Plan Your Day on Paper

There is a general opinion which is expressed once in a while that digital devices will kill the handwriting. All studying can be done on some kind of portable computer these days, namely a tab or a smartphone. You can search for information, take notes, write, and plan on your gadget. Besides, there is an app for everything. However, something about the very aesthetics of paper notepads and organizers speaks of the different — the paper items will live long, as they provide not just visual, but also tangible experience of scheduling and planning. So, use paper planners to organize your day. You might disagree that there are lots of specific apps which you can use to do your planning super-fast and effectively. For example, you can find a colorful calendar app and a nicely-looking notepad, in case you are not satisfied with the native ones. You can even make complex notes by including different types of media (text, drawings, links, and other). However, if you imagine a good paper notebook, you will see that it can be far better than your bunch of apps. First of all, the information you store is physically accessible to you —Â  it does not go anywhere for no apparent reason. At the same time, digital data may be not available simply because you changed the device or because it was just lost as a result of some malware or attack. You can have a universal notebook and take all your college notes with you and access them at need regardless of the quality of your Internet connection. Secondly, you can visualize your information even better than using digital tools on a device. You can buy some colored tape or stickers and assign them to specific plans, subjects, or types of activities that you will be listing in the notepad. You can use colors to prioritize tasks — just put a fire-red sticker next to the most important task in the list, and you will see it as soon as you open your paper organizer. Similarly, you can cover the issues that have been changed with strips of grey tape, for example. Thirdly, when you write something down on paper, you make it more tangible. This is why it is better to use notepads for planning, as you know that you didn’t just type something in for the sake of the record, but with a serious intention on your mind. Also, you can cross out items, rumple the pages, or tear them off entirely. You cannot do that digitally. And how about drawing on the margins while taking notes in a class? Of course, this is all optional, and some may find paper organizers not really fitting for their planning activities. Planning your schedule and activities on paper requires some dedication. However, once you’ve found yourself a perfect notepad, you can experiment with the content and its style as much as you like: use colors, write, rewrite, and overwrite, draw, highlight everything you want with stickers. Just be sure to not get lost in all the creative activity — as it turns out, planning can be creative too.

Character Analysis of Dracula - 537 Words

In the novels world, Dracula has many mystical powers, some which has been shown only on several occasions and some which he uses for his daily life. Dracula also has a very unique personality, which could tempt women and make them vulnerable. This means, Dracula could dominate every human being individually, not as a group. His powers and personality has something in common. Count Dracula uses his powers and unique abilities as a tool to ridicule religions and Gods decisions and as a great threat to the mainstream society. Count Dracula has the ability to seduce women, making them even more vulnerable by making them become openly sexual, and often make them fall in love with him and join his side. Although his ability can be powerful, it can also become a weakness at some point because he possibly doesnt have full control of his emotions. His motivation is to make his victims join his side either as a vampire by drinking the blood or as a human by seduction and turn against the victims friends and family, causing troubles for his opposition, which makes his seduction power a threat to the society, in this case, the friends and relatives. The combination of this ability and his other abilities, to make himself younger and possibly hypnotism as it was impossible to resist the Counts seduction, is considered as one of the biggest threats. For example, Dracula has succeeded in seducing Lucy and Mina and tempted them both, resulting vampire Lucy to turn against ArthurShow MoreRelatedDracula Seen in New Eyes 760 Words   |  3 PagesDracula Seen in New Eyes Dracula by Bram Stoker which is written in the style of journal entries, newspaper clippings, and other forms of personal narratives from various characters, and their viewpoints of the peculiar events surrounding them. There are many interpretations of this novel, many different viewpoints on the themes of the novel. Carol Senf, wrote an essay called Dracula: The Unseen Face in the Mirror. In this interpretation, there are many different viewpoints and ideas about DraculaRead MoreDracula, By Bram Stoker1148 Words   |  5 PagesIn Bram Stoker’s Dracula, there is a plethora of ways the novel can be critically analyzed, but there’s one theory in particular that I found the most interesting to apply. I used the theory of deconstructuralism to critically analyze Dracula, and to help break down the story into particular meanings and themes that can contradict the typical perceptions and first impressions of the novel. To better help complement my analysis, I read and analy zed another popular article by John Paul Riquelme, titledRead MorePollution And Redemption In Dracula, By Anne Mcwhir1272 Words   |  6 PagesPollution and Redemption in Dracula, written by Anne McWhir, a Professor Emerita at the University of Calgary, analyzes the complex relationships between characters of Bram Stoker’s, Dracula. McWhir acknowledges seemingly opposing themes within Dracula, â€Å"Dracula is remarkable for its blurring and confusion of categories. Modem and primitive, civilized and savage, science and myth are confused; so too are other categories-good and evil, clean and unclean, life and death† (31). She explains the purposeRead MoreDracula Extension Speech1098 Words   |  5 PagesFrom the ability to change physical form to a blood-thirsty nature society has always been morbidly fascinated with the concept of Dracula. It has not only seduced literature such as Bram Stoker’s Dracula but also infected mainstream music and film industries. M any composers have expanded and appropriated much of the vampire genre such as Francis Ford Coppola’s Dracula and Slayer’s Bloodline. The ideas surrounding vampires has been of good versus evil, the nature of religion and immortality. It isRead MoreGothic Elements In Dracula Essay1499 Words   |  6 PagesBram Stoker s Dracula is a staple of the Gothic Horror genre. It is a novel that has been scrutinized by countless readers since it was published in 1897. While Stoker s novel is certainly not the first example of a piece of gothic horror, or even the first example of a gothic horror story focusing categorically on vampires, it still managed to plenarily capture the attention of the public. But not only did Dracula enthrall the readers of its time, but it perpetuated to be a mainstay of the gothicRead MoreEssay on Stokers Portrayal of Women in Dracula1193 Words   |  5 Pagesliterature ever created, Dracula by Bram Stoker has been interpreted many different ways, b eing torn at from every angle possible. Just as one might find interest in interpreting novels differently, he or she might also find interest in the plot, prose, or theme, all of which ultimately lead to the novels overall tone. Throughout the novel, it becomes blatant that the novel contains an underlying theme of female incompetence and inferiority. Through a true feminist’s eyes, this analysis can clearly be understoodRead MoreDracula, By Bram Stoker1166 Words   |  5 PagesThe story of Dracula is well documented and has stood the test of time since it’s Victorian age creation. More times than not, literature writings are a reflection of the era from which they are produced. In the case of Dracula, Vampire literature expresses the fears of a society. Which leads me to the topic I chose to review: sexuality. The Victorian Era was viewed as a period diluted in intense sexual repression and I believe that Dracula effectively exploited this as the fear of sexuality w asRead MoreEssay on Oral Dracula From A Reader And Femminist Perspective1431 Words   |  6 Pages Bram Stokers â€Å"Dracula† an oral presentation Good Morning/Afternoon Today I will review Bram stokers’ 1897 novel Dracula, the approaches I will be using to reviewing the novel include the world centred approach, and the reader response approach exploring the themes of reader positioning and the authors intented reading and reader, then focusing on the world centred approach of the feministtheory. reader centred -attention on the reader -different readers from different social, cultural, religiousRead MoreOral Dracula from a Reader and Femminist Perspective1443 Words   |  6 PagesBram Stokers Dracula an oral presentation Good Morning/Afternoon Today I will review Bram stokers 1897 novel Dracula, the approaches I will be using to reviewing the novel include the world centred approach, and the reader response approach exploring the themes of reader positioning and the authors intented reading and reader, then focusing on the world centred approach of the feministtheory. reader centred -attention on the reader -different readers from different social, cultural, religiousRead MoreLiterary Review of Bram Stokers Dracula Essay1230 Words   |  5 PagesReview of Bram Stoker’s Dracula Prior to the creation of the literary classic â€Å"Dracula†, Bram Stoker spent his time managing the Lyceum Theatre and legendary actor Henry Irving. According to Jennifer Dorn, when the novel was first published in 1897, critics regarded it as a â€Å"pulp fiction potboiler† (Dorn). The novels declaration as a literary masterpiece came many years later. A graduate of Trinity college, Stoker came from a middle class Irish family, the son of a civil servant. The publication

Food, Water, Shelter, Clothes, And So On. These Are The

Food, water, shelter, clothes, and so on. These are the few necessities that an individual needs to survive. However, most of these things do not come for free. In many places, in order to obtain these items in exchange for currency. In contemporary society, one must give up their time and effort to obtain a wage that will aid them in procuring the necessary means of survival. Although, earning a wage in exchange for labour did not start off that way with my family. In fact, from generation to generation, the types of employment my family occupied has shifted in each generation as well as indicated the rise of several social changes. The roots of my family commences in the Philippines, specifically, in a northern region called†¦show more content†¦Interestingly, a manghihilot does not earn a daily wage nor charge their clients out of fear that they’re healing powers would be less potent (Stuart Jr., 2003). Instead, payment is done on a voluntary basis and differ from one person to another (Stuart Jr., 2003). For instance, some people choose to donate money while others offer things like food and cigarettes (Start Jr., 2003). Although this did not provide a stable means of obtaining subsistence, my grandfather also was a skilled fisherman. This allowed this part of my family to be able to put food on the table. Meanwhile, his wife, Faustina Torres was a housewife until 1950, when she passed away a few days after my father, Raymundo Torres, was born. My father immigrated to Canada in 1985. He worked for a company known as the Seafarer’s International Union. An organization that delivers carg oes in different parts of the world including, Europe, Asia, South America, and so forth. He worked for this organization until 1998, before being diagnosed with cancer and passing away in 1999, leaving a wife and two children behind. The death of my father lead my mom to work during the weekend as a housecleaner to provide extra income. Currently, I reside with my mother and my brother. My mother still works a full time job at Peerless Clothing Inc., and my brother is a recent Concordia University graduate, working for Royal Bank Canada as a customer service representative. As for me, I amShow MoreRelatedPersuasive Essay About Homeless1005 Words   |  5 Pageslost something? How about losing everything? Imagine you have everything you truly need, you have good food, water, clothes and happiness. Your joy is beyonf, lifes exactly where you would like it. Your truly happy. Suddenly, everything comes crashing down. Your income of money has depleted. Its gone. You lost your job. You arent able to sustain your family. Your source of water, food and clothes is at the last drop of usage. Your happiness is still there, flickering but dim. Then, you have to doRead MoreHomelessness Is All Over The Nation1565 Words   |   7 Pagesthem are the cold streets. No sane human being would ask to be left without shelter and sustenance, but what if by a tragic incident, one day all your belongings are gone and the only items left in your possession are the clothes you’re wearing. Where would one find a place to protect them from Mother Nature or find food to remain alive? If I were placed in this particular predicament, I’d choose to search for food and a shelter in Livermore, California, because on the outskirts of this town lies a richRead MoreShould Kids For Your Bug Out Bags?789 Words   |  4 PagesMust-Haves (1). Food. Bug out gear is designed to have survival items to last you for no less than 3 days. That means enough food for 72 hours. It should contain dried foods and not canned foods, they are lighter and much easier to carry. (2). Water. Nobody can survive without water for very long. You could never carry enough. (3). Water Purification. Because you can t carry all the water you ll need it s a good idea to have some way of purifying water you can find. Pack two methods of water purificationRead MoreEssay On Hospitality In The Odyssey920 Words   |  4 Pagesand hospitality the Greek give to their guest when people come over to their home. Hospitality plays a major role in Greek society. In American society, today hospitality is not a priority. The most we do is let guest in to sit and offer maybe food and water. In the Odyssey Homer shows in Greek culture that hospitality is very important several times in the text and should treat everyone as royalty. Odysseus crashes into a random island with strangers and like a good host they take care of him. NausicaaRead MoreThe Problem Of Homelessness And Homelessness1562 Words   |  7 Pageseither depending on someone else or finding a shelter where you can have a nap. Waking up with the noises of the cars and other sounds, and getting something to eat whenever you feel hungry but that does not come easy as you need to have money or find food by the garbage and the least option would be begging for other humans that look alike. Not finding where to clean yourself and take a shower would make you dirty and filthy with rag and torn clothes. Now, the same person who appears to be same,Read MorePolice And Firefighters : An Evacuation Plan1299 Words   |  6 Pageslocations, and shelter the ones who no longer have a home or a safe place to live temporarily. Our first step is to evacuate the citizens before they are attacked by the infected, but we must first have an evacuation plan. An evacuation plan should be simple, you would want to keep everyone as calm as possible. According to blogs.cdc.gov, you should identify the possible emergencies in your area. In this case the emergency is the fact that the zombies are located in the north so our evacuation routeRead MoreA Case Of A Horrific Disaster1296 Words   |  6 Pageslocations, and shelter the ones who no longer have a home or a safe place to live temporarily. Our first step is to evacuate the citizens before they are attacked by the infected, but we must first have an evacuation plan. An evacuation plan should be simple, you would want to keep everyone as calm as possible. According to blogs.cdc.gov, you should identify the possible emergencies in your area. In this case the emergency is the fact that the zombies are located in the north so our evacuationRead MoreMaslow s Hierarchy Of Needs744 Words   |  3 PagesHierarchy of Needs, a list of necessary needs in order to live with healthy mental. The levels are physiological, safety, love, esteem, and self-actualization. Physiological deals with survival needs which include food, shelter, and water. Safety is the need to be secure from danger, a shelter or safe environment. Love is the is need for affection and belongingness, friends and family. Esteem is the personal worth, success and achievements. Self-actualization is actualizing one’s potential and what youRead MoreI Feel Los t689 Words   |  3 Pagesdripping in blood from a luggage compartment smashing down on him from the engine failure, looks like an all red version of stepping out of the shower and not toweling your hair dry, and all that blood is blowing on to me. I get sick at the sight of blood so when earl’s fat face dripped it into my mouth and onto my face I puked violently causing my body to spasm and squeeze myself from between the wall and him. I was now blindly trying to find the exit when I am suddenly sucked out and the wind blows theRead MoreThe Road By Cormac Mccarthy1289 Words   |  6 Pageslife remaining on the earth, except the cannibals and some of the scavengers. The father and son continue their journey in search of food, shelter and clothing also. Their search of food and shelter is successful at times; however, they always keep searching for more and more clothes, as it was too cold for them to carry on their journey with a small collection of clothes and they even ne eded more and more blankets which could save them from the freezing cold (McCarthy). The author has shown how the

The American Dream - 859 Words

The concept of the ‘American Dream’ has changed dramatically over the past couple decades. Originally, the ideal American Dream consisted of marriage, children, a stable job with a high enough income to save and invest, and buying a house for the family. Subsequent of the Great Recession, buying a house is not as desirable or even feasible for the millennial generation. Millennials are interested in a different American Dream, focused on receiving an education and making enough money to pay the bills. There are multiple factors that drive Millennials away from homeownership, including difficulty obtaining a mortgage loan, establishing credit, permanency, and securing a down payment. A large contributor to the decrease in homeownership†¦show more content†¦Because of this, more and more Americans are renting in lieu of purchasing a home. Even though the younger generation isn’t buying homes, older generations and even Millennials with more stable finances have the opportunity to step in and purchase homes in order to turn around and rent them out. The rent charged is more than the mortgage, so the owner gets their house paid for while earning a profit and the renter can enjoy the pros of living in a house without the cons of purchasing it themselves. Additionally, due to the imbalance between the cost of living and minimum wage, Millennials are driven to adopt the trend of teaming up and renting a house with multiple roommates in order to save money. This further decreases the populace of both homebuyers and persons renting individual homes. While many Millennials are taking this route in terms of houses, even more Millennials are not even elect the housing option but rather move into apartments or townhomes for the purpose of saving money. Returning to the inconsistency between a living wage and what Millennials are bringing in on average, Millennials have become accustomed to the lifestyle of temporary commodities. We don’t like committing to anything from our relationships to our jobs; Millennials will work three part-time jobs before they settle in a nine-to-five full-time career path. Permanency is not a welcomed idea in our lives, and buying a house is the biggest financial commitment one can make.Show MoreRelatedImmigrants And The American Dream1362 Words   |  6 PagesImmigrants and the American Dream In the article â€Å"The American Dream†, by James Truslow Adams in The Sundance Reader book, he stated that the American dream is that dream of a land in which life should be better and richer and fuller for everyone, with opportunity for each according to ability or achievement. 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The show obtains successful Entrepreneurs ready to invest their own money into other Americans wanting to be just like them, reaching the American dream and become a successful entrepreneur. The show presents entrepreneurs working towards the goal of creating a business to not only gain wealth but also change the way we live today. The show is to keep the American dream alive and well while

Study Of The Airline Industry Resilience And The Terrorist...

Finally, Company Size, Industry, Company Ownership, Organizational Design (Czinkota et al., 2010), and Firm Age are introduced in the model to control for factors beyond relationships that could influence the dependent variable of performance resilience. Data Analysis The research method relies upon the general methodological framework used by Gittell et al. (2006) in the study of the airlines industry resilience to the terrorist attacks of 9/11. This exploratory archival data analysis employs quantitative statistical techniques from the terrorism and international business literature stream. Initially, correlation analysis between the operationalized independent variables, moderating variables, control variables and the dependent variable will be conducted, using Pearson Correlation Coefficients as a measure, to identify and evaluate non-causal associations and strengths of relationships between variables. In addition, scatterplots would be created of the variables to determine whether linear relationships exist. An analysis of variance (ANOVA) would be used as the general structure for statistical testing of the conceptual model, shown in Figure 4, using the F-test. Moreover, the F-test would be an initial overall inference test of the operation alized conceptual model. Furthermore, collinearity diagnostics tests for multi-collinearity on the independent and moderating variables will be performed using Variance Inflation Factors as a gauge to assess any overlap orShow MoreRelatedTerrorism And Its Effects On The World And Society1385 Words   |  6 Pagesespecially since the 9/11 attacks, that there are growing effects of terrorist attacks (Waxman 2). Terrorism can be the leading effect of PTSD and psychological effects as well. Numerous studies have now been conducted on the psychological effects of terrorism on individuals (Waxman 2). These studies have looked at how terrorist attacks affect people’s mental health. There has been particular attention to the incidence of post-traumatic stress disorder following the terrorist attacks (Waxman 2). Not justRead MoreThe Business Continuity Plan For A Dummy Variable1461 Words   |  6 PagesCountries independent variables. The Erosion variable operationalizes the negative moderating effect from deterioration or wearing away of performance resilience over time. In other words, the Erosion variable is indicating the recency of the terrorism incident. The Erosion moderating variable is measured as the number of days since the last terrorist incident using the difference of the Event Identification Number from Table 3 of the GTD (2015). The Severity moderating variable is measured usingRead MoreThe Economic Loss Of Terrorism1666 Words   |  7 Pagesfrom impact studies of the resulting damages (Frey et al., 2007). The economic loss measurements capture the direct market value impact of terrorism, but do not fully account for intangible losses. Finally, the third category of measurement of impact is utility loss, often used in human resource journal articles concerning terrorism. The utility loss category captures the qualitative indirect and intangible losses of terrorism, such as well-being and emotional impact. For this study, we use the cumulativeRead MoreCategorization Of The Global Terrorism Database ( 2015 )1683 Words   |  7 Pages4. When necessary, we augmented the GTD data with terrorism data collected in the RAND Database of Worldwide Terrorism Incidents, a compilation of 40,000 incidents of terrorism coded and detailed from 1968 to 2009 (RAND, 2015). Finally, we gather industry and firm-level survey da ta from academic journals and public entities including insurance providers. Table 4 Categorization of the Global Terrorism Database (2015) Category Global Terrorism Database Fields GTD ID # Date Event Identification NumberRead MoreA Research Study On International Business Studies Essay1925 Words   |  8 Pagesboth theory and practice. My area of research study is how international businesses apply past terrorism experience creating organizational resilience to absorb, endure and bounce back from future terrorist attacks. Table 1 - Synopsis of Two Research Papers in Resilience to Terrorism Title Attribute Relationships, layoffs, and organizational resilience airline industry responses to 9/11 Another day, another dollar: Enterprise resilience under terrorism in developing countries Author(s)/(Date)Read MoreAttack Incidents On A Firm1831 Words   |  8 Pagesvariable representing the depth of proficiency, knowledge, best practices and insights that corporations, who were directly impacted by a specific terrorist incident, acquire from coping with the effects of terrorism. The Terrorism Experience is measured in terms of the cumulative number of terrorism incidents that directly affected the firm. The number of attack incidents on a firm is a Traditional type of terrorism measurement as categorized by Frey et al. (2007) in Table 2. The data source for measuringRead MoreThe Difference Between Sustainability And Resilience1901 Words   |  8 Pagesthe difference between â€Å"sustainability† and â€Å"resilience† according to the video. What do you think of this description compared to what you found in the literature? According to the video the difference between sustainability and resilience, we feel was looked at in a totally different way than usually. The video suggests that the idea of resilience is a more useful concept than the idea of sustainability and the idea of resilience comes from the study of ecology and it s really about how systemsRead MoreSouthwest Airlines Case2196 Words   |  9 PagesSouthwest Airlines 2002: An Industry Under Siege Case Study â€Å"Discussion Format† MGMT 5113 Team 7 Dag Yemenu Sachin Gupta Michelle May Shaun Evans November 22nd 2003 Problem Overview Southwest Airlines has employed unique operational strategies, incorporating industry revolutionizing methodologies, while developing and sustaining a strong corporate culture that has allowed Southwest Airlines to be profitable for a phenomenal 30 straight years and capture the Airline Industry ServiceRead MoreCase Analysis American Airlines5546 Words   |  23 PagesAnalysis of American Airlines In an attempt to generally identify the airlines and travel industry this analysis will examine the key players in these industries. Whenever we think of the airline industry by definition the key players in this industry include commercial/private airline companies, employees, aircraft manufacturers, customers/consumers of flight service, travel agencies and government entities responsible for regulation of the industry. Currently the airline industry as a whole seemsRead MoreThe Financial Performance of Low-Cost and Full-Service Airlines in Times of Crisis8844 Words   |  36 PagesFinancial Performance of Low-Cost and Full-Service Airlines in Times of Crisis Triant Flouris, Thomas John Walker. Canadian Journal of Administrative Sciences. Halifax: Mar 2005. Vol. 22, Iss. 1; pg. 3, 18 pgs Abstract This paper examines the stock and accounting performance of three major airlines in the United States in the aftermath of the September 11, 2001, terrorist attacks. September 11 (9/11) resulted in dramatic changes in the airline industry and had significant implications for the economic

Business and Corporations Law Forrest v ASIC

Question: Discuss about the Business and Corporations Law Forrest v ASIC. Answer: Introduction The directors of any corporation are bestowed with the responsibility of governing the company, on behalf of its shareholders. This responsibility or duty is imposed upon the directors in Australia through Corporation Act 2001(Cth). Section 198A (1) of this act puts forward that requirement of the business to be managed as per the directions provided by the directors of such company. This gives rise to the obligations on all the directors, in both general, as well as, lawful manner. This act provides a range of duties for all the directors of the company (Australian Institute of Company Directors, 2017). For instance, the directors have the duty of protecting the company from any such dealings or transactions, which can lead to insolvency. The case of Forrest v ASIC (Australian Securities and Investment Commission) [2012] HCA 39 is amongst the leading cases, regarding the breach of directors duties which have been covered through the governing legislation, and the judgment of which was given by the High Court of Australia. In this case, the director of the company was alleged to have breached the various section of Corporations Act, which included the duty of care and diligence (Australasian Legal Information Institute, 2017a). This report covers the details of this case. Forrest v ASIC (2012) In this case, Fortescue Metals Group Ltd, Fortescue in short, wanted to develop a port, a railways and a mine, so as to enable the exportation of the output of the mine, which would be obtained in the future (Latimer, 2012). For this, the company entered into three different Framework Agreements, and each of these three agreements was with some Chinese entity. For these purposes announcements were made at different times, to the ASX, i.e., the Australian Stock Exchange, which were coupled by media releases issuing. These announcements claimed that binding contracts were drawn with all three Chinese entities (Levin, 2012). The ASIC, in March 2006, initiated proceedings against Fortescue, along with Andrew Forrest, Forrest in short, who was a substantial shareholder of the company Fortescue, its chairman and CEO, in the Federal Court of Australia. The ASIC contested the legitimacy of truth behind the announcement of the company, made to the media, in addition to the broader market pertaining to a chain of Framework Agreements, among three of the state-owned Chinese corporations and the company (High Court of Australia, 2012). This Framework Agreement was related to the financing and building services which had to be provided regarding the Pilbara Iron Ore and Infrastructure Project of the company (Hill Thomas, 2015). The Framework Agreements were described in the announcements as amounting to a binding contract. Though, the agreements terms did not have the wholesome certainty and hence, it was doubtful to be enforceable in a lawful manner. The claims of the ASIC were dismissed by Justice Gilmour at the trial (High Court of Australia, 2011). But when an appeal was made to the Federal Courts Full Court, the claims of ASIC were held to be successful for obtaining the order relating to the: Misleading or deceptive conduct of Fortescue, which contravened Corporation Acts section 1041H; The breach of continuous disclosure requirements by Fortescue which were as per section 674 of the Corporations Act; and The failure on part of Forrest for exercising his powers, along with the discharge of his obligations contained in section 180(1) of the act, regarding reasonable care, and diligence, resulting in the breach of this section (Naik, 2015). Both Forrest and Fortescue made an appeal against this decision given by the Full Court of Federal Court. They also sought out for the reinstatement of the order which were made at the first instance by Justice Gilmour. The four members of the High Court, on October 2nd 2012, dismissed the case made by ASIC and stated that the statements made in this case, were neither misleading nor deceptive (Briffa Jaque, 2012). Duties Breached Section 180 of the Corporations Act, 2001, enforces a civil obligation on the directors, along with the other officers of any company, pertaining to acting with care and diligence. Section 180(1) provides that the quoted individuals have to use their authority, and also have to fulfill their obligations with a level of diligence and care, which a prudent individual would exercise if he/she was in the position of the quoted individuals under similar circumstances and was occupant of the office of the quoted individuals in the company. A civil penalty for the breach of this section is provided in section 1317E (Australasian Legal Information Institute, 2017b). However, section 180(2) provides the defense to the directors, which is also known as the business judgment rule. The requirements contained in subsection (1) are deemed as having been met, along with the equivalent duties contained in the common law and in equity, when the quoted individuals make a business judgment. This business judgment is based on the judgment made for proper purpose, and with good faith; and the quoted individuals do not have any kind of significant personal interest in the issue revolving round the undertaken judgment; has informed themselves regarding the issue of judgment, to such extent which is considered as appropriate one; and has an unhindered conviction that the undertaken decision is in the paramount interest of the company. For the rationality of this belief, the position of a reasonable individual in similar circumstances is taken as the benchmark (Swaab, 2017). The allegation of the ASIC was that Forrest had contravened the subsection (1) of this act, on the basis of the contravention of section 1041H or section 674 of this act (Humphrey Corones, 2014). Decision Holding the announcements as based on the opinions, which was held in a reasonable manner, the case of ASIC was dismissed by the trial judge. When an appeal was made by the ASIC to the Full Federal Court, the same was upheld. It was held by the full bench of Federal Court that the announcements made by Fortescue did indeed amount to deceptive and misleading conduct and that the company had failing in fulfilling the continuous disclosure requirements, as they did correct the deceptive and misleading conduct, upon the release of the announcements (Lo, 2016). It was also established by the full bench that Forrest had contravened the duties imposed on him as a director and also breached the act, through the involvement in both the drafting, and the release of the announcements (Australasian Legal Information Institute, 2012). When this decision was made, Fortescue and Forrest jointly applied to the High Court of Australia, an appeal, which asked for reinstating the decision taken by the trial judge. It was held by the High Court of Australia that the announcements were the representation of the Chinese companies and Fortescue and that these had entered into the agreement, with the intention of each of the parties, to make the same as binding. This representation was held by the High Court as being none of the following, i.e., fraud, deceptive or misleading (Yip, Tan Lim, 2013). The issues which were present in the appeal were narrowed by the summary dismissal of the contentions of ASIC by the High Court of Australia, as per which the Board of Fortescue and Forrest had acted in a manner which can be deemed as dishonest, regarding the making of the above stated announcements. The inquiry of the High Court was focused upon whether or not, the use of term binding agreement by Fortescue in the announcements was actually deceptive or misleading, or whether or not, the same was likely to deceive or mislead. With reference to the intended audience, a close scrutiny of the implication of this expression was conducted by the High Court of Australia. Wide sections of the business or commercial community, along with the investors, were defined as the intended audience by the High Court (Jade, 2012). In spite of the literal meaning of the term binding agreement, it was held by the High Court that the expression did not essentially convey the notion that the agreement would be enforceable in a legal manner. It was stated by the judges that an individual in specific situation, should not be required to evaluate the legitimacy of a contract, in short its valid formation. Along with this, it was also not necessary to assess the practicability of the contract to compel performance as per the enforcement measures applicable on the main jurisdiction, before a statement is made to the community regarding a contract being as a binding one (Naik, 2015). The High Court also held that there was an absence of the evidential base for making the assumption that an individual who read these announcements would form an opinion or understanding regarding the parties entering into agreements, which would be enforceable by the courts of Australia as per the law of the nation, in case of a dispute arising in the future, amongst them. The court also held that Fortescue was not required to release the entire text of the Framework Agreements, so as to be in conformity with the obligations relating to continuous disclosure (Briffa Jaque, 2012). The approach of the High Court in this case was consistent with the claims being dependent on the facts, relating to the deceptive or misleading conduct. The court analyzed the accurate summarization of the Framework Agreements content and the announcements brought forward the point as being constituted as a binding contract. Reliance was also made on the preliminary issue regarding the reasonable belief, as stated earlier. Rejecting the submission of ASIC, the High Court held that the agreements were governed by the Australian laws and the contract included the foreign state owned entities, which were executed in China, and they did not have a clause of choice of forum (Naik, 2015). A contention was also made by the ASIC regarding the attempt of the director, i.e., Forrest to modify the conditions stated in the Framework Agreements, pointing in the direction that the drawn agreements did not have the intention of being binding. This argument was rejected by the judges and they stated that the contractual negotiations taking place after the same has been drawn could not be amounted as repudiation of the previous agreements. Further, the same was deemed as legitimate commercial conduct for continuation of making an attempt for striking a better bargain (Briffa Jaque, 2012). As the statements were held to be neither of the three, i.e., fraud, deceptive or misleading, the court held that there was no failure on part of Fortescue and Forrest regarding the compliance of obligations covered under this act. As a result of this, the declarations and the decision of the Federal Court were set aside by the High Court. Further, the High Court reinstated the decision of the trial judge declaring that there was no contravention of the Corporations Act 2001, on part of Fortescue and Forrest (Plessis, Hargovan Bagaric, 2010). In short, the appeal of Fortescue and Forrest was upheld that their conduct was not held as deceptive or misleading, which could contravene section 1041 of this act. And the claims made regarding the breach of section 674, pertaining to continuous disclosure, along with section 180 (1) of this act pertaining to duties of directors, were contingent upon the breach of section 1041 of this act. And so, the claims for both these sections were dismissed, due to the dismissal of claims relating to the deceptive or misleading conduct (Naik, 2015). Conclusion The study of the case of Forrest v ASIC presents an important lesson, which is in conformity to the established principles under the corporate law, specifically relating to the statements which are made in the ASX announcements, and these have to be both correct, as well as, verifiable. In the given case, the ASIC made claims against the company and its director, for undertaking misleading or deceptive conduct, which resulted in the failure of compliance with the continuous disclosure requirements and contravened the duty of care, as well as, diligence on part of the director. The trial judge discarded these claims, upon which an application was made by the ASIC to the Federal Court, which overturned the decision of the trial judge. As a result of this, both the company and its director, made an appeal to the High Court of Australia, which reinstated the decision of the trial judge after rejecting the decision of the Federal Court. References Australasian Legal Information Institute. (2012). Forrest v Australian Securities and Investments Commission Anor; Fortescue Metals Group Ltd v Australian Securities and Investment Commission Anor ([2012] HCA 39) Case Summary [2012] HCASum 39 (2 October 2012). Retrieved from: https://www3.austlii.edu.au/au/other/HCASum/2012/39.html Australasian Legal Information Institute. (2017a). Forrest v Australian Securities and Investments Commission [2012] HCA 39 (2 October 2012). Retrieved from: https://www.austlii.edu.au/au/cases/cth/HCA/2012/39.html Australasian Legal Information Institute. (2017b). Corporations Act 2001 - Sect 180. Retrieved from: https://www.austlii.edu.au/au/legis/cth/consol_act/ca2001172/s180.html Australian Institute of Company Directors. (2017). What are the duties of directors?. Retrieved from: https://www.companydirectors.com.au/membership/the-informed-director/what-are-the-general-duties-of-directors Briffa, P., Jaque, A. (2012). Twiggy Off the Hook- Forrest v Australian Securities and Investments Commission [2012] HCA 39. Retrieved from: https://www.swaab.com.au/Publications/Publications/Twiggy-off-the-hook-Forrest-v-ASIC High Court of Australia. (2011). Forrest V. Australian Securities And Investments Commission And Anor (P44/2011) Fortescue Metals Group Ltd V. Australian Securities And Investments Commission And Anor (P45/2011). Retrieved from: https://www.hcourt.gov.au/assets/cases/p44-2011/P44-2011.pdf High Court of Australia. (2012). John Andrew Henry Forrest V Australian Securities And Investments Commission Anor Fortescue Metals Group Ltd V Australian Securities And Investments Commission Anor [2012] HCA 39. Retrieved from: https://www.hcourt.gov.au/assets/publications/judgment-summaries/2012/hca39-2012-10-02.pdf Hill, J.G., Thomas, R.S. (2015). Research Handbook on Shareholder Power. Northampton, MA: Edward Elgar. Humphrey, J., Corones, S., (2014). Forrest v ASIC : a perfect storm. Australian Law Journal, 88(1), pp. 26-37. Jade. (2012). Forrest v Australian Securities and Investments Commission; Fortescue Metals Group Ltd v Australian Securities and Investments Commission [2012] HCA 39; 247 CLR 486; 86 ALJR 1183; 291 ALR 399; 91 ACSR 128. Retrieved from: https://jade.io/article/281587 Latimer, P. (2012). Australian Business Law 2012 (31st ed.). Sydney, NSW: CCH Australia Limited. Levin, D. (2012). Forrest v ASIC; Fortescue Group Metals Ltd v ASIC [2012] HCA 39. Retrieved from: https://mtecc.com.au/forrest-v-asic-fortescue-group-metals-ltd-v-asic-2012-hca-39/ Lo, S.H.C. (2016). In Search of Corporate Accountability: Liabilities of Corporate Participants. Newcastle upon Tyne: Cambridge Scholars Publishing. Naik, L. (2015). A case note on the Forrest v ASIC decision and the High Court's view on when the term 'binding contract' may be misleading or deceptive. Retrieved from: https://cornwalls.com.au/sharing-knowledge/legal-updates/high-court-rules-in-favour-of-fortescue-metals-group-ltd-and-andrew-forrest.aspx Plessis, J.J.D., Hargovan, A., Bagaric, M. (2010). Principles of Contemporary Corporate Governance (2nd ed.). Cambridge: Cambridge University Press. Swaab. (2017). A Practical Guide To Directors Duties. Retrieved from: https://www.swaab.com.au/expertise/corporate/directors-duties/ Yip, A., Tan, J., Lim, H.Y. (2013). Forrest v Australian Securities and Investments Commission [2012] HCA 39 (Australia, High Court, 2 October 2012). Retrieved from: https://www.lexology.com/library/detail.aspx?g=34dadd8a-2201-4331-80a8-513a56c2df9c

Entrepreneurship Australian Football League

Question: Discuss about the Entrepreneurship for Australian Football League. Answer: Introduction Entrepreneurship is the ability and the desire to develop and organize a business, and manage it along with the associated risks with the aim of making profits. The typical example of entrepreneurship is starting a business. In the field of economics, entrepreneurship is characterized by innovation and risk-taking and is an essential element in the ability of the nation to succeed in an ever-changing and rising competitive global market. Many business people have endured the challenges and risks in the process of starting their businesses and establishing them to become multi-billion investments. Such prominent entrepreneurs are in most cases driven by the will and urge to start their investment, and they usually have higher dreams that make them work towards achieving their goals. This paper is meant to focus on Andrew Demetrio, an Australian business person whose business has been a successful one in the history of Australia. Background of Andrew Demetriou Andrew Demetriou, born in 1961, is an Australian investor and a sports administrator who held the office of the CEO of the Australian Football league (AFL) in ended in 2014. After retirement from the football career, the businessman chaired many companies leading to his appointment to the office of the CEO of the AFL players association under the responsibilities for the negotiation new collecting bargaining contracts between the league and the player. Demetriou in his roles as the head of the AFL Commission was obligated to make changes that included the expansion of the league from 16 teams to 18 and also brokering two new TV rights deal. Andrew is the youngest son of Greek Cypriot immigrants (O'Reily O'Reily, 2014). His elder brother played senior football for Essendon in the mid-1970s. Andrew Demetriou graduated from the La Trobe University with Bachelor of Arts in 1993 and diploma in education in 1984. He was then awarded the distinguished alumni awards of the university in 200 9 and a doctor of letters in 2005 recognizing his contributions towards sports management and the Australian society through his leadership. He is also known for the support he had towards the important social issues; his managerial career has the best of his histories where he is widely recognized for his position as the CEO of the AFL elected by the board of directors in 203. In 2008, Andrew Demetrio was acknowledged as the highest paid administrator through his generous salary package (Ho Jakubowicz, 2014). In 2005, Demetrio was an instrumental individual in securing a record-breaking AUD780 million TV rights contract that included a live coverage of the AFL matches in all countries of Australia through a free-to-air subscription. His powerful character was first seen when he was the CEO AFL in the boards desire to get a team to operational and based on the gold coast. Characteristics of Andrew Demetrio Andrew Demetrio has been well recognized and appreciated for his excellent skills in administrative and management positions. He has portrayed many qualities in his leadership journey especially during his time as the CEO at AFL. Some of his qualities are as below; Developing and Retaining Good Team When Demetrio became the CEO, he replaced some members of the AFL management with a team of smart and intelligent individuals who displayed excellent traits. The team worked together for many years and has been in a relationship described as loyalty and respect relationship (Casson, 2008). Andrew developed the team which he was sure would strengthen his weakness, and he once said: the people in my team are smarter than me. Problem Solver and negotiator The quality of problem-solving and negotiator matches Andrew Demetrio considering negotiation was one of his responsibilities as the CEO AFL where he exercised the best of it juggling with different deals simultaneously. Andrew believed that believed that a competent leader can focus on many, negotiations that are equally important at the same time. He also implied that negotiations and managing conflicts start early in his day considering family if young children that needed his best negotiation skills. He mentions that the latter is always his warm up for the big game (Coyle-Demetriou Demetriou, 2007). Decisive In leadership, making tough decisions is never easy; however, Andrew believed that people would respect the fact that one has done a change decision even if they dont like it rather than being stagnant. He made tough decisions in 2004 at the time he called for any women humiliated in any way by any AFL player. Even though there were opponents, it was a decision that Demetrio made and was respected by the AFL fraternity. Act with Integrity Andrew considers integrity to be the most important leadership qualities along with respect and maintenance of good values. He is a different and determined leader who believes that young people can be taught how to embrace and adopt the values of respect and leadership. The businessman believes that acts associated with integrity are a trait that he would love to see adopted across organizations including the AFL during the time he was the CEO (Guthrie, 2010). Discuss the processes of opportunity recognition and idea development Entrepreneurship is currently one of the rapidly developing and expanding sectors in the existing economic arrangements. In every industry today, and in both the corporate and the small business levels, business people have considered the tools are driving the improvement initiatives in the market. Following these recognitions, one can argue that there are different and insufficient proved connections between the acknowledged current business theories and the place of business in the economy and the strategies of a company. The below stages are the creative steps towards opportunity recognition and idea development; Preparation- is the foundation of experience and knowledge that comes from the creative journey. Incubation- It is a step where the person is thinking about an individual issue and considers it an idea. Insight- Insight is the moment of recognition of the opportunity. It is regarded as an illumination and a point where the core solution originates and become awareness spontaneously. Evaluation- is a step where the insights are analyzed for their validity. It can be termed as the verification phase of the process of opportunity recognition and idea development. Elaboration- is where the creative insight is actualized and is made ready for presentation. The Type of Business Developed and the Competitive Advantages Andrew Demetriou founded a global sports media and entertainment consulting, marketing and technology services company in Singapore. Beyond boundaries, the company was established along with the former Football Federation Australia boss Ben Buckley and is a boutique consultancy that has a small team of twelve executives (Carsrud Bra?nnback, 2007). The company services cover strategy development, execution of projects, broadcasting and media valuations and negotiations amongst other businesses. The firm has a competitive advantage in the market considering it is a business founded and run by well-known and reputable individuals who have been known for their success in various sectors in the sports business. The business is also advantageous in the market as it has been launched and has been recognized by many people in the sports and media market because of its founders who are considered to be intelligent individuals in the business (Cuervo, Ribeiro Roig, 2007). Future Suggestions for the Andrew Demetrio Andrew Demetrio has been well known for his excellent leadership qualities and values. His success as the CEO of the ALF is a credit to his business since his clients believe in his success in administration, negotiations, and management. However, it is recommended that Demetrio develop a smarter team of executives that will be strategizing the business, to share ideas with him and make joint decisions for the better of the business success and growth. Even though Demetrio has a well recognized and appreciated business, he still needs to incorporate marketing strategies for entry into the global market and make his business operational in many countries in the world as possible. With wings in the global marketplace, the business will with no doubt be the leading sports and media company in the world considering it is the only firm recognized and appreciated for these services, along with the many other services it is offering the market (Stokes, Wilson Mador, 2010). Conclusion From the discussion, it is evident that entrepreneurship is the art of starting a business and managing it to its best, through growth and development until it becomes profitable. Andrew Demetrio is an Australian businessman in the context who have been spotted as a quality and competent business leader. He has shown excellent leadership qualities in business since the time he was the CEO ALF. On retirement, he launched a company dealing with matters regarding sports, media, and negotiations that has also been doing well in the market. Demetrio has displayed competency in many ways and has been the focus of many sports agencies and businesses. His core values and characters are the best leadership qualities that any business leader would be advised to adopt in their leadership tenure. Demetrio has displayed the fact that business needs the passion and urge for success to be able to make the best in the field. References Stokes, D., Wilson, N., Mador, M. (2010). Entrepreneurship. Hampshire, UK: South-Western/Cengage Learning EMEA. Cuervo, G. A., Ribeiro, D., Roig, S. (2007). Entrepreneurship: Concepts, theory and perspective. Berlin: Springer. Casson, M. (2008). The Oxford handbook of entrepreneurship. Oxford: Oxford University Press. Carsrud, A. L., Bra?nnback, M. E. (2007). Entrepreneurship. Westport, Conn. [u.a.: Greenwood Press. Henry, C. (2007). Entrepreneurship in the creative industries: An international perspective. Cheltenham, UK: Edward Elgar. Coyle-Demetriou, M., Demetriou, A. J. (2007). Integrating complementary and conventional medicine. Oxford: Radcliffe. O'Reily, T., O'Reily, T. (2014). Titus O'Reily's 2014 AFL season almanac. Melbourne: Titus O'Reily. Ho, C., Jakubowicz, A. (2014). 'For those who've come across the seas ... ': Australian multicultural theory, policy and practice. Guthrie, B. (2010). Man bites Murdoch: Four decades in print, six days in court. Melbourne: Melbourne University Press.