The Cost of Language Switch of Bilinguals Essay

The Cost of Language Switch of Bilinguals - Essay Example This paper culminates in form of a discussion and suggestions to the educators and for the bodies of knowledge covering the entirety of the spectrum of stakeholders in the language learning and acquisition and domains particularly for bilinguals Bilingual speakers normally have to shift across the two languages in their communication activity and particularly in speech production. The fundamental fact here is that the bilinguals have to separate their two languages and settle for the appropriate lexical alternative; one language for effective communication purposes. Abutalebi J et al 2007) note that in the sense of the foregoing, the process entails that the bilinguals have to be possession of effective neural mechanisms that will suffice to facilitate smooth switching and to avert the highly likely chances of interference or the probable competition between the two language alternatives. This is particularly so considering the fact that the first and second languages both posses protruding neuro-anatomical bases as illuminated by the topical neuro-imaging researches. Bilinguals have to possess feasible lexical selection. This highlights the dynamics that characterise the process in which bilinguals have to go through in the techniques of switching between languages. The switch demands various neural mechanisms and facilities which have been illumined by various researches and propounded models. The broad range of varying challenges or costs that a bilingual incurs in the process of switching between languages demands a deeper exploration. The process evidently involves various psychological transitions and processes which will be explored in this study. Literature Review The concern and keen interest around the nature of costs and processes entailed in the switch between languages by bilinguals has received overwhelming contributions from various researchers, scholars and professionals. The studies, experimentations and researches conducted shed valuable light on the nitty-gritties of the language switching process of the bilinguals. Rodriguez-Fornells et al (2002) have presented that the processes of language switching for bilinguals can be accomplished on the basis and facilities of effective neural mechanism that will suffice to prevent distortion and interference and even the projected tendency of competition involving the two languages of the bilingual. The scholars have reinforced that the foregoing is particularly so in view of the fact that the first and second languages have both overlapping neuro-anatomical foundations that have been enunciated in researches focused on neuroimaging. In the contributions made by Costa et al., 1999; (2004) there is a presentation and outline of two salient models. The scholars have proposed two kinds of neuro-cognitive theories and frameworks on the matter of lexical selection mechanisms. One of the model types takes a thrust articulating that in the language switching processes only words in a particular language system are activated. In this framework the researchers

Violent content in media and controversy surrounding it Essay - 1

Violent content in media and controversy surrounding it - Essay Example This means that the violence depicted in animated films with violent theme do not have corresponding violent impact on the people watching them. Mostly, children and adolescents are the ultimate targets of animated TV programs or films and it is important to know what some of the prevailing research studies have to say about the impact of media violence on children and adolescents. The significant research designs reveal that media use does not lead to real-life violence, but to hostility and indirect violence (Kuntsche 230). However, in order for these hostility and indirect violence to develop, excessive media use must be a must. This means that adolescents without excessive exposure to violent content in the media are likely not to develop behaviors pertaining to hostility and indirect violence. In other words, one cannot generalize the point that exposure to media with violent themes lead to violent behavior of the viewers. There must be linked level of exposure to it, but this d oes not suggest that media violence has direct result to the emancipation of violent behaviors. In the first place, researchers do not know for sure how exactly and to what extent the media leads to long-term changes in aggressive behaviors (Surette 68). However, one thing that is clear is that many people who are exposed to media violence show no evidence of violent behaviors (Gentile 24). This means violence is something that may be triggered by other essential factors aside from the excessive exposure to violent media. This is a strong point of those who believe that media violence does not lead to violent behaviors. For them, violence is something that is caused by other factors and in no way that media violence is responsible for delinquent behaviors. For them, animated movie films or programs have no significant impact on the individual’s violent behavior tendency. After all, the occurrence of

Answering one of the following questions Research Paper

Answering one of the following questions - Research Paper Example However, citizenship to any state comes with duties and responsibilities and USA is not an exception. Becoming US citizen occurs through two significant processes including being born in USA when the parents are American citizens. Another way for foreigners is by naturalization. This involves an application to become US citizen after staying in USA for some time. The great depression affected US policies through the implementation of then president Franklin Delano Roosevelt in his New Deal1. Before the great depression on October 29, 1929, when stock market crashed, American citizens had adopted a new lifestyle of spending more on consumable goods. At the same time between 1922 and 1928, many Americans estimated at 1.5 million had bought stocks while seeing it as an easy way to make ‘fast’ money2. American women had no rights of choosing lifestyle such as smoking. In 1904, one woman was arrested for smoking in public in New York City3. In the period before the depression, American women and their children’s citizenship depended on their race and marriage. Under the naturalization act of 1907, any American born woman would lose her nationality citizenship if they were married to noncitizens. In addition, during the period between 1855 and 1930s, children born overseas to women born in United States did not automatically become US citizens but they would only if their fathers were Americans4. The constitution mediated the nationality of women through races and marriages. In the early 1930s, women through use of women’s group pressured for removal of the barriers to independent nationality. In early in 1700s, aliens obtained US citizenship by living in the country for a minimum of 5 years. This allowed African-Americans taken as slaves to obtain American citizenship. The process involved two sections of 3 years staying in US then applying to become citizens. Two additional years were required to petition application in court. Between 1900 and

In a large number of situations both insurers

In a large number of situations both insurers â€Å"In a large number of situations both insurers and the courts recognise that the doctrine of subrogation in insurance may have unfortunate results and is wasteful. It is clear that the doctrine no longer serves any useful purpose†. Discuss. INTRODUCTION It has been recognised that fundamentally it is tort law that ensures compensation for loss in terms of compensation within the concept of the tortfeasor restoring loss through damages being paid to the person wronged[1]. In terms of insurance this liability can be revealed through the idea behind third party liability, the first party being the insured, the second party being the insurer, and the third party relating to any potential for restitution needing to be paid to anybody not included within the terms of the contract who might have met some sort of loss through the actions of the insured person, eventually becoming incorporated into the law of liability. Meanwhile, subrogation[2] has been defined as â€Å"the substitution[3] of one person in place of another with reference to a lawful claim†[4] or, more simply, the recognition in law that a lawful claim may be pursued by a third party in accordance with the principles of substitution[5]. Various types of subrogation are recognised, revealed as legal, statutory and conventional subrogation, the latter relating specifically to the terms of a contract, the legal revealed in allowing one individual to assume the rights over another and the statutory occurring as a result of the law being applied in terms of legal subrogation. This essay, focuses on the tenets of insurance law through which the principle of indemnity is revealed through the doctrine of subrogation in terms of its conventional interpretation within its statutory framework, i.e. as a remedy in â€Å"what might be classified as unjust enrichment in a legal system that is based upon the civil law†[6]. Subrogation originates from both common law and the laws of equity and it is also through both equity and common law that it continues to be administered, with the law of restitution recognised as a quasicontract within common law rather than incorporated into the laws of contract[7] or the law of tort. It has, however, become clear that this doctrine of subrogation no longer serves any useful purpose and has by been recognised both insurers and the courts that, in many situations, it may have unfortunate results and is wasteful. This essay discusses the issues surrounding the concept of subrogation and presents an argument that suggests that the function of this doctrine is, indeed, outmoded, inefficient and costly. DISCUSSION No Profit Rule Any capricious risk reassigned through a contract of insurance is subject to various fundamental assumptions, one of which is the factor surrounding that risk’s arbitrary nature. Through the element of ‘utmost good faith’[8] it is expected that the person to be insured discloses everything that could be relevant to the risk that the insurer is taking when it has agreed to insure the client[9]. Similarly, the client may not be put at a disadvantage by any actions the insurer may undertake, with a number of regulations to ensure that the insurer adheres to acceptable practices and the insured does not, through any misrepresentation, preclude any entitlements owed to the insurer[10]. Under the terms of the ‘made whole principle’ the insured person must be reimbursed in full prior to any profit being considered liable to the insurer, and the insurer may not implement the doctrine of subrogation until the insured person has been reimbursed in full[11], exc ept where a clause in the policy enables the insurer to apply the principle of subrogation when only partial payment has been made. Nevertheless, insurers are within their statutory rights to offer a voluntary settlement to the insured person and then pursue judgment with the expectation of receiving full compensation through implementing the doctrine of subrogation against the third party’s liability insurance. However, the client may not jeopardise the trust that exists between insurer and insured by claiming more than their loss[12], more recently the basis of a case where a Canadian Court of Appeal reduced the amount of compensation received by the Appellant, while they: â€Å"imposed significant punishment for the bad faith of the respondent without upsetting the proper balance between the compensatory and punitive functions of tort law†. Although in English law claiming more than the actual loss is not specifically illegal, to do so would be in breach of equitable principles and the doctrine of indemnity which assumes that the insured person would not make a profit from their loss. The doctrine of subjugation may be used in certain cases, stipulated by the courts, in order to remedy situations[13] whereby an unjust profit had been made, in accordance with the explanation given by Lord Diplock in Orakpo v Manson Investments Ltd: â€Å"It is a convenient way of describing the transfer of rights from one person to another, without assignment or assent of the person from whom the rights are transferred and which takes place in a whole variety of widely different circumstances†[14]. Should the situation occur whereby the insured profits, it would be expected that they reimburse any excess to their insurer[15]. Meanwhile, if, after both the insured and the insurer has been fully indemnified, there is excess money from the claim, the insurer is within their rights to claim it, as in the case of Yorkshire Insurance Co v Nisbet Shipping Co[16]. Similarly, if a claim is settled in full by a third party and the money paid to the insurer, then that insurer is legally within their rights to deduct any excess from the compensation before paying the residue to the insured in accordance with the terms of their insurance agreement, as revealed in the case of Scottish Union National Insurance Co v Davis[17]. Evidence of Loss The Courts tend to interpret insurance policies in accordance with those rules relating to the laws governing contracts, taking the overall context as being consistent with the actual intended meaning[18] although, in situations where a meaning might be unclear it is usually the insured person who benefits in accordance with the doctrine of contra proferentem in terms of the guidelines of equity, although in the case of Leppard v Excess Insurance Co Ltd the actual sum awarded to the insured was reduced on Appeal as it was ruled the insured had been awarded indemnity in excess of his loss[19]. Accordingly, and in view of the fact that insurance policies are subject to the rules of contract, it is necessary to ascertain whether the client was insured and, if so, under what terms, as revealed in the case of Sprung v Royal Insurance (UK) Ltd[20] where it was decided that, although the plaintiff had clearly suffered a loss through the late payment of his claim, the: â€Å"loss was recoverable in law from the defendants in addition to the interest element of the sum which had already been paid in respect of the loss under the policy†[21]. However, the figure awarded should be in accordance with the market value of the property and, in situations where a property was incomplete, the value of the loss should reflect the market value at the time the loss occurs, illustrated by the case of Richard Aubrey Film Productions Ltd v Graham[22] who, nearing completion of their filming, had their negatives stolen. At completion the film had an estimated market value of around  £20,000 but, as it still required further editing and other attention, thought to be around  £4,700 in value, prior to release the full market value was not considered to be appropriate. It was interpreted that compensation should be in accordance with the value of an ordinary indemnity contract, reflecting the sum a buyer would be prepared to pay for the film at the time of loss. An overriding factor in assessing whether compensation may be payable is the legislation appropriate to each individual case, identified through either its comprehensive cover or through its specific limitations in terms of criteria. Policies need to take account for the devastation fire can cause, taking into account ‘reasonable reinstatement’ as clarified by Reynolds v Phoenix Assurance Co Ltd[23] relating to the proposed refurbishment of an old mill. On the advice of their insurance brokers they greatly increased their indemnity. Subsequently a fire destroyed most of the building. It was established that the policyholder genuinely intended to rebuild the property and should be properly indemnified, although an issue was raised with the doctrine of undue enrichment, which was taken into account. Remedy of Restitution According to case law, and especially clarified by Lord Diplock[24], it is generally an accepted principle that the rule of subrogation cannot be appropriate in every case and should be utilised reservedly for instances where it is especially pertinent and, as clarified in the case of Re TH Knitwear (Wholesale) Ltd[25], only to the satisfaction of the courts, as in the case of Campbell Auto Finance Co v Warren in 1933[26], and similarly in later rulings, e.g. Re Chobaniuk and Canadian Johns Manville Co Ltd[27], although there are always exceptions. Subrogation may occur through the breach of duty or duplicity by the defendant resulting in the plaintiff being owed some form of corrective justice and recognised as a fundamental principle that profit may not be assumed through deceit[28], or the doctrine of unjust enrichment[29], in accordance with Lord Goff’s ruling in Lipkin Gorman[30]: â€Å"A claim to recover money at common law is made as a matter of right; and even though the underlying principle of recovery is the principle of unjust enrichment, nevertheless, where recovery is denied, it is denied on the basis of legal principle†. An insurer may enter into a simple subrogation by metaphorically standing in place of the insured person[31], after the insured person’s claim has been paid[32], and claiming the value of the insured person’s indemnity from this third party. This claim through subrogation must, however, be undertaken in the name of the insured person to reflect the fact that liability continues even though the insured person has already been indemnified. In effect, this means that the insurer is forcing the insured person to undertake further action despite the fact that they have already received full payment. The result will reimburse the insurer to the value of that which has already been paid to the insured. In theory, this would enable an insured person who had suffered a loss from the actions of a third person, to receive double compensation through a secondary action against the third party, the tortfeasor, as in the case of Caledonia North Sea Ltd v London Bridge Engineering Co[33] during which the insurers were allowed to â€Å"exercise a right of subrogation and sue in the insured's name under the contracts of indemnity†. The perception of compensation has a dual function: the satisfaction of obtaining justice against a defendant and the plaintiff being compensated to the value of their loss. Nonetheless, debate[34] currently surrounds the issue of deducting collateral damages that might already have been paid to the plaintiff, the intention being that the plaintiff should be left in the position they were in before the liability occurred according to the precepts of common law as ruled in British Transport Commission v Gourley[35]. It was recognised in Parry v Cleaver[36] that common law offers no recognition of prior benefits being deducted or not with it being left to the courts’ discretion to rule in accordance with â€Å"justice, reasonableness and public policy†[37] and, despite the law of tort remaining at variance with any of the more updated methods of compensation, its procedures continue to be an important way of recompensing for loss with the result that collateral compensati on often results in a breach of the doctrine of unjust enrichment, as revealed in British Transport Commission v Gourley: â€Å"it is a universal rule that the plaintiff cannot recover more than he has lost†¦Before Gourley’s case it was well established that there was no universal rule with regard to sums which came to the plaintiff as a result of the accident but which would not have come to him but for the accident†[38]. This ruling was later upheld in Hussain v New Taplow Paper Mills Ltd[39] due, in part, to Lord Bridge’s view that the tortfeasor should not benefit because the plaintiff had paid insurance premiums or received other payments as the result of charity, i.e. an award of damages having a deterrent effect through the defendant having to pay compensation, highlighted in the case of Redpath v Belfast and County Down Railway[40], although this was later superseded by British Transport Commissioners v Gourley[41]. When Browning v War Office[42] was heard in the Court of Appeal it was noted that: â€Å"whether the policy of the common law in these types of actions is to provide restitution for the plaintiff or to visit retribution on the defendant?†[43]. CONCLUSION Insurance law does not necessarily correlate with the principles of common law, with indemnity considered to be non-deductible due to a variety of reasons, part of which appears to be a reflection on the courts’ attitude to social policy. It was ruled in the case of Caledonia North Sea Ltd v London Bridge Engineering Co[44], i.e. Caledonia North Sea Limited (Respondents) v British Telecommunications Plc (Appellants) (Scotland) and Others[45]: â€Å"insurance company recoveries, under their right of subrogation, most often flow from tort actions is quite natural, but without significance. Subrogation is an equitable principle and applies to contract rights as fully as it does to tort actions†¦ The insurer is subrogated to appellant's contract right of indemnity. This sustains the cause of action against appellant for the identical reason that subrogation sustains a tort action where the plaintiff has been paid for his loss† The case of Parry v Cleaver[46], decided in the House of Lords, illustrates the incongruous situation of continuing to recognise the doctrine of subrogation in insurance, recognised by both insurers and the courts as being wasteful and no longer serving any useful purpose, with both the opportunity and the possibility of various unfortunate results emerging from this practice continuing, the concept of insurance having diminished the influence tort alone now has in terms of restitution[47]. Insurance companies now reimburse up to 94% of all damages and 88% of all claims in tort through insurance premiums that have been pre-paid[48]. The law of restitution or quasicontract is recognised at common law rather than contractual remedies or remedies at tort. However, evidence provided by case law suggests that the circumstances in which these remedies are applied is reliant on a specific set of principles[49] and there appears to be considerable doubt as to the criteria for subrogation allowed to be applied, with it being suggested that applying it arbitrarily was unacceptable – it should be a â€Å"matter of principle†[50]. The definitive case that has been acknowledged as introducing the law of restitution into case law was Moses v Macferlan[51]. â€Å"The law of restitution is the law relating to all claims†¦which are founded upon the principle of unjust enrichment†[52]. It has been claimed that ‘federal class actions have tripled over the past 10 years’ represented by a burgeoning escalation of over 1000%[53] and is contributing to an incipient damage to the US economy with ‘litigation costs increased at four times the growth of the overall economy’[54]. Krauss observes that the law of tort is ‘not insurance against unfortunate losses†¦[it]†¦does not exist to protect against risks’. As he clarifies, the competitive nature of the insurance industry enables premiums paid by policy holders to cover the cost of most claims[55]. In the US this may be achieved through social insurance, welfare payments and tax law or by way of private insurance, none of which had evolved to such developments as modern society enjoys when the cases of Castellain v Preston[56] and Darrell v Tibbetts[57] were being heard in the Court of Appeal during the 19th Century. Subrogation was ruled in Darrell v Tibbetts[58] as payment had been made for a loss which, in retrospect, was revealed not to have been a loss and, as such, the plaintiff was entitled to seek redress from the courts in order to be reimbursed for his loss. In Castellain v Preston, however, this was not the case and ultimately resulted in both sellers and purchasers, in effecting conveyance of property, to be required to insure that property against loss, an apparent example of a wasteful exercise. The ruling made by Chitty J was on the premise that â€Å"The contract of sale was not a contract†¦for the preservation of the buildings insured†[59]. However, it was also recorded that Chitty, J correlated ‘subrogation’ with â€Å"the insurers are entitled to enforce all the remedies whether in contract or in tort†, thereby paving the way to future confusion between when subrogation was an appropriate action and blurring the distinction between the law of contract, that of tort and that of quasicontract administered through common law. The case went to Appeal where Brett, LJ[60] interpreted simple subrogation as a doctrine of subrogation interchangeable with the doctrine of indemnity. The Law Reform Commission state that Brett, LJ ‘distorted the definition of subrogation so as to cover the case’[61] with the effect that it has subsequently been misapplied in many other cases[62], with its true application, equity, continuing to be incorrectly interpreted over the years as subrogation. The Commission states: â€Å"†¦its long-term effect has been to introduce a confusion into the heart of the law in this area which has rendered its workings obscure and which must be stripped away before the remedies made available†¦to enforce the principle of indemnity can properly be understood†[63]. This reinforces their view of sufficient welfare provision and private insurance cover to preclude the need to subrogate a claim against a tortfeasor. In accordance with this view, the doctrine of subrogation can no longer serve any useful purpose and, in view of the amount of waste in terms of litigation costs and courts’ time that results from this doctrine far outweighs its continued value or rationale. Total Word Count (excluding bibliography and footnotes): 3,000 words BIBLIOGRAPHY BOOKS: Beatson, J (2002): Anson’s Law of Contract, Oxford: Oxford University Press, Page 20. Bird and Hird (2001): Modern Insurance Law, London: Sweet and Maxwell, Page 256 Black's Law Dictionary, 6th Edition (1990). Burrows, (1993): The Law of Restitution, London: Butterworths, Page 1 Goff and Jones (1998): The Law of Restitution, [5th ed]. London: Sweet and Maxwell, Page 3 Krauss, Michael I (1992): Tort Law and Private Ordering, USA: St Louis University Press Mitchell, Charles (1994): The Law of Subrogation. Oxford: Oxford University Press, Page 4 Oxford English Dictionary, The Compact Edition ( Oxford, 1987), ii. 3126 Virgo, Graham (1999): Principles of the Law of Restitution. Oxford: Oxford University Press ARTICLES: Barker, (1995): Unjust Enrichment: containing the beast. In OJLS, 15, 457,473 Barker, (1998): Rescuing Remedialism in Unjust Enrichment Law: why remedies are right. In CLJ, 57, 301. Birds, John: Contractual subrogation in insurance. [1979] JBL 124, Pages 132 133 Connor, Martin F (2000, October): Taming the Mass Tort Monster, In the National Legal Centre for the Public Interest, Page 4 Hasson, Reuben: Subrogation in insurance law a critical evaluation. [1985] 5 Oxford J Legal Stud 416, Page 425 428 HMSO: Report of the Royal Commission on Civil Liability and Compensation for Personal Injury [UK Pearson Commission (1978, Vol. 2, para. 509) [Cmnd 7054] Law Reform Commission CONSULTATION PAPER ON COLLATERAL BENEFITS (LRC CP 15 1999) Dublin: IPC House ONLINE RESOURCES (Site visited 25/05/05. Hyperlinks functioning) Krauss, Michael I (2004): Medical Malpractice: is it time for Tort Reform in Maryland, USA?: The Maryland Public Policy Institute http://www.mdpolicy.org/research/health/MDMedMal.pdf Parsons, Chris (2002): Moral Hazard and Behavioural Aspects of Liability Insurance. http://64.233.183.104/search?q=cache:VR1wzB7SfwEJ:www.nottingham.ac.uk/business/cris/ukec/2002paper5.doc+Pearson+Commission%2Binsurance%2Bclaims%2B88%25%2Btort+hl=en TABLE OF CASES: British Transport Commission v Gourley [1956] AC 185, [1955] 3 All ER 796, [1956] 2 WLR 41, 2 Lloyd's Rep 475, 34 ATC 305, [1955] TR 303, 49 RIT 11 Browning v War Office and Another [1960 B. No. 3080] [COURT OF APPEAL] [1963] 1 QB 750 Caledonia North Sea Ltd v London Bridge Engineering Co [2000] Lloyd's Rep IR 249 Campbell Auto Finance Co v. Warren [ 1933] 4 DLR 509 at 515 Canadian Johns Manville Co Ltd [1969] 39 WWR 680 at 681 Castellain v Preston Others [1881-1885] All ER Rep 493 Castellain v Preston and Others [1882] 8 QB D 613 (April 4) Castellain v Preston and Others [1883]11 QB D 380 (March, 12) Commercial Union Ass Co v Lister (1874)LR 9 Ch 483 Darrell v Tibbetts (Court of Appeal) 5 QB D 560 Hussain v New Taplow Paper Mills Ltd [1988] 1 AC 514, [1988] 1 All ER 541, [1988] 2 WLR 266, [1988] ICR 259, [1988] IRLR 167 Leppard v Excess Insurance Co Ltd [1979] 2 All ER 668, [1979] 1 WLR 512, [1979] 2 Lloyd's Rep 91, 2 ILR 107, 250 EG 751, [1979] EGD 246 Lipkin Gorman (A Firm) v Karpnale Ltd [1991] 2 AC 548, 578 Livingstone v Rawyards Coal Co (1880) 5 App Cas 25, 39 Morrison and Morrison v. Canadian Surety Co, n. 4 above, at 86 per Coyne, JA Moses v Macferlan [1776] 2 Burr. 1005, 1012; 97 ER 976, 981 Napier v Hunter [1993] 2 WLR 42: Lord Napier and Ettrick and Another v Hunter and Others and Lord Napier and Ettrick v RF Kershaw Ltd and Others [Consolidated Appeals] HL [1993] AC 713 Orakpo v Manson Investments Ltd and Others [ 1978] AC 95, [1977] 3 All ER 1, [1977] 3 WLR 229, 36 P CR 1 Page v Scottish Insurance Corporation Ltd; Forster v Page (Court of Appeal) [1929] 33 Ll.L Rep. 134 Parry v Cleaver (House of Lords) [1970] AC 1, [1969] 1 All ER 555, [1969] 2 WLR 821, [1969] 1 Lloyd's Rep 183, 6 KIR 265, (48 MLR 20) Phoenix Assurance Co v Spooner [1905] 2 KB 753 Rayner v Preston (1881) 18 Ch D 1 Regal Films [1946 OCA] Reynolds and Anderson v Phoenix Assurance Co Ltd and Others (Queen’s Bench Division) [1978] 2 Lloyd's Rep 440 2 ILR 75, 3 ILR 51, 247 EG 995, [1978] EGD 172 Re TH Knitwear (Wholesale) Ltd [ 1988] Ch 275 at 286 Richard Aubrey Film Productions Ltd v Graham [1960] QB 2 Lloyd's Rep 101 Scottish Union National Insurance Co v Davis [1970] 1 Lloyd’s Rep 1 Sprung v Royal Insurance (UK) Ltd [1999] Lloyd's Rep IR 111, (Transcript: Smith Bernal) West of England Fire Insurance Co v Isaacs (Court of Appeal) [1895 1899] All ER Rep 683 Whiten v. Pilot Insurance Co., [2002] 1 S.C.R. 595, 2002 SCC 18 Yorkshire Insurance Co Ltd v Nisbet Shipping Co Ltd (Queen’s Bench) [1962] 2 QB 330, [1961] 2 All ER 487, [1961] 2 WLR 1043, [1961] 1 Lloyd’s Rep 479 1 Footnotes [1] Livingstone v Rawyards Coal Co (1880) 5 App Cas 25, 39 [2] Concept introduced in by Court of Appeal in the cases of Darrell v Tibbetts [1880] (Court of Appeal) 5 QB D 560 and Castellain v. Preston, ( 1883) 11 QBD 380 [3] The Compact Edition of the Oxford English Dictionary ( Oxford, 1987), ii. 3126 [4] Black's Law Dictionary, 6th Edition (1990). [5] Orakpo v. Manson Investments Ltd [ 1978] AC 95 at 112, per Lord Edmund-Davies [6] Orakpo v Manson Investments Ltd [ 1978] AC 95 per Lord Diplock [7] Beatson, J (2002): Anson’s Law of Contract, Oxford: Oxford University Press, Page 20. [8] Bird and Hird (2001): Modern Insurance Law, London: Sweet and Maxwell, Page 256 believe that â€Å"It may be that there is no general continuing duty of utmost faith†¦Ã¢â‚¬  [9] West of England Fire Insurance Co v Isaacs [1897] 1 QB 226 [10] Phoenix Assurance Co v Spooner [1905] 2 KB 753 [11] Page v Scottish Insurance Corporation [1929] 98 LJKB 308 [12] Rayner v Preston (1881) 18 Ch D 1 [13] Mitchell, Charles (1994): The Law of Subrogation. Contributors. Oxford: Oxford University Press, Page 4 [14] [ 1978] AC 95 per Lord Diplock [15] Darrell v Tibbetts [1880] (Court of Appeal) 5 QB D 560 [16] [1962] 2 QB 330 [17] [1970] 1 Lloyd’s Rep 1 [18] Leppard v Excess Insurance Co Ltd [1979] 2 All ER 668, [1979] 1 WLR 512, [1979] 2 Lloyd's Rep 91, 2 ILR 107, 250 EG 751, [1979] EGD 246 [19] ibid [20] [1999] Lloyd's Rep IR 111 [21] Sprung v Royal Insurance (UK) Ltd [1999] Lloyd's Rep IR 111, per Hedley, J [22] [1960] QB 2 Lloyd's Rep 101 [23] [1978] QB 2 Lloyd's Rep 440 [24] Orakpo v Manson Investments Ltd [ 1978] AC 95 per Lord Diplock [25] [ 1988] Ch 275 at 286, per Slade LJ [26] Campbell Auto Finance Co v. Warren [ 1933] 4 DLR 509 at 515, per Masten JA [27] [1969] 39 WWR 680 at 681, per Friesen DCJ [28] Barker, (1995): Unjust Enrichment: containing the beast. In OJLS, 15, 457,473 [29] Burrows, (1993): The Law of Restitutio

The Theme of Masculinity in Shakespeare’s play, Macbeth :: GCSE Coursework Macbeth

The Theme of Masculinity in Macbeth  Ã‚  Ã‚   In Shakespeare’s play, Macbeth‚ the theme of masculinity is explored. As Macbeth matures‚ there are times when his masculinity is put to the test, mostly after the murder of Duncan. There are four main themes in which masculinity is presented in the play. It was once considered that the more bloodthirsty and violent you were, the more manly you would be considered. Patriotism was regarded as a very masculine pathway and to die in battle for your cause, or better, for your country was in some ways a great act of heroism and a honourable way to die‚. This is one of the main themes of masculinity explored in Macbeth and can be illustrated by the simple quote of the man who will soon cold-bloodedly kill Banquo. The question put forth by Macbeth is whether the murderer will try and be a good Christian. He believes that to kill another man will make him more of a man and replies, We are men, my liege.‚ We can see patriotism active in the play when Siward seems unmoved by the news of the death of his son brought to him by Ross. Pleased in the knowledge that his son died an honourable man, fighting for his cause, he is happy because, knowing that his sons wounds were on his chest, he knows his son was not killed running away. If that was the case, Siward would not of though of his own son so highly. But like a man he died‚ There is a point where one cannot do anything that will make one more of a man‚ is a concept that Macbeth argues, indirectly, in the play. He thinks that after the murder of Duncan, which is wife thought made him a great man, there is nothing that he could do to be more of a man‚, Macbeth believes that he has done the ultimate deed, and that to do anything else to try to prove yourself would just be wrong because it would overshadow the deed that was done before it. I dare do all that may become a man; Who dares do more is none.‚ In Lady Macbeth‚s eyes if Macbeth did not kill Duncan than he would not be a man to her anymore, she believes that he would be denying all urges for greater wealth and prosperity that man should have. She is wondering why he is not taking the opportunity to be king when he can easily do so, in reality, we know why Macbeth is contemplating the murder of Macbeth, because he has morals, qualities that we consider manly today.

Night World : Soulmate Chapter 6

Hannah opened her eyes. â€Å"Oh, thank God,† Paul said. He seemed to be almost crying. â€Å"Oh, thank God. Do you see me? Do you know who you are?† â€Å"I'm wet,† Hannah said slowly, feeling dazed. She touched her face. Her hair was dripping. Paul was holding a water glass. â€Å"Why am I wet?† â€Å"I had to wake you up.† Paul sagged to the floor beside the couch. â€Å"What's your name? What year is it?† â€Å"My name is Hannah Snow,† Hannah said, still feeling dazed and bodiless. â€Å"And it's-† Suddenly memory rushed out of the fog at her. She sat bolt upright, tears starting to stream from her eyes. â€Å"What was all that?† â€Å"I don't know,† Paul whispered. He leaned his head against the couch, then looked up. â€Å"You just kept talking-you were telling that story as if you were there. It was really happening to you. And nothing I could do would break the trance. I tried everything-I thought you were never going to come out of it. And then you started sobbing and I couldn't make you stop.† â€Å"I felt as if it were happening to me,† Hannah said. Her head ached; her whole body felt bruised with tension. And she was reeling with memories that were perfectly real and perfectly hers†¦ and impossible. â€Å"That was like no past life regression I've ever read about,† Paul said, his voice agitated. â€Å"The detail†¦ you knew everything. Have you ever studied-is there any way you could have known those kinds of things?† â€Å"No.† Hannah was just as agitated, â€Å"I've never studied humans in the Stone Age-and this was real. It wasn't something I was making up as I was going along.† They were both talking at once. â€Å"That guy,† Paul was saying. â€Å"He's the one you're afraid of, isn't he? But, look, you know, regression is one thing†¦ past lives is another thing†¦ but this is crazy.† â€Å"I don't believe in vampires,† Hannah was saying at the same time. â€Å"Because that's what that guy was supposed to be, wasn't it? Of course it was. Caveman vampire. He was probably the first one. And I don't believe in reincarnation.† â€Å"Just plain crazy. This is crazy.† â€Å"I agree.† They both took a breath, looking at each other. There was a long silence. Hannah put a hand to her forehead. â€Å"I'm †¦ really tired.† â€Å"Yeah. Yeah, I can understand that.† Paul looked around the room, nodded twice, then got up. â€Å"Well, we'd better get you home. We can talk about all this later, figure out what it really means. Some kind of subconscious fixation†¦ archetypical symbolism†¦ something.† He ran out of air and shook his head. â€Å"Now, you feel all right, don't you? And you're not going to worry about this? Because there's nothing to worry about.† â€Å"I know. I know.† â€Å"At least we know we don't have to worry about vampires attacking you.† He laughed. The laugh was strained. Hannah couldn't manage even a smile. There was a brief silence, then Paul said, â€Å"You know, I think I'll drive you home. That would be good. That would be a good idea.† â€Å"That would be fine,† Hannah whispered. He held out a hand to help her off the couch. â€Å"By the way, I'm really sorry I had to get you all wet.† â€Å"No. It was good you did. I was feeling so awful- and there were worse things about to happen.† Paul blinked. â€Å"I'm sorry?† Hannah looked at him helplessly, then away. â€Å"There were worse things about to happen. Terrible things. Really, really awful things.† â€Å"How do you know that?† â€Å"I don't know. But there were.† Paul walked her to her doorstep. And Hannah was glad of it. Once inside the house, she went straight down the hall to her mother's study. It was a cluttered comfortable room with books piled on the floor and the tools of a paleontologist scattered around. Her mother was at her desk, bending over a microscope. â€Å"Is that you, Hannah?† she asked without looking up. â€Å"I've got some marvelous sections of haversian canals in duckbill bones. Want to see?† â€Å"Oh†¦ not now. Maybe later,† Hannah said. She wanted very much to tell her mother about what had happened, but something was stopping her. Her mother was so sensible, so practical and intelligent†¦. She'll think I'm crazy. And she'll be right. And then she'll be appalled, wondering how she could have given birth to an insane daughter. That was an exaggeration, and Hannah knew it, but somehow she still couldn't bring herself to tell. Since her father had died five years ago, she and her mother had been almost like friends-but that didn't mean she didn't want her mother's approval. She did. She desperately wanted her mother to be proud of her, and to realize that she could handle things on her own. It had been the same with the notes-she'd never told about finding them. For all her mom knew, Hannah's only problem was bad dreams. â€Å"So how did it go tonight?† her mother asked now, eye still to the microscope. â€Å"That Dr. Winfield is so young-I hope he's not too inexperienced.† Last chance. Take it or lose it. â€Å"Uh, it went fine,† Hannah said weakly. â€Å"That's good. There's chicken in the crockpot. I'll be out in a little while; I just want to finish this.† â€Å"Okay. Great. Thanks.† Hannah turned and stumbled out, completely frustrated with herself. You know Mom won't really be awful, she scolded herself as she fished a piece of chicken out of the crockpot. So tell her. Or call Chess and tell her. They'll make things better. They'll tell you how impossible all this stuff about vampires and past lives is. †¦ Yes, and that's the problem. Hannah sat frozen, holding a fork with a bite of chicken on it motionless in front of her. I don't believe in vampires or reincarnation. But I know what I saw. I know things about Hana . ., things that weren't even in the story I told Paul. I know she wore a tunic and leggings of roe deer hide. I know she ate wild cattle and wild boar and salmon and hazel nuts. I know she made tools out of elk antler and deer bone and flint†¦. God, I could pick up a flint cobble and knock off a set of blades and scrapers right now. I know I could. I can feel how to in my hands. She put the fork down and looked at her hands. They were shaking slightly. And I know she had a beautiful singing voice, a voice like crystal†¦. Like the crystal voice in my mind. So what do I do when they tell me it's impossible? Argue with them? Then I'll really be crazy, like those people in institutions who think they're Napoleon or Cleopatra. God, I hope I haven't been Cleopatra. Half laughing and half crying, she put her face in her hands. And what about him? The blond stranger with the bottomless eyes. The guy Hana didn't have a name for, but Hannah knew as Thierry. If the rest of it is real, what about him? He's the one I'm afraid of, Hannah thought. But he didn't seem so bad. Dangerous, but not evil. So why do I think of him as evil? And why do I want him anyway? Because she did want him. She remembered the feelings of Hana standing next to the stranger in the moonlight. Confusion†¦ fear†¦ and attraction. That magnetism between them. The extraordinary things that happened when he touched her hand. He came to the Three Rivers and turned her life upside down†¦. The Three Rivers. Oh, God-why didn't I think of that before? The note. One of the notes said â€Å"Remember the Three Rivers.† Okay. So I've remembered it. So what now? She had no idea. Maybe she was supposed to understand everything now, and know what to do †¦ but she didn't. She was more confused than ever. Of course, a tiny voice like a cool dark wind in her brain said, you didn't remember all of it yet. Did you? Paul woke you up before you got to the end. Shut up, Hannah told the voice. But she couldn't stop thinking. All night she was restless, moving from one room to another, avoiding her mother's questions. And even after her mother went to bed, Hannah found herself wandering aimlessly through the house, straightening things, picking up books and putting them down again. I've got to sleep. That's the only thing that will help me feel better, she thought. But she couldn't make herself sit, much less lie down. Maybe I need some air. It was a strange thought. She'd never actually felt the need to go outside for the sole purpose of breathing fresh air-in Montana you did that all day long. But there was something pulling at her, drawing her to go outside. It was like a compulsion and she couldn't resist. I'll just go on the back porch. Of course there's nothing to be scared of out there. And if I go outside, then I'll prove there isn't, and then I can go to sleep. Without stopping to consider the logic of this, she opened the back door. It was a beautiful night. The moon threw a silver glow over everything and the horizon seemed very far away. Hannah's backyard blended into the wild bluestem and pine grass of the prairie. The wind carried the clean pungent smell of sage. We'll have spring flowers soon, Hannah thought. Asters and bluebells and little golden buttercups. Everything will be green for a while. Spring's a time for life, not death. And I was right to come out. I feel more relaxed now. I can go back inside and lie down†¦. It was at that moment that she realized she was being watched. It was the same feeling she'd been having for weeks, the feeling that there were eyes in the darkness and they were fixed on her. Chills of adrenaline ran through Hannah's body. Don't panic, she told herself. It's just a feeling. There's probably nothing out here. She took a slow step backward toward the door. She didn't want to move too quickly. She had the irrational certainty that if she turned and ran, whatever was watching her would spring out and get her before she got the door open. At the same time she edged backward, her eyes and ears were straining so hard that she saw gray spots and she heard a thin ringing. She was trying, desperately, to catch some sign of movement, some sound. But everything was still and the only noises were the normal distant noises of the outdoors. Then she saw the shadow. Black against the lighter blackness of the night, it was moving among the bluestem grass. And it was big. Tall. Not a cat or other small animal. Big as a person. It was coming toward her. Hannah thought she might faint. Don't be ridiculous, a sharp voice in her head told her. Get inside. You're standing here in the light from the windows; you're a perfect target. Get inside fast and lock the door. Hannah whirled, and knew even as she did it that she wouldn't be fast enough. It was going to jump at her exposed back. It was going to †¦ â€Å"Wait,† came a voice out of the darkness. â€Å"Please. Wait.† A male voice. Unfamiliar. But it seemed to grab Hannah and hold her still. â€Å"I won't hurt you. I promise.† Runrunrunrun! Hannah's mind told her. Very slowly, one hand on the door knob, she turned around. She watched the dark figure coming out of the shadows to her. She didn't try to get away again. She Had a dizzying feeling that fate had caught up with her. The ground sloped, so the light from the house windows showed her his boots first, then the legs of his jeans. Normal walking boots like any Montanan might wear. Ordinary jeans-long legs. He was tall. Then the light showed his shirt, which was an ordinary T-shirt, a little cold to be walking around at night in, but nothing startling. And then his shoulders, which were nice ones. Then, as he stepped to the base of the porch, she saw his face. He looked better than when she had seen him last. His white-blond hair wasn't crazily messed up; it fell neatly over his forehead. He wasn't splattered with mud and his eyes weren't wild. They were dark and so endlessly sad that it was like a knife in the heart just to see him. But it was unmistakably the boy from her hypnosis session. â€Å"Oh, God,† Hannah said. â€Å"Oh, God.† Her knees were giving out. It's real. It's real. He's real and that means†¦ it's all true. â€Å"Oh, God.† She was trembling violently and she had to put pressure on her knees to keep standing. The world was changing around her, and it was the most disorienting thing she'd ever experienced. It was as if the fabric of her universe was actually moving-pulsing and shifting to accommodate the new truths. Nothing was ever going to be the same again. â€Å"Are you all right?† The stranger moved toward her and Hannah recoiled instinctively. â€Å"Don't touch me!† she gasped, and at the same moment her legs gave out. She slid to the floor of the porch and stared at the boy whose face was now approximately level with hers. â€Å"I'm sorry,† he almost whispered. â€Å"I know what you're going through. You're just realizing now, aren't you?† Hannah said, whispering to herself, â€Å"It's all true.† â€Å"Yes.† The dark eyes were so sad. â€Å"It's†¦ I've had past lives.† â€Å"Yes.† He squatted on the ground, looking down as if he couldn't keep staring at her face anymore. He picked up a pebble, examined it. Hannah noticed that his fingers were long and sensitive-looking. â€Å"You're an Old Soul,† he said quietly. â€Å"You've had lots of lives.† â€Å"I was Hana of the Three Rivers.† His fingers stopped rolling the pebble. â€Å"Yes.† â€Å"And you're Thierry. And you're a †¦Ã¢â‚¬  He didn't look up. â€Å"Go on. Say it.† Hannah couldn't. Her voice wouldn't form the word. The stranger-Thierry-said it for her. â€Å"Vampires are real.† A glance from those unfathomable eyes. â€Å"I'm sorry.† Hannah breathed and looked down at him. But the world had finished its reshaping. Her mind was beginning to work again. At least I know I'm not crazy, she thought. That's some consolation. It's the universe that's insane, not me. And now I have to deal with it-somehow. She said quietly, â€Å"Are you going to kill me now?† â€Å"God-no!† He stood up fast, uncoiling. Shock was naked on his face. â€Å"You don't understand. I would never hurt you. I †¦Ã¢â‚¬  He broke off. â€Å"It's hard to know where to begin.† Hannah sat silently, while he looked around the porch for inspiration. She could feel her heart beating in her throat. She'd told Paul that this boy had killed her, kept killing her. But his look of shock had been so genuine-as if she'd hurt him terribly by even suggesting it. â€Å"I suppose I should start by explaining exactly what I am,† he said. â€Å"And what I've done. I made you come outside tonight. I influenced you. I didn't want to do it, but I had to talk to you.† â€Å"Influenced me?† It's a mental thing. I can also just communicate this way. It was his voice, but his lips weren't moving. And it was the same voice she'd heard at the end of her hypnotic session, the voice that wasn't Paul's. The one that had spoken in her head, saying, Hannah, come back. You don't have to relive this. â€Å"You were the one who woke me up,† Hannah whispered. â€Å"I wouldn't have come back except for you.† â€Å"I couldn't stand to see you hurting like that.† Can somebody with his eyes be evil? He was obviously a different sort of creature than she was, and every move he made showed the grace of a predator. It reminded her of how the wolves had moved-they had rippled. He did, too, his muscles moving so lightly under his skin. He was unnatural- but beautiful. Something struck her. â€Å"The wolves. I picked up a silver picture frame to bash them with. Silver.† She looked at him. â€Å"Werewolves are real.† At the last moment her voice made it a statement instead of a question. â€Å"So much is real that you don't know about. Or that you haven't remembered yet. You were starting to remember with that shrink. You said I was a Lord of the Night World.† The Night World. Just the mention of it sent prickles through Hannah. She could almost remember, but not quite. And she knew it was crazy to be kneeling here having this conversation. She was talking to a vampire. A guy who drank blood for a living. A guy whose every gesture showed he was a hunter. And not only a vampire, but the person her subconscious had been warning her about for weeks. Telling her to be afraid, be very afraid. So why wasn't she running? For one thing, she didn't think her legs would physically support her. And for another-well, somehow she couldn't stop looking at him. â€Å"One of the werewolves was mine,† he was saying quietly. â€Å"She was here to find you-and protect you. But the other one†¦ Hannah, you have to understand. I'm not the only one looking for you.† To protect me. So I was right, Hannah thought. The gray female was on my side. She said, â€Å"Who else is looking?† â€Å"Another Night Person.† He looked away. â€Å"Another vampire.† â€Å"Am I a Night Person?† â€Å"No. You're a human.† He said it the way he said everything, as if reminding her of terrible facts he wished he didn't have to bring up. â€Å"Old Souls are just humans who keep coming back.† â€Å"How many times have I come back?† â€Å"I †¦ I'd have to think about it. Quite a few.† â€Å"And have you been with me in all of them?† â€Å"Any of them I could manage.† â€Å"What do the rest of the notes mean?† Hannah had been gathering speed, and now she was shooting questions at him in machine-gun fashion. She thought she was in control, and she hardly noticed the hysterical edge to her own voice. â€Å"Why am I telling myself I'll be dead before I'm seventeen?† â€Å"Hannah†¦Ã¢â‚¬  He reached out a hand to calm her. Hannah's own hand moved by reflex, coming up to ward his off. And then their fingers touched, bare skin to bare skin, and the world disappeared.

Ikea Invades America Essay

Founded in 1943 by a poor Swedish farmer named Ingvar Kamprad, IKEA is now one of the largest furniture retailers in the world. From its inception, Kamprad wanted to create cheap, quality furniture that everyone could afford. That formula led to IKEA’s early success in Sweden and has carried over until today. To its customers, IKEA is not just a store but a way of life, which may be evident through the cult-like following the company has achieved. When talking about the four P’s of marketing (product, price, place, promotion), there are few companies in the world that have mastered this concept better than IKEA. IKEA has been able to recognize the demands of its shoppers and create compelling products that meet those demands at a reasonable price. Its products are sold at unique stores that serve strategically important, geographic markets. This paper examines the factors that have made IKEA such a big success and offers some recommendations for future growth in the United States. Today, IKEA has over 240 stores in 35 countries and has revenues of over $26 billion. Its revenues double every 5-6 years and the company is now expanding to growing markets like China, Japan, and Brazil. The future of IKEA looks brighter than ever. For a brief snapshot of IKEA’s current sales around the world see Appendix 1. In 1985, IKEA decided to invade America. Faced with this early failure, IKEA retooled its furniture to fit American tastes. IKEA soon became the fastest growing furniture retailer and the 14th largest furniture retailer overall in the United States. IKEA executives needed to find a balance of how to create new furniture offerings without losing its unique design and corporate soul. By examining IKEA’s marketing strategy and answering a series of four questions, we have developed recommendations (see Appendix 2) that we think will lead to IKEA’s continued growth and success. 1) What are some of the ways that furniture retailers have sought to overcome these purchase obstacles? : a) identifying a product that consumers like, b) visualizing the product in the consumer’s home, and c) getting the product in the consumer’s home? In furniture sales, there are two general strategies: the low-end and the high-end. The low-end offers cheap, utilitarian furniture that is dreary looking. Cheap furniture is marketed to people such as college students who have a small budget. The cheap furniture is also displayed in poorly lit showrooms that offer little to no customer service. High-end furniture stores compete on quality and service. The high-end offers a large selection in each style and sub-style of furniture, which results in the showroom having a large inventory. The broad, variety strategy virtually guarantees that a customer’s preferred style will be available. The high-end stores also have high touch sales associates to help customers with product selection and furniture measurement. Sales associates are trained to educate their customers; such as explaining the life spans of different materials. They also reassure customers that their furniture will last a life time. Visualizing a piece of furniture in a person’s home can be very difficult. The high-end furniture stores have beautiful showrooms that are elaborately decorated to help the customer visualize where they can place new furniture or how they can redecorate their home. High-end stores also offer interior design services. Most retailers offer credit to make high-end furniture more affordable. All retailers offer home delivery, sometimes free, to make the transition as painless as possible for the customer. As an added bonus, retailers offer to assemble the furniture in the customer’s home. Sometimes, delivering the furniture also involves rearranging furniture, as well as removing and discarding old furniture. Providing these services makes the purchase of new furniture an easy and worry-free process. 2) Explain IKEA’s reverse positioning strategy. IKEA created a matrix used to prioritize product lineup and price. (See Appendix 3) Primarily the matrix is used to set a target retail price and select a product style. With the matrix system, IKEA is able to identify product line opportunities and gaps; creating a well rounded store. IKEA has avoided the image of the low end furniture store by displaying furniture in brightly lit showrooms. These showrooms help customers envision how the furniture interacts with the allotted space. Plus color coordinated cards provide design tips and information kiosks are on hand to help customers. All of these features reinforce IKEA’s self service ethos without making the customer feel abandoned. In IKEA’s case, the firm rejected the standard business models for both high-end and low-end furniture stores. IKEA’s furniture is composed of cheaper parts that are not visible and are not under high stress through use and a higher quality material is used for the visible parts or parts under high stress. This gives IKEA’s furniture a higher end look while keeping their costs low. IKEA’s reverse positioning kept prices low, while eliminating many services thought essential to a higher-end store. The company replaced them with unique services for its category: a bright, inviting showroom, furniture that was attractively designed, a child care center, a restaurant serving Swedish meatballs, and brightly colored house wares and clever toys. As a result, IKEA successfully avoided the feel of the low-end retailers, and customers â€Å"find the IKEA shopping experience to be immensely appealing (Moon, â€Å"IKEA Invades America,† 5). 3) What are some of the various product/service attributes that IKEA has chosen to withhold from its customers? IKEA seems to incorporate a hybrid strategy focusing on both cost and differentiation. IKEA attempts to price in the low to midrange category. IKEA does not build its furniture to last a lifetime, which in-fact flows well with its ad campaigns focused on letting go of the semimetal value Americans often place on furniture. IKEA products are known for falling apart after a few years; however, its customers are typically satisfied with the look, functionality, and affordability of IKEA products (Moon, 2004, p. 5). Its focus is on cost-efficiency, so the company uses higher-quality materials on visible surfaces and lower-quality materials elsewhere. High-end stores compete on quality and â€Å"high touch† experience and selection. Nearly all types of furniture stores offer delivery services. However, IKEA successfully eliminated many of these attributes. IKEA products are designed to be transported unassembled in flat boxes, which keeps shipping costs low and prevents IKEA from having to deliver/assemble furniture for customers (Moon, 2004, p. ). Customers are responsible for transportation of their furniture and assembly of their furniture. Although this step may seem like its decreasing the consumer experience/perceived product value; it’s actually keeping the customer involvement level high. Moreover, the competitive pricing offered at IKEA is attributed to letting customer build their own furniture, which keeps costs to a minimum. Formerly, IKEA only produced a few different designs; however, this has changed in recent years. In order to be consistent with IKEA’s self-service ethos and to keep costs low, the ratio of sales assistants to customers is kept low. The low number of sales associates can have a negative effect on the consumer experience. To handle furniture questions, customers are provided with product descriptions and measuring tape so they can make their own measurements. 4) What are some of the areas that IKEA has managed to achieve cost efficiency by implementing a number of firm-specific operation processes? A number of cost effective operating processes have been implemented by IKEA. In furniture design, IKEA engineers often select cheaper/low quality materials for less visible areas that experience minimal stress and expensive materials for visible areas that undergo stress. This aids IKEA in producing durable, good-quality products at low costs. IKEA has worked with over 1,800 suppliers in over 50 countries and often uses suppliers from developing countries. To keep costs down, IKEA usually purchases in bulk and often orders various components of a given product from different suppliers. IKEA is strict with employees about waste; it enforces minimal travel budgets and requires them to save electricity. IKEA keeps a small staff in stores and provides self-serve trolleys to aid consumers in loading their vehicles. Typical furniture retailers require a larger staff and/or incur shipping costs for delivery of their bulky, already assembled products. Flat packaging allows IKEA customers to transport their purchases home and eliminates the expense of home delivery. IKEA’s flat packaging strategy is another firm specific operating process. The strategy was inspired by an employee who, in 1955, removed the legs off a table to fit it into a customer’s car. This strategy requires designers to keep in mind the amount of space their products take up in their unassembled form. Flat packaging also helps prevent damage to the products during the shipping process. IKEA will often redesign their products multiple times to achieve space optimization and reduce shipping costs. Space optimization typically lowers prices for consumers; however, it may lengthen the assembly process. IKEA should continue to incorporate cost cutting activities across the board so long as the consumer experience remains positive.