Best friend essay writing
Controcersial Persuasive Essay Topics
Tuesday, August 25, 2020
Audiometry Lab Report Example | Topics and Well Written Essays - 500 words
Audiometry - Lab Report Example It likewise helps with surveying the nature, degree, and reasonable justification of the conference disability of s tolerant. The unadulterated tone audiometry is utilized in deciding the edge of knowing about the patient. This is characterized by the most minimal hearing level at which the patient reacts at any rate 51% of the opportunity to sound-related improvements. These limits are discovered utilizing techniques as suggested by the American Speech-Language-Hearing Association. Unadulterated tone edge testing ought to be dealt with in a sound controlled room. This will help in abstaining from veiling by unsatisfactory commotion levels in the room. An audiogram is made out of three principle parts to be specific, unadulterated tone testing that decides capacity to recognize sound, and discourse testing decides capacity to decipher sound, and tympanometry which helps in characterizing where the issue is. The typical hearing capacity extends between 10 - 25 dB HL while for serve cases it goes between extreme 70 - 85 dB HL. For the principal understanding, the left ear, frequencies between 0-2000(Hz), the consultation capacity extends between - 20ââ¬50dBHL. As the rate increments past 2000 Hz, the meeting capacity increments from - 30 to - 10 dBHL. Nonetheless, when the rate hits past 4000 Hz, the conference capacity diminishes to - 36 dBHL. Then again, the correct ear, the consultation capacity increments step by step with the exception of when the recurrence arrives at 250-500 Hz where the conference capacity stays consistent. Nonetheless, this shows the correct ear has a superior listening capacity. For the subsequent patient, the consultation capacity fluctuates between various frequencies. In the left ear, the conference capacity increments between 250-2000 Hz. Be that as it may, when the recurrence goes past 2000 Hz, the meeting capacity begins to diminish. This delineates when sound recurrence goes past 2000 Hz, the consultation capacity of the left ear gets invalid. Be that as it may, for the left ear, the conference capacity increments. Most of edges are about 0 dB HL for a sound ear. Focuses under 0 dB HL on the scale assign
Saturday, August 22, 2020
Three Rules For A Good Book Essays - Mr. Tucket, Oregon Trail
Three standards for a decent book The two books that I read this late spring are: California Blue by David Klass, and Mr. Tucket by Gary Paulsen. There are three standards for composing a decent book. Lamentably nobody realizes what they are. That statement was said by W. Somerset Maugham. Each Author has their own three guidelines. I concocted my own. The three principles that I believe are the most significant.
Friday, August 7, 2020
Step by Step Guide on How to Write A Compare And Contrast Essay
Step by Step Guide on How to Write A Compare And Contrast Essay In this blog, we are going to share with you how to write a compare and contrastessay. Lets get started:- What is a compare and contrast essay? Summary What is a compare and contrast essay?Steps in Writing a Compare and Contrast EssaySelect the Topic CarefullyThink of the Structure of TextIntroductionBe CreativeAdd Some FactsApproaches to a Compare and Contrast EssayBlock ApproachPoint-by-Point ApproachTopics to Consider For Compare and Contrast EssaysTips for Compare and Contrast Essay WritingConclusion A compare and contrast essay refers to the similarities and significant differences of more than two objects. It is one of the most common methods of essay writing assignments for students. Students will need to find out the key points between more than two subjects for compare and contrast essays that will make the comparative analysis on and then evaluate the similarities and differences between those significant points. A compare and contrast essay shows the similarities and differences between two topics such as Comparing: Defines the similarities between the two subjects.Contrasting: Defines the differences between two topics. Steps in Writing a Compare and Contrast Essay Select the Topic Carefully Before start writing a compare and contrast essay, you need to choose a topic. Keep in mind that the topic should showcase their analytical and writing skills. You should choose those topics to compare which are in trend and interesting for your users. Think of the Structure of Text The structure of compare and contrast is to contain an introduction, a paragraph of one topic, a paragraph of another topic, and also a paragraph of conclusion. The students can start with an introduction, then write a paragraph that defines the similarities among the two common subjects, then a paragraph that discovers the differences among the two subjects, and then lastly end with a conclusion. Introduction Students must begin the compare and contrast essay with a compelling presentation that catches the attention of readers and introduces the topic. Be Creative Try to be and remain creative throughout the work. For instance, do not write, Ill inform students about this in my work. Rather than take the readers interest by asking two questions on all subjects: What draws teenagers to eat fast food? Why do some teenagers prefer not to eat fast food? Add Some Facts In the introduction, students must give a general outline of the compare and contrast essay. It provides the readers with the full topic of understanding students are writing about. It is an excellent idea to provide a brief historical outline. You can either start with a joke or a story. Apart from that you can also use a provoking statement in the introduction. Approaches to a Compare and Contrast Essay When writing a compare and contrast essay, students may take any of the two most approaches. Following are the two major approaches: Block Approach This approach for compare and contrast essay uses the rational pattern of defining the common points in the light of significant elements. Then all others are listed in proper paragraphs in the body and having a logical series. Point-by-Point Approach This approach is a more inclusive approach for the structure of compare and contrast essays. Topics to Consider For Compare and Contrast Essays Compare and contrast between two comedies or tragedies of William Shakespeare.The Compare and contrast between two women poets of choice, like Maya Angelou and Margaret Atwood.Compare and contrast between the customary American nuclear and Japanese family structure.Compare and contrast the effects of music and the impacts of the Internet in the childhood of the digital era.The Compare and contrast among a bacterium and a virusCompare and contrast between the monument of David through Bernini and Michelangelo Tips for Compare and Contrast Essay Writing Pick an appropriate SubjectTime to Brainstorm between Similarities and DifferencesEnhance the ArgumentOrganizational StructureA proper OutlineProof to SupportUse of Transitional WordsReview and Proofread Conclusion This information provides more information discussing how to write a compare and contrast essay, how to structure this kind of essay, how to use, compare and contrast structure terms, and how to confirm you use proper criteria for contrast or comparison. If you have some issues regarding the compare and contrast essay, you can take advantage of our company. Our company is the best writing service with various experts throughout the world. Contact us for the best essay writing help and get started with an expert essay writer.
Saturday, May 23, 2020
John F. Kennedy Gave the Order for the Bay of Pigs Invasion
When John F. Kennedy, President of the United States of America, gave the orders to invade Cuba and overthrow Castro, America was expecting a victory. The American population expected Cuba to be destroyed. They thought Cuba could not stand up to the United States. What they didnââ¬â¢t expect was that Cuba would put up a fight. The Bay of Pigs invasion was a deciding factor in the Cold War that gave Cuba and the Soviet Union strength, and decreased morale and confidence in the Americans. The Bay of Pigs invasion took place during the Cold War, which was not an actual war, but it consisted of tensions between the USSR (United Soviet Socialist Republic) and the United States and both their allies. The Cold War began in the late 1940ââ¬â¢s and ended in the early 1990ââ¬â¢s. Harry S. Truman, Dwight D. Eisenhower, John F. Kennedy, Lyndon B. Johnson, and Richard Nixon were several important United States Presidents during the time of the Cold War. Joseph Stalin, Nikita Khrushchev, and Leonid Brezhnev were several important Soviet leaders at the time. Ernesto ââ¬Å"Cheâ⬠Guevara and Fidel Castro were also some of the more important leading figures in Cuba. On the first of January in 1959, Fidel Castro took over the presidency of Cuba, using his ââ¬Å"guerilla armyâ⬠(ââ¬Å"Bay of Pigs Invasionâ⬠) to overthrow General Fulgencio Batista, an ââ¬Å"American-backed presidentâ⬠(ââ¬Å"Bay of Pigs Invasionâ⬠). A dishonest and tyrannical dictator, Batista was disliked by his people, yet he was a friend to the United States. He didShow MoreRelatedKennedy Doctrine1168 Words à |à 5 PagesThe Cold War and U.S. Diplomacy James Cantrell POL 300- International Problems May 16, 2013 Professor Mark A. Stallo, Ph.D. During John F. Kennedyââ¬â¢s presidency the United States was seriously concerned with stopping the spread of communism throughout the world and there where hot spots that sparked the Kennedy administrations attention. Containment was the United States foreign policy doctrine that proclaimed that the Soviet Union needed to be contained to prevent the spread of communismRead MoreThe Bay of Pigs: One of the Most Important Political Decisions in the History of the United States 2279 Words à |à 10 PagesThe Bay of Pigs was one of the most important political decisions in the history of the United States. The decisions that were made by President John F Kennedy showed us that the United States was far from perfect. The Bay of Pigs Invasion globally embarrassed the United States because of the lack of constructed thought put into it and its completely failed outcome. The Bag of Pigs Invasion was an unsuccessful attempt by United States exiles to overthrow the government of the Cuban Dictator FidelRead MoreEvents Leading to the Cuban Missile Crisis1579 Words à |à 6 PagesCuba, a country just south of the United States of America, was the center stage of events leading up to the Cuban Missile Crisis. Actions attempted by Presidents John F. Kennedy and Dwight D. Eisenhower prior to the crisis gave incentive to the Soviet Union and Cuba to agree to place missile installations in Cuba. The Cuban Missile Crisis was an incident that might have potentially led to a third world war because of the already heightened tensions between Cuba and the U.S. - but this time withRead MoreThe Bay Of Pigs Invasion1147 Words à |à 5 PagesLouis Tullo Mrs. Forsyth U.S. History II 30 March 2016 Bay of Pigs Invasion Bays in pigs invasion is a cold war planned and fought by American president John F. Kennedy in an attempt to overthrow in early 1960ââ¬â¢s. This came after Fidel Castro overthrew the then Cuban president Fulgencio Batista. The president was corrupt and had allies in the United States allowing the Americans to control the Cuban economy (Khan 21). The incoming Castro did the opposite by disapproving the Americans and resistedRead MoreThe Bahia De Cochinos Invasion : Who Carries The Blame?1947 Words à |à 8 PagesThe Bahà a de Cochinos Invasion: Who Carries the Blame? The Bay of Pigs invasion, has been a hotly debated topic since its occurrence in April of 1961. Many historians place blame on the shoulders of the President, whose administration carried out the plan, John F. Kennedy. However, others place blame on the President Dwight Eisenhower whose administration devised the plan. Some cite the failures in the planning committed by Kennedy, while others say the failure of the invasion lies on Eisenhower sRead MoreJohn F. Kennedy s Strategy On Foreign Policy1275 Words à |à 6 PagesJohn F. Kennedyââ¬â¢s Strategy on US Foreign Policy Although John F. Kennedyââ¬â¢s record on foreign policy has received mixed reviews because of his all too short presidency, Kennedyââ¬â¢s approach or strategy on how to deal with international issues gave the United States of America options on foreign policy, both then and now. John Fitzgerald Kennedy was born to a rich and privileged family who was already a well politically connected family. The Kennedyââ¬â¢s fortune came from the stock market, entertainmentRead MoreCuban Missle Crisis and the Realist Perspective Essay1172 Words à |à 5 Pagesrealist perspective. In 1961, President John F. Kennedy launched the Bay of Pigs Invasion of Cuba, which was a thwarted attempt by a CIA-trained force of Cuban exiles to invade southern Cuba, with assistance from United States armed forces, to oust the corrupt government of Fidel Castro. This failed operation had sent the US back into a defensive position. In former President Dwight D. Eisenhowerââ¬â¢s remarks to Kennedy he stated, ââ¬Å"The failure of the Bay of Pigs will embolden the Soviets to do somethingRead MoreThe Cuban Missile Crisis : Background1620 Words à |à 7 Pageseastern Germany were leaving because they want communism, so the Soviet built the wall. Before the wall 300,000 people and whe n the was were built on 24 made it across the wall. ââ¬Å"A wall is a hell of a lot better than a war.â⬠John F. Kennedy, August 1961. Another quote John F. Kennedy said about the Berlin walls is ââ¬Å"There are many people in the world who really donââ¬â¢t understand, or say they donââ¬â¢t, what is the great issue between the free world and the Communist world. Let them come to Berlin. There areRead MoreCuban Missile Crisis : The End Of The World1647 Words à |à 7 PagesRevolution that lead up to the United States losing their ties with Cuba. The Bay of Pigs invasion was an unsuccessful attempt to remove Fidel Castro from power in Cuba that ultimately hurt the United States more than it helped. After the failed Bay of Pigs invasion, Castroââ¬â¢s relation with the Russians was strengthened because it was then that Castro announced that Cuba would become a Socialist Republic. President John F. Kennedy was successfully able to avoid a nuclear war by his use of appe asement andRead MoreJohn F. Kennedy s Record On Foreign Policy1304 Words à |à 6 PagesAlthough John F. Kennedyââ¬â¢s record on foreign policy has received mixed reviews because of his all too short presidency, Kennedyââ¬â¢s approach or strategy on how to deal with international issues gave the United States of America options on foreign policy, both then and now. John Fitzgerald Kennedy was born to a rich and privileged family who was already a well politically connected family. The Kennedyââ¬â¢s fortune came from the stock market, entertainment, and other business ventures by Joseph ââ¬Å"Joeâ⬠Kennedy
Tuesday, May 12, 2020
Personal Narrative For The Nebraska State Writing Test
I teach fourth grade language arts where my main focus is to prepare my students to write a personal narrative for the Nebraska State Writing Test in January. Reading and writing are intertwined in my area of professional responsibility as I motivate my students to write a well-organized, creative personal narrative. As I have taught writing, I have found reading, writing, speaking, and listening go hand in hand when composing a personal narrative (Bruning, 2011, p. 299). First of all, reading is an important part of the writing process. It can be difficult to teach students who enter my classroom with different reading levels. Due to this, I use fiction stories to expose my students to a variety of themes and styles of writing. I have found it easier for my students to understand a writing prompt when I have introduced it with a narrative story. For example, we read Jakeââ¬â¢s 100th Day of School by Lester L. Laminack for the prompt: Memories are something that are specia l to you. Think about a time you remember well. It could be a memory about a special celebration, a favorite sports moment, or a fun time with a friend or family member. Write a story about this memory using specific details so that the reader will understand the event and your thoughts and feelings. While reading a variety of stories, I am able to point out literary elements to my students. I know reading to my students can teach my students about good writing (Bruning, 2011, p. 295). I alsoShow MoreRelatedWriting and Research Paper2935 Words à |à 12 PagesWriter at Work following some of the articles. HE ââ¬â Harbrace Essentials ââ¬â recommended writing handbook. Strunk and White and the Purdue University Online Writing Lab can be found online (links in resources). Questions? E-mail the instructor: patricia.green@hccs.edu Other Materials Paper and pen Folder for handouts Jump drive/flash drive Grade Percentages Essay #1: (10%) 500 word personal memoir on childhood and family, or a sense of place Essay #2: (10%)Read MoreWhat Is Apa Style2702 Words à |à 11 Pagesmore . . . Getting Started with APA Citation Style What is APA Style? American Psychological Association (APA) style is one of several styles for academic writing. This guide covers frequently used citation forms. The sixth edition of the Publication Manual of the American Psychological Association (BF 76.7 .P83 2010) is a comprehensive resource, available at most UBC Libraries. General Rules â⬠¢ Formatting: The preferred APA font is a serif typeface such as Times New Roman with 12-point sizeRead MoreInterpretation of the Text13649 Words à |à 55 Pagesliterary work Literature is writing that can be read in many ways. We can read it as a form of history, biography, or autobiography. We can read it as an example of linguistic structures or rhetorical conventions manipulated for special effect. We can view it as a material product of the culture that produced it. We can see it as an expression of beliefs and values of a particular class. We can also see a work of literature as a selfcontained structure of words - as writing that calls attention to itselfRead MoreANALIZ TEXT INTERPRETATION AND ANALYSIS28843 Words à |à 116 Pagesindividual and depends to a great extent on his knowledge and personal experience. Thatââ¬â¢s why one cannot lay down a fixed ââ¬Å"modelâ⬠for a piece of critical appreciation. Nevertheless, one can give information and suggestions that may prove helpful. PLOT The Elements of Plot When we refer to the plot of a work of fiction, then, we are referring to the deliberately arranged sequence of interrelated events that constitute the basic narrative structure of a novel or a short story. Events of any kind, ofRead MoreStudy Guide Essay25129 Words à |à 101 Pagesand developed by the faculty to help you master the content of the course. Each chapter in the study guide corresponds to a chapter in the textbook. Study guides vary depending on the course, but most will include: Learning Objectives Overviews Self Tests Summaries Key Terms Critical Analysis Questions (graduate and doctoral students only) The most efficient way to complete this course is to read the materials in both the study guide and textbook in the sequence in which it appears, generally from beginningRead MorePsy Evaluation Essay11057 Words à |à 45 PagesGuide NOTE: Your final exam will consist of 100 questions selected from the following, as well as selected questions from in-class tests on Food Addiction and on The Joyful Mind; correct answers to those tests have already been posted to the doc sharing portion of the Ecompanion Website. You can use the answers to check the answers you gave on your chapter study tests. Your final exam is on Wednesday, September 12, 2012; You will have from 8:15AM to 9:45AM to complete the final exam. There are noRead MoreFundamentals of Hrm263904 Words à |à 1056 Pageswealth of interactive visual and audio resources, WileyPLUS gives you everything you need to personalize the teaching and learning experience. à » F i n d o u t h ow t o M A K E I T YO U R S à » www.wileyplus.com ALL THE HELP, RESOURCES, AND PERSONAL SUPPORT YOU AND YOUR STUDENTS NEED! 2-Minute Tutorials and all of the resources you your students need to get started www.wileyplus.com/firstday Student support from an experienced student user Ask your local representative for details! Read MoreHuman Resources Management150900 Words à |à 604 Pageslevels were offered promotions, transfers to other jobs in GE Fanuc, or early retirement buyouts. Additionally, employees were promised profit sharing, which has resulted in up to three weeks additional pay in profit sharing bonuses in some years. The test of the change is in the results. GE Fanucââ¬â¢s revenue is up women employees, who composed about three-fourths of the bankââ¬â¢s workers. As a result, several years later about one-fourth of all managers and executives are women. Similar attention also wasRead MoreOne Significant Change That Has Occurred in the World Between 1900 and 2005. Explain the Impact This Change Has Made on Our Lives and Why It Is an Important Change.163893 Words à |à 656 PagesD421.E77 2010 909.82ââ¬âdc22 2009052961 The paper used in this publication meets the requirements of the American National Standard for Information Sciencesââ¬âPermanence of Paper for Printed Library Materials, ANSI Z39.48-1992 Printed in the United States of America 2 4 6 8 9 7 5 3 1 C ONTENTS Introduction Michael Adas 1 1 World Migration in the Long Twentieth Century â⬠¢ Jose C. Moya and Adam McKeown 9 â⬠¢ 2 Twentieth-Century Urbanization: In Search of an Urban Paradigm forRead MoreStephen P. Robbins Timothy A. Judge (2011) Organizational Behaviour 15th Edition New Jersey: Prentice Hall393164 Words à |à 1573 PagesOrganizational Behavior This page intentionally left blank Organizational Behavior EDITION 15 Stephen P. Robbins ââ¬âSan Diego State University Timothy A. Judge ââ¬âUniversity of Notre Dame i3iEi35Bj! Boston Columbus Indianapolis New York San Francisco Upper Saddle River Amsterdam Cape Town Dubai London Madrid Milan Munich Paris Montreal Toronto Delhi Mexico City Sao Paulo Sydney Hong Kong Seoul Singapore Taipei Tokyo Editorial Director: Sally Yagan Director of Editorial Services:
Wednesday, May 6, 2020
How Does Equity Fulfil the Common Law Free Essays
How Does Equity Fulfill the Common Law Common Law Equity fulfils the common law, although it does not endeavour to displace it with a moral code. In order to be influential, the law is to be professed as both certain and predictable, and also flexible and fair. Specifically, it needs clear rules on the one hand, but flexibility on the other to produce exceptions to cases that lead to apparently incongruous or unjust conclusions if the rules are applied rigidly. We will write a custom essay sample on How Does Equity Fulfil the Common Law or any similar topic only for you Order Now Equity is an essence of principles, doctrines, and rules advanced initially by the Court of Chancery in positive competition with the rules, doctrines and principles of the Common Law Courts. The obliteration of the old Court of Chancery and the Common Law Courts, has led to the proposition that the distinction between law and equity is now outdated; that the two approaches are now ââ¬Ëfused. On the contrary, the better analysis, is that the common law and equity remain distinct but mutually dependent features of law: ââ¬Ëthey are working in different ways towards the same ends, and it is therefore as wrong to assert the independence of one from the other as it is to assert that there is no difference between them. ââ¬â¢ For a long time, the two structures of common law and equity ran uncomfortably side by side. Until 1615 it was by no means established which one was to prevail in the event of a dispute. Yet, even after that year the inconsistency between the two systems continued for a very long time. After the restructuring of the English court system in 1865, it was decided that in the event of a conflict between the common law and equitable principles, equity must prevail. The Judicature Acts 1873-1975 created one system of courts by amalgamating the common law courts and the courts of equity to form the Supreme Court of Judicature which would administer common law and equity. Accordingly the court ââ¬Ëis now not a Court of Law or a Court of Equity, it is a Court of Complete Jurisdiction. ââ¬â¢ The area of law recognized as Equity developed in England and Wales in the Middle Ages in situations where the ordinary common law had failed to afford suitable redress. Many legal actions, for example, originated by the issue of a writ but the slightest inaccuracy on the writ would invalidate the entire action. Another inadequacy in the ordinary common law involved the fact that the only remedy was damages; that is, compensation, therefore, the court orders did not exist to require people to do something or to desist from some conduct, for example, sell as piece of land according to an agreement made or stop using a particular title. Dissatisfied litigants frequently preferred to petition the King for him to mediate in a specific case, the courts were, in any case, the Kingââ¬â¢s courts. These petitionsââ¬â¢ for justice were dealt with by the Kingââ¬â¢s Chancellor who determined each case according to his own discretion. Over the years, the decisions made by Lord Chancellor became known as the rules of equity, derived from the Latin meaning levelling. These new-found rules came to be applied in a special court, the Chancellorââ¬â¢s Court, which became identified as the Court of Chancery. Equity began to appear as an apparent set of principles, rather than a personal jurisdiction of the Chancellor, during the Chancellorship of Lord Nottingham in 1673. By the end of Lord Eldonââ¬â¢s Chancellorship in 1827 equity was recognized as a precise jurisdiction. Nevertheless the development of a parallel but distinct system of dispute resolution was certainly bound to generate a conflict. An individual wronged by a failure of the common law to remedy a gross injustice would apply to the court of equity. The Chancellor, if the case accepted it, would approve of a remedy preventing the common law court from imposing its order. The catharsis transpired in the Earl of Oxfordââ¬â¢s Case, where the court of common law ordered the payment of a debt. The debt had previously been paid, but the deed giving affect to the requirement had not been cancelled. The court of equity was prepared to grant an order preventing this and resolving the deed. The collision was in due course resolved in favour of equity; where there is an inconsistency, equity prevails. This rule is now preserved in the Supreme Court Act 1981, s 49. The history of equity is regarded by its constant ebb and flow between compatibility and competition with the common law. More recent developments in equity include, for example, the recognition of restrictive covenants, the expansion of remedies, the development of doctrines such as proprietary estoppel, the enhanced status of contractual licences, and the new model constructive trust. There is an effort, then again, to validate these new developments, which are all illustrations of judicial inspiration, by precedent. As Bagnall J said in Cowcher vCowcher: ââ¬Ëthis does not mean that equity is past childbearing; simply that its progeny must be legitimate- by precedent out of principle. It is well that this should be so; otherwise no lawyer could safely advise on his clientââ¬â¢s title and every quarrel would lead to a law-suit. ââ¬â¢ In all probability the single most significant feature of equity is the trust. If title to any property is vested in a person as trustee for another, equity not only restrains the trustee from denying his trust and setting himself up as absolute owner, but impresses on the trustee positive duties of good faith towards the other person. Although one of the original development of equity, the protection granted to equitable owners behind a trust has developed considerably over the last 50 years. Remedies represent some interesting illustrations of the difference between law and equity; a difference which arose as; ââ¬Ëan accident of history,ââ¬â¢ according to Lord Nicholls in A-G v Blake. Ordinarily legal rights and remedies remain separate from equitable ones. Some similarities do, nevertheless, occur. For illustration, an injunction, an equitable remedy, can be sought for an anticipatory breach of contract, or to stop a nuisance, both common law claims. In A-G v Blake, the House of Lords authorized the equitable remedy of account of profits for an assertion for violation of contract where the common law remedy of damages would have been insufficient. The equitable remedy of account of profits is usually accessible where there is a fiduciary relationship but the House of Lords endorsed its request otherwise in exceptional cases where it was the operative way to remedy a wrong. By distinction, in Seager v Copydex, proceedings were brought for breach of confidence in regard for confidential information exposed by the defendants about a carpet grip. Such a claim is equitable and normally the equitable remedies of injunction and account are obtainable. On the other hand, an injunction would have been unsuccessful and he judges awarded damages. It would appear, consequently that a common law remedy is available for an equitable claim for breach of confidence. The new model constructive trust resulted in the main due to the resourceful activity of Lord Denning MR. In Hussey v Palmer, Lord Denning explained the constructive trust as one ââ¬Ëimposed by the law wherever justice and good conscience require it. Cases such as Eves v Eves, where the woman was awarded an equitable interest in the property signifying her involvement in terms of heavy work, and Cooke v Head, a comparable case, regard this progress further. On the other hand, it might be that this progression has come to a standstill since the retirement of Lord Denning. A number of modern cases, including Lloyds Bank v Rosset, have re-established former ideology in this s phere relating to the survival of a common intention that an equitable interest should occur, and the existence of a direct financial contribution. These ethics are more analogous to those relating to the formation of a resulting trust. The new model constructive trust has been for the most part thriving in the field of licences. At common law, a contractual licence was controlled by the doctrine of privity of contract, and failed to present protection against a third party. Equitable remedies have been made accessible to avoid a licensor violating a contractual licence and to permit a licence to bind third parties. It has been acknowledged that certain licences may produce an equitable proprietary interest by means of a constructive trust or proprietary estoppel. In Binions v Evans, it was decided by Lord Denning that purchasers were compelled by a contractual licence between the former owners and Mrs Evans, an occupant. A constructive trust was imposed in her preference as the purchasers had bought specifically subject to Mrs Evansââ¬â¢ interest and had, for those grounds, paid a reduced price. Also in RE Sharpe, a constructive trust was imposed on a trustee in bankruptcy regarding an interest obtained by an aunt who lent money to her nephew for a house purchase on the arrangement that she could live there for the rest of her life. The volatility of these progressing fields is once more shown in recent case law which seems to hold back from an advancement which may have pushed the boundaries too far. Obiter dicta from the Court of Appeal in Ashburn Anstalt v W JArnold Co, accepted in Habermann v Koehler, propose that a licence will only give effect to a constructive trust where the conscience of a third party is influenced: it will be imposed where their behaviour so deserves. Judicial resourcefulness in equitable disciplines is therefore made subject to refinements by judges in later cases. Proprietary estoppel is an additional illustration of an equitable doctrine which has seen momentous progression in the interest in justice ever since its formation in the leading case of Dillwyn v Llewelyn. The dogma is established on encouragement and acquiescence whereby equity was equipped to arbitrate and adjust the rights of the parties. Its relevance has been further improved by the Court of Appeal in Gillet vHolt, where a wider line of attack to the doctrine was taken that depended, eventually, on the unconscionability of the act. Once more, it is an advancement which is outside of the organization of property rights and their registration recognized by Parliament. Cases such as Jennings v Rice show that the principle of proprietary estoppel and the protection of licences by estoppel continue to be a successful means used by the judges for the protection of licences and equitable rights. The extent to which the right welcomes protection is adaptable owing to the conditions of the particular case. For example, in Matharu v Matharu, the licence did not bestow a beneficial interest but presented to the respondent a right to live in the house for the rest of her life. A different prevailing progression in equity has resulted from the decision of the House of Lords in Barclays Bank plc v Oââ¬â¢Brien. The case has proclaimed the re-emergence in a broad sense of the equitable doctrine of notice. They present that, where there is undue influence over a co-mortgagor or surety, this may provide augmentation to a right to prevent the transaction. This right to avoid the transaction amounts to an equity of which the mortgagee may be considered to have constructive notice. This revivification of the equitable doctrine of notice in a contemporary situation reveals evidently the flexibility of equity. A number of cases pursued this pronouncement. In Royal Bank of Scotland v Etridge, the House of Lords laid down common procedures for the application of the doctrine of notice in this situation. In summary equity fulfils the common law, although it does not endeavour to displace it with a moral code. There have been setbacks and refinements, over the last 50 years, in the progress of new doctrines relating to the trust. How to cite How Does Equity Fulfil the Common Law, Papers
Friday, May 1, 2020
Marketing Strategy & Plan of Cadbury- PESTEL Analysis & CAGE Framework
Question: Analysing External and internal environment of cadbury, their CSR using CSR stance model and the last section will be their overseas opportunity in one country except UK using that countries PESTEL analysis and CAGE framework between UK and the other country. Answer: 1.0 Introduction A company can be assessed by its strategic position in the market with respect to its competitors. This paper consists of a n extended research analysis on the biggest confectionary organization in the world, Cadbury. It will assess the critical aspects of the strategic selections which are availed to Cadbury. The paper will give the reader a significant knowledge about the various tools of research and also their importance in analysing and evaluating the markets for a business entity. The core purpose of this project is to support Cadbury to expand in its home country and also internationally with the proper use of accurate modes, theories and concepts. The strategies of marketing model will be applied and analysed in this report to indicate the competitive and market position of Cadbury. Recommendations are also given to measure the perspective of the company on the growth of the profits and revenue along with the share of market. However the planned segmentation is also evaluated critically on the foundation of the multiple procedures to categorize the financially attractive fragment for Cadbury. The available position in the industry is also identified with the help of strategic framework. The reaction of the competitors offers a detailed assessment of the probable reaction of the competitors along with the options to the strategic plans of Cadbury which are counteractive. The paper finally ends with the justification of the most possible strategic location for further operations of the business (Agudo-Valiente, Garcs-Ayerbe and Salvador-Figueras, 2013). Does The Intricacy of The Topic Intimidate You? Tame Your Fear with Unmatched Assignment Help Services from Professional Writers 2.0 Background of the Company John Cadbury founded this company in the year 1831 which was covered successfully and also revolutionized the processing of cocoa in the market from the year 1866. Cadbury then merged successfully with Schweppes in the year 1969. The company is now internationally acknowledged as the most reputed organisation with the acclamation of an international status, Cadbury Schweppes PLC (referred to as Cadbury hereinafter). The company also successfully employs more than 45,000 employees in around 60 countries worldwide. The company is positioned strategically as the fourth highest supplier of the chocolate and sugar confectionary all over the world. The supreme successful product that was promoted by Cadbury since the year 1905 is Dairy Milk, the product has become very popular melted chocolate in UK along with the other chocolate bars internationally in the terms of revenue. The companys three major pillars in its strategic success are top notch quality, money value and sound advertisement (Ajibola and Njogo, 2012). 3.0 Research Design Research design which is used in this paper focuses mainly on the accurate tools of research like PESTEL Analysis, Porters Five Forces Model to assess the external environment of Cadbury so as to recognize the probable opportunities and threats. To evaluate the internal environment the resources and capabilities framework is used in the report. To equalize with the opportunities and the external threats with the internal weakness and strengths TOWS matrix have been applied here. The corporate social responsibility of the company is also analysed clearly with the support of Carrolls Pyramid of CSR and CSR stance. To assist in the growth of Cadbury in the international market UAE PESTEL Analysis and the CAGE framework is considered to identify and point the profitability of the markets (Appleton, McKeown and Woodside, 2011). 3.1 Consequence and Outcomes With the involvement of these tools to the Cadbury Company it will help us to recognize the probable opportunities in expanding the business and also assist it forecasting the threats which cannot be anticipated now. The market of UK confectionery is very much established market having a high demand and also levels of penetration. Additionally, the market is very much controlled and is also influenced by the big players like Mars and Nestle. Thus it becomes very essential for Cadbury to be pre-emptive in implementing the different strategies of business which are effective after considering the various factors and also to construct an effective strategy of corporate social responsibility to achieve the competitive advantage (Appleton et al., 2011). 4.0 External Analysis The first and foremost fundamental step of strategic management is to analyse the current factors of the environment within which the operations of the company will be executed. The environmental factors consist of both internal and external factors. PESTLE framework is used to evaluate the external environment. There are two aspects of this analysis. The first aspect is to identify the environment in which the operations of the company take place and secondly, it gives valuable data to the company which helps in predicting the circumstances and situations of the future (Assessing the industry using Porter's five forces, 2014). Furthermore the PESTLE framework also gives a certain amount of essential fundamental knowledge to examine the macro environment; it has some constraints in measurements terms. They are: The first setback which was seen that the PESTLE analysis does not adopt the quantitative measurement method. It was majorly concentrated on the qualitative approach if measurement. The autonomous assessment of the each factor of the PSTLE model may not replicate the exact situation. According to (Beneke et al., 2015) the PESTLE analysis must adopt the approach which is based on the inter dependence of the aspects of the model. However with these restrictions the PESTLE framework is very used by the companies to examine the external environment and the impact of the same on the objectives and targets of the organization. 4.1 PESTLE Analysis- UK Confectionery Industry The factors of the framework of PESTLE have a possible influence on the company, Cadbury. Thus the analysis that is mentioned below is of high importance for Cadbury if they want to successfully execute its operations of the business. Political Factors The political factors very much scrutinize the industry of the UK confectionery. It has both positive and negative impact on the company. It is very much essential for Cadbury to make themselves aware of the different political factors which are mentioned below: The government has initiated campaigns to advertise the healthier way of living among every citizen. It is also additionally, pushing the drink and the food companies to manufacture all healthy products with a clear labelling (BOYLE, 2012). Argument on Fat Tax- The first country to initiate the fat tax on food which contains 2.2% of saturated fat was Denmark. This also included confectioneries. Later it was obliterated because the food price was inflated after this. The medical experts however seemed to believe that the fat tax was an efficient way to decrease the obesity that was prevailing in UK. Thus as that fat tax can increment the unhealthy food price, it might be implemented in near future (Bray, 2015). Economic Factors Cadburys margin of profit is affected by the economic factors. It is necessary for an organization to know the factors so that they can take steps which are important to lessen the impact of this factor. Being responsive to the campaigns on obesity the companies manufacturing chocolates are now downsizing the bars of the chocolates before the VAT rise. The changes in climate are also affecting the yields of the crops. The prices and the trade balance are being affected in this return. The crisis in the economy y might also affect the spending of the consumers and also the chocolates which are premium will be considered as unaffordable luxury for at least some months (Bugge and Lavik, 2012). Social Factors The consumers of a company are the most essential assets for a company. Thus it is significant for Cadbury to comprehend the alterations in the needs of the consumers and also the social trends so as to manufacture value products. To deal with the downfall in the economy the consumers always prefer to save money by staying home, however to have a sweetening experience and for the guests they have started purchasing the chocolate bags. As we know that the chocolate is a versatile gift in every occasion; boxed and seasonal chocolates have experienced a very high demand thereby giving rise to the sales which have been forecasted to rise by 12.5%. In the present economic and social surrounding it has been seen that the sale of dark chocolates have increased dramatically (Collier, 2010). Technological Factors To attain a competitive advantage over the competitors Cadbury should be updated technologically and should also make use of the best and the latest technology that is present in the market. In the current world the researchers and analysts are working with the growers of cocoa by the assistance of the satellite; internet connections so that it can improve the evenness and quality of their beans. The companies are now opting for the advanced methods to examine and also rank the cocoa beans. In addition they are also taking the help of six division flavour wheel to fetch out natural aroma and the essence. The change in the shape of the chocolate is a surprising trend which is ruling the market for a decade. The chocolate today are prepared very creatively in various combinations and shapes like for example Oreo biscuits having chocolates combined with it (Dulà i, Gnjidi and Alfirevi, 2012). Environmental Factors The key element of Cadbury to execute its business is Cocoa. Cadbury should be responsive to the fact that there are certain effects of the environment on the production of the cocoa beans. Cadbury can design its own strategies to make sustainable cocoa. The changes in the climate are estimated to affect the cocoa farms of West Africa. By some years, more than half of the countries producing cocoa might be too hot to help in the growth of the cocoa. There is a huge decrement in the production of the cocoa because of the plant disease like black pot. The disease is a very serious problem which is destroying more than 85% of the cocoa crop. This disease is significantly severe in Central and West Africa. With the outburst of Ebola the production of cocoa beans and its trade have been affected adversely (George, Owoyemi and Onakala, 2012). Legal Factors Cadbury should be responsive enough towards the alterations in the legal regulations and law to produce their products in a legally acknowledged manner. It is very much essential for the global players in manufacturing chocolates to be upgraded with the latest changes in the law or else it might affect the reputation of the company. The current legal laws are mentioned below: The chocolate and the cocoa products must follow up with the reserved details that are formed by the Coca and Chocolate Products Regulations Act. The members of CAOBISCO should abide by with the food and safety policy laid down by EU so that the companies execute practises of fair trade and also give sales and superior products to its consumers (Jerzewska-Zychowicz, Jeznach and Kosicka-Gbska, 2012). The government of UK have enacted the imposition of penalties which is worth 4500 for any company who fails to comply with the description and labelling requirements. 4.2 Porters Five Forces Model To improve the effectiveness of a business plan, there is a necessity to evaluate the present situation. The best approach in this process is using the framework of Porters Five Forces Model. This model assists to recognize the competitive force of an industry and also give an indication of the industrys attractiveness. The following diagram will show the determinants of the model (Ketola, 2013). Figure 1: Porters Five Forces Model New entrants The confectionery market in UK is very much established and reputed in the market with top demand and also increased penetration level. There are around 274 producers of confectioneries in UK. The market is highly influenced and controlled by the major players like Nestle, Mondelez International and Mars. The company Cadbury is deemed to be an essential barrier for the new entrants because the company has a strong recognition of brand and also the threat of new firms is considerably less on Cadbury. Until and lest the product is innovative enough associated healthy style of living it cannot connect with the market to make its presence because already the market is captured by Cadbury (Kozelov et al., 2014). Threat of Substitutes The threat from substitution is very les on Cadbury because the brand equity is the key competitive edge of the company. Furthermore for the last few decades there is an increasing apprehension on the healthy life style. Thus there has been a huge increase in the sales of the products which are sugar free, products having reduced aft and cereal bars and calories providers. As per a survey recently it has been seen that the demand for the dark chocolates have also increased since it is deemed to be healthier than the other chocolates (New Partnership launched, 2010). Buyer Power There are two types of buyers in the confectionery markets; majorly the retailers and the ultimate consumers. There are also five super markets who dominate the confectionery retail markets in UK. These players are ASDA, TESCO, ALDI, SAINSBURYS and MORRISONS. These stores force more power of negotiation than the regular customers. The customers also purchase confectionary from the retailers in the local areas which are purchase on compulsion, for getting daily essentials. The confectionery products are broadly appreciated by every person in UK and they think it to luxury which is affordable (Pai and Subramanian, 2014). Supplier Power The industry dealing in confectionery works primarily with merchants of food ingredients who supply the products like sugar, cocoa and gelatine. The key producers of cocoa are in Latin America, West Africa and South East Asia. In accordance with a recent study it was founded that Mars, Mondelez and Nestle controls 38.5% of the entire global supply. The Cadbury-cocoa partnership have kept the supplier power ti a low state because the funds in the partnership are invested in cocoa farms located in India, Ghana, Caribbean and Indonesia so as to determine a long term supply of cocoa (Parasramka and Dufresne, 2012). Competitive Rivalry It has been seen that there exists an aggressive competition in the confectionery industry due to the existence of multiple manufacturers. The big players like Nestle, Ferrero, Mondelez and Mars are indeed very robust brands which will give a very hard competition to Cadbury. These companies are striving for high presence in market by the implementation of multiple marketing strategies. 4.3 Recommendations It is essential for the company Cadbury to ponder over all the external factors and taking them into consideration and turn them into opportunities and plan an effective strategy to execute a successful business. The company is recommended to continue investing in the innovation of the product since it is providing a competitive advantage for Cadbury. It must come up with more innovative and interesting strategies and promotion tactics to uphold the sturdy brand awareness so as to decrease the competitive rivalry. Cadbury should also focus on producing low-calorie and healthy confectionery to address the customers high concerns for healthy life style (Petrone, Gaziano and Djouss, 2013). 5.0 Internal Analysis Resource and Capabilities According to (Sager, 2012), the resources and the capabilities of a market play a major role in constructing a top quality value for the consumers and also in achieving the competitive edge. In the year 1980 there was a shift from the industrial framework to the resource based view (RBV); this highlights the significance of the external environment. The major purpose for this shift is inability of industrial structure to rationalize that why certain firms in the similar industry vary in the internal performance. Resources The resources can be differentiated into intangible and tangible resources. As per (Salabun, 2014) the tangible resources can be physical, financial and human resources while the intangible resources are the skills and also the corporate culture, knowledge of the employees and the company policies. It is very much essential to convert the resources to valuable yield. The capabilities are things which are more than the resources; it comprises, constructs and also transforms te resources so as to create value for the products (Salabun, 2014). Financial Resources Bank overdraft of Cadbury has reduced compared to 2012 Increment of 29.5% in the cash balance Increment in the working capital and also in shareholders capital. Physical Resources The core production unit of Cadbury is located at Bourneville. Mondelez is investing 75 million in the plant of Bourneville Cadbury to create it a world class one. Cadbury also has their own online and physical stores to transact their products. Other than this the company also have teamed up with various retail stores on a huge scale. Technological Resources Cadbury has the right to approach the top notch facilities. The company has started the Chocolate Centre of Excellence in 2012 for the purpose of research and development. Cadbury has adopted ERP system and SAP so as to cope with the merger Human Resource Management There are over 150,000 employees in Cadbury who are very much dedicated and well trained. Cadbury follows a decentralized system of organizational structure. The employee opportunities and benefits such as wellness of the employees, good salary package, pension schemes and insurance plan. Innovation Cadbury have innovated a new range of snacks like dairy milk LU Ritz recently, bringing in together two brands by investing around 7.3m in the process of marketing. Cadbury also industrialized the chocolates which are temperature tolerant. Reputation Cadbury is well known for its quality and purity. Cadbury is positioned as te world class brand in confectionery. The practise of fair trade in Cadbury made a vast difference in the reputation of the company. Table 1: Tangible and Intangible Resources Capabilities The different capabilities of Cadbury which adds to their core competencies are mentioned below: Having a strong experience in the industry of confectionery Pure and high quality Development of new product Advertising strategies Strong image of the brand Unique resources of the world Global strategy of marketing 5.1 Recommendations Cadbury should do a critical analysis of its business environment so as to categorize the strengths and weakness of the company. The acquisition has led to the loss of job for many employees. Cadbury should try to sustainits human resources and integrate the corporatecultures of both Cadbury itself and Kraft for accomplishing better performance and making optimum use of the resources and also the capabilities to stay one step ahead of the competitors in the confectionery market (Saltini and Akkerman, 2012). 5.2 TOWS Framework The TOWS structure is a sequential analysis of the organization which will tally the external opportunities and threats of the organization with the internal strengths and weakness. Internal Factors External Factors Strength Cadbury is the market in manufacturing chocolate in over 200 countries. Cadbury has brands which are strong enough to compete with the different manufacturers of chocolate. The company has strong brand loyalty. With the acquisition of Kraft, Cadbury has high access to the resources and the capabilities. Weakness Mondalez has a difficult task to sustain the emotional bond with the consumers of UK same as Cadbury. Problem to incorporate two different corporate cultures of Mondalez and Cadbury. Very high impact often competitors. There were arguments on the quality control of Cadburys products globally. Opportunities The leading manufacturers of chocolate are working with the Ghana Government towards the sustainability of cocoa. Technological alterations in the confectionery industry. SO Campaigns of sustainability will create goodwill and a good brand image of Cadbury among the consumers. Introduction of the new technologies in manufacturing chocolates to fetch more exotic flavours. WO Brand image will be hampered with the increment in the lines of product. Cadbury must balance the product lines to uphold the stability in the market growth. Threats Introduction of different laws and policies Changes in climate and outburst of dangerous disease. Substitute product threats. ST Cadbury should invest in multiple initiatives to support the farmers in sustainable farming of cocoa Manufacturing healthier products WT Threat are uncontrolled like incurable disease impacting on coca plantation Price wars might be triggered by the aggressive competition. Table 2: TOWS Framework 6.0 Corporate Social Responsibility The framework of CSR is a very vital framework for any company which are trying to donate some of its profit to the betterment of the society. It means the spectrum of benefits for the society as a whole with the activities of the business (Srdjevic, Bajcetic and Srdjevic, 2012). 6.1 Pyramid of Corporate of Social Responsibility There are four aspects of CSR which comprises of legal, economic, philanthropic and ethical. According to the current trends philanthropic and ethical functions are very essential in the corporate world. The following diagram shows the layers of the pyramid (Tokede, Gaziano and Djouss, 2011). Figure 2: Pyramid of CSR There are multiple initiatives which were undertaken by Cadbury on CSR. The following are some of the activities listed. $500 million USD was invested in coffee and cocoa origins. The company aimed at cutting down 14% of the usage of water and energy for the sustainable environment. Cadbury provided employment to the young people to motivate them. Educational projects were supported to develop their skills. Balanced and physical lifestyle initiatives were undertaken. Homeless and Vulnerable people were taken care of (Toledo, 2013). The Purple goes Green campaigns were initiated to decrease the plastic waste and encourage recycling. 6.2 Application of CSR Stances Forum of the interaction of the stakeholders Since Cadbury takes the consideration of multiple stakeholders in implementing strategies so it comes under this forum. Cadbury considers all its stakeholders to conduct its business (Vank, Mikol and vkov, 2012). Triple Bottom Line and Systems The company measures their growth on the foundation of their financial growth along with the environmental growth. Cadbury aims to manufacture their products in a sustainable manner by maintaining ethical codes of standard (Viveros, 2014). Proactive Cadbury is proactive in the societys betterment and donates a lot to it by initiating a number of SCR strategies like, health and welfare, etc. Good Practice ensured by System Cadbury started the initiative named the call for well being an approach for high well being of the people (Wilkins, 2010). 7.0 Other International Opportunities The suitable country in which Cadbury can diversify its business is UAE, which is very perfect for the market en try of Cadbury. The market of UAE chocolate confectionery is forecasted to flourish at a CAGR of 7.01% around 2014-2019 (Widmer, Lerman and Lerman, 2012). 7.1 CAGE Framework United Kingdom UAE Cultural Distance Native language is English, others being Irish, Welsh, etc. Social Norms- Meeting and greeting, punctuality and giving gifts. Religion- Christian 72%, Hindu- 1.5% and Muslim 2.5% Arabic is the main language other immigrant languages being English, Hindi, Urdu, etc. Social Norms- Ethnically different from UK, Islamic greeting Islam dominated religion Political Distance Monarchy Constitutional Perception of corruption index- 7.6 Federal government of UAE with many organs CPI- 5.8 Geographical Distance UK comprises four countries Population- 7,420,220 Comprises seven emirates Population- 1,138,351 Economical Distance 7 times more economical than UAE After Germany, second largest economy in Europe High standard of living. Open economy with huge per capita income. Three times industry establishments than UK. Table 3: Cage Framework 7.2 Rationale of the entry in the market of UAE. There are highly favourable conditions of tax in UAE with less barriers of trade which actively attract the investors from the international market. The tourism sector is the major reason to enter the market. UAE invites around 12 billion tourists every year which is a high potency for entering the market. The company can also establish Cadbury world for the tourists attraction in UAE. The company can also manufacture chocolate dates according to the taste and preferences of the localities in UAE. Cadbury has to initiate various marketing strategies to promote its market presence in the confectionery market of UAE (Wright, 2014). 7.3 Market Entry Strategy It is strongly recommended to the company for an alliance and joint venture strategy for entering the UAE market to set up the business. The perfect strategy is joint venture because the risk of the investment is shared among the partners and it also gives a huge access to the resources. Executing an alliance with a partner in UAE will help Cadbury to identify the market in detail and the localities can also be targeted. The quality of the product can also be efficiently monitored and Cadbury will also be to come up with innovative products with joined strategies (Yksel, 2012). 8.0 Conclusion The world biggest confectionery company is Cadbury for its strong brand image. Thus it is very vital for the company to analyse its internal and external environmental factors to be well aware of the alteration to attain a competitive edge. Research tools like Porters Five Forces, PESTLE, TOWS, etc give the company the effective information for designing its business plan with the changing preferences of the consumers. Besides this Cadbury should continue working for the society as well to protect the brand equity and goodwill. 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