The HR department needs to evaluate performance of employees and those who squander fadeed expectations should be compensated for their actions. Research has shown that rewarding employees for good performance is the number one incentive for keeping up this trend.These compensation packages can come in the follo backstage ways Holiday Offers End of Year Bonuses Equities Awards payment Increments Provision of Flexible Working Hours Straight forward Promotion Schemes and public life Developments If the HR department includes these incentives, then it provide ensure that employees are agreeable with the Company. It will as well as contribute towards good staff retention rates. This is particularly crucial in increasing stability within the organisation. It also makes employees come across with the firm and instils a sense of loyalty. Handy, 1999) Planning in the system of rules The Human Resource Departm ent is placed with the business of ensuring that it plans adequately for all the organisations future engagements that will involve people. One important aspect of this is planning for employees in the organisation. It is important that the organisation ensures that all the employees under its wing are just enough to increase value to the organisation. The Department indispensable ensure that staff members are not too many because if they exceed this amount, then the organisation stands too lose.It must plan adequately to ensure that staff members are not too few either, otherwise they will be over functional those who are already in place. Consequently, there will be paltry motivation resulting from fatigue. The HR department is also bestowed with the responsibility of planning future organisational goal in relation to people or elucidate these same goals to staff members. This function of the department ensures that people in the organisation have a general direction which th ey are working towards.Organisations that have a clear direction are always more(prenominal) effective those members of staff will be more result point rather than just working for the sake of it. The Department is also responsible for setting day to day objectives necessary for streamlining activities within the organisation and thus ensuring that work is not just done haphazardly. (Hyde, 2004) Negative Aspects of Functions and Roles of the Human Resource Department There are a number of problems that arise as the department goes about its activities Problems in RecruitmentThe department may whatsoevertimes be unable to adequately coordinate and incorporate all the employees involve in the Companys operations. One such example is the NHS. In the year 2004, the organisation was found to be wanting in its human resource departments functions. The Company was recruiting a large counterpoise of its employees 40% from Asian and African countries. This means that the organisation wa s draining medical personnel from those needy countries and using them for themselves. (Katherine, 2002) Such a practice showed that the HR department had exercised bad judgement in ts staffing function. Instead, it could have used these foreign nurses as temporary measure and put in place a strategy to train local nurses such that it could stop depending on those poor countries for supply of nurses. Problems in Remuneration In the process of trying to motivate members of staff to perform correct, the Human Resource may make deals that finally cause problems. A case in point is the theme Depot. This Company has an employee Compensation policy that requires that one should be rewarded for the time they have served the Company.The Home Depot Company offers an end of year bonus, basic salary and devote on stock shares as an incentive for some of its employees The CEO of the Company Robert Nardelli lost his job in the year 2007. This was because the company has experienced a lot of losings under his leadership its shares fell by eight percent in the stock exchange and he deserved to perish the Company. However, because the Human Resource Department had put in place a policy that requires all members of staff to be given the incentive mentioned above, he left with a lot of money. It was reported that he had with him about two hundred and ten million dollars.The Company had no way out of this payment because HR had already passed that policy and they were bound by the law. This goes to show that sometimes policies do by the HR department do not benefit the Company especially if the parties involved are considered as losses to the Company. (Michael, 2007) Problems in Planning Sometimes the HR Department can employ people who may not contribute towards organisational principles. A classic example is the Arthur Andersen Company that fell apart in the year 2002. This was an American Company that dealt with audits.It was initially very successful in its operation s prior to that disastrous year. But in the latter years of its operations, the Company was involved in two accounting scandals that tarnished its name and subsequently caused failure. The Company failed to plan well for the kind of employees it recruited. This was witnessed when one of its employees in the Legal Department called Nancy Temple was fined in the Court of law for non adherence to accounting laws. This problem could have been prevented if the HR department had evaluated this employee before hiring her and also evaluation should have been done during her performance.If HR had been extremely critical, then they would have earn that the employee did not adhere to Company principles and would therefore have terminated her employment. Beside this, the Arthur Andersen Human Resource department also failed in its communication function to employees. The department should have ensured that they constantly croak to members of staff about the goals and objectives of the Compan y on a day to day basis. This would have made them very clear in the minds of employees and would have prevented the twilight of the Company.Strategies to Improve Human Resource Departments Value to the Organisation fosterage and Internships It is not necessarily a guarantee that a nominee who did well in the recruitment exercise is the best in playacting an organisations functions. New employees need orientation into the Companys functions and can also improve some inefficiency that these new employees may have in relation to their skills. This is the purpose of placing them on internships. (Norbert, 1967) prep is also essential for members of staff who have been working for the organisation for a long time.This is especially so in the wake of technological advancements, legal changes and changes in serve well delivery. It is important for an Organisation to keep up with industry trends otherwise it faces the riskiness of becoming obsolete especially in the background of inc reasing competition. Training need not be restricted to improvement of skills it can also involve improvement of attitudes. This is normally characterised by attendance of workshops and other forms of talks. Training also increases motivation of employees and gives them that extra boost of energy needed to fare them through tough times in their jobs.All the above tasks are placed under the Department of Human Resource because it is the one that will asses when training is needed, who needs the training, where and by whom. This aspect is a sure to improve value of the HR Department in the organisation. An example of a company that adheres to this principle is Marks and Spencer retail chain outlet. The Company offers training for twelve moths. Here new employees are taught all that is necessary to meet organisational goals and objectives then they can start work when they are ready to do so. (Norbert, 1967) reservation Better Use of TimeThe Human Resource is conferred with the respo nsibility of ensuring that all members of staff perform to their best ability. It could improve this area by facilitating better use of time in all departments within the organisation. Time is one of the most crucial yet intangible assets of the Company. The proper use of this resource could maximise production and achievement of organisational goals. (Harold, 2003) The Department can do this by planning activities to be carried out in the organisation. It can make schedules for the mingled activities that have to be done in the organisation and thus drive on better flow of information.In addition to this, the Company can also ensure that all members of staff are held accountable for not performing a certain task. This is especially in regard to maintenance of the schedules. In so doing, human the Human Resource Department will be ensuring that employees do not simply report to work and that the time played out at work is directly proportional to output. Improving Organisational C ulture The Human Resource Department can try to improve organisational refining through a three step procedure. The first step of the process is observation.In this step HR finds out what makes ups or what the companys coating is like. HR should also be very intense on the organisational needs. Here, HR should realise that personal fulfilment works better and therefore should try to ensure that the change is relevant to every staff member. In this stage, HR should try to explain to all staff members or stakeholder the advantage of transforming the culture in the organisation. This should be made clear so that all can see the advantages at the individual level and not simply at the organizational level. Erica, 2006) Then HR should try to eliminate all inhibitions in staff members minds. It is possible that some may title that they tried one or two strategies before and it did not succeed. This are what are called cries of despair and HR should try its best to explain to staff membe rs the need of changing the culture of the organisation. The next step is the analysis of sundry(a) aspects. Here, there is collection of data needed in making certain that culture changes. This stage involves checking out the success features or the factors that can hurry its success. There should be calibration of data collected.Staff members should be made to understand that there are no perfect situations for implementation of changes. The analysis should involve assessing whether the information is sensible or not. Whether data gathered will be protagonistful or not and if it is too little or too much. Staff members should be requested for data that will help change the culture. Of course when trying to bring in change HR Department should have perceived benefits, a deadline for execution and also the realised gains in relation to the change in culture. In this step, there should be reality checks which should be done often.There should also be invariable integration. Thro ugh this scheme HR Department should be able to change the culture in the organisation and add value to it. (Harold, 2003) Conclusion The Human Resource Management teams main function is to manage people. There are positive and negative aspects of this function first of all, the HR department enriches the organisation through recruitment procedures and an example an effective HR team in this area is Tesco Ireland. HR department also ensures that members of staff follow a general direction by frequently clarifying and reminding them of the organisations goals.Besides this, they are also responsible for organising incentives or compensation packages to motivate employees. All these functions contribute towards organisational effectiveness. However, there are some negative aspects of HR it has to bear the burden of blame if an employee performs poorly like the Arthur Andersen Company. Besides this, some policies made by the department may be detrimental to the Company like in the Home Depot Companys case. Improvements to their role can be done by agreement training for staff members, organising activities for the organisation and changing organisational culture. (Erica, 2006)

Video Game Violence

Video patch force-out Video Game military unit Law Poses Questions, is an editorial located in the online magazine V Planet. Vance Velez, the origin of the controversial issue, opposes the chapiter fairness involving specific forms of delineation punt furiousness, which is on the verge of organism passed in the Legislature. He successfully persuades his earreach that the capital of the United States natural law force force limits mickles rights and that they should run into a stand against the proposed justice. His auditory sense includes mountain who atomic number 18 in favor of the capital letter equity, concerned p arnts, and self-aggrandising moving picture hazardrs that oppose the capital of the United States law, who be, in his rendering, those 18 or older.Those who atomic number 18 in favor of the law whitethorn include politicians, or mothers who sewer relate to influential military unit on children. Adult delineation gamers argon those who enjoy playing tv set games as a favorite pastime, fair(a) like golf or aerobics, for most Ameri hobos. Its no argument that television set games ar becoming more ruby, states Velez. Many p bents and politicians oppose the violence slightly point want to get these kind of icon games banned. A politician who opposes this specific form of violence is bloody shame Lou Dickerson. bloody shame Lou Dickerson is a State Legislator who has proposed a law to restrict certain crimson worldly in video games.The proposed law, which is quoted in the editorial, states Levies a fine up to five hundred dollars on anyone who rents or sh ars to or soone 17 or younger computing device games in which the player kills or injures a human form that is picture as a public law enforcement officer. Police officers and throw outfighters are include in that classification. Velez addresses many flaws in the proposed law in detail and as well as explains few consequences that may occur if the law is passed. Vance Velez is the causation of many editorials that out on this online magazine. His broad knowledge of video games allows him to pinpoint the important problems of the law.He successfully persuades people that are in favor of the law, that it may, in the long run, real harm our young. The authors primary(prenominal) argument throughout the editorial is backed by issuing a series of examples how many games that do not thwart young children, may be banned beca office of a faulty law. He mentions that passing the law go remote(predicate) limit peoples rights and may in addition act as a gateway law, to limit others rights. If they bespeak away our right to buzz off fun and view what we enjoy, then what else volition they take away when violence is still present in our connection? Vance Velez explains in detail why people should oppose the capital of the United States law on video games. Although he does introduce and define many term involving video games, he expects the reader to at least confirm both(prenominal) knowledge about video games. He addresses many games, like Simcity and sniffy Theft Auto, which have been in the mainstream lately therefore, readers must be up to date with video games and must be familiar with certain faceface of video games in order to understand the authors references. Velez addresses prominent video gamers and lets them know that their precious games may be lost, so he urges them to take action and protest this pending law.Velez opposes the capital letter law beca social occasion it violates peoples rights. Velez stand that taking away things develop Americans enjoy would be a crime in itself beca implement it violates the Freedom of destination rights. In his rendering a bestride American is a mortal who knows right from maltreat. He states, The cap law, beca subroutine its built on business organization of the unknown and lack of communication, fails to recognize the freedom of speech r ights. The author uses countersign by referring to peoples values of their rights. The author opens the first split up with a question, Whats the right way to protect children from violence? He challenges to those who are against video game violence and lets them know that he wants safety for our young with the use of good reasons. He gains trust from this reference by viewing he wants things for the better. His definition of children includes those who have a sense of right and aggrieve but are still easily influenced. He believes that video games arent harming children its some other factor that is the reason why video games are harming really young kids, such(prenominal) as lack of parent guidance and discipline. Velez negotiation about this later on in his editorial.He then uses pathos to hail to the feelings of concerned parents, and those who are in favor of the majuscule law, as he states, This is the fourth time that politicians have tried to pass laws regulating untamed content in video games. This interview sees how helpless and unsuccessful the governance is when it comes to passing these types of laws. This listening feels sorry for the regime, they sort of sapidity down at them shame. Those who are in favor of the Washington law may draw to think that people who cant drive up their minds set up our country.They may start to question the proposed law and wonder if it too, will fail. Velez quotes Mary Lou Dickerson, who explains what the state legislator really thinks about video games in response to a lawsuit. The lawsuit filed today against Washingtons ban on sales or rentals of cop-killing games to children comes as no surprise. Certain elements of the video-game industry clearly want the right to grass any game, no matter how brutal, racist or sick, to any child, no matter how young. Velez rebuts this argument by initially stating its in intrusion of Freedom of address rights. Politicians are actually trying to ban base less video games which are a pastime that many liberal Americans enjoy. By bragging(a), Velez states that he means, Those people who are 18 or older. He persuades this reference to take action by standing up against the law. Velez remarks, Taking away an individuals right to have fun and enjoy video games can be argued as a trespass. The author is addressing heavy(p) gamers when he states this because they have the energy to stand up against such laws.The authors statements threaten bragging(a) gamers and force them have a sense of danger that their lives are be controlled. Velez grows his argument by mentioning games that are harmless, in his opinion, which may be banned because they violate the grounds of the Washington law. His example of the game Simcity, appeals to word of honor and ethos by explaining how an educational game would be in misdemeanour of the law. He says, In the game of Simcity, you can cause a minor accident in your city by causing a tornado, an earthquake or a flood.These haps can destroy the police station or stop department, which would be in misdemeanor of the proposed Washington law. His audiences are those who are for the Washington law and concerned parents when he explains how innocent games, according to Velez, are the victims of the proposed law. He persuades them by making them examine not all violent video games are harmful to children. I think if this audience is familiar with the game of Simcity, they would agree that it is not a violent game, but the author makes them crystallise that their values will be lost if the law passes, by the use of pathos.Many video gamers would dumbfound this offensive because they arent able to enjoy their innocent games. The audiences emotions are being involved in this carve up with the use of pathos. The authors ethos is clarified once his familiarity and expertise with video games produce to show and as he introduces situations that are possible once the law is pass ed. In another example of a harmful video game, the definition according the Washington law, Velez introduces the game Rampage, where giant gorillas and lizards destroy cities, similar to queen Kong.The author explains that in the game the animals are capable of crushing police stations and police cars. Rampage, which attracts gamers between the ages of eight and sixteen, would be in violation of the Washington law. The author introduces the silliness of the Washington law. He makes the audience construe that highly fictional characters arent harmful to children however, he states, In the governments eyes, they will make children grow up to be terrorists. Velez describes the many holes the proposed law contains.Those who are for the Washington law are persuaded with word of honor in this situation because they believe it is entirely fair for children or tear down adults to have fun if the game is totally safe. They may likewise think of other forms of give intainment that ma y likewise be involved with this kind of law. They imagine other situations where law enforcement officers are portrayed or killed, such as in numerous movies such as, Robin Hood and Lethal Weapon. Why arent these issues being address? Are video games that much worse than violent movies and plays?In his exsert paragraph, Velez explains his beliefs involving the problems of violent video games. His finger points to government and most importantly, the childrens parents. He explains that parents have the responsibility to judge what their child sees and adjudicates. Some adult audiences might dumbfound his accusation offensive and may get turned off by his remarks, because they are blunt and obtrusive. An example of this is when he remarks, The parents should be responsible ample to monitor their children and make sure that that particular game does not innovate the console (videogame system) itself. Reasonable adult audiences may actually listen to run into what the author is trying to get across.His use of tidings appeals to those who are in favor of the Washington law because he makes them think about how parents could be the source of the problem. They may agree that parents need to be on the search out for what is safe and unsafe for their children. Velez explains that parents allow children to play violent video games that influence children to do harm which portray video games as the main source of the problem. Its easier to blame an image or machine than it is to blame people, Velez said. The parent problem may make more sense to his opponent audience if they arent biased and read the editorial with an open mind. In conclusion, Vance Velez was really familiar with his topic, which gave him sufficient credibility to persuade those in his audience who are in favor of the Washington law, to think twice about their rig and possibly accept his belief, that passing the Washington law is a mistake.Hes also successful at persuade adult gamers, those 18 or older, to take action against the proposed Washington law. His arguments were well thought out and persuade by using logos and pathos. However, his alternative to the Washington law was a bit broad and didnt really include a solution. He identified the problems that might occur if the law is passed, such as the departure of Freedom of Speech Rights, but he had no feedback on how else to guide with the situation. I believe authors overall argument was persuading even though he didnt include a proposed solution.Video Game ViolenceVideo Game Violence Video Game Violence Law Poses Questions, is an editorial located in the online magazine V Planet. Vance Velez, the author of the controversial issue, opposes the Washington law involving specific forms of video game violence, which is on the verge of being passed in the Legislature. He successfully persuades his audience that the Washington law limits peoples rights and that they should take a stand against the proposed law. His audience includes people who are in favor of the Washington law, concerned parents, and adult video gamers that oppose the Washington law, who are, in his definition, those 18 or older.Those who are in favor of the law may include politicians, or mothers who can relate to influential violence on children. Adult video gamers are those who enjoy playing video games as a favorite pastime, serious like golf or aerobics, for most Americans. Its no argument that video games are becoming more violent, states Velez. Many parents and politicians oppose the violence some even want to get these kind of video games banned. A politician who opposes this specific form of violence is Mary Lou Dickerson. Mary Lou Dickerson is a State Legislator who has proposed a law to restrict certain violent natural in video games.The proposed law, which is quoted in the editorial, states Levies a fine up to euchre dollars on anyone who rents or sells to someone 17 or younger data processor games in which t he player kills or injures a human form that is depicted as a public law enforcement officer. Police officers and firefighters are include in that classification. Velez addresses many flaws in the proposed law in detail and also explains some consequences that may occur if the law is passed. Vance Velez is the author of many editorials that appear on this online magazine. His broad knowledge of video games allows him to pinpoint the main problems of the law.He successfully persuades people that are in favor of the law, that it may, in the long run, actually harm our youth. The authors main argument throughout the editorial is backed by issuing a series of examples how many games that do not display young children, may be banned because of a faulty law. He mentions that passing the law will limit peoples rights and may also act as a gateway law, to limit others rights. If they take away our right to have fun and view what we enjoy, then what else will they take away when violence is still present in our club? Vance Velez explains in detail why people should oppose the Washington law on video games. Although he does introduce and define many damage involving video games, he expects the reader to at least have some knowledge about video games. He addresses many games, like Simcity and high-minded Theft Auto, which have been in the mainstream lately therefore, readers must be up to date with video games and must be familiar with certain type of video games in order to understand the authors references. Velez addresses adult video gamers and lets them know that their precious games may be lost, so he urges them to take action and protest this pending law.Velez opposes the Washington law because it violates peoples rights. Velez stand that taking away things mature Americans enjoy would be a crime in itself because it violates the Freedom of Speech rights. In his definition a mature American is a someone who knows right from wrong. He states, The Washington la w, because its built on panic of the unknown and lack of communication, fails to recognize the freedom of speech rights. The author uses logos by referring to peoples values of their rights. The author opens the first paragraph with a question, Whats the right way to protect children from violence? He appeals to those who are against video game violence and lets them know that he wants safety for our youth with the use of good reasons. He gains trust from this audience by exhibit he wants things for the better. His definition of children includes those who have a sense of right and wrong but are still easily influenced. He believes that video games arent harming children its some other factor that is the reason why video games are harming genuinely young kids, such as lack of parent guidance and discipline. Velez dialog about this later on in his editorial.He then uses pathos to appeal to the feelings of concerned parents, and those who are in favor of the Washington law, as he states, This is the fourth time that politicians have tried to pass laws regulating violent content in video games. This audience sees how helpless and unsuccessful the government is when it comes to passing these types of laws. This audience feels sorry for the government, they sort of look down at them shame. Those who are in favor of the Washington law may stick to think that people who cant make up their minds groom our country.They may start to question the proposed law and wonder if it too, will fail. Velez quotes Mary Lou Dickerson, who explains what the state legislator actually thinks about video games in response to a lawsuit. The lawsuit filed today against Washingtons ban on sales or rentals of cop-killing games to children comes as no surprise. Certain elements of the video-game industry clearly want the right to sell any game, no matter how brutal, racist or sick, to any child, no matter how young. Velez rebuts this argument by initially stating its in violation of Freedom of Speech rights. Politicians are actually trying to ban violent video games which are a pastime that many adult Americans enjoy. By adult, Velez states that he means, Those people who are 18 or older. He persuades this audience to take action by standing up against the law. Velez remarks, Taking away an individuals right to have fun and enjoy video games can be argued as a violation. The author is addressing adult gamers when he states this because they have the talent to stand up against such laws.The authors statements threaten adult gamers and make them have a sense of danger that their lives are being controlled. Velez begins his argument by mentioning games that are harmless, in his opinion, which may be banned because they violate the grounds of the Washington law. His example of the game Simcity, appeals to logos and ethos by explaining how an educational game would be in violation of the law. He says, In the game of Simcity, you can cause a minor disaster in yo ur city by causing a tornado, an earthquake or a flood.These disasters can destroy the police station or fire department, which would be in violation of the proposed Washington law. His audiences are those who are for the Washington law and concerned parents when he explains how innocent games, according to Velez, are the victims of the proposed law. He persuades them by making them lay down not all violent video games are harmful to children. I think if this audience is familiar with the game of Simcity, they would agree that it is not a violent game, but the author makes them realize that their values will be lost if the law passes, by the use of pathos.Many video gamers would find this offensive because they arent able to enjoy their innocent games. The audiences emotions are being involved in this paragraph with the use of pathos. The authors ethos is clarified once his familiarity and expertise with video games begin to show and as he introduces situations that are possible o nce the law is passed. In another example of a harmful video game, the definition according the Washington law, Velez introduces the game Rampage, where giant gorillas and lizards destroy cities, similar to tabby Kong.The author explains that in the game the animals are capable of crushing police stations and police cars. Rampage, which attracts gamers between the ages of eight and sixteen, would be in violation of the Washington law. The author introduces the silliness of the Washington law. He makes the audience realize that highly fictional characters arent harmful to children however, he states, In the governments eyes, they will make children grow up to be terrorists. Velez describes the many holes the proposed law contains.Those who are for the Washington law are persuaded with logos in this situation because they believe it is further fair for children or even adults to have fun if the game is only safe. They may also think of other forms of entertainment that may also be involved with this kind of law. They imagine other situations where law enforcement officers are portrayed or killed, such as in numerous movies such as, Robin Hood and Lethal Weapon. Why arent these issues being turn to? Are video games that much worse than violent movies and plays?In his snuff it paragraph, Velez explains his beliefs involving the problems of violent video games. His finger points to government and most importantly, the childrens parents. He explains that parents have the responsibility to judge what their child sees and hears. Some adult audiences might find his accusation offensive and may get turned off by his remarks, because they are blunt and obtrusive. An example of this is when he remarks, The parents should be responsible enough to monitor their children and make sure that that particular game does not enter the console (videogame system) itself. Reasonable adult audiences may actually listen to hear what the author is trying to get across.His use of l ogos appeals to those who are in favor of the Washington law because he makes them think about how parents could be the source of the problem. They may agree that parents need to be on the look out for what is safe and unsafe for their children. Velez explains that parents allow children to play violent video games that influence children to do harm which portray video games as the main source of the problem. Its easier to blame an image or machine than it is to blame people, Velez said. The parent problem may make more sense to his opponent audience if they arent biased and read the editorial with an open mind. In conclusion, Vance Velez was precise familiar with his topic, which gave him enough credibility to persuade those in his audience who are in favor of the Washington law, to think twice about their daub and possibly accept his belief, that passing the Washington law is a mistake.Hes also successful at convincing adult gamers, those 18 or older, to take action against the proposed Washington law. His arguments were well thought out and convincing by using logos and pathos. However, his alternative to the Washington law was a bit broad and didnt really include a solution. He identified the problems that might occur if the law is passed, such as the dismissal of Freedom of Speech Rights, but he had no feedback on how else to trade with the situation. I believe authors overall argument was persuading even though he didnt include a proposed solution.

How does Shakespeare develop character, plot and theme in Act 3 scene 4 of Macbeth? Essay

In this essay, I will answer the head teacher How does Shakespe ar develop char fermenter, plot and theme in second 3 scene 4 of Macbeth? by divulging into Macbeth written by Shakespeargon. Macbeth is a play with issues such as military force, villainy, assassination, deceit and snake pit, which are die badly for during twist 3 scene 4 of Macbeth. This scene is where all the issues grouping to findher to form a scene of evilness of human.Macbeth was a gentle at the start, became the Thane of Cawdor and assassinated office Duncan to thrust himself to power. Although he regretted for murdering baron Duncan since lady Macbeth encouraged him to murder Duncan.He thats coming must be provided for, and you shall put this nights great business into my dispatch, which shall to all our nights and geezerhood to come give solely sovereign s sort and masterdom. (Lines 64 to 67, Act 1 eyeshot 6) peeress Macbeth used veiled words because she was afeared(predicate) that direct langu age would make Macbeth refuse to act. This is narrate for Macbeth was originally a kind and non ambitious person, however, afterward doll Macbeths persuasion he decided to crop up King Duncan.After Macbeth became King, he circulate assassin to murder Banquo. During the banquet, he received the news of Banquos goal entirely Banquos son managed to escape.Here had we now our countrys honour roofed, were the graced person of our Banquo present.(Lines 40-41, Act 3 scene 4)This quote do by Macbeth means if solitary(prenominal) Banquo were here, all the nobility of Scotland would be beneath our roof. In addition, it returns he pretended he did not know Banquo had been hit and to cross-file the Scots Lords his kindness and respect to Banquo until now he is the King now. However, when Banquos touch suddenly appeared in front of him only if no bingle could dupe Banquos ghost. Macbeth was terrified and astonished because he was the only one who knew Banquo is already dead .Thou canst not say I did it never shake the gory locks at me?(Lines 50-51, Act 3 scene4)First, it is highly glutinous that the King suddenly say something weird that does not relate to the dinner. Additionally, from the Scottish lords view, Macbeth seems had do something bad and trying to extend it from them which created a feeling of chaos and unsafe. Further more(prenominal), it is a sign that Macbeth is not suitable to be a King.Ay, and a bold one, that dare look on that which might appal the jaw (Lines 58-59, Act 4 scene4)Avaunt and quit my sight Let the earth hide thee Thy bones are marrowless, thy blood is cold Thou hast no guess in those eyes (Lines 93-95, Act 3 scene4)I personally would sound off Macbeth was mad even though his married woman was trying to persuade commonwealth this is modal(prenominal) and all the things he said are like hints that he had murdered someone who we do not know and he is back. In my opinion, no guests would expect this from Macbeth beca use he had never be put one overd in this weird way and he is very brave man since he had killed many battalion in battles. dame Macbeth was a dominant character. She was portrayed as ambitious, acqui stickive to power by Shakespeare. When bird Macbeth was first introduced in the play, she was reading a letter from Macbeth, which was describing the three weird sisters prophecy.He brings great news (Lines 36, Act1 scene5)At this point, her only concern was whether Macbeth is capable of fulfilling the prophecy and certainly, she would grab hold of this aspect to persuade Macbeth to do it in order to satisfy her hunger to power. The side by side(p) quotes made by Lady Macbeth states how she criticizes Macbeth.If we should check?(Macbeth, Lines 58, Act 1 scene7)We fail?(Lady Macbeth, Lines 59, Act 1 scene 7)The quote made by Lady Macbeth shows she believes her hubby should become ambitious and be confidence. In addition, Lady Macbeth did not insult Macbeth because this would only make Macbeth feel even worst of him. At this point, she was disappointed by Macbeth since she could not believe her husband did not show any determination to make use of this excellent chance to kill King Duncan and fulfill the prophecy and to satisfy her hungriness to power.And live a coward in thine deliver esteem, letting I dare not deferment upon I would (Lady Macbeth, line 43, Act 1 scene 7)I have given suck and know how tender tis to love the babe that milks me I would, while it was smiling in my face, Have plucked my nipple from his boneless gums and dashed the brains come erupt, had I so sworn as you have through with(p) to this. (Lady Macbeth, Line 54-59, Act 1 scene 7)Furthermore, due to emotions Macbeth is feeling at this point, he tells his wife the couple will will proceed no further in this business, which explains the assassination would not happen due to the respect King Duncan had recently showed him, he was not willing to need out the plan. This frustrates Lady Macbeth and leads her using an separate tactic to persuade Macbeth to stand on her side. Example of another tactic is calling Macbeth as a coward, and informs him she would rather kill a newborn baby rather than fracture a promise like the one Macbeth has to her.On the other hand, she had tried and true to cover up for Macbeth even though she did not know what only was happening to Macbeth. The following quote made by Lady Macbeth shows her affright to Macbeth even Macbeth did not tell her Banquos last which states he did not trust her wife.Sit, worthy friends. My lord is of often thus, and hath been from his youth. Pray you keep seat.(Lines 53-54, Act 3 scene4)I pray you speak not he grows worsened and worse. Question enrages him. At once, good night. Stand not upon the order of your going, but go at once.(Lines 118-121, Act 3 scene 4)These two quotes are major piece of evidence, which suggest Lady Macbeth was putting huge amount of effort to cover for Macbeth and this shows she really loved him and she knew there is something that Macbeth had done but has not informed her yet which is a hint for Macbeth no bimestrial trusted Lady Macbeth.The Scottish lords were playing a less authorized role in the play compared to Lady Macbeth and Macbeth. However, they were dumb important since they fight back the Scottish government. Macduff and Ross were the two key lords in the play since they were envious near Macbeth (apart from Banquo).Ist kn make who did this more than spread over deed?(Ross, line20, Act 2 Scene4)Those that Macbeth hath slain. (Macduff, Line 21, Act2 scene4)A supportive quote made by Macduff, which supports that Macbeth is envious because Macduff did not assume any other people killed King Duncan but only assumed Macbeth murdered King Duncan. Moreover, the following quote shows he dislike Macbeth.Will you to Scone?(Ross, Line 35, Act2 Scene4)No, cousin, Ill to Fife.(Macduff, Line36, Act 2 Scene4)An extremely supportive evidence f rom Macduff to support argue that Macbeth was the murderer because Macduff did not requisite to go to the Scone and instead he would like to go to Fife. Under popular circumstances, all the lords would attend to this kind of important ceremony but Macduff had elect to ignore it which is out of order. In my opinion, at this point of the play Macduff seems to be suspicious some Macbeth.This is mainly due to the worsen friendship betwixt Macbeth and Macduff since Macbeth killed the guards who look related to Duncans death without allowing anyone to ask them a question and the guards were the only clue for King Duncans death. This leads other people to think why Macbeth just killed the guards who were drunk and had damn daggers in their hand. As a result, Macbeth became suspicious to Duncans death. From a third persons view, Macbeth seems to be trying to cover the truth.In addition, during the Banquet Macbeth suddenly saw a ghost of a bloody man and he was terrified about this whic h is unusual because he used to be a general and then he would not be afraid of dead people. This made Macbeth became even more suspicious because after he became King, disorders and chaos has been consecutively occurring. Additionally, the lords would oppugn the relationship between Macbeth and a ghost of bloody man because they would agitate if Macbeth were the suitable one for this position.The relationship between Macbeth and Lady Macbeth was complex and hard to analysis because it has been changing throughout the play. At the beginning of the play Lady Macbeth was introduced as a kind and loving wife, who underneath was a designing and deceitful person. She received a letter from Macbeth about the weird sisters prophecy.It is also full othmilk of Human Kindness to occlusion the nearest way.(Line 15, Act 1 scene 5)Lady Macbeth would like to get a line the fastest route to royalty by murdering King Duncan, however she knew Macbeth is not ready for this since recent respect from King Duncan makes Macbeth loyal to King Duncan. Additionally, they are friends and Duncan is a good King therefore there was no power to kill him.Wouldst thou have that which thou esteems the illustrate of life, and live a coward in thine own esteem.(Line 41-43, Act1 Scene7)She called Macbeth a coward that live in thine own esteem because she is deeply desire to gain more power and the only way is to be queen but this needs Macbeth to uphold with her, however, Macbeth was not ready to murder King Duncan. Therefore, she insulted her husband to intimidate her husband to satisfy her own need. At this point, their relationship is poor because Lady Macbeth was forcing her own husband to do something he was really willing to do.Immediately after the murder of King Duncan, Macbeth was remorseful and frightened. When she heard Macbeth was talking about his bloody hands, she says My hands are of your color, but I shame to wear a heart so white.(Lines 68, act 2 scene 2)This is eviden ce that Lady Macbeth was on the same side as Macbeth as she meant her hands are red too, but she was not regretful as she said she would be ashamed to have a heart so white.In act 3 scene 2, we know that Macbeth have not been communicating as well as before Duncans death, because Lady Macbeth had to ask the servant to call for Macbeth therefore she could talk to him.When Lady Macbeth asks, whats to be done, Macbeth did not want to tell her and since he did not want his wife to get further involvement in this mess. Therefore, he repliedBe bare of the knowledge, dearest Chuck.(Lines 45, Act 3 Scene2)This quote can be evidence for both side arguments. The first side is Macbeth did not trust his wife anymore therefore he refused to let her know anything. On the other hand, Macbeth really loved his wife and he attempts to protect her from this mess. In my own view, he did not trust Lady Macbeth because it was she who encouraged him to get unloosen of King Duncan and disorders and chao s had been brought in.After Lady Macbeth had asked all the guests to get out in the last part of Act 3 scene 4, I believe Lady Macbeth was in charge because she asked Macbeth all the questions and Macbeth answered all of them. At last, he listened to his wife to go to log Zs.You lack the season of all natures, sleep (line 141, Act 3 Scene 4)Come, well to sleep. (Line 142, Act 3 Scene4)They started to cooperate again, which is a signal that their relationship is developing because they both helped each other out in the banquet. If Lady Macbeth did not love Macbeth so much she would not in an attempt to restore order and made him act normal again. Nevertheless, she could do that for other reasons. Such as she might be more worried about Macbeth leaked out the secret about Duncans death than Macbeth mental health state.In Act 5 Scene 1, Lady Macbeth said she could see Duncans blood on her hands and tries to gargle it off, but nothing could was it away.Heres the smell of the blood sti ll all the perfumes of Arabia would not sweeten this little hand.(Line 43, Act 5 Scene 1)This could made by Lady Macbeth is a strong evidence to show her she is mad because no one could see the blood and only she could. Additionally, she had been woefulness from this for a period. Afterward, she committed suicide because she could not cope with the guilt of murdering King Duncan.There are many different themes. The most famous one is order/chaos and followed by the difference between the false and the real.In Act 3 Scene 4, as the banquet begin the lords were told to sit down in order because it is a formal dinner. However, during the process, Macbeth went crazy because he said he saw a ghost of a bloody man, which is odd. At the end, all of the guests were told to get out as soon as possible but all in once. The banquet had started in order, perfect in chaos. This is a demonstration of the Kingdom because when King Duncan was ruling everything was normal, no chaos but when Macbet h ruled the country chaos and disorders were brought in since he had to hide the truth but he was becoming more suspicious and therefore he killed all the people who he believes is trying to get rid of him. At last, blood will only bring in more blood.An example for difference between false and the real is whether Banquos ghost is real. This depends on the director to decide to bring on a Ghost or not. Of all the characters on stage, only Macbeth could see the Ghost. The advantage of an invisible Ghost is the audience will know what is genuinely happening instead of guessing what Macbeth is doing on the stage. However, the downside is as the ghost sibyllic to be invisible, so no one should able to see and this includes the audience. some other tricky question of putting on a visible ghost is what does he wear and how does he move?

Walmart vs Amazon

Oder succeeder and qualifiers Today there are over 4,000 Walmart Stores in the U. S. and over 3,000 internationally. In other side, amazon is the worlds largest online retailer. so both of them must(prenominal) be covering the elements of business quite well. There are close to(prenominal) aspects that I want to talk how they win enunciates from customers. First, both of them have a let loose price of their products. Second, they have fantastic lineament management and customer services. Finally, their talkies are satisfied by customers. First, both of them have a natural depression price of their products. Wal-mart gives an advertisement that said Low Prices.E truly Day. Everywhere. Wal-mart has focused on low cost leadership, low operation and production costs in establish to ensure that each produce has the low possible price. Therefore, in customers mind, they go away think Wal-mart equals to the lowest prices. There is a disadvantage of Wal-mart. If Wal-mart qui te a littlenot provide the lowest price one day, then customers leave be no emergency to shop at Wal-mart. For amazon, its strategies of low price are totally diametrical from Wal-mart. Customers end stir up the lowest price of products from Amazon because customers faecal matter repugn with Amazon on Amazon.It means there are multiple prices for a product on Amazon. Then, you can find the lowest price. In addition, sometimes, Amazon will provide some price polices. For example, if customers bought products from Amazon. Then the price drops. Customers can get some refund from Amazon. Also, if customers buy products very often, they can be Amazons prime. Customers should pay about seventy dollars per year. Then, they can get cheaper price of the product compare with general customers. Moreover, customers can get set-apart shipping or shipping in a shorter time of some products. Furthermore, customers can shop through using Amazon credit card.They can get 3% fend for on any (prenominal)thing they buy from Amazon, 2% back at gas stations, restaurants, and drug stores, and 1% back on anything from any other retailer. Second, they have fantastic quality management and customer services. Wal-mart has a strong focus on better quality. It worked with several hundred suppliers and products interrogation facilities. They will test more than 5,250 products to ensure great value quality is equal to or better conduct more than 2,700 consumers to compare the flavor, aroma, texture, color, and air of great value products Change the formulas for 750 items including breakfast ereal, cookies, yogurt, laundry detergent, and paper towels and put in more than 80 new products, such as thin rancour pizza, fat rationalise caramel swirl ice cream, strawberry yogurt, organic fertiliser cage-free eggs, double stuffed sandwich cookies, teriyaki beef jerky and more, all at unbeatable prices. From Amazon, it has customer product review under each product, so customers ca n see what other customers thought. They will know the product quality is unattackable or bad. Then, they will decide whether they will buy it or not. Furthermore, it is very easy to return products to Amazon. Finally, their deliveries are satisfied by customers.Walmart can deliver product to your door, and the product price is the same as in store. From Amazon, as I mentioned before, customers can be the Amazon prime. Then, they can get free shipping or shipping in a shorter time. In additional, Amazon does international shipping. It is very convenient for international students. Furthermore, it can guarantee speed delivery. Amazon. com offers Guaranteed Accelerated Delivery dates on select items when you choose Express shipping. If your order doesnt arrive by the Guaranteed Accelerated Delivery date, your shipping charges will automatically be refunded.