Wednesday, November 20, 2019

Macroeconomic convergence, economic growth and financial development Dissertation

Macroeconomic convergence, economic growth and financial development of India - Dissertation Example India is an emerging country that has developed into an open market economy. In 2010, CIA World Fact Book ranks India as 5th in the world economy having $4.06 trillion gross domestic product (GDP.). However, same source indicates there are still traces of its past autarkic policies because of the social democratic policies that have governed the country since 1947 to 1991. At that time, the economy was characterized by extensive regulation, slow growth, protectionism, and corruption. Reforms introduced in early 1990s that included trade and industry liberalization, removal of government control from the industries, and transfer of control of government resource to private business sector accelerated economic growth. Vernani (n.d.) estimated India’s economic growth since 1951 up to 1971 stayed at 3%, and in 1995 went up to 5%. Since 1997, India’s expansion has been more than 7%. India’s growth comes from farming, cultivation, craft, new industries and other ser vices (CIA). Total labor force is 478 million; 52% is in agriculture, 34% is in services and 14% for other industries. India boasts of a large educated English-speaking population that becomes its asset for its export of information technology and software workers. The economic growth slowed down to 6.7% in 2008-2009 but has improved to 7.4% for the rest of 2009 to 2010 (Virnani) Due to big local demand  in 2010, the country recovered strongly from the economic meltdown and has charted over 9% growth. (Virmani,) At this time too, investment growth rate doubled as well as private consumption and imports accelerated; however, government consumption slowed down. Vernani explained that in 2007, investments were over 35%; demands were much higher than previous years; investment rate grew to 18%; domestic demands climbed to 60.1% and a negative rate for exports. However, despite the pronounced growths, CIA showed problems of India that include extensive privation, insufficient infra structures, limited employment opportunities in non-agriculture sector, inadequate way in to quality education, and accommodation of â€Å"rural-to-urban migration†. Financial development in India The process of financial system in India according to Sandhya (2009) †is an interaction of financial institutions, financial markets, financial instruments/assets/securities and financial services which are controlled by the government† . The Indian financial system is also parallel in the role of other governments in the financial markets. Cihak (2011) said the role of governments in finance was less before the global crisis because empirical studies showed harmful effects of government interventions. The crisis changed the minds of the people and thought that it is time for the government to adopt policies to maintain stability, drive growth and create jobs. As such, clearer roles emerged for the government to adopt direct interventions such as ownership, credit gua rantees and liability guarantees. Government has to regulate and supervise economic activities and to promote competition, infrastructure and technology, Cihak said. Empirical results of macroeconomic convergence theories. Economic convergence starts with simple cooperation on agreed upon aspects from among member countries that often lead to integration or merger of these countries. Maruping (2005) defines macroeconomic convergence as a local assimilation that requires joining of two or more states, basically thru a Privileged Agreement, sometimes done thru Bilateral Trade Agreeements.  He describes economic convergence as an organized plan intended for the easy access of service and goods as well as coordination of foreign economic policies of these states in the same region. According to the Dictionary of Trade Policy Terms of WTO, regionalism is described as â€Å"actions by governments to liberalize or facilitate trade on a regional basis, sometimes through free-trade are as or

Sunday, November 17, 2019

People of Britain Essay Example for Free

People of Britain Essay The emergence of television as a mass medium of communication was the key turning point in improving leisure opportunities for the ordinary people of Britain. How far do you agree with this statement? At the beginning of the 20th century, the lives of ordinary people were not ideally suited to the world of leisure. An urbanised workforce and an economy geared toward industry saw lower-class people working long hours at a low pay rate. This style of living left hardly any free time and disposable income, both key requirements for leisure opportunities. The aristocracy had always revelled in the world of leisure; their high incomes and low maintenance professions gave them a perfect framework for pursuits such as dancing, theatre going, hunting, socialising and horse riding. Although there were popular activities of the working classes family games within the home for example, or more commonly, an evening spent in the local pub leisure was limited. I believe that television was the key form of mass communication to improve the leisure opportunities of the working classes as it was accessible, cheap, and knew how to cater for changing styles and tastes. When television was first introduced on a wide scale in 1936 only a small percentage of the British public owned a television license. Its initial emergence as a mass medium was therefore not a turning point, as the ordinary people simply did not have access to it. It was difficult for television to flourish before the fifties anyway, due to the condition of Britain prior to world war two. The earliest form of television had actually been introduced in the late twenties for a trial run, but the economic slump of the decade guaranteed an impossible environment in which to launch it. The British workers were in a poor situation, and leisure opportunities would have been at the bottom of their priorities list. Shortly afterward, the country was gearing up for war and with the emphasis on this preparation the BBC was forced by the government to shut down television broadcasting until 1945. As a result of the impracticalities of earlier decades, television was not a widespread phenomenon until the 1950s, when in 1952 the first televised coronation of Elizabeth II took place, with the BBC dedicating a whole day to the coverage. 50% of the population watched the ceremony (a figure of around 25 million people) and sales of television sets rocketed prior to the event. I would argue that it was the 1950s and onwards, in which television became a crucial part of ordinary peoples leisure time. As part of the consumer culture of the fifties, the sale of television sets increased massively more than 42,000 sets were sold every month in 1950 and this figure had more than tripled by the mid 1950s when 140,500 sets were sold per month in Britain. Television seemed to be ideally suited to the working classes; it was cheap (after the initial purchase of the set and a television license, no extra fees were needed), based in the home (travelling would have cost extra money), family orientated (working class families were usually larger than those of other classes) and a relaxing leisure pursuit after a long day at work. The environment of the 1950s was significantly different from those of the 20s, 30s and 40s. Britain was considerably wealthier due to the post-war boom shared by other countries such as America, there was full employment and the importance of leisure seemed to grow especially with the influence of 1950s American youth culture. Televisions ability to change and adapt to the interests of the ordinary classes and the youth of the decade was also something that set it aside from other forms of mass communication. Whilst BBC radio had come under criticism for being too elitist, television (especially during the 1960s) made a real effort to represent the working classes. By the late 50s ITV was producing very popular variety shows- a mix of comedy, music and other light entertainment wrapped in a family package which appealed to a mass audience. Televisions interest in the needs and wants of the majority continued into the sixties. The 1960s has been described as the decade of television revolution, with the introduction of many new programmes designed for the working classes. The new ITV channel had been very successful since its launch in 195_ and the BBC split into BBC1 and BBC2 in the early sixties, with colour being introduced in 1968.

Friday, November 15, 2019

Gender Differences in Multitasking: Texting During Lectures

Gender Differences in Multitasking: Texting During Lectures Today, the communication technology has been growing widely to the extent that we can communicate with each other anytime and anywhere. As long as there is Wi-Fi or network coverage, our smartphones, tablets or computers can be used as a communication tool or a gadgets for us to receive new information in the world. Consequently, this function is so easily accessed by all, we are able to receive text messages, phone calls, emails and social network notifications throughout the whole day. However, this can be either a blessing or a curse. As we are exposed to all these information and entertainments, these can be a distraction in our daily tasks. To be specific, students in college are able to access to all these functions most of the time, it has pushed students to multitask more often in their daily lives. These might interfere with their studies as multitasking involves in switching tasks from one and another as well as the attention (Judd, 2013). In a study done by Wilkes University, 95% of the students bring their phones to college every day and 91% of the students admitted to using their cellphones during lectures (Harris, 2013). This has shown that most students tend to multitask in class as they listen to the lecture and use their phone at the same time for either text messaging, social networking or any other purposes. However, research on multitasking have proven that the human has no ability to perform more than one overlapping task at the same time due to the interference occurs in human information processing system (Levy Paschler, 2001; Wood et al., 2012). In other words, students can hardly concentrate in class if they are using their phone at the same moment. This explanation is consistent to the findings of Bowman, Levine, Waite Gendron (2010) that students who instant message while reading take longer time to finish the task. For generations, the stereotype of women are better at multitasking is debated across the world. Although scientist in University of Pennsylvania has supported this statement by discovering females’ brains are connected from left to right, while men has more intense movement in certain part of the brain (Spencer, 2013), many research done on multitasking has rejected the idea. Buser and Peter (2011) reported that women suffer as much as men while multitasking and have no significant differences in productivity of tasks. Not only that, even Conner, Laws, O’Connor and Stoet (2013) found that women outperform men in multitasking, they pointed out that their results cannot be generalized as the empirical studies on gender differences in multitasking is insufficient. Theoretical Framework Living in this world where we are overwhelmed by all perceptual information, our human information processing system can detect, recognize and identify chunks of stimuli at the same time (Hedge, 2013). As so, in this context, attention has given the model a function to either enhance or inhibit information, in other words, our attention chooses which certain information for further processing or ignore (McClelland, 2007). However, when two information are presented and are asked to process at the same time, the ability to attend both fully will be impaired as there are insufficient capacities in the information processing system; this attempt of trying to focus on multiple stimuli at one time is also known as divided attention (McClelland, 2007). One of the example of divided attention is multitasking, which can be defined as performing more than one task simultaneously or switching from one task to another back and forth (APA, 2006). In the human mind, multitasking is managed by a process called executive control; and to decide which cognitive processes and when it is performed, the executive control system will go through two stages – the goal shifting (decision of what to do) and role activation (action of switching task) (Meyer, Evans Rubinstein, 2001). Hence, people tend to repeatedly switch between tasks to achieve two things at a time without constant awareness; although it might seems productive and efficient, it is explained that multitasking leads to more mistakes and more time consumed as there will be brief mental blocks during switching of tasks (Meyer, Evans Rubinstein, 2001). Past Research Many past research have shown that multitasking in class can lead to poor academic performance. Junco (2012) conducted a research examining the relationship between in-class multitasking and academic performance, by giving out survey forms to a large number of students (N = 1,839) measuring their technology usage in class and internet skill to be compared to their grade point average (GPA). He then reported that constant multitasking in class (which include surfing social networking website, chatting and text messaging) has a significant negative correlation with students’ over semester GPA (Junco, 2012). Additionally, Carrier, Cheevar, Lim and Rosen (2011) did an experimental study on the frequency of text messaging interruption during a lecture has found that students in High texting group (16 messages or more) scored significantly lower than the Moderate texting group (8 to 15 messages) and No or Low texting group (0 to 7 messages) in the quiz after a 30 minute videotaped l ecture. Through the cross-cultural analysis of surveys results on mobile phone etiquette and multitasking in class, it showed that Americans and Chinese students both believe using cellphone in class will not interfere their learning but Americans students find it more appropriate to text in class than the Chinese; additionally, no gender significant difference is found (Rosenfeld, 2014). Many other research have furthered this study by doing an experimental study on multitasking in class with the awareness of cellphone distraction. Even many students did not believe that using their smartphones in class is a distraction from their learning, the scores of the short quiz given after the same lecture between students who use cellphones in class and students who listen to lecture without cellphones have a significant difference where students who anticipate in communication technology have a lower score (Elder, 2013). This result is consistent to the findings of a mixed experimental study on th e relationship between self-regulation, attention and cognition learning ability in classroom learning, which reported that college students who constantly self-regulate tend to have a better cognition learning by sustaining their attention during lecture as they text less (Klausner, Wei Wang, 2012). Besides, during an accounting principle lecture in Columbus State University, the half of 62 students who are allowed to multitask in class in the form of communicating with each other through texting did worse in the exam than the other half of students who are not allowed to use their cellphones during lecture (Ellis, Daniels Jauregui, 2010). Although in this study they did a comparison between male and female, they found that gender has no significant impact on learning ability without taking account of whether they multitask or not (Ellis, Daniels Jauregui, 2010). This research is similar to a recent experimental study which both groups of psychology students, who are asked to text and to switch off their phones during a short 20-minute lecture, are then given a short quiz to test their learning ability; the researchers concluded that texting in class is a strong distraction during lecture like other past research, but no gender comparison is done (Dietz Henrich, 2014). Howeve r, in the research of gender difference on multitasking have shown that women suffer as much as men in divided attention while completing multiple task at the same time and choose to avoid multitasking upon free will (Buser Peter, 2011; Strayer, Ward Watson, 2013). Description of Study Although many research has done on student multitasking capabilities in class (Carrier, Cheever, Lim Rosen, 2011; Ellis, Daniels Jauregui, 2010; Gingerich Lineweaver, 2013) and gender differences in multitasking (Buser Peter, 2011; Conner, Laws, O’Connor Stoet, 2013), there are limited research that compared male and female students’ academic performance if they multitask in class. In this study, we will be examining the gender difference in multitasking during a lecture. The aim of this experimental study is to see whether male or female students can multitask better while learning. All participants recruited for the study will be separated to different groups based on gender and will undergo one experiment each, either texting during lecture or no texting during lecture. As all participants will have to attend a half an hour English Literature class, the no texting group will not be allowed to access to their cellphone. However, for the texting group, each participant will receive a text message every 5 minutes and is required to reply. At the end of the experiments, all four groups of participants will be given a quiz to test their understanding of the lecture. Based on Carpenter et al. (2012) and Ellis, Daniels and Jauregui (2010), we hypothesize that texting in class will lead to a poorer performance in the quiz. Then, based on Buser and Peter (2011) and Strayer, Ward and Watson (2013) on gender differences in multitasking, we hypothesize that there will be no differences in both gender on performance in quiz for texting during lecture. Method Design The independent variable of this study is gender differences in multitasking, with two levels, male and female; the dependent variable is quiz scores. This is a between subject design as the participants will be separated to different groups and only go through one experiment either texting during lecture or no texting during lecture. Participants Approximately 80 male participants and 80 female participants, from all races, will be recruited from different private colleges in Penang for the experiment. This is because all the past research used participants less than this amount. A total of 62 participants of both gender are tested on the study by Ellis, Daniels and Jauregui (2010); and a total of 67 participants are used in the study of Gingerich and Lineweaver (2013). The age of the participants will be 18 to 25 (M = 21.25), which most people in this age attend college. The participants are recruited through purposive sampling where they have to meet the 2 following criteria, enrolling in an undergraduate program and is able to understand English perfectly. The students will be participating the experiment voluntarily. Materials A half an hour lecture of English Literature Studies will be given to all participants. As the participants recruited are from variety of courses, this is to ensure that the students have not been to the lecture before and have no prior knowledge in it. At the end of the experiment, a 20 multiple choice question quiz based on the lecture will be given to the participants to answer. As for the treatment group, a total of 6 text messages will be send to the participants which consists of basic conversation questions, such as â€Å"What is your hobby?† Procedure This experimental study will be done in a big lecturer hall with a clear projector screen and perfect sound system. Before the experiment is conducted, all the participants will be asked to sign the inform consent form. After that, they will be divided into four groups, the male control group, the female control group, the male texting group and the female texting group. The students will be told whether or not they are receiving text messages. For all four groups of experiment (the female control group, the male control group, the female texting group and the male texting group), the lecturer and the English Literature lectures given will be same. However, on the treatment group for both genders, each participant will receive a text message every 5 minutes and they are required to reply the message before the next message comes. After the 30 minutes lecture is finished, all participants will be asked to take a short multiple choice questions quiz based on the class conducted. Once the students have finished the quiz, they are allowed to leave. Statistical Analysis As this experimental study only consist of one independent variable and one dependent variable, the data will be analyzed using SPSS with independent one-way ANOVA; and to see if there is significant differences between two means of independent groups. History: The Act Of God Defence History: The Act Of God Defence The Law of Tort is a developing and ever dynamic field and is a conception evolving through centuries. This field is used with principles under which tortuous liability can be demanded. Simultaneously, certain other principles are used, to oppose these claims for compensation. These counter claims, or defences are used to evict those innocent citizens from tortious liability who have been unfairly implicated with claims imposed on them. These defences were framed from time to time to keep up with the very basis of imposition of tortious liability on an individual- i.e, creating a sense of deterrence while keeping up with the basic values of justice. One such defence which will be discussed elaborately with cases subsequently is ACT OF GOD. MEANING Act of God means an event which happens independently of human action such as death from natural causes (Actus dei nemini facit injuriam), storm, earthquake, tides, volcanic eruptions etc., which no human foresight or skill could reasonably be expected to anticipate. For example, damage from a tornado or a lightning strike would be considered an act of God. Damage would not be considered an act of God if it is caused by the property owner. Vis is a Latin word meaning any kind of force, violence or disturbance to person or property. Vis major is an act of God. The doctrine states that a person is absolved of liability if it was directly caused by vis major. LEGAL DEFINITION Act of God was first judicially defined in Tennet v. Earl of Glosgow Lord Westbury, was first recognised by Blackburn J. in Rylands v. Fletcher and was first applied in Nichols v. Marsland and many other cases. Blacks Law Dictionary defines an act of God as An act occasioned exclusively by violence of nature without the interference of any human agency. A natural necessity proceeding from physical causes alone without the intervention of man. It is an accident which could not have been occasioned by human agency but proceeded from physical causes alone. Vis major is similarly defined, as A greater or superior force; an irresistible force. A loss that results immediately from a natural cause without the intervention of man, and could not have been prevented by the exercise of prudence, diligence, and care. According to Salmond act of God includes those acts which a man cannot avoid even by taking reasonable care. Such accidents are are the result of natural forces and are incoherent with the agency of man. Thus it is an act which is due to natural causes directly and exclusively without human intervention, and that it could not have been prevented by any amount of foresight and pains and care reasonably to have been expected from him i.e. the defendant . Accor ding to Lord Mansfield, it is something in opposition to the act of man. Conclusion: It has been said that it would be probably never be capable of complete, exact unassailable definition. But it has also been said that this untheological expression is well understood by lawyers. It is such a direct, violent , sudden act of nature that no man could forsee and if he can, he cant prevent it. ELEMENTS NATURAL CAUSES An act of God is an uncommon, extraordinary and unforeseen manifestation of the forces of nature, or a misfortune or accident arising from inevitable necessity. An act of god cannot be prevented by reasonable human foresight and care. The effect of ordinary natural causes may be foreseen and avoided by the exercise of human care. For example, the fact that rain will leak through a defective roof is foreseeable. In case of foreseeable causes, failure to take the necessary precautions constitutes negligence, and the party injured in the accident may be entitled to damages. An act of God, however, is so extraordinary and devoid of human agency that reasonable care would not avoid the consequences. Therefore in such cases the injured party has no right to damages. Acts of god are generally attributable to forces of nature. They are generally in the nature of accidents caused by tornadoes, perils of the sea, extraordinary floods, and severe ice storms. Snowstorms of great violence have been held to be acts of God. Whether freezes are acts of God depend on the locality and season of the year in which they occur, i.e., their foreseeability is affected to a greater extent than other natural occurrences by these factors. Catastrophic earthquakes and volcanic eruptions should be defined as acts of God since they measure up to the accepted definitions of act of God in every respect. However, fires are generally not considered acts of god unless they are caused by lightning. Whether or not a particular natural event warrants such an adjective is a function of such things as the intensity of the event, characteristics of the area, and climatic history. UNUSUAL VIOLENCE- BOTH SUDDEN AND IRRESISTIBLE AN OCCURRENCE NOT REASONABLY FORSEEABLE The basic and prime element of an act of god is the happening of an unforeseeable event. For this, if the harm or loss was caused by a foreseeable accident that could have been prevented, the party who suffered the injury has the right to compensation. However, the damage caused by an unforeseen and uncontrollable natural event is not compensable as it could not have been prevented or avoided by foresight or prudence of man. Moreover, courts are of the opinion that the act of God defence exists only if the event is so exceptional and could not have been anticipated or expected by the long history of climate variations in the locality. It is constructed by only the memory of man i.e. recorded history. The courts may even demand expert testimonies to prove that an event was unforeseeable. IMPOSSIBLE TO PREVENT BY ANY REASONABLE PRECAUTIONS AND ABSENCE OF HUMAN AGENCY CAUSING THE ALLEGED DAMAGE It means practically impossible to resist. Negligence constitutes failure to take the necessary precautions. In an incident where a human factor was present, even though the harm could not be prevented, the fact that the human factor exercised reasonable care and precautions to prevent the harm has to be proved if the defence of act of God has to prevail. If negligence is alleged and proved, the defence of act of God will fail. If a home owner was negligent in properly maintaining a tree that fell on a passerby, he cannot be exempted from liability by act of God principle. In Clark v. Multnomah, the Court made a decision that the flooding of a house was not an act of God where it was caused by the breakage of a pipe fitting in the house. The cause of harm was evidenced by the fact that a repairman had worked with the part that broke just hours earlier. ESSENTIALS There must be operation of natural forces like exceptional rainfall, storms, tempests etc. without any human intervention. The incident must be extraordinary and not which could be anticipated and reasonably be guarded. ORIGIN HISTORICAL EVOLUTION The term act of God occurs and is described in holy texts dating back to the 13th century, specifically referring to acts that God has undertaken. The act of God referred is that which is used in legal and insurance circles when discussing any act which is outside human control and governance and therefore not the responsibility of any individual or corporation. The term was first used in this way in the mid-19th century. Peter Simmonds Dictionary of Trade Products, 1858, uses the term: Force-majeure, a French commercial term for unavoidable accidents in the transport of goods, from superior force, the act of God, etc. In July 1803, The Times included this legal ruling given in a court case by Lord Ellenborough, which is in terms that we are now familiar with from our own household insurance policies: By Common Law, Carriers are insurers against every loss of property entrusted to their care, except losses arising from the Act of God, or the Kings enemies. Earthquakes, floods, hurricanes, tornadoes, wildfires, drought and a deadly tsunami are a long series of natural calamities of seemingly large proportions have been witnessed by us . Lives are lost, properties destroyed , and emotions shattered when these forces of nature tragically strike. The natures blow may be so intense that it may come as a total shock and baffle both to the direct victims of the disaster and, subsequently, to the accused tortfeasors Defendants are quick to claim act of God as a defence to these lawsuits. For three centuries, the act of God defence has been accepted in negligence and strict liability cases. Act of God, as a legal concept shows up not only as a defence, but also in discussions of duty and causation. At first glance, the act of God defence seems a simple, direct concept with few gradations or intricacies. Consequently, all too often, many lawyers have misused the phrase act of God to mean any unfortunate act of nature. In a sixteenth century opin ion, in the Shellys Case best known for the famous property law doctrine, the court wrote in terms of performance becoming impossible by an act of God, which was the death of one of the parties. In an attempt to give life to this notion of fairness, the courts in Shelleys Case and other early decisions drew lines between those acts which were natural and those which were caused by man, so as to forgive man for those acts that were beyond his anticipation or control. The court stated: It would be unreasonable that those things which are inevitable by the Act of God, which no industry can avoid, nor policy prevent should be construed to the prejudice of any person in whom there was no laches. No further explanation of the phrase, Act of God, was provided by the court. The phrase again appeared in the 1702 case of Coggs v. Bernard, which invoked liability for a bailment by a common carrier. Justice Powell opined that a bailee shall answer accidents, as if the goods were stolen; but not such accidents and casualties as happen by the act of God, as fire, tempest for the bailee is not bound, upon any undertaking against the act of God. The act of God defence expanded from common carriers into other areas of strict liability. The Courts then extended the act of God defence to cases of negligence. The act of God defence received prominence in decisions construing the common-law liability of common carriers who were treated as insurers of the goods they carried. In 1785, Lord Mansfield delivered a unanimous opinion in Forwardv. Pittard which involved an accidental fire for which the carrier was in no way at fault. The court clearly established a rule of strict liability for common carriers: It appears from all the cases for 100 years back, that there are events for which the carrier is liable independent of his contract. Again, in Forward, the English courts limited the act of God defence by excluding acts of man. In addition, the burden of proof was shifted from the plaintiff to the defendant to establish the existence of the act of God defence. Although the courts subsequently split on the liability issue for common carriers whose delay subjected its freight to damage from an act of God, there was a consensus that liability would result if the common carriers knew that the force of nature was coming. CASE LAW: In Nichols v. Marsland(1875)( Discussed in judicial cases section) APPLICATION Act of God is often a difficult defence to establish. It requires both the exclusion of human agency and unforeseeability to establish an act of God. For an event to be a legal act of God, the natural event must have been the sole and immediate cause of the injury, with no co-operation of man, or any admixture of human means. Generally speaking, then, the vis major defence can apply to a case involving damage or harm by a natural force, but only in circumstances in which that force is strong enough to overcome and nullify any potential contributory cause by a human agency. The issue is whether the magnitude of force is reasonably foreseeable such that a defendant should have taken precautions to avoid personal injury or property damage resulting from it. For example, a 55-mile-per-hour wind gust, though rare, is reasonably foreseeable in Wisconsin. However, a 200-mile-per-hour tornadic wind is probably not; the vis major defence would apply to personal injury or property damage caused by such a force, even if a human agency (for example, a product such as a window or door) was involved. With respect to rain: An hourly rainfall of three inches, while heavy, is not unforeseeable in Wisconsin; an eight-inch hourly rainfall probably is. A basement collapse would probably implicate the vis major defence in favour of a basement contractor in the latter circumstance but not in the former circumstance. When property damage or personal injury is caused in part by a natural force and in part by a human instrumentality, the plaintiff should argue that the natural force was foreseeable and should have been anticipated in a manner that would have avoided the damage. The defendant then has the burden to establish that the natural-force component of the cause was so huge and so monumental that it was not reasonably foreseeable. The point is that the occurrence of natural phenomenon need not be unique, nor need it be one that happens for the first time; it is enough that it is extraordinary or exceptional and so as it could not be reasonably anticipated and also it must be free from human conduct. The word vis major imports something abnormal and with reference to the context means that the property by the act of God has been rendered useless, for the time being i.e. it was rendered incapable of any enjoyment. Vis Major to afford a defence must be the immediate cause, the causa causans, and not merely a causa sine qua non of the damage complained of. The mere fact that vis major co-existed or followed on the negligence is no adequate defence. Before an act of God may be admitted as an excuse the defendant must himself have done all he is bound to do. The legal maxim Actus dei nemini facit injuriam means the Law holds no man responsible for the act of God. The important thing in regard to vis major is not the positive intervention of natural forces but a process of nature not due to the act of man and it is this negative side which deserves emphasis. It is thus a negation of liability. Complete exclusion of human cause is a difficult standard for a defendant to overcome, which likely explains why the defence is not commonly argued or upheld. As a result, modern courts sometimes characterize acts of God as unavoidable accidents because, although the terms often are synonymous, unavoidable accidents need not be free from human agency. ACT OF GOD AND INEVITABLE ACCIDENT DISTINGUISHED Every act of God is an inevitable accident but not vice versa. An Act of God is discrete and distinct from inevitable accident. In order that an accident may be an act of God it must have followed directly from natural causes without human intervention. In Nugent v. Smith, Cockburn, C.J. said All causes of inevitable accident, casus fortuitous meaning an uncontrollable accident, may be divided into two classes: Those which are occurred by elementary forces of nature not connected with the agency of man or other cause [Act of God] Those which arises either wholly or in part by agency of man. [Inevitable Accident] Example- 1. If a ship is pushed ashore by a violent storm, this is the Act of God; but if it is run ashore during a fog by mistake, however unavoidable on the part of captain, this is the act of man. If a building is set on fire by lightning, this is an act of God; but not so if it is done by human through falling of a lamp even though this was due to no negligence. INEVITABLE ACCIDENT ACT OF GOD Could not be prevented by the exercise of ordinary care, caution and skill A direct violent, sudden and irresistible act of nature as could not, by any amount of human care and skill have been resisted is Act of God. May be controlled by human beings 2. Not controlled by human beings. 3. Strict liability can be imposed on the tortious liability occurred due to inevitable accidents 3. Even strict liability can also not be Imposed in cases of torts arising out of acts of Gods 4. The courts have discretionary power in determining the defendants tortuous liability 4. No discretionary power Conclusion : The defence of inevitable accident is a more general defence and is distinct from the act of God in so far as it is dependent on human agency and not on natural forces and in the degree of unexpectability. ACT OF GOD NEGLIGENCE Negligence, in law, especially tort law, is the breach of an obligation (duty) to act with care, or the failure to act as a reasonable and prudent person would under similar circumstances. Both these defences (act of God Negligence) are based on reasonable foreseeability. In terms of foreseeability, the question is not whether a similar event has occurred before, but whether the risk that this particular mishap may occur is foreseeable. Thus, a flood, earthquake, hurricane, or other natural force need not have previously struck a particular location for negligence to exist. Liability may still exist if reasonable design, construction, operation, inspection, or maintenance. For a plaintiff to recover damages, this action or failure must be the proximate cause of an injury, and actual loss must occur. In cases of joint causation, where both human negligence and act of God have a role to play, the traditional sine qua non (but for), substantial factor, or legal causation tests apply. If the act of God is so overwhelming that its own force produces the injury independent of the defendants negligence, then the defendant will not be liable. If the damages suffered are incurred solely due to natural causes without any known fault, there is no liability because of the act of God. There are two ways of viewing this situation. The act of God either supersedes the defendants negligence, or the defendants negligent act is not a cause in fact of the injury. In either case, the defendants act did not cause the damage since the injury would have occurred anyway. The party injured in the accident may be entitled to damages. An act of God, however, is so extraordinary and devoid of human agency that reasonable care would not avoid the consequences; hence, the injured party has no right to damages. Accidents caused by tornadoes, perils of the sea, extraordinary floods, and severe ice storms are usually considered acts of God, but fires are not so considered unless they are caused by lightning. JUDICIAL CASES Nichols v. Marsland  [1]   In this case, The defendant had constructed certain artificial lakes on her land by damming up a natural stream at appoint higher up than the defendants land. An extraordinary rainfall, greater and more violent than any within the memory of witnesses, caused the stream and lakes to swell to such an extent that the artificial banks burst and the escaping water rushed on to the plaintiffs land and carried away four county bridges. Nichols, the plaintiff brought an action for damages on the plea that the defendant was liable under the rule in Rylands v. Fletcher  [2]  . HELD: The contention was rejected and the defendant was held not liable. The Court of Exchequer Chamber held that she ought not to be liable for an extraordinary act of nature which she could not reasonably foresee. It was said that one is only bound to provide against the ordinary operations of nature, but not against her miracles. Greenock Corpn. V. Caledonian Railway Co.  [3]   The facts were that the corporation in laying out a park constructed a pool for children in the bed of a stream and there altere its course and obstructed its natural flow. Owing to rainfall of extraordinary intensity, the stream overflowed at the pond and great volume of water poured down a streetand flooded down the property of a railway company. HELD: It was held that this was not damnum fatale and the Corp. was liable. Nichols case was distinguished on the ground that in that case it was the storing of water in a reservoir and not with interference with the course of natural stream and that anyone who does interfere with it must provide against even an extraordinary rainfall. State of Mysore v. Ramachandra  [4]   In this case, the State had constructed a reservoir for the supply of drinking water for the villagers of Nipani. But the construction was not completed and the over-flow channel linked with reservoir was partially constructed. Land and crops were damaged due to flow of water resulted from rain. The plaintiff filed the suit for damages. HELD: The State resisted the suit that it was the act of God. But, the court rejected the defence and observed Assuming an act of God such as flood wholly unprecedented, the damage in such a case results not from the act of man in that he failed to provide a channel sufficient to meet the contingency of the act of God. But for the act of man there would have been no damage from the act of God. T. Gajayalakshmi v. Secretary, PWD, Govt. of T.N.  [5]   The deceased, a cyclist, who was going on his way was electrocuted by the falling of an overhead electric wire. HELD: The court rejected the contention of Electricity board that it was an unexpected event due to rain and wind and that the snapping of the electric wire was an act of God. It also rejected the plea that the death took place due to the negligence of the deceased in his leaving the home that day in rain and wind. Mahindra Nath Mukherjee v. Mathuradas Chaturbhuj  [6]  . A cinema advertising board was placed on the roof of the defendant which fell down and injured the plaintiff. Plaintiff brought a suit against the defendant and contended that the board fell due to storm of unusual severity. But, it was observed that during the season of monsoon a storm of this magnitude is not uncommon. The defendant had not ensured or foresee that the fixing of banner on such a height is strong enough to face the pressure of storm during monsoon season. The Calcutta High Court held that such a storm cannot be said to be so unexpected that no human foresight could reasonably be expected to anticipate it and cannot be regarded as vis major or act of God. Hence, the suit was allowed and the defendant was found negligent. Before the act of God can be admitted the defendant could have taken reasonable care and done all that what he was bound to do. Kallulal v. Hemchand  [7]   The defendant constructed a building and it was collapsed and as a result of it, two sons of the plaintiff were dead. Before the day the building collapsed there was a heavy rain. The defendant pleaded the rain as an act of God HELD: The court observed that the Acts of God must be apparent on the face of the records. They must be known and affect largely to entire public. The defendant was held liable. The act of God or vis major can also be explained mathematically as follows: (i) Unprecedented + Unforeseen + Irresistible = Act of God (As it has been discussed in this Chapter in the cases Nichols v. Marsland; Mahindranath v. Mathura Dass) (ii) Unprecedented + Foreseen + Irresistible + Act of God (Nichols v. Marsland case) (iii) Precedented + Unforeseen + Irresistible = Act of God (Greenock Corporation case) (iv) Precedented + Foreseen + Irresistible = Act of God (Greenock Corporation and Mahindranath cases) EXAMINING ACT OF GOD PRESENT SITUATION Vis Major as a defence depends on two ; lack of predictability and lack of control. If either criteria is missing, the defence fails. Both were solidly based for centuries on the lack of scientific knowledge. Man not only lacked the ability to predict the forces of nature, but also the ability to guard against, control, or otherwise minimize their impacts. In the words of the ancient mime writer Publilius, it is vain to look for a defence against lightning. Today, foreseeability is based not only upon the past, but also upon that which modern technology and science allow us to project into the future. Science has advanced to the point where we can understand many forces of nature, such as precipitation and flooding. Historically, we know which areas have been subjected to specific forces of nature. Scientifically, we can predict the areas which may be subjected to such forces. At first glance, the act of God defence should continue to play a role in strict liability cases. Part of th e underlying purpose of the act of God doctrine was to ameliorate strict liability. In strict liability a number of exceptions have evolved. Whether a particular occurrence amounts to an Act of God is a question of fact, but the ambit of this defence is somewhat restricted. Increased knowledge seems to limit the unpredictable. Natural hazards are no longer a mystery to us. Hence, the applicability of the act of God defence has shrunk in inverse proportion to rapidly expanding concepts of foreseeability. Conversely, environmental changes at the global level have left some scope for Vis Major as a defence. Unforeseen disasters like the July 26, 2005 floods in Mumbai or the devastating Tsunami on 26 December 2004, which was the result of severe earthquake with its epicentre at Indonesia can still be attributed to acts of God. These disasters were completely unforeseen and any prior intimation about the same would not have helped bring the situation under control. Such natural catastrop he has left some scope for the use of Act of God as a defence. Flaws in The Common Laws Approach to The Act Of God Defence 1. The Problem of Increasing Event Foreseeability In terms of Event Foreseeability, there are two independent trends which suggest a strong possibility that climatic events which historically qualified as Acts of God may become increasingly foreseeable: improved meteorological techniques and the effects of climate change. It is undeniable that there is increased data available and increased forecasting powers inherent in the continuing development of meteorological science. This trend has two impacts on the foreseeability of such climatic events for purposes of the Act of God defence: (1) defendants can increasingly know that the hurricane or storm is coming with time to take some precautionary steps in response because they will be warned of it (so that it will be more difficult to say that the event was unexpected or unanticipated); and (2) climatic data of past storms will continue to accumulate (so as to support conclusions that the event is not unusual for the location at that time of year). In short, the climatic events which historically may have been considered Acts of God will be more foreseeable in the future and thus less likely to support the defence simply because we will know more and more about the weather. In short, as climatic change increases the frequency and intensity of hurricanes, heavy storms, and the flooding associated with such climatic events, it appears that it will be harder for defendants to claim that the events themselves or the consequences of those events were not foreseeable. Thus, the defence is likely to be diminished in its utility simply because it will be harder to satisfy the legal requirements relating to the Event Foreseeability necessary to invoke the defence 2. The Problem of Response Forseeability As the climatic events themselves become more foreseeable, Response Forseeability becomes more critical to the Act of God defence because the burden is on the defendant to show that it took reasonable precautions in light of the foreseeable risk. It is here that foreseeability in the context of the Act of God defence really breaks down because of the inability of the defendant to foresee what the adequate response is before the climatic event occurs. To illustrate the problem, consider a fact pattern taken from the Act of God case law: a warehouseman holding goods for a customer in a Gulf Coast state in which a hurricane could strike. Given that a significant climatic event (i.e. a hurricane in the Gulf) is foreseeable, the court will have to analyze whether the defendants actions were reasonable in light of the foreseeable risk. CONCLUSION Although the act of God defence that a defendant is insulated from liability for personal injury or property damages caused by a natural cause is rarely used, it may become more common and general in the future if predictions of disastrous weather events caused by global warming prove true. One prediction related to global warming is that catastrophic weather events such as hurricanes, tornados, and torrential rains will occur more often. All of these have the potential for causing extensive personal injury and property damage and consequently mental trauma. Therein lie the core for more frequent, common and general use of the vis major defence. Is it still viable? How might it apply as a defence to tort? The act of God defence is as common today as ever. Though, it is still not relied on very often, likely because of the difficulty of proving that human elements played no role in causing an injury. The potential application of vis major will expand if meteorological predictions concerning climate change through global warming come to accomplishment and realization. However, as these events become more common, the standard of what constitutes a reasonably foreseeable natural force will doubtless itself expand. This again would confine application of the vis major defence insofar as defendants become obligated to anticipate and account for effects of more extreme and dangerous natural phenomena, especially those associated with the weather. However, in the era of global climate change, courts can hardly pretend that causation can be determined to be natural or human. Storm patterns and frequencies are changing. Growing seasons are shifting. Glaciers are melting and seas rising. Global climate change will present courts with the kinds of difficult factual situations that make it impossible to pretend the old act of God divide should stand untouched. Even though a particular defendant in a given case may not have been demonstrably at fault, the act of God doctrine remains analytically flawed because it requires that nature be the sole cause of a phenomenon to the exclusion of all human action

Tuesday, November 12, 2019

Riots- Rough notes

Riots were a series of riots, looting's, arson and civil disturbances that occurred in Los Angels on April 29th 1992, lasting 6 days through to May 5th. They were triggered by the acquittal of police officers in a trial regarding a videotaped police brutality incident. 4 police officers were caught on amateur video beating an unarmed African- American motorist-Rodney King. The case was taken to trial and the four (white police officers) were acquitted of any wrong doing (by a 12 person Jury: 10 whites and no African Americans).The Rodney King Incident TLD only trigger the most destructive US call disturbance f the 20th century It created outrage In the press and It triggered a national debate on police brutality. In one way the riots did what hip hop had been trying to do for years, particularly since 1 988 with the birth of gangs rap – make the America which existed outside of the Ghetto's see what was really going on.According to the California Economic Development Departmen t between April 1 992 and April 1 992 108,00 local Jobs vanished- Black and Latino communities were hard hit with a combined 29. 7 % in poverty and more than 13% unemployed. In depressed South Central only 45% of African-American males were employed African-Americans have by far the lowest rate of two-parent families in Southern California â€Å"Gangs are never going' to die out. You all going' to get us Jobs? 016-year-old Grape Street Crisp -quoted In Mike Davis (historian) book City of Quartz Bloods and Crisp are the two mall gangs In LA at the time Black gangs Bloods (Red) Crisp (Blue) very territorial, street violence, drive by shootings, violent nature, Influenced youth local youth were bored with nothing to do drugs, guns, cars etc the local demographic leading up to and during the riots was ripe for civil unrest Juvenile and adult arrest rates- analyzing this source: reliable, police released these were angry and acting out, there was no doubt that there was a violent crime nature brewing in LA â€Å"What we have is people sick of the police and that's when you have a revolution in your hands† -Ice Cube Why were people sick of the police ? People were angry with the actions they took in order to deal with gang violence in LA: one of the main factors in the growing anger amongst communities particular black and Latino ones was the constant racial profiling and targeting of black and Hispanic youths ?> by the LAPPED. Operation Hammer for example was an initiative employed by the LAPPED in order to crack down on gang violence. Their aim was to arrest and incarcerate â€Å"suspected gang members† before they could commit a crime. What this objective led to was mass arrests of youths becoming common and as a consequence a large number of those arrested were never charged ?> leaving many personally victimized by the police force ?> greater number of hostility towards the police. *Complaints against police brutality increased by 33% in the perio d of 1984 and 1989 but only 1% of those complaints were ever followed up.In 1982 for example following a rash of LAPPED ‘chuckhole killings of young black men in custody Chief Gates advanced the theory that the deaths were the faults of the victims' racial anatomy and not excessive police force and I quote † We may be finding that in some Blacks when the chuckhole is applied the veins or arteries do not open up as fast as they do on normal people. † Many statements like these were constantly made in the media e. G â€Å"Tonight we pick ‘me up for anything and everything. OLAP spokesman (9 April 1988)† â€Å"l think people believe that the only strategy we have is to put a lot of police officers n the street and harass people and make arrests for inconsequential kinds of things. Well, that's part of the strategy, no question about it. Chief Gate† The use of the phrases â€Å"normal people†, tonight we pick them up for anything, Harass peop le etc is inflammatory in a society which is already deeply affected by issues of poverty, lack of education, lack of Jobs, broken families and prejudice. White perspective ?> the general perspective of the white community LA TIMES: Thank you very much for the interview with Police Chief Daryl Gates and County Sheriff Sherman Block. You gave them a fair chance to explain crime and gangs. Much too often the media make these two important law-enforcement gentlemen out as being callous and insensitive to the community's needs. Fortunately, we got to see the real side to these heroes who are trying to protect us as best they can. JASON M.NONSOCIAL Glendale proud of the policing strategies they implemented saw the gang culture as an epidemic Chief Gates saw the Rodney King verdict as wrong because the police officers â€Å"stepped out of line† but in an interview still tried to defend them, giving them Monnet to beating Rodney King up Sick and tired of gang bangers ( to put it sim ply) Saw gangs rap as a threat to the youth: they wanted to shut them up Worked with the government and publicly criticized groups like N. W. A tried to arrest as many as they could they were scared of â€Å"the hood† they believed that there were a few corrupt individuals in the LAPPED but the whole LAPPED wasn't corrupted but why and what was the effect ?The police perspective generally was a reaction to what the community were saying and feeling (white particularly and sometimes other aces), people were scared to sit on dining tables in case they would get shot. While it gave a sense of protection (â€Å"protect and serve†) to some parts of the communities, others felt victims, the LAPPED insisted they were not racist, Just careful. The perspective of black youths was represented through the art form of gangs rap ?> a voice for the voiceless. Police brutality is clearly a common theme throughout many gangs rap songs, the actions of police led to a lot of resentment towards police as seen in the song â€Å"Buck that Police† ?Analyses a few lyrics from songs and family detachment.Buck that police† ?> first indicator of low education -derogatory label is used on themselves- maybe that's the point (Amiga) -constant references to the police ?> the broken relationship between the communities and police â€Å"Authority to kill a minority' ?> not literally kill but destroy the foundations of their culture (police brutality ?> people are angry) -the whole last part of the song links back to Operation Hammer ? > why it made people angry (searching people because they were black, prejudices etc) Buck that police in particular was the theme song for the riots as the lyrics spoke to he people-resonating with what they were feeling Gangs rap artists like Ice- T and NNW, saw themselves as street reporters most of the situations in their rap is secondary accounts of things, personae taken on and it's hardly personal situations It neither glorifi es nor says â€Å"it's k† for these things to be happening but then from a black perspective- is what the LAPPED doing k ?

Sunday, November 10, 2019


I. Problem Identification 1. Demand on Edmunds Corrugated Parts and Services products are diminishing. 2. Remote location of its business. 3. High price of ram material. 4. Difficulty of replacing hardworking and loyal existing employee. II. Objectives 1. To keep the company of its current standing in the market in the future. 2. To develop new parts and products that will compete on new trends of shipping products. 3. To find other target market that will increase its market share. 4. To train and develop highly skilled worker at an earlier time to replace the retiring workforce. III. Analysis and Methodology The case is being solved on the point of view of Mr. Larry Edmunds the Owner. Methodology use in analysis – SWOT Analysis Strength: 1. More than 2 decades in existence. 2. It has hardworking and loyal workforce. 3. Industry leader with exceptional reputation for reliability. 4. Market share is at 75 percent Weaknesses: 1. Location is rural. 2. Products are not up the current technology. 3. Revenues were beginning to show clear signs of stagnation. 4. Current workforces are nearing retirement. Opportunities: 1. Diversification of new and existing products. 2. Has 50,000 square foot factory. 3. Youthful workforce is available 4. Other alternative business venture is emerging. 5. Make use of the internet as a marketing tool. Threats: 1. Products are going to be obsolete. 2. Paper industry is being wipeout. 3. Clients are going overseas for a joint venture. 4. Surviving manufacturers are investing on high quality machines that broke down less frequently. IV. Alternative Courses of Actions 1. Develop new parts and product that will cater the new machines use in manufacturing new shipping products. 2. Make a careful study to branch out the business to other areas to increase its share in the market. 3. Find an alternatives source of materials like durable plastics for shipping products. 4. Hire younger workforce and develop their skills. V. Conclusion / Recommendation: The company should always look on the ever evolving market trend on manufacturing and distribution on its industry. The company should adapt quickly to keep its share in market or introduce machines that will keep industry grow and lower production cost through automation. All of the alternative courses of actions are recommended to keep the company move forward and achieve its goals.

Friday, November 8, 2019

Karl Marx Essays - Philosophy, Politics, Culture, Materialists

Karl Marx Essays - Philosophy, Politics, Culture, Materialists Karl Marx 1818-83, German social philosopher and revolutionary; with Friedrich Engels, a founder of modern Socialism and Communism. The son of a lawyer, he studied law and philosophy; he rejected the idealism of G.W.F. Hegel but was influenced by Ludwig Feuerbach and Moses Hess. His editorship (1842-43) of the Rheinische Zeitung ended when the paper was suppressed. In 1844 he met Engels in Paris, beginning a lifelong collaboration. With Engels he wrote the Communist Manifesto (1848) and other works that broke with the tradition of appealing to natural rights to justify social reform, invoking instead the laws of history leading inevitably to the triumph of the working class. Exiled from Europe after the Revolutions Of 1848, Marx lived in London, earning some money as a correspondent for the New York Tribune but dependent on Engels's financial help while working on his monumental work Das Kapital (3 vol., 1867-94), in which he used Dialectical Materialism to analyze economic and social history; Engels edited vol. 2 and 3 after Marx's death. With Engels, Marx helped found (1864) the International Workingmen's Association, but his disputes with the anarchist Mikhail Bakunin eventually led to its breakup. Marxism has greatly influenced the development of socialist thought; further, many scholars have considered Marx a great economic theoretician and the founder of economic history and sociology. Bibliography

Wednesday, November 6, 2019

Learn How Apples First Smartphone Came to Be

Learn How Apple's First Smartphone Came to Be According to the Oxford English Dictionary, a smartphone is â€Å"a mobile phone that performs many of the functions of a  computer, typically having a touchscreen interface, internet access, and an operating system capable of running downloaded apps.† As those of you who know your smartphones history are aware, Apple did not invent the smartphone. They did, however, bring us the iconic and much-imitated iPhone, which debuted June 29, 2007. Precursors to the iPhone Prior to the iPhone, smartphones were often, bulky, unreliable, and prohibitively expensive. The iPhone was a game-changer. While its technology was state-of-the-art at the time, since more than 200  patents  went into its original manufacture, theres no pinpointing a single person as the iPhones inventor. Still, a few names- including Apple designers John Casey and Jonathan Ive- stand out as being instrumental in bringing Steve Jobs vision for a touchscreen smartphone to life. While Apple had produced the Newton MessagePad, a personal digital assistant (PDA) device, from 1993 to 1998, the first  concept for a true iPhone-type device came about in 2000 when Apple designer John Casey sent some concept art around via an internal email for something he called the Telipod- a telephone and iPod combination.  The  Telipod  never made it into production but Apple co-founder and CEO Steve Jobs did believe that cell phones with a touchscreen function and access to the Internet were the future of accessible information. Accordingly, Jobs set a team of engineers to tackle the project.   Apples First Smartphone Apples first smartphone, the ROKR E1, was released on Sept. 7, 2005. It was the first mobile phone to use iTunes, the music-sharing software Apple had debuted in 2001. However, the ROKR was an Apple and Motorola collaboration, and Apple was not happy with Motorolas contributions. Within a year, Apple discontinued support for the ROKR. On Jan. 9, 2007, Steve Jobs announced the new iPhone at the Macworld Convention. It went on sale on June 29, 2007. What Made the iPhone So Special Apples chief design officer from 1992 to 2019, Jonathan Ive, was largely responsible for the look and feel of the iPhone. Born in Britain in February 1967, Ive was also the principal designer of the iMac, the titanium and aluminum PowerBook G4, MacBook, unibody MacBook Pro, iPod, iPhone, and iPad. The first smartphone with no dedicated keypad for dialing, the iPhone was entirely a touchscreen device that broke new technological ground with its multitouch controls. In addition to being able to use the screen to select and use apps, users could scroll and zoom as well with a finger swipe. The iPhone also introduced the accelerometer, a motion sensor that allowed the user to turn the phone sideways and have the display automatically rotate to suit. While it was not the first device to have apps or software add-ons, it was the first smartphone to manage the apps market successfully. Siri The iPhone 4S was released with the addition of a personal assistant called Siri, a voice-controlled, artificial intelligence-based assistant that could not only perform numerous tasks for the user, it could also learn and adapt to better serve that user, as well. With the addition of Siri, the iPhone was no longer a mere phone or music player- it literally put an entire world of information at the users fingertips. Waves of the Future Since it made its debut, Apple has continued to improve and update the iPhone. The iPhone 10 (also known as iPhone X), released in November 2017, is the first iPhone to use  organic light-emitting diode  (OLED)  screen technology, wireless charging, and facial recognition technology to unlock the phone. In 2018, Apple released three versions of the iPhone X: iPhone Xs, iPhone X Max (a larger version of the Xs), and the budget-friendly iPhone Xr, all with improved camera technology that enables what Apple terms, Smart HDR (high dynamic range) photography. Going forward, Apple is expected to continue with OLED displays for its 2019 devices, and there are some rumors that the company plans to soon retire its earlier LCD (liquid crystal display) displays altogether.