Tuesday, May 19, 2020
Awakening of Shareholder Activism - Free Essay Example
Sample details Pages: 8 Words: 2385 Downloads: 2 Date added: 2017/06/26 Category Business Essay Type Narrative essay Level High school Tags: Act Essay Did you like this example? Awakening of Shareholder Activism: Reflection on Indian Framework Introduction à ¢Ã¢â ¬Ã
âShareholder activism is not a privilege- it is a right and a responsibility. When we invest in a company, we own part of that company and we are partly responsible. If there is something wrong, we must become active and vocal.à ¢Ã¢â ¬Ã Mark Mobius Recognizing the significance and need for bringing about a transformation towards protection of minority shareholdersà ¢Ã¢â ¬Ã¢â ¢ interest, Indian legislature introduced the concept of Class Action Suit (à ¢Ã¢â ¬Ã
âCASà ¢Ã¢â ¬Ã ), or what is popularly known as à ¢Ã¢â ¬ÃÅ"representative suità ¢Ã¢â ¬Ã¢â ¢, within range of safeguards provided statutorily. This radical development has evidently found a strong foothold within the growing arena of corporate governance in India.[1] A civil law remedy in United States[2] and a crucial weapon for safeguarding investorsà ¢Ã¢â ¬Ã¢â ¢ interest within a company, class action recognizes shareholder activism as just another compon ent that is devised procedurally to entitle investors the right to take collective action against the prejudicial actions done by or on behalf of the company.[3] The new Companies Act, which was long-anticipated and welcomed in India recently, lays down a strict regime for those accepting deposits from the public and also gives protection for whistle blowers.[4] Class Action Suits: Concept and Scheme in other Jurisdictions In common parlance, the term à ¢Ã¢â ¬ÃÅ"class actionà ¢Ã¢â ¬Ã¢â ¢ suggests a legal recourse collectively initiated by a group of investors, having common interest and cause of action, on behalf of the company to seek remedy on behalf of all the other aggrieved investors. In other words, it gives right to one member on behalf of a group to initiate an action against the defending company on the premise that they have the same locus standi.ÃÆ'à ¢Ã ¢Ã¢â¬Å¡Ã ¬Ã ¢Ã¢â ¬Ã ¹[5] Governed by Federal Rules of Civil Procedure, 1938[6] and State laws within the framework of United States, class action has, over time, culminated into a broad spectrum of jurisprudence and procedural underpinnings. CAS was gradually broadened to cover monetary remedy.[7] On the other hand, European Union has restricted the scope of this remedy only to aggrieved consumers.[8] Another jurisdiction where the concept finds emphasis is Australia wherein this crucial component of discipline for shareholder activism has been generally discerned in light of principles of common law.[9] Significance and Lessons from Satyam Class action will afford protection to small and dissenting investors and make directors and promoters more accountable. Even though CAS has been well-established within Indian frame, the concept was not accorded much importance until it was statutorily recognized through introduction of its scheme within Companies Act of 2013 (the à ¢Ã¢â ¬Ã
â2013 Actà ¢Ã¢â ¬Ã ). In the advent episodes of corporate farces like Enron in Un ited States and Satyam in India, shareholder protection has evolved as a novel discourse that reinforces responsibility of insiders to bolster their role as patrons for legal compliance of internal affairs. In addition to providing effective and economically viable recourse against the company than on an individual basis, representative suits aim to promote efficient settlement of claims while also minimizing resources. It is aimed at deterring company officials from giving effect to scrupulous maneuvers against the interests of a class of investors and averting legal compliance. The well-known Satyam debacle highlighted the need for regulation towards investor protection when small Indian shareholders were left with no effective remedy while investors who were based in United States were assured range of possible remedies.[10] This enormous set back culminated into efforts directed at protecting interests of persons like these investors who are devoid of any bargaining power. In Satyam fiasco, fraudulent schemes were floated while inflated balance sheets. Deceiving the shareholders regarding its profits, the company officials had flouted almost all the fiduciary duties. A New Beginning: Statutory Framework in India à ¢Ã¢â ¬Ã
âRepresentative suitsà ¢Ã¢â ¬Ã [11] and Public Interest Litigation (PIL)[12] were the only recourses available to the shareholders to enforce their rights against the company prior to the enactment of 2013 Act. Section 245[13] as enshrined under Chapter XVI (à ¢Ã¢â ¬Ã
âPrevention of Oppression and Mismanagementà ¢Ã¢â ¬Ã ) of 2013 Act introduces the concept of CAS. Accordingly, it can be initiated under two situations, as namely: If the management of the company is being conducted in a manner prejudicial to the interest of the company, as provided under Section 245(1) or; in case of misleading statements in the prospectus, as stipulated under Section 34 to 36 of 2013 Act. These provisions deal with mis-st atement in prospectus and the criminal as well as civil liability associated with it. Section 245(1) enumerates the grounds for initiating CAS. These include restraining company from going beyond Memorandum, Articles or provisions of law, passing and acting on a resolution on the basis of suppression of material facts. The scheme of CAS, being a representative suit, stipulates a threshold required to be met for filing an application under Section 245(3) of 2013 Act. An application can be filed by hundred or more members of a company having share capital or a percentage of shares cumulatively held by aggrieved members as may be prescribed, whichever is less.[14] Any shareholder holding shares above this prescribed limit can file an application, provided these shares are fully paid up.[15] In cases involving a company having no share capital, an application is required to be filed by one-fifth of its total members.[16] An application can further be filed by hundred or more deposito rs of a company or group of depositors constituting the prescribed percentage, whichever is less. Furthermore, depositor(s) who has invested certain percentage of the total deposit as prescribed is eligible to file an application.[17] The procedure after admitting the application is provided under Section 245(5). It is initiated by service of a public notice to all the members or depositors of the company. Subsequently, all admitted applications are combined into a single application and all members or depositors are conferred freedom to collectively decide the lead applicant. If the members or depositors of the class are unable to come to a consensus, the National Company Law Tribunal (NCLT) is empowered to appoint an applicant who shall be in-charge of the proceedings on behalf of applicants.[18] No parallel application for the same cause of action is allowed under Section 245(5) (c). Moreover, the cost of proceedings is required to be compensated by company, and in case of suc cessful claim, by the fraudulent person. Company and all persons associated with it are bound by the order passed by NCLT.[19] In the event of failure to comply with the order, the company shall be punished with fine which shall not be less than rupees five lakh but may extend to rupees twenty-five lakh.[20] In respect of à ¢Ã¢â ¬ÃÅ"every officer of the company who is in defaultà ¢Ã¢â ¬Ã¢â ¢[21], the punishment covers imprisonment for a term which may extend to three years and with fine which shall not be less than rupees twenty-five thousand and more than rupees one lakh.[22] Additionally, the concept of CAS does not apply to Banking Company.[23] The provisions of Sections 337 to 341 of 2013 Act, which deal with liability of certain company officials for committing fraud during winding up mechanism, are to apply mutatis mutandis[24] in relation to an application made to NCLT. The legal expenses incurred while pursuing class action by members under Sections 37 and 245 can be reimbursed from Investor Education and Protection Fund, provided it is authorized by NCLT.[25] As per SEBI (Investor Protection and Education Fund) Guidelines of 2009, Investor Protection and Education Funds are required to be maintained by Securities Exchange Board of India (SEBI) for aiding legal proceedings taken by the investor associations that are registration. Clause 5(2)(d) of the Guidelines provides for à ¢Ã¢â ¬ÃÅ"aidà ¢Ã¢â ¬Ã¢â ¢ to investorsà ¢Ã¢â ¬Ã¢â ¢ associations, that are recognized by SEBI. Accordingly, investors are provided financial assistance to undertake legal proceedings for safeguarding their interest in securities that are listed or proposed to be listed on any of the recognized Stock Exchanges.[26] Notably, the ambit of the term à ¢Ã¢â ¬ÃÅ"aidà ¢Ã¢â ¬Ã¢â ¢ is broad enough and hence can be interpreted to cover litigation cost under CAS. Due to similar wordings of the provisions under Sections 245 and 241, class action is misread with provisions governing oppression and mis-management. An application under Section 241against oppression and mis-management can only be filed by members of the company whereas, under Section 245, both members and depositors can file applications.[27] Even though both provisions provide certain thresholds, it is worthy to note that the NCLT has discretion to waive threshold in cases dealing with oppression and mis-management.[28] While applications under Section 241 can be filed against the company and its statutory appointees, Section 245 applications can be filed against the company, any of its directors, auditor, including audit firm, expert or advisor or consultant or à ¢Ã¢â ¬ÃÅ"any other personà ¢Ã¢â ¬Ã¢â ¢.[29] Application under Section 241 is restricted to past, present or recurring activity. However, the scope of remedy for CAS is wide enough to cover future actions of the company. Essentially, the rationale for having distinct provisions for class acti on and recourse against oppression and mis-management was that, although majority of cases for oppression and management were entertained by Company Law Board (CLB), the scope of these cases failed to cover all forms of fraudulent conduct by defaulter or any person who may be associated with the company. Offshoot of Corporate Governance: Revolutionary or Hollow? Clearly, the new provision under Section 245 lacks clarity which, in turn, erodes its effectiveness. The scope of the term à ¢Ã¢â ¬ÃÅ"depositorà ¢Ã¢â ¬Ã¢â ¢ has been restricted to circumstances that involve acceptance of à ¢Ã¢â ¬ÃÅ"deposità ¢Ã¢â ¬Ã¢â ¢[30]. The rationale for explicitly excluding the depositors who are in consultation with Reserve Bank of India cannot be logically comprehended as there may only be negligible considerations distressing the component of deposit. Moreover, the provisions for CAS clearly allow piercing the corporate veil by allowing members to take action against auditors, expert or any other person who have a contract with company. This breaches the privity of contracts executed by the company and such persons. Section 245 fails to provide opt-out mechanism for the investor who may choose to move NCLT individually. In United States, if an investor is not satisfied with settlement made on his behalf, he/she is conferred the option to opt-out of the proceedings.[31] Further, contingency fee is allowed for in United States. This incentivizes investors to combine their claim and initiate collective proceeding.[32] On the contrary, as per Bar Council of India Rules and Advocates Act of 1961, contingency fee not permitted in India. Furthermore, Courts have been following the practice of awarding cost in favor of winning party. Consequently, the losing party is required to incur all costs which is undoubtedly an additional burden sanctioned by Court. Therefore, if plaintiff-investors lose CAS, they are required to sustain huge losses comprising of the l itigation fees, investment in the company and defendantà ¢Ã¢â ¬Ã¢â ¢s litigation cost. Section 245 fails to provide limitation period. Moreover, the compensation awarded as a group may be argued to be less as compared to the individual case. VI. Conclusion CAS will strengthen investorsà ¢Ã¢â ¬Ã¢â ¢ protection and will retain investor confidence. The power given to the members will deter auditors, experts, directors and advisors from being flouting the accuracy of financial data and promote quality of its reporting. The major advantage of CAS is out-of-court proceedings before a specialized forum like NCLT. The adjudication of disputes before NCLT promises efficiency and less consumption of time. This consideration, however, will be diminished by the lack of certainty within relevant CAS provisions. Consequently, the numerous discrepancies will make recurrent Court proceedings a commonplace. While considering the cost of coordinating and filing suit, the scheme of CAS is necessary to be inculcated within the practice of investor associations. However, there are very few investors association that are registered with SEBI.[33] It is, undoubtedly, important that investors are made aware of the newly incorporated provisions in order to be able to fully address their concerns against those of companies. 1 | Page Donââ¬â¢t waste time! Our writers will create an original "Awakening of Shareholder Activism" essay for you Create order [1] Khushboo Narayan, Model India Files Class Action Suit in NSEL case, LiveMint, January 15, 2014. Available at: lt;https://www.livemint.com/Companies/dBYpED1LWXWA9Vp4F1qX9O/Modern-India-files-class-action-suit-in-NSEL-case.htmlgt;. [2] Fed. R. Civ. P. 23. [3] PR. Raamaanathan, Class Action Law Suits vis-ÃÆ'à -vis Companies Act, 2013, 42 Taxman 513 (2014). [4] Public Trust of India, Now, Whistleblowing Mechanism for Public Deposit Taking Companies, The Financial Express, October 02, 2013. Available at: lt;https://www.financialexpress.com/news/now-whistle-blowing-mechanism-for-public-deposit-taking-companies/1177349gt;. [5] Alipak Banerjee, M.S. Ananth and Vyapak Desai, U.S. Court Dismisses Class Action Suit Against Mahindra and Mahindra, Dispute Resolution Hotline, (Mar 26, 2014). Available at: lt;https://www.nishithdesai.com/information/research-and-articles/nda-hotline/nda-hotline-single-view/newsid/2316/html/1.html?no_cache=1gt;; J.J. Iraniet. al.,Report of The Expert Committee on Company Law. Available at:lt;https://www.mca.gov.in/MinistryV2/chapter7.htmlgt;. [6] Fed. R. Civ. P. 23. [7] Barabin v. Aramark Corp., No. 02-8057, 2003 WL 355417, at *1 (3d Cir. Jan. 24, 2003)(citing James v. City of Dallas, 254 F.3d 551, 571 (5th Cir. 2001)); Jefferson v. Ingersoll Intà ¢Ã¢â ¬Ã¢â ¢l, Inc.,195 F.3d 894, 898 (7th Cir. 1999); Murray v. Auslander, 244F.3d 807, 812 (11th Cir. 2001). [8] John Davies and Andrew Austin, Consumer Class Actions in the EU, Freshfields Bruckhaus Deringer, (April, 2009). Available at: lt;https://www.freshfields.com/uploadedFiles/SiteWide/Knowledge/Consumer class actions in the EU.pdfgt;. [9] Federal Court of Australia Amendment Act (Cth), Part IV A (1991); See. Stuart Clark and Colin Loveday, Class Actions in Australia: An Overview, Clayton Utz, (2004). Available at: lt;https://www.claytonutz.com/docs/Class Actions_Aug04.pdfgt;. [10] John Samuel Raja, Corporate Governance: How New Rules Will Change Indian Companies, The Economic Times, Jan. 8, 20 13.Available at: https://articles.economictimes.indiatim es.com/2013-01 08/news/362166631 corporate-governance-companies-bjp-president-nitin-gadkari/2gt;; Also See. Ruchir Sinha and Nishchal Jodhpuria, The Great Deception, Asia Law, February 2009. Available at:lt;https://www.nishithdesai.com/fileadmin/user_upload/pdfs/Ma Lab/AsiaLaw-Satyam.pdfgt; . [11] Civil Procedure Code, Order I, R. 8 (1908). [12] Paul Karlsgodt (Ed.), World Class Actions: A Guide to Group and Representative Actions Around the Globe, 525 (Oxford University Press 2013); Supreme Court of India has upheld S.P Gupta v. Union of India, AIR 1982 SC 149 and Upendra Baxi v.State of U.P., (1981) 3 Scale 1136, uphold the validity of PublicInterest Litigations. [13] The Companies Act, 245 (2013). [14] Id. 245(3) (i) (a). [15] Id. 245(3) (i) (a). [16] Id. 245(3) (i) (b). [17] Id. 245(3) (ii); See. The Companies Act, 75 (2013). [18] Id. 245(5) (b). [19] Id. 245(6). [20] Id. 245(7). [21] Id. 2(60). [22] Id. 245(7). [23] Id. 245(9). [24] Cas es [25] The Companies Act, 125(3)(d) (2013). [26] SEBI (Investor Protection and Education Fund) Guidelines, R. 5(2) (d) (2009). [27] The Companies Act, 245(3) (ii) (2013). [28] Id. 244(1) Proviso. [29] Id. 245(1) (g). [30] Id. 2(31). [31] Fed. R. Civ. P. 23(e)(3); See. Muhammad v. County Bank of Rehoboth Beach, Del., 189 N.J. 1, 912 A.2d 88 (2006). [32] Model Rules of Professional Conduct, Rule 1.5 (c) (1983). [33] Bharati V. Pathak, Indian Financial Systems: Markets, Institutions and Services, 757, Dorling Kindersley (3rd ed., 2011).
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Wednesday, May 6, 2020
Code Of Ethics For Nurses - 1331 Words
Code of Ethics for Nurses 1. Introduction- Explain your knowledge of this business profession. Why did I choose nursing? At the age of 43 I am back in school to further my education in the health field in nursing. Am I doing it to make a difference in the world or as a longstanding career? To be a nurse, it takes a special type of person that has extraordinary personal qualities and traits. A good nurse should have compassion, respect, and the need and want to help others. Therefore be sensitive, but passionate about their work. The experience that draws me to this area of work ; working in an emergency room for almost six years as a patient care technician and an emergency technician(EMT) has given me an inside view on nursing. Twenty years ago if you would have asked me to go visit someone in a hospital, I would have come up with some kind of an excuse not to go. I dreaded the place; seeing people sick, the smell, the hurting, and dying was the last thing I wanted to see. After taking care of my sick mom had given me that courage to face the unforeseeable future of working in the medical field. Following the passing of my mom, I became a Certified Nursing Assistant in a nursing home. In addition, I became a patient care technician, which led to a Certified Emergency Technician at an emergency room. I am currently still employed at the hospital, which has given an opportunity to be a part of a great emergency team of Physicians, Physician Assistants, and nurses. I amShow MoreRelatedCode Of Ethics For Nurses1274 Words à |à 6 PagesCode of Ethics for Nurses In the nursing profession, nurses often find ethical reasoning that not only evaluates actions and their results, but also questions why we perceive certain incidences to be paramount for us as humans. Ethics attempts to decide how actions are deemed right or wrong. 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The nursing code of ethics was adopted in order to determine and define ethical values for nurses. Human dignity, privacy, justice, autonomy in decision making, commitment, loyalty, human relationship, compassion, fairness, responsibility, honesty and individual and professional competence are considered an integral part of the nursing profession. Nurses as membersRead MoreCode Of Ethics For Nurses1614 Words à |à 7 PagesCode of Ethics for Nurses The American Nurses Association (ANA) established the code of ethics for nurses to serve as a foundation for practice and nursing standards. Nurses that enter the field are educated on the code of ethics and its provisions that make up the balanced foundation that is used to this day. The code of ethics is to be honored by every nurse, and every nurse should know their ethical obligation to their patients (American Nurses Association [ANA], 2015). This approach encompassesRead MoreThe Code Of Ethics For Nurses1082 Words à |à 5 PagesIntroduction The code of ethics for nurses provides a framework on ethical principles that nurses are supposed to follow while providing patient care. Under this code, nurses are not allowed to pry into information on patients not directly under their care, and they could not share any patient information to individuals who are not privileged to know such information. (American Nurses Association, 2015). Ethical issues related to electronic health records (EHRs) are extremely beneficial toRead MoreCode Of Ethics For Nurses1114 Words à |à 5 Pages Professional Code of Conduct Fadrique R. Charlot Nova Southeastern University Professional Code of Conduct Health professionals hold the commitment of providing quality health care to the society in order to fulfil the health concerns of the general population presented daily. 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Nurses make decisions on a daily basis regarding what information to tell patients. The specific issue in question is whether a nurse should abide by the Code of Ethics for Nurses by revealing the truth to the patient or refrain from telling the truth to the patient because they are respecting the wishes of the patientââ¬â¢s family. Nurses and health care professionals should always tell the truth to their patients unless theRead MoreThe Nurse s Code Of Ethics1022 Words à |à 5 Pageshas a code of ethics, that sets standards and guidelines that are set in place to protect both the professional and the client. Ethics play a key role in day to day business. This paper will discuss the nurseââ¬â¢s code of ethics, the advantages and disadvantages, and difficulties that the author may have following the established code. This paper will also discuss whether or not there are rules that have too much emphasis on them, and rules that do not. The nurseââ¬â¢s code of ethics was draftedRead MoreCode of Ethics for Nurses Essay1605 Words à |à 7 PagesRunning head: SYSTEM OF INQUIRY PAPER System of Inquiry Paper Wendell A. Garcia University of Phoenix March 18, 2008 American Nurses Associationââ¬â¢s Code of Ethics for Nurses Ethics is an integral part of the foundation of nursing. Nursing has a distinguished history of concern for the welfare of the sick, injured, and vulnerable and for social justice. This concern is embodied in the provision of nursing care to individuals and the community. Nursing encompasses the prevention of
Defending Barbie Free Essays
When I was young, one of the most favorite songs I usually listened to is ââ¬Å"Barbie Girlâ⬠. The song started with funny melodies about a blonde single girl named Barbie. She lived in her dream house with swimming pool, convertible and lovely things. We will write a custom essay sample on Defending Barbie or any similar topic only for you Order Now She also had a boyfriend named Ken. She was not a girl coming from this song but a doll who was created in 1959 by Mattel. Until now she is over 50 years-old but her beauty and her lifestyle are always the dream of children. She does not look like the fashionable trends which will be old-fashionable after a short period. Her influences to children never decline. Barbie is not only a plastic doll that cannot talk and interact but also a friend who plays an inspiring role in their life. In my experience with playing and owning Barbieââ¬â¢s, Barbie has had nothing but the fun and positive impacts on my life. First of all, the most positive impact of Barbie is the meaningful messages which she brings to us through her story. Barbie is famous with her dream house, convertible, beautiful outfits, luxurious jewelries and expensive shoes. She owns the luxurious things which she acquires them all by herself from being a career woman. She is a symbol of a successful woman by working in a wide range of jobs such as a dentist, a teacher, a police, a chef, a baby-sitter, a fire-fighter, an artist and so on. For this reason, she can earn a lot of money by her own capacity and buy everything she likes. Not just that, Barbie is also a fashionmonger. She always appears in the most beautiful outfits with different styles and she will be the person who updates the newest fashionable trends of famous brands. She has a boyfriend but she does not dependent on his bank account. She is depicted as an independent girl who does not rely on a man to take care or support for her. By her own way, Barbie becomes an ideal model of women, a public idol who many children want to become. They all want a Barbie to play with and to be like her because of her meaningful message that Barbie can be anything she wants and so do they. Besides that, there are countless valuable messages she brings to children such as being feminine, living independent from man, doing anything you want, working any kind of jobs which you like, achieving your dreams by putting your heart and mind into it, being fashionableâ⬠¦ hrough her special and unique lifestyle. Secondly, Barbie helps children develop their creation. Owning a Barbie doll is not a simple work. When we buy a Barbie, she just looks like the other Barbie dolls with same faces, same body shapes, same outfits or even same colors of hair. However children have their freedom to make her become different. Whether she will become a unique doll depends on childrenââ¬â¢s hands and minds. If they want Barbie to be different, they have to figure out and act. It is the way Barbie motivates childrenââ¬â¢s minds in imaginative acts. Holding Barbie in their hand, they can start to change the appearance of Barbie by typing her hair up with rubber brands, make braids or change Barbie hair lengths by cutting shorter too. Besides that, they can also try to replace the set of her outfits by the other one. It is not compulsory that Barbie has to wear this T-shirt with his trouser. Children can combine the t-shirt with a long skirt and create a new style. Moreover they can modify the length of her dresses as they might like or they can even try to sew a new dress or a T-shirt for her. The ideas to imagine the context which Barbie belongs to is not a bad ideas. For example, Barbie who wears a gorgeous dress may attend in a prom party. Not just that, due to her flexible body children can modify the position of her arms, bend her legs or sink her head like she is greeting someone for their ideas. Barbie makeovers are not only fun, but also creative. It step by step helps children show their own style. Barbie successfully shows her power in promoting the childrenââ¬â¢s imagination and creation. Moreover Barbie is a friend who inspires children to show their own identity. Playing with their Barbie, children have a chance to show their dream, their lifestyle and their personalities. The children would like to spend many hours to take part in a role play that Barbie is the main character. The context is one of the necessary elements in their imaginative play. Nothing is scripted in their imagination; it includes childrenââ¬â¢s pretended role play. In their play, Barbie will be a reflective image of children. For example, if the child considers Barbie as a teacher, she may create a play that Barbie goes to the school and works at 7 a. m. At 5 p. m, she comes back her home and plays with her children. Then there are some conservation between Barbie and her childrenâ⬠¦ In this case, perhaps the child has a dream to be a good teacher in future. She also thinks about her future as a kind mother with a lot of children around her. Besides that, the child shows her time for Barbie going to work and coming back home means that she is very good at managing her time. However the role of Barbie in these plays is not fixed. Children usually change Barbieââ¬â¢s careers and extend the plots as well as the conservation to illustrate their family life, imagine adolescent life and glamorous events. Barbie will be the copy of children which helps them show their dreams, their personalities and their real life. Since I was 12 years old, Barbie was always appeared in my wish lists. That was the time when I came to my friendââ¬â¢s house and saw her doll. Her Barbieââ¬â¢s beauty going along with her beautiful outfits and accessorizes makes me fall in love with her. However it was not easy to own a Barbie doll due to its price and its market distribution. I remember at that time it is very difficult to find the original Barbie in Vietnam. The only way to own a Barbie doll at that time was you had to buy in America and send back. My dream only came true when my uncle came back to Vietnam in 2009. He brought a Barbie doll as a gift for me. Although it was not a right time for me to play Barbie due to my busy schedule and my age, I still felt very happy when owning such a beautiful doll. Every weekend, I have to go to Ho Chi Minh City and I take a bus to come back my hometown. When I leave, my younger sister usually stays at home alone. As the result, Barbie became my younger sisterââ¬â¢s friend whom she could spend for hours to play with. One day when I came home from Ho Chi Minh City, my sister asked me to design some clothes for Barbie. I accepted her request because I thought this was a good chance to me for practicing my sewing skills. We came to some tailor shops asking for scarps of fabric together. Then we tried to sew the simplest outfit for Barbie without taking her measurements or sketching out her outfit including a strapless shirt and a mini skirt. Although they were not really excellent, it was an unexpected success and it made us feel really satisfied for our efforts. By sewing the outfit for Barbie, we together stimulate our creation. Not just that, she also enjoyed changing Barbieââ¬â¢s appearance for example the hair. Thanks to the long and straight hair, my sister created many different hairstyles as far as she could imagine. Sometimes Barbie becomes a charming girl with the small lovely braids, another time she turned into an active girl with the basic horse-tail style. Besides that as far as I know, she also had a schedule for taking care of Barbie. She usually changed Barbieââ¬â¢s hair and her outfits every day and cleaned the dirt in Barbie every weekend. Taking care of Barbie shows how thoughtful and careful she was. Barbie somehow helps me realize my sisterââ¬â¢s identity. Sometimes when I came home and saw my younger sister was talking to Barbie. She often played a role as a teacher and Barbie was her student. She had her own classroom map which included the position of her friends and Barbie in class. She taught Barbie the subjects she studied such as Math, Literature or Music. Thanks to the plays she performed together with Barbie; I realize many potential capabilities of my younger sister as well as her identity and her thoughts. While many people today only pay attention to Barbieââ¬â¢s unreal body shape and argue about her negative influences she may bring to children due to her story and her lifestyles, they seem to forget her positive impacts. In my opinion, instead of complaining about Barbie and her body measurements, we should reinforce the facts that Barbie helps life of children become more beautiful and lively. By the time when children grow up, Barbie will help them figure out their career, their characteristics and their lifestyle. She is not a plastic doll who was named Barbie but a bridge and an instructor guiding children to their future. What a wonderfully full and imaginative world we enjoy with Barbie! How to cite Defending Barbie, Papers
History of musical theatre Essay Example For Students
History of musical theatre Essay Musical Theatre Renaissance The antecedents of musical theatre in Europe can be traced back to the theatre of ancient Greece, where dance and music were included in stage comedies and tragedies during the 5th century BCC. The 3rd-century BCC Roman comedies of Plateaus included song and dance routines performed with orchestrations. The Romans also introduced technical innovations. For example, to make dance steps more audible in large open air theatres, Roman actors attached metal chips called Isabella their stage footwear, creating the first tap shoes. Middle Ages By the Middle Ages, theatre in Europe consisted mostly of traveling minstrels and small performing troupes of performers singing and offering slapstick comedy. 1830 Minstrel Shows This form of Musical Theatre was entertainment in America, these types of performances contained comical sketches, variety acts, dancing and music. This was performed mainly by white people with black face (black painted face) The Minstrel show first began in the sass but did not become popular until the sass. It was still a form of entertainment until 1910, performances from amateurs lasted until the sass. As black people began to become victorious against racism, the popularity began to decrease. Musicals as we know them today have their roots in opera. An opera is a dramatic presentation in which the story is told through music, similar to modern musicals. Opera got its start in Italy, around the turn of the 17th century. In opera, there is generally no spoken dialogue; sung passages and dramatic arias move the plot along. This is similar to popular sung-through musicals of today, such as Vita, Less Miserable and Phantom Of The Opera. 50 This type of musical theatre was popular between 1850 and 1960 and it was known as Musical Hall. It entailed a mixture of popular song, comedy and specialty acts. British music hall was quite similar to American Vaudeville, in which in contained comedy acts and rousing songs. 1860 Burlesque is a form of entertainment that is an extravagant parody of drama, musical or a piece of literacy. Burlesque is later used as a term for performances of variety a cts, this type of Burlesque was extremely popular from the sass to the sass. This was often performed as past of cabarets acts and at clubs, it was even performed theatres too. These featured bold comedy, and female striates acts. The popularity of Burlesque lessened however, recently it has become more popular once again. The first musical was the Black Crook by Charles M. Barres and Giuseppe Proper in 1866, which ran for a record breaking 474 performances. History of musical theatre By racked Vaudeville is another form of entertainment from America. This form of entertainment was like a variety act. The beginning of Vaudeville began in the sass and the popularity declined in the sass. A vaudeville performance was made up of many different scenes and acts that were grouped together. Many vaudeville acts consisted of magic, singers dancers scenes from plays, acrobatics movies and minstrels. Vaudeville was known as The heart of the American show business for many decades. Vaudeville was the most popular type of entertainment in America at that time. 1904 In 1904, Musical comedy started, which is a type of musical or movie or play which it as a simple yet funny and emotional plot, and musical numbers. Musical theatre contained things from every single genre, packed with colorful sets and bright costumes. 1923 Film musicals are musicals that are in Hollywood films. This is where characters of the film will sing songs to advance the plot line. Most of these musicals involved a submerge of musical comedy, which combined music, comedy and dancing. The first film musical was in 1923. 1961 Rock Musicals This form of musical is one where all the songs are of one genre or band. Some rock casuals follow a story through song. .u180a25af93dcbd8312067c15d1e4669c , .u180a25af93dcbd8312067c15d1e4669c .postImageUrl , .u180a25af93dcbd8312067c15d1e4669c .centered-text-area { min-height: 80px; position: relative; } .u180a25af93dcbd8312067c15d1e4669c , .u180a25af93dcbd8312067c15d1e4669c:hover , .u180a25af93dcbd8312067c15d1e4669c:visited , .u180a25af93dcbd8312067c15d1e4669c:active { border:0!important; } .u180a25af93dcbd8312067c15d1e4669c .clearfix:after { content: ""; display: table; clear: both; } .u180a25af93dcbd8312067c15d1e4669c { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u180a25af93dcbd8312067c15d1e4669c:active , .u180a25af93dcbd8312067c15d1e4669c:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u180a25af93dcbd8312067c15d1e4669c .centered-text-area { width: 100%; position: relative ; } .u180a25af93dcbd8312067c15d1e4669c .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u180a25af93dcbd8312067c15d1e4669c .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u180a25af93dcbd8312067c15d1e4669c .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u180a25af93dcbd8312067c15d1e4669c:hover .ctaButton { background-color: #34495E!important; } .u180a25af93dcbd8312067c15d1e4669c .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u180a25af93dcbd8312067c15d1e4669c .u180a25af93dcbd8312067c15d1e4669c-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u180a25af93dcbd8312067c15d1e4669c:after { content: ""; display: block; clear: both; } READ: Music and the Media - Pop music EssayThe first rock musical was in the sass. Some examples of rock musicals are: Hair, Grease, Rent, Spring Awakening and Next To Normal. 1975 Musicals that contain popular songs with a connection with an era or band, are known as Jukebox musicals. The songs are sung in certain parts of the musical to fit the plot. Usually if the musical numbers are from a band or musician, the plot will be a biographical story. For example Buddy was about the life of Buddy Holly and Mamma Aim was about the music of ABA. The first Jukebox musical was in 1975.
Wednesday, April 29, 2020
The Effect of Endorphins on Pain free essay sample
Neurotransmitters are chemicals located in the brain that are responsible for communication of the information between and throughout the brain and the body. They send and transport signals via nerve cells (neurons). Without neurotransmitters our organism wouldnt have the ability to function because they are responsible for the operations in our body. With neurotransmitters, the brains sends signals to the other parts of the organism to perform the actions they need to. In past decades, numerous experiments were done to prove that and to find more about the neurotransmitters. In 1987, Dr. Jon Levine of the University of California in San Francisco found out that placebo can be expressed as chemical. In other words, he believed that the brain can produce neurotransmitters that can act as pain-killers, therefore in some cases, the mentioned neurotransmitters may trick the organism to believe they were given a certain drug treatment that will relieve pain. We will write a custom essay sample on The Effect of Endorphins on Pain or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The brain produces the neurotransmitters called endorphins which are similar to opiates and thus influence our body. As i. e. morphine is an opiate that will in certain quantity relieve the pain in our body, endorphins are naturally produced opiates that will act in a same way as morphine does. In the same year he conducted an experiment called Placebos effect on pain may equal a dose of morphine to really prove whether the neurotransmitters endorphins are responsible for pain-killing and they can act as pain-killers (equal a dose of morphine). Dr Levine wanted to see if giving the participants regular sugar pills and telling them they are pain-killers will have the same effect as if they were really given a pain-killer pill. As participants were under the influence of the placebo, the endorphins are produced and the pain is relieved. Then, his second aim was to then conclude to what does of morphine does placebo equal. The participants were regular patients in a dental clinic who were told to drink a regular pain-killer in order to relieve pain after the appointment. They were told that the pills were regular everyday pain-killers, but truly they were ordinary sugar pills. The experimenters divided the participants in two groups (independent sample). The participants in both groups were experiencing some form of pain after the same or similar dentist appointment. The participants in the first group were given one sugar pill and were told that the pill was a pain-killer. Then, the participants in the second group were also given a sugar pill, but they were also given a pill containing a chemical called naloxone which prevents the production of endorphins and therefore no placebo effect would occur (they were possibly told to take two because of the amount of pain). * Dr. Levine believed that if they were given naloxone, this would stop the production of endorphin and thus there would be no chemicals that would suppress the feeling of pain. *the number of participants in each group was not available The findings were similar as his hypothesis. The participants from the first group didnt feel any pain after taking the pill because the endorphins were produced and acted as opiates to prevent any further pain. In the second group the participants told the experimenter that they were still experiencing pain, which was expected because the chemical naloxone prevented the production of endorphins and the participants underwent no treatment with opiates whatsoever. With additional studies, dr.Levine concluded that the effect of the placebo possibly equals to 8 milligrams, which is an amount of morphine that will surely suppress pain in a human. Dr. Levine concluded that human behavior can be influenced using placebo. If someone was told that a certain substance the person is intaking will help him feel better or different, the persons brain will act according to it. The person taking the substance has expectations regarding the use of the substance ââ¬â the person will expect to feel better just by taking the pill and therefore automatically feel better. Dr. Levine suggested a reasonable justification ââ¬â the naturally-produced chemical endorphin is responsible for these operations. The advantage of this study is that it is easy to draw results from it. We knew how placebo worked, but not why. By determining that endorphins are responsible for placebo, we need to justify that. In both cases there would be production of endorphins if just the sugar pill was given and with the production of endorphins the relieving of pain. To see if endorphins have something to do with placebo, we have to reject the endorphins and see if there will be any change. To reject the production of endorphins the experimenter used naloxone and saw that there was no placebo-effect if there was no production of endorphins. The possible disadvantage would be that there can be other factors along with endorphins that influence the placebo-effect about which the experimenter does not know. The findings are widely used today. The endorphins are also popular because they are linked to happiness, excitement, pain, etc. We always tell people to rather feel happy and cheerful when theyre experiencing pain psychologically or physically because that would help them. And if the placebo-effect is linked to the endorphins, the effect is very beneficial.
Tuesday, April 14, 2020
Comparison and Contrast Essay Sample - Creation Vs Evolution
Comparison and Contrast Essay Sample - Creation Vs EvolutionComparison and Contrast Essay Sample come in two parts: the essay itself and the report. The test that you'll be taking is from the United States standards test known as the MCAS (Massachusetts College Admission Test). This test is specifically designed to assess English composition, which is one of the things that you'll be expected to do on your essay.The essay is divided into five sections: one for each chapter of the essay, a summary section, and the conclusion. The short essay test is graded based on what you've written in each of these sections, as well as whether or not it actually helps you learn more about any given topic.As part of the comparison essay sample on creation vs evolution, students will be expected to write an essay based on actual research conducted in high school. In this essay, students will be writing about how their knowledge about the topic came about, what they learned while doing so, and the man ner in which they learned. This particular project is usually taken by students who are already taking the state standardized exam (or the national exam) to help them prepare for future test taking.Students also take a comparative essay based on scientific theory. In this particular essay, students are asked to describe how they have used a scientific theory to solve a problem or make a prediction. Of course, this kind of essay is designed to provide students with an idea of how science works.It's important to note that the essay is divided up into parts, each of which is assessed in terms of its ability to help a student learn. The first section is what students may call a 'test' section. Here, students are going to be challenged to find a solution to a problem that has been presented to them in a novel way.This portion of the essay is supposed to help students learn to be able to reason and analyze information. The second section is what students will refer to as a 'summary' secti on. Here, students will be asked to express their personal opinions on a certain subject, and it is here where students are supposed to let their true emotions show through.The last portion of the essay is the conclusion. Here, students are expected to discuss something that they found interesting, controversial, or surprising.Comparison and Contrast Essay Sample - Creation Vs Evolution works best when students practice on different versions of the essay and are encouraged to edit and make changes to the essay before writing it. When students are told ahead of time what parts of the essay will be on each of the report forms, it will help them focus on the important things.
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