The Effects Of Acid Rain Essay Example For Students

The Effects Of Acid Rain Essay Acid RainINTRODUCTION: Acid rain is a great problem in our world. It causes fishand plants to die in our waters. As well it causes harm to our own race aswell, because we eat these fish, drink this water and eat these plants. Itis a problem that we must all face together and try to get rid of. Howeveracid rain on its own is not the biggest problem. It cause many otherproblems such as aluminum poisoning. Acid Rain is deadly. WHAT IS ACID RAIN?Acid rain is all the rain, snow, mist etc that falls from the sky ontoour planet that contains an unnatural acidic. It is not to be confused withuncontaminated rain that falls, for that rain is naturally slightly acidic. It is caused by todays industry. When products are manufactured manychemicals are used to create it. However because of the difficulty and costof properly disposing of these products they are often emitted into theatmosphere with little or no treatment. We will write a custom essay on The Effects Of Acid Rain specifically for you for only $16.38 $13.9/page Order now The term was first considered to be important about 20 years ago whenscientists in Sweden and Norway first believed that acidic rain may becausing great ecological damage to the planet. The problem was that by thetime that the scientist found the problem it was already very large. Detecting an acid lake is often quite difficult. A lake does not becomeacid over night. It happens over a period of many years, some timesdecades. The changes are usually to gradual for them to be noticed early. At the beginning of the 20th century most rivers/lakes like the riverTovdal in Norway had not yet begun to die. However by 1926 local inspectorswere noticing that many of the lakes were beginning to show signs of death. Fish were found dead along the banks of many rivers. As the winters icebegan to melt off more and more hundreds upon hundreds more dead fish(trout in particular) were being found. It was at this time that scientistbegan to search for the reason. As the scientists continued to work theyfound many piles of dead fish, up to 5000 in one pile, further up theriver. Divers were sent in to examine the bottom of the rivers. What theyfound were many more dead fish. Many live and dead specimens were takenback to labs across Norway. When the live specimens were examined they werefound to have very little sodium in their blood. This is typical a typicalsymptom of acid poisoning. The acid had entered the gills of the fish andpoisoned them so that they were unable to extract salt from the water tomaintain their bodies sodium levels. Many scientist said that this acid poising was due to the fact that itwas just after the winter and that all the snow and ice was running downinto the streams and lakes. They believed that the snow had been exposed tomany natural phenomena that gave the snow its high acid content. Otherscientists were not sure that this theory was correct because at the timethat the snow was added to the lakes and streams the Ph levels would changefrom around 5.2 to 4.6. They believed that such a high jump could not beattributed to natural causes. They believed that it was due to airpollution. They were right. Since the beginning of the Industrialrevolution in England pollution had been affecting all the trees,soil andrivers in Europe and North America. .u90ae0e7cd7776695ab6faebf67504e87 , .u90ae0e7cd7776695ab6faebf67504e87 .postImageUrl , .u90ae0e7cd7776695ab6faebf67504e87 .centered-text-area { min-height: 80px; position: relative; } .u90ae0e7cd7776695ab6faebf67504e87 , .u90ae0e7cd7776695ab6faebf67504e87:hover , .u90ae0e7cd7776695ab6faebf67504e87:visited , .u90ae0e7cd7776695ab6faebf67504e87:active { border:0!important; } .u90ae0e7cd7776695ab6faebf67504e87 .clearfix:after { content: ""; display: table; clear: both; } .u90ae0e7cd7776695ab6faebf67504e87 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u90ae0e7cd7776695ab6faebf67504e87:active , .u90ae0e7cd7776695ab6faebf67504e87:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u90ae0e7cd7776695ab6faebf67504e87 .centered-text-area { width: 100%; position: relative ; } .u90ae0e7cd7776695ab6faebf67504e87 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u90ae0e7cd7776695ab6faebf67504e87 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u90ae0e7cd7776695ab6faebf67504e87 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u90ae0e7cd7776695ab6faebf67504e87:hover .ctaButton { background-color: #34495E!important; } .u90ae0e7cd7776695ab6faebf67504e87 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u90ae0e7cd7776695ab6faebf67504e87 .u90ae0e7cd7776695ab6faebf67504e87-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u90ae0e7cd7776695ab6faebf67504e87:after { content: ""; display: block; clear: both; } READ: Guilt And Then There Were None EssayHowever until recently the loses of fish was contained to the southernparts of Europe. Because of the constant onslaught of acid rain lakes andrivers began to lose their ability to counter act their affects. Much ofthe alkaline elements; such as calcium and limestone; in the soil had beenwashed away. It is these lakes that we must be worried about for they willsoon become extinct. A fact that may please fishermen is that in lakes/rivers they tend tocatch older and larger fish. This may please them in the short run howeverthey will soon have to change lakes for the fish supply will die quickly inthese lakes. The problem is that acid causes difficulties the fishsreproductive system. Often fish born in acid lakes do not survive for theyare born with birth defects such as twisted and deformed spinal columns. This is a sign that they are unable to extract enough calcium from thewater The Effects Of Acid Rain Essay Example For Students The Effects Of Acid Rain Essay Acid RainINTRODUCTION: Acid rain is a great problem in our world. It causes fishand plants to die in our waters. As well it causes harm to our own race aswell, because we eat these fish, drink this water and eat these plants. Itis a problem that we must all face together and try to get rid of. Howeveracid rain on its own is not the biggest problem. It cause many otherproblems such as aluminum poisoning. Acid Rain is deadly. WHAT IS ACID RAIN?Acid rain is all the rain, snow, mist etc that falls from the sky ontoour planet that contains an unnatural acidic. It is not to be confused withuncontaminated rain that falls, for that rain is naturally slightly acidic. It is caused by todays industry. When products are manufactured manychemicals are used to create it. However because of the difficulty and costof properly disposing of these products they are often emitted into theatmosphere with little or no treatment. We will write a custom essay on The Effects Of Acid Rain specifically for you for only $16.38 $13.9/page Order now The term was first considered to be important about 20 years ago whenscientists in Sweden and Norway first believed that acidic rain may becausing great ecological damage to the planet. The problem was that by thetime that the scientist found the problem it was already very large. Detecting an acid lake is often quite difficult. A lake does not becomeacid over night. It happens over a period of many years, some timesdecades. The changes are usually to gradual for them to be noticed early. At the beginning of the 20th century most rivers/lakes like the riverTovdal in Norway had not yet begun to die. However by 1926 local inspectorswere noticing that many of the lakes were beginning to show signs of death. Fish were found dead along the banks of many rivers. As the winters icebegan to melt off more and more hundreds upon hundreds more dead fish(trout in particular) were being found. It was at this time that scientistbegan to search for the reason. As the scientists continued to work theyfound many piles of dead fish, up to 5000 in one pile, further up theriver. Divers were sent in to examine the bottom of the rivers. What theyfound were many more dead fish. Many live and dead specimens were takenback to labs across Norway. When the live specimens were examined they werefound to have very little sodium in their blood. This is typical a typicalsymptom of acid poisoning. The acid had entered the gills of the fish andpoisoned them so that they were unable to extract salt from the water tomaintain their bodies sodium levels. Many scientist said that this acid poising was due to the fact that itwas just after the winter and that all the snow and ice was running downinto the streams and lakes. They believed that the snow had been exposed tomany natural phenomena that gave the snow its high acid content. Otherscientists were not sure that this theory was correct because at the timethat the snow was added to the lakes and streams the Ph levels would changefrom around 5.2 to 4.6. They believed that such a high jump could not beattributed to natural causes. They believed that it was due to airpollution. They were right. Since the beginning of the Industrialrevolution in England pollution had been affecting all the trees,soil andrivers in Europe and North America. .u2ef581781317a78498d355fe8d1137e0 , .u2ef581781317a78498d355fe8d1137e0 .postImageUrl , .u2ef581781317a78498d355fe8d1137e0 .centered-text-area { min-height: 80px; position: relative; } .u2ef581781317a78498d355fe8d1137e0 , .u2ef581781317a78498d355fe8d1137e0:hover , .u2ef581781317a78498d355fe8d1137e0:visited , .u2ef581781317a78498d355fe8d1137e0:active { border:0!important; } .u2ef581781317a78498d355fe8d1137e0 .clearfix:after { content: ""; display: table; clear: both; } .u2ef581781317a78498d355fe8d1137e0 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u2ef581781317a78498d355fe8d1137e0:active , .u2ef581781317a78498d355fe8d1137e0:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u2ef581781317a78498d355fe8d1137e0 .centered-text-area { width: 100%; position: relative ; } .u2ef581781317a78498d355fe8d1137e0 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u2ef581781317a78498d355fe8d1137e0 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u2ef581781317a78498d355fe8d1137e0 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u2ef581781317a78498d355fe8d1137e0:hover .ctaButton { background-color: #34495E!important; } .u2ef581781317a78498d355fe8d1137e0 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u2ef581781317a78498d355fe8d1137e0 .u2ef581781317a78498d355fe8d1137e0-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u2ef581781317a78498d355fe8d1137e0:after { content: ""; display: block; clear: both; } READ: Stereotypes about Homelessness in America in Dumpster Diving by Lars Eighner EssayHowever until recently the loses of fish was contained to the southernparts of Europe. Because of the constant onslaught of acid rain lakes andrivers began to lose their ability to counter act their affects. Much ofthe alkaline elements; such as calcium and limestone; in the soil had beenwashed away. It is these lakes that we must be worried about for they willsoon become extinct. A fact that may please fishermen is that in lakes/rivers they tend tocatch older and larger fish. This may please them in the short run howeverthey will soon have to change lakes for the fish supply will die quickly inthese lakes. The problem is that acid causes difficulties the fishsreproductive system. Often fish born in acid lakes do not survive for theyare born with birth defects such as twisted and deformed spinal columns. This is a sign that they are unable to extract enough calcium from thewater

Cmo emigrar legalmente a los Estados Unidos

Cmo emigrar legalmente a los Estados Unidos   Obtener una tarjeta de residencia permanente es el requisito imprescindible para emigrar legalmente a los Estados Unidos. Esa tarjeta tambià ©n se conoce como permiso de residencia o como green card.   Es cierto que se puede permanecer legalmente en Estados Unidos sin esa tarjeta, pero en otro estatus y siempre se tratarà ­a de una estancia temporal, aunque puede ser ms o menos larga. La tarjeta de residencia permite permanecer y trabajar de forma permanente en los Estados Unidos y puede ser, adems, un puente hacia la adquisicià ³n de la ciudadanà ­a americana por naturalizacià ³n. En este artà ­culo se explican las formas de obtener la tarjeta de residencia y trmites especiales, cules son los requisitos de que debe cumplir el solicitante, los tiempos de tramitacià ³n y, finalmente, cules son los errores que pueden causar el problema de que la green card no sea aprobada. Cà ³mo se adquiere la tarjeta de residencia permanente Aproximadamente, cada aà ±o fiscal 1 millà ³n de personas extranjeras obtienen la tarjeta de residencia por uno de los numerosos caminos creados por la ley para sacar la green card. La mayorà ­a, aproximadamente 6 de cada 10, la obtienen por ser familiar de un ciudadano o de un residente permanente.   Las estadà ­sticas acreditan que en la mayorà ­a de los casos se necesita un patrocinador, es decir, un familiar o una empresa, esto à ºltimo para el caso de trabajadores. Sà ³lo en casos especiales no se necesita patrocinador. Por ejemplo, ciertos casos de trabajadores excepcionales con reconocimiento internacional por su trabajo, asilo, loterà ­a de visas de diversidad o visas de inmigrante de inversià ³n EB-5, cancelacià ³n de la orden de deportacià ³n dictada por un juez, etc. Lo importante de este apartado es entender que no es suficiente querer emigrar. Es necesario reunir los requisitos para poder iniciar uno de los caminos creado por las leyes migratorias.   Trmites para la tarjeta de residencia Los trmites son diferentes segà ºn el tipo de camino que cada persona sigue para obtener la green card. Por ejemplo, en las peticiones de familia el patrocinador debe enviar la peticià ³n, probar parentesco, acreditar medios econà ³micos para el sostenimiento de la persona patrocinada, etc. Por el contrario, si se trata de una peticià ³n por empresa se va a necesitar una aprobacià ³n previa por parte del Departamento de Trabajo. En el caso de que se trate de asilo, se necesita una decisià ³n afirmativa parte del Servicio de Inmigracià ³n y Ciudadanà ­a (USCIS, por sus siglas en inglà ©s) o de una corte migratorio.   Si se trata de la visa de diversidad, hay que aplicar en octubre por internet en la pgina del Departamento de Estado y ganar una loterà ­a que se celebra en mayo del aà ±o siguiente, etc. Es decir, los trmites son distintos segà ºn el camino que se emplee para la residencia. Requisitos que debe reunir el potencial migrante En la fase final de la tramitacià ³n de la green card el proceso puede pararse y la peticià ³n negarse si se considera que la persona es inadmisible.   Es cierto que dependiendo del camino para la green card, algunas de esas causas no se tienen en cuenta, por ejemplo, estancia ilegal en casos de green card por razones humanitarias como la visa U. Pero la regla general es que hay que mirar con lupa esas circunstancias, ver cundo no aplican, cundo es posible pedir un perdà ³n, cundo hay que simplemente esperar o cundo no se puede hacer nada. En otras palabras, hay que asesorarse con un abogado de inmigracià ³n. Adems, en los casos en los que el problema surge por estancia ilegal en los Estados Unidos y se est en el paà ­s es conveniente entender cundo se puede ajustar el estatus a pesar de esa circunstancia y cundo no es posible y necesariamente hay que salir de USA para completar el proceso mediante un procedimiento consular. Esto es importante porque en el momento en que se sale de los Estados Unidos salta lo que se conoce como el castigo o penalidad de los 3 à ³Ã‚  10 aà ±os, que complica y mucho la obtencià ³n de la tarjeta. En otras palabras, si se tiene al menos una causa que convierte a la persona en inadmisible hay que asesorarse para ver cà ³mo aplica a las circunstancias personales de cada caso.   Duracià ³n de la tramitacià ³n Los tiempos de espera desde que se inicia el proceso de la peticià ³n al momento en que se aprueba y se obtiene la green card puede variar desde apenas 4 meses a ms de 20 aà ±os. En estos momentos los trmites ms rpidos son para los familiares inmediatos de ciudadanos, es decir, cà ³nyuges, padre, madre e hijos solteros menores de 21 aà ±os. Por otro lado, los mexicanos que son hijos casados de ciudadanos estn teniendo una demora superior a los 22 aà ±os. Las demoras, particularmente en peticiones de familia, hay que tenerlas en cuenta, porque pueden ser mucho ms largas de lo que se cree. Errores que perjudican el proceso de obtencià ³n de la green card Entre todos los errores destacan los siguientes: - Mentir a un oficial migratorio o del consulado. Y lo cierto es que es frecuente que la mentira sea sobre cosas que no afectarà ­an a la obtencià ³n de la green card. Sin embargo, el mentir es considerado un fraude de ley que es causa de denegacià ³n de la residencia. - Quedarse ilegalmente en Estados Unidos cerrando el paso a muchas de las formas de obtencià ³n de la residencia (aunque no todas ya que en algunos casos sigue siendo posible). - Casarse como turista inmediatamente despuà ©s de ingresar a los Estados Unidos - Casarse con un novio distinto al que patrocinà ³ la visa K-1 Conclusià ³n Hay muchas formas de obtener la green card. Pero como dice el dicho, hay las que hay y no se puede inventar lo que no hay. Adems, es importante entender los trmites, todo lo que se pide, dà ³nde surgen los problemas y cules son los tiempos de demora para la forma especà ­fica que se utiliza para sacar la green card. Para finalizar, es de interà ©s tomar este test de respuesta mà ºltiples sobre cà ³mo sacar la green card y cà ³mo conservarla, ya que en asuntos migratorio el mejor consejo es estar informado para evitar los problemas. Este es un artà ­culo informativo. No es asesorà ­a legal.

Development of the Troubles in Northern Ireland Essay

Development of the Troubles in Northern Ireland - Essay Example They did this by discriminating in houses and jobs in favor of Protestants and by gerrymandering local boundaries, which gave Protestants a majority in the local government of Londonderry, a predominantly Catholic area. In 1967 Catholic nationalist and republican leaders formed the Northern Irish Civil Rights Association (NICRA), inspired by the Civil Rights Movement in the US, to campaign against discrimination (Purdy, 2000). Goulding's plan caused a decisive split in the IRA and its political wing in 1969-70. Traditionalists rejected Goulding and set up the Provisional IRA, taking its name from the 1916 Provisional Government. And it was the 'Provos' (Purdy, 2000) who rigorously stuck to a strategy of bombings and shootings in the 1970s and 1980s with some hardcore support in working-class Catholic ghettos in Belfast and Londonderry. Attacks on the British Army and the Royal Ulster Constabulary were justified by the claim that the Provos were engaged in a war against an occupying power. The political dimension was neglected until some of the younger IRA leaders, notably Gerry Adams and Martin MacGuiness, moved into Provisional Sinn Fein. Then and only then did a disposition to compromise emerge with successive IRA ceasefires, and the amazing recent spectacle of Sinn Fein members taking up appointments in the new Northern Ireland Assembly. The strategy of abstentionism had at long last been cast aside. In the words of Purdy, (2000) People's Democracy was formed in October 1968 by students at the Queen's University, Belfast, as a radical, socialist offshoot of NICRA. It became the principal initiator of violence in the North, seeking revolution and confrontation as it marched into Protestant areas and helped to destroy the moderate centre in Ulster politics. People's Democracy was at the centre of nearly every violent confrontation between civil rights demonstrators and the unionists, backed up by the RUC (Royal Ulster Constabulary). On 4 January 1969 there was a civil rights march (based on Martin Luther king's Selma freedom march in 1965) from Belfast to Londonderry, organized by People's Democracy. It was attacked outside Derry by a Protestant mob wielding cudgels: the RUC gave the marchers no protection. Later that day the RUC and 'B' Specials (Protestant special constabulary) went on the rampage in Derry's Catholic Bogside. In retaliation the inhabitants sealed off the Bogside, making it a 'No-Go area' and called it Free Derry (Townson, 2006). These events broke up the alliance which Terence O'Neill, the Northern Ireland Prime Minister, was promoting between the moderates in both communities. James Chichester-Clark replaced O'Neill as Prime Minister in April 1969 and tried to reduce tension by introducing reforms Catholics had long demanded to end discrimination in housing, jobs and local government, but the reforms came too late. There was serious rioting in the summer of 1969, which the RUC was unable to contain, so

Determine the Optimal Investment Performance Appraisal Systems Research Paper

Determine the Optimal Investment Performance Appraisal Systems - Research Paper Example This is considered as one of the first phase in understanding the performances of an individual, economic circumstances, desires and aims. The starting point of this situational profiling comprises of investigating the source of wealth, stage of life of the investor and volume of these sources of wealth. There are mainly two common sources of wealth for the individual investors. They are, (1) Wealth generated by entrepreneurial activity- wealth is created through this activity perhaps indicates knowledge of the investors and experience, by way of the risk-taking judgment. (2) Wealth accumulated all the way through inheritance or one-time windfalls or accumulation of wealth over a long period of safe job- Wealth is acquired through this way indicates that individual has less knowledge about risk-taking activity. â€Å"Terminologies vary, but for practical purposes we can consider the individual investor to be either affluent or high net worth. â€Å"For the affluent investors, the t otal economic resources are of roughly the same magnitude, as they claim on those resources resulting from the investors’ life choices† (Torre & Rudd, 2004, p. 2). Those choices normally consist of a need for post retirement expenses, the purchase of homes and the educational expenses of kids. When the investor is middle aged or young, fiscal activities normally symbolize the smaller part of his whole resources, with human assets and real estate possessions representing the bulk of his possessions. â€Å"Traditional finance assumes that all investors exhibit three major characteristics, such as, 1. Risk aversion- Investors minimize risk for a given level of return or maximize return for given level of risk. 2. Rational expectation- Investors... The paper demonstrates that evaluating performance presenting it fairly is vital to the energy of an investment firm. Portfolio managers and security analysts create decisions under circumstances of uncertainty concerning the relative attractiveness of individual investments and market sectors; the function of performance analysts is to explain the result of those decisions. Portfolio management is the art and science for making decision in terms of investment mix and policy, achieve the objective of investors, by investing asset for individual or institutions. Portfolios defined as â€Å"a collection of investments all owned by the same individual or organization. These investments often include stocks, which are investments in individual businesses; bonds, which are investments in debt that are designed to earn interest; and mutual funds, which are essentially pools of money from many investors that are invested by professionals or according to indices†. It is constituted to achieve a level of expected return with lowest risk possibility. The portfolio management has been involved with new product development and innovate projects to achieve maximum profit. In the sense of modern portfolio it is professionally constructed strategy for investment to achieve more growth from a nominal amount of capital. It defined as â€Å"Overall investment strategy that seeks to construct an optimal portfolio by considering the relationship between risk and return, especially as measured by alpha, beta, and R-squared.

IP 4 English Essay Example | Topics and Well Written Essays - 500 words

IP 4 English - Essay Example The defenders of Smartphones claim that with the implication of Smartphones in schools, students can stay updated with the current research, they can be could at life management and quick in responding to tasks. The aim of this expository paper is to discuss the subject of Smartphone and its usage from different perspective to understand its effectiveness as a technological advancement. Critics claim that Smartphones can damage the thought process of humans because it can give access to unimportant facts as well. However, on the other hand, it is claimed by the defenders that Smartphones have allowed humans to stay active regarding things around them. In the present world, where billions of facts and figures are exchanged in a single day, it is imperative for everyone to stay aware of the viral information. Students, being the most active learners, can get a lot of benefits by using Smartphones to gain information (Wankel & Blessinger, 2013, p. 50). It is considered that there are roughly 3000 productivity mobile phone applications that are currently being downloaded and used by mobile phone users every day. These phone applications are used by phone users to mark important appointments, tasks, reminders etc. This allows them to stay aware of their responsibilities. At the same time, critics claim that this will make students to rely on Smartphones a lot and not their intelligence. Defenders provide supporting claim that time tables are reasonably used to mark such reminders and tasks already. Smart phones have rather allowed them to stay active more than ever (Wankel & Blessinger, 2013, p. 55). Critics claim that in order to make a person to be active in meeting deadlines and completing tasks, Smartphones are not needed. Such an assertion is presented because defenders claim that students can stay connected to

Analysis of Singapores Intellectual Property Laws

Analysis of Singapores Intellectual Property Laws The Issue of Intellectual Property Protection From the previous assignment, we have look into the cases involving McDonald Corporation and Future Enterprise PTE LTD, we have also introduced the basic intellectual property laws and how they are inter-related to one another. In this assignment, we will analyze the Singapore Laws that is related to the cases involved, and then we will provide recommendation to give our client a better idea of the rules and regulations they should abide. Summary of the cases McDonald Corporation and Future Enterprise PTE LTD, core-operating unit of Food Empire Holding Limited, are involved in two law cases during the period of 2003 to 2007. McDonald lost the first case in 2003 as the mark used by Future Enterprise is visually different from McDonald Corporation. Furthermore, Future Enterprise has its eagle device while McDonald Corporation has its golden archer. Therefore, the color scheme, font, and typeface on the mark of the Future Enterprise is very different from the one used by McDonald Corporation. McDonald Corporation sued Future Enterprise again in 2005 for amending the logo of MacCoffee by dropping the eagle device. McDonald Corporation has won this court case against Future Enterprise as there is a higher chance of confusion that will occur in the public and both products names are relate to coffee beverages. Both cases mentioned above are inter-related with each other as both cases involved the Intellectual Property Law of Trade Mark Act (TMA) where s15 of the TMA is highly emphasized. In the midst of both cases, both McDonald Corporation and Future Enterprise have made various appeals to the cases and this shows that both companies have the great intention and desires to protect their own trademarks. The connection between both cases shows that McDonald wanted to monopolize their trademark as far as food and beverages were concerned. Future Enterprise which also wanted to conserve its right of the prefix Mac in the same industry tried its best to maintain its position. Description and Analyze of the Singapore Law Involved In the case study, the Singapore Law that involved is mainly the Trademark and Passing off laws under the Intellectual Property Law. The laws involved can be classified into two main categories of Common Law and Statute Law. Statute Law Involved: (Refer to appendices Section A, A: 1 for definition of Statute Law) The Statute Laws that are applicable in the following case are Section 12(1), Section 15 and Section 23(1) of the Trade Marks Act (Cap 332, 1992 Rev Ed). Below are the descriptions of the different section of laws involved and the reasons why it is involved: Section 12(1): Any person claiming to be the proprietor of a trade mark used or proposed to be used by him who is desirous of registering it shall apply in writing to the Registrar in the prescribed manner for registration in Part A or B of the register. Reason: McDonald Corporation claims that Future Enterprises marks were not made in good faith as it has adopted a naming convention of using the prefix Mac follows by a food or beverage descriptive. This is similar to McDonald Corporation naming convention for their products, which McDonald Corporation feels that Future Enterprise is making use of similar naming convention to promote their products. Section 15: It shall not be lawful to register as a trade mark or part of a trade mark any matter the use of which would, by reason of its being likely to deceive or cause confusion or otherwise, be disentitled to protection in a court of justice, or would be contrary to law or morality, or any scandalous design. Reason: McDonald Corporation claims that the naming convention and the using of the prefix Mac adopted by Future Enterprise would likely to deceive or cause confusion among the public. McDonald Corporation feels that the consumers may be misled thinking that Future Enterprises mark is a series of mark belonging to McDonald Corporation. Section 23(1): Except as provided by section 25, no trade mark shall be registered in respect of any goods or description of goods that is identical with or nearly resembles a trade mark belonging to a different proprietor and already on the register in respect of: The same goods; The same description of goods; or Services or a description of services, which are associated with those goods or goods of that description. Reason: McDonald Corporation claims that Future Enterprises mark is identical and has a near resembled to their trademark. McDonald Corporation also claims that Future Enterprises marks are associated with their goods in respect of restaurant and catering services as McDonald Corporation regards Food and Beverages is associated with hotel or restaurant service. Common Law Involved: (Refer to appendices Section A, A: 2 for definition of Common Law) There are quite a number of Common Laws involved in our case study, we will look into the major cases that are referred to in corresponding to the different sections of Trade Mark Act that are involved. (Refer to appendices Section A, A: 3 for other cases referred (Common Laws)) Case refers corresponding to Section 12: (Refer to appendices Section A, A: 4 for the summary of the case) Tiffany Co v Fabriques de Tabac Reunies SA [1999] 3 SLR 147 (folld) McDonald Corporation referred to the mentioned case as a support to enhance the claim that Future Enterprises mark is not made in good faith, claiming that Future Enterprise was making use of the prefix Mac to promote their products to the public through the association to McDonald Corporation. Case refers corresponding to Section 15: (Refer to appendices Section A, A: 4 for the summary of the case) McDonalds Corporation v McBagels Inc (85 Civ 7868, 10 December 1986) (refd) McDonald Corporation referred to the mentioned case as a support to enhance the claim that using the prefix Mc or Mac as a naming convention will result confusion in the public to think that Future Enterprises products that has the name mark of Mac is associated to McDonald. Dispute and Resolution Mechanism: Singapore has its own hierarchy of Courts when dealing with Criminal and Civil Law. (Refer to appendices Section A, A: 5 for the diagram of Singapores hierarchy of Courts) Singapore Law system is very strict and serious to trade mark offences, it has imposed a fine of up to $100,000 and/or imprisonment for a maximum term of 5 years for criminal liability in infringement act. For civil infringement, the court can award statutory damages of up to $1million. Usually, the High Court in the hierarchy of Singapore Court system will deal with intellectual property disputes and infringement. Referring to the Case Study, the case is dealt in High Court but due to appeal, the case is later brought into the Court of Appeal in resolving the case. Laws and their relevancy to the case Relevant laws and their application: Under s12(1) of the Act that the respondents claim to proprietorship of the three marks was not made in good faith as it had copied the common distinctive prefix of the appellants family of marks, namely, Mc; Under s15 of the Act that the registration of the three marks would likely deceive or cause confusion to the public; and Under s23(1) of the Act that the application marks were identical with or nearly resembled the trade marks belonging to the appellant. Fairness and unfairness: First case: (Refer to appendices Section B, B: 1 for Scenario of first case) It was decided in the first case that McDonald was unable to stop Future Enterprise form producing their products due to infringements of trademarks. I believed that the decision was fair as many evidence was provided to prove that Future Enterprise had made an effort to make their products distinctive to prevent confusion to the public. The evidence, from the article says that the products Future Enterprise produced were packaged with an eagle logo and it was sold mainly at NTUC FairPrice and Mustafa supermarkets in Singapore. This evidence enhances the point that Future Enterprise and McDonald were selling products targeted at different audiences from different markets. Furthermore, the article also showed that Future Enterprise has had its own product logos and color schemes different from McDonald. This point further showed that the marks were different whether it is in the aspects of appearance, sound or concept. Thus, it proves that customers/consumers had more ways to differentiate between the products of these 2 organizations, which further enhance the fairness of the judgment for this case. Last but not least, McDonald further protested that it had spent millions of dollars to create goodwill for it Mc series of marks, but evidence showed from the article says that Future Enterprise had also spent substantial time and resources in order to gain recognition from global market leaders. Therefore, it is fair to say that Future Enterprise did not cause loss whether in goodwill or financial damages, thus I think it is fair to say that fair judgment were made in this case. Second case: (Refer to appendices Section B, B: 2 for Scenario of second case) In the second case, Future Enterprise was brought up to court by McDonald again as they wanted to update their product design by dropping off their eagle logo. McDonald felt that their marks and naming conventions would be relatively similar which could cause confusion if Future Enterprise were to take out the distinctive eagle logo. Evidence from the article says that the two names sounded and looked too alike, and a substantial amount of average Singaporean would be confused with these two products. And also, the concept too was proved to be similar whether it is the products they are selling or the locations that they are selling the products. But, in our own opinion, we felt that there was unfairness presented in this judgment. In the first Court case between McDonald and Future Enterprise, it was judged that there were too many differences between McDonald and Future Enterprise whether it is in their logo, the products they sells or the audience they targeted. Thus, MacCoffee was able to be registered as a trademark and McDonalds appeal were dismissed. Yet, in the second court case, Future Enterprise loses the chance for its MacCoffee to be registered as a trademark name as they decided to drop their distinctive eagle logo. The first case stated that there were unanimous decisions in believing that products from Future Enterprise were not similar, whether in visual, sounds or concept, in comparison with products from McDonald. And also, evidence from the first case stated that the audience they targeted was remarkably different and the products they sold were also different. The judgment of the second case said that their marks were too similar and it would cause confusion after they drop the eagle logo. The appeals were dismissed with $10,000 payment made from Future Enterprise to McDonald. We felt that this judgment were unfair as there were contradictions which existed within this two cases. The products they sold were relatively different, ready-to-drink beverages from McCafe, and 3-in-1 coffee mix from MacCoffee. This presented a huge contrast between the products sold by the 2 organizations. Also, since it was decided in the first court case that the logos, type font, color schemes and targeted audiences were different for products of this 2 organizations, it should be brought up in the second case too in order to ensure fairness in this case. Thus they should take it into consideration of all these differences in the second court case rather than just concentrating on the similarities caused by the removed logos. Steps to further protect intellectual property rights For McDonald Corporation: Increase the monopolization of the prefix Mc into other service area that their business might want to expand into or have influence on. This is because the use of Mc is only subjected to McDonald in hotel and restaurant service and they might consider the use of this prefix into other service area thus, McDonald can maintain the rights of this prefix in other areas and future companies wont make use of the prefix in the same service area. For Food Empire Holdings: Food Empire Holdings could distinguish itself to McDonalds on the MacCoffee and McCafe by using back their earlier registered mark which appears below an eagle device, on its coffee products. This eagle device can play a part in determining whether the application mark is the same as McDonalds. (Refer to appendices Section B, B: 1 for the picture of Food Empire packaging) Recommendation As a consultant engaged by a big advertising company Do-It-Right Limited, we are responsible to report on the state of intellectual property protection in Singapore and to generally advise them whether there is an inherent and prevailing culture that respects other persons intellectual property rights. Thus, to start with it, we will recommend Do-It-Right Limited Company to advice their multinational clients to understand their own country intellectual property laws and the procedures of registering the trademark. In Singapore Intellectual Property Law, it is categorized into 6 main areas of: Copyright and Neighboring Rights, Industrial Designs, Patents, Confidential Information/Trade Secrets, Trade Marks and Passing Off. These are the 6 main areas under that Intellectual Property Law where the client ought to have a general knowledge of as understanding the laws in each area will be able to help clients to know the ways or methods to safeguard their intellectual properties by knowing which the areas of laws they should look into. To further protect clients intellectual property rights, it is a best advice for client to register their product. For Example: If an organization know that their property or design can be register under the Trademark protection, it is best to register in order to be under law of protection instead of limited protection. This is to ensure when an issue arise of a rival company copying the organization product or design. Organization in this case can use passing off law to protect their rights but this will result them to have limit law of protection if they fail to register their product design. Moreover, Trademark Law offer a great degree of protection comparing to Passing Off Law as Passing off Law require the breaching of Goodwill, Misrepresentations and Damage in order for the Law to take into consideration or effect. Thus in conclusion, it is important for Client to register their product or design under the Intellectual Property Law of protection to have more coverage of protection Lastly, we will also advice them to research on their competitors logo and name to avoid any misinterpretation and misunderstand of their own logo and name to their competitors. It is strongly recommended to use a unique and distinct design for their logo and name, which will lessen the chances of their competitors imitating their name and logo. Conclusion Through our case study on Mc Donald Corporation and Future Enterprise, we have a deep understanding about Intellectual Property Law in Singapore and how it can truly save guard our own personal property. We are also able to analyze the cases and discuss whether the Singapore Courts had made a right judgment. We had gained knowledge of Singapore Courts dealing with cases that involved the Intellectual Property Rights and know the importance of Intellectual Property that under the coverage of law to protect the important asset of an organization. References 1McDonalds Corp v Future Enterprises Pte Ltd 2Food Empire Holdings Ltd 3 McDonalds Wikipedia, the free encyclopedia 4 Welcome to McDonalds 5 McDonalds Singapore 6 Singapore Intellectual Property Law#section5 7 Trademark Wikipedia, the free encyclopedia 8 Passing off Wikipedia, the free encyclopedia 9 McDonalds Corp v Future Enterprises Pte Ltd 10 Rules of Court Appendices Extra Information Section A: A: 1 Statute Law Statue Law is written law that is created by governing authority like the parliament in the form of legislation to state out the civil order of the country and to implement and clarify the policies and operations of the government. Statute Law is also the law that state the consequences or punishments for committing a certain criminal or civil crime such as the Trademark Act or Passing off Act; new law can be introduced and existing law can be taken away in order to accommodate to the nation. A: 2 Common Law Common Law is unstated or unwritten law that is created by judges through court decisions. The decisions made by the judges on current case will depend on the decisions made in similar previous cases that took place. In other word, similar infringements and disputes, that have taken place in previous cases, will result the current case to follow the decisions and reasoning that being used. Common Law system is complicated, as the de cisions made in previous cases will affect the law in future cases and is totally distinguish from Statute Law. Moreover, the decisions made are bounded within a limited given jurisdiction. E.g. Decisions made in higher court such as Court of Appeal will affect the decisions in lower court. A: 3 Case(s) referred to (Common Law): Australian Woollen Mills Limited v F S Walton and Company Limited [1937] 58 CLR 641 (refd) Auvi Pte Ltd v Seah Siew Tee [1992] 1 SLR 639 (folld) Bali Trade Mark [1969] RPC 472 (refd) Beck Koller Company (England) Limited, In the Matter of an Application by [1947] 64 RPC 76 (fold) Brown Shoe Company Inc, Application by [1959] RPC 29 (folld) Carnival Cruise Lines Inc v Sitmar Cruises Ltd [1994] 120 ALR 495 (folld) Compatibility Research Ltd v Computer Psyche Company Ltd [1967] FSR 63 (refd) Future enterprise Pte Ltd v Tong Seng Produce Pte Ltd [1998] 1 SLR 1012 (refd) Genette Trade Mark [1968] RPC 148 (folld) Harrods Limited v Harrodian School Limited [1996] RPC 697 (refd) Karu Pty Ltd v Jose [1994] 30 IPR 407 (folld) Kellogg Co v Pacific Food Products Sdn Bhd [1999] 2 SLR 651 (folld) Lever Brothers Ltd v Bedingfield [1899] 16 RPC 3 (folld) Lifestyle 1.99 Pte Ltd v S$1.99 Pte Ltd [2000] 2 SLR 766 (folld) McDonalds Corporation v McBagels Inc (85 Civ 7868, 10 December 1986) (refd) McIndians, In the matter of an application to register the mark (UK Patent Office 16 August 1996)(refd) McMint, Opposition by McDonalds Corporation to the registration of the trademark (Australian Trade Mark Office, 7 November 1997) (folld) McSalad and McFresh, Opposition by McDonalds Corporation to the registration of the trademark (Australian Trade Mark Office, 1 May 2000) (not folld) McVeg, Opposition by McDonalds Corporation to the registration of the trademark (Australian Trade Mark Office, 10 November 1997) (folld) PB Foods Ltd v Malanda DairyFoods Ltd (1999) 47 IPR 47 (distd) Pianotist Company, In the Matter of an Application by (1906) 23 RPC 774 (folld) SEMIGRES Trade Mark [1979] RPC 330 (folld) Shell Co of Australia Ltd v Esso Standard Oil (Australia) Ltd (1963) 109 CLR 407 (folld) Shell Co of Australian Ltd v Rohm Haas Co (1949) 78 CLR 601 (refd) Smith, Hayden Coy Ld, In the Matter of an Application by (1946) 63 RPC 97 (refd) Soldan Holding + Bonbonspezialitaeten GmbH, Re Application by (Singapore Trade Marks Registry, 20 July 2001) (refd) Sports Cafà © Ltd b Registrar of Trade Marks (1998) 42 IPR 552 (folld) Super Coffeemix Manufacturing Ltd v Unico Trading Pte Ltd [2000] 3 SLR 145 (folld) Tiffany Co v Fabriques de Tabac Reunies SA [1999] 3 SLR 147 (folld) UNIMAX Trade Mark [1979] RPC 469 (folld) Vitamins Lds Application, In the Matter of [1956] RPC 1 (folld) Wagamama Ltd v City Center Restaurants plc [1995] FSR 713 (refd) Yuen Yu Kwan Frank v McDonalds Corporation [2001] WL 1422899 (refd) A:4 Summary of cases for Common Laws Summary of Case refers corresponding to Section 12: Tiffany Co opposed the registration of the mark Tiffany by Fabriques de Tabac Reunies SA on cigarettes though; Tiffany Co has no monopoly in cigarettes industries. This may results in confusion as the entire word mark Tiffany was being copied over and the public might think that the cigarettes sold is produced or has connection to Tiffany Co upon seeing the Tiffany band of cigarettes. Summary of Case refers corresponding to Section 15: McDonald Corporation objected the use of McBagel in bagel bakery restaurant, as it would create confusion in public that people might think that McBagel is somehow associated with McDonald Corporation. Moreover, a survey was conducted and numerous people believed that McBagel was associated to McDonald Corporation due to the use of the prefix Mc. A.5 Diagram of Singapores hierarchy of Courts Section B: B: 1 Scenario of first case: McDonald had wanted to stop listed Future Enterprises from distributing products named MacNoodles, MacTea and MacChocolate. However, the court of appeal decided in a unanimous decision that the three trademarks were not deceptively similar to McDonalds Mac or Mc prefix. Thus in this case, the laws of protecting trademarks did not help McDonald to stop Future Enterprise from distributing their products, and also Future Enterprise were able to win this case as they did not breach the law of passing off. B: 2 Scenario of Second case: The dispute continues as Future Enterprise, a subsidiary and core unit of listed Food Empire Holding decided to updates it product design, MacCoffee to drop its original eagle design. McDonald objected as the similarity now existed when Future Enterprise decides to take out its distinct eagle design. After objection arose, Future Enterprise appealed for the MacCoffee brand to be registered as trademark, which in the end the appeal was dismissed. The laws of protecting trademark in this case were being carried out. MacCoffee were not distinct enough to be registered as a trademark, thus the appeal was dismissed. Also, after removing the eagle design, it was judged that goodwill was breach in terms of causing confusion to the public with similar products. Thus McDonald had successfully won this case with the appeal and Future Enterprise appeals were all dismissed and they were to pay a sum of $10,000 to McDonald to cover their loss. Section C: C: 1 Pictures of Food Empire MacCoffe packaging Old Packaging New Packaging Schedule of Meeting Date Discussion 28th May 2008 Analyze the cases Facts Inter-relationship Tasks allocated to each of the members 30th May 2008 Discuss the research done Singapore Laws (Statute Law Common Law) Singapore Courts Intellectual Property Rights Started the report writing 5th June 2008 Continuation of the report Modification of report Error Checking Rephrasing 9th June 2008 Finalization of the report Work Plan 3.1 Description of Assignment The objective for this final report gives us more understanding of the Singapore Laws that can be applied to these two cases. We are able to apply our basic knowledge learned in the lecture to discuss whether the cases had been judge fairly. 3.2 Team Members Nur Afidah Binte Afandi, Mark Heng Kok Hoong, Teo Lay Hoon, Goh Kok Jui Kelvin, Chai Guo Wei Problems encountered and Solutions 4.1 Problem: Time Consume Solution: Planning out the schedule what we should do first and what should we do next helps to cut down the time wastage. Analysis of Singapores Intellectual Property Laws Analysis of Singapores Intellectual Property Laws The Issue of Intellectual Property Protection From the previous assignment, we have look into the cases involving McDonald Corporation and Future Enterprise PTE LTD, we have also introduced the basic intellectual property laws and how they are inter-related to one another. In this assignment, we will analyze the Singapore Laws that is related to the cases involved, and then we will provide recommendation to give our client a better idea of the rules and regulations they should abide. Summary of the cases McDonald Corporation and Future Enterprise PTE LTD, core-operating unit of Food Empire Holding Limited, are involved in two law cases during the period of 2003 to 2007. McDonald lost the first case in 2003 as the mark used by Future Enterprise is visually different from McDonald Corporation. Furthermore, Future Enterprise has its eagle device while McDonald Corporation has its golden archer. Therefore, the color scheme, font, and typeface on the mark of the Future Enterprise is very different from the one used by McDonald Corporation. McDonald Corporation sued Future Enterprise again in 2005 for amending the logo of MacCoffee by dropping the eagle device. McDonald Corporation has won this court case against Future Enterprise as there is a higher chance of confusion that will occur in the public and both products names are relate to coffee beverages. Both cases mentioned above are inter-related with each other as both cases involved the Intellectual Property Law of Trade Mark Act (TMA) where s15 of the TMA is highly emphasized. In the midst of both cases, both McDonald Corporation and Future Enterprise have made various appeals to the cases and this shows that both companies have the great intention and desires to protect their own trademarks. The connection between both cases shows that McDonald wanted to monopolize their trademark as far as food and beverages were concerned. Future Enterprise which also wanted to conserve its right of the prefix Mac in the same industry tried its best to maintain its position. Description and Analyze of the Singapore Law Involved In the case study, the Singapore Law that involved is mainly the Trademark and Passing off laws under the Intellectual Property Law. The laws involved can be classified into two main categories of Common Law and Statute Law. Statute Law Involved: (Refer to appendices Section A, A: 1 for definition of Statute Law) The Statute Laws that are applicable in the following case are Section 12(1), Section 15 and Section 23(1) of the Trade Marks Act (Cap 332, 1992 Rev Ed). Below are the descriptions of the different section of laws involved and the reasons why it is involved: Section 12(1): Any person claiming to be the proprietor of a trade mark used or proposed to be used by him who is desirous of registering it shall apply in writing to the Registrar in the prescribed manner for registration in Part A or B of the register. Reason: McDonald Corporation claims that Future Enterprises marks were not made in good faith as it has adopted a naming convention of using the prefix Mac follows by a food or beverage descriptive. This is similar to McDonald Corporation naming convention for their products, which McDonald Corporation feels that Future Enterprise is making use of similar naming convention to promote their products. Section 15: It shall not be lawful to register as a trade mark or part of a trade mark any matter the use of which would, by reason of its being likely to deceive or cause confusion or otherwise, be disentitled to protection in a court of justice, or would be contrary to law or morality, or any scandalous design. Reason: McDonald Corporation claims that the naming convention and the using of the prefix Mac adopted by Future Enterprise would likely to deceive or cause confusion among the public. McDonald Corporation feels that the consumers may be misled thinking that Future Enterprises mark is a series of mark belonging to McDonald Corporation. Section 23(1): Except as provided by section 25, no trade mark shall be registered in respect of any goods or description of goods that is identical with or nearly resembles a trade mark belonging to a different proprietor and already on the register in respect of: The same goods; The same description of goods; or Services or a description of services, which are associated with those goods or goods of that description. Reason: McDonald Corporation claims that Future Enterprises mark is identical and has a near resembled to their trademark. McDonald Corporation also claims that Future Enterprises marks are associated with their goods in respect of restaurant and catering services as McDonald Corporation regards Food and Beverages is associated with hotel or restaurant service. Common Law Involved: (Refer to appendices Section A, A: 2 for definition of Common Law) There are quite a number of Common Laws involved in our case study, we will look into the major cases that are referred to in corresponding to the different sections of Trade Mark Act that are involved. (Refer to appendices Section A, A: 3 for other cases referred (Common Laws)) Case refers corresponding to Section 12: (Refer to appendices Section A, A: 4 for the summary of the case) Tiffany Co v Fabriques de Tabac Reunies SA [1999] 3 SLR 147 (folld) McDonald Corporation referred to the mentioned case as a support to enhance the claim that Future Enterprises mark is not made in good faith, claiming that Future Enterprise was making use of the prefix Mac to promote their products to the public through the association to McDonald Corporation. Case refers corresponding to Section 15: (Refer to appendices Section A, A: 4 for the summary of the case) McDonalds Corporation v McBagels Inc (85 Civ 7868, 10 December 1986) (refd) McDonald Corporation referred to the mentioned case as a support to enhance the claim that using the prefix Mc or Mac as a naming convention will result confusion in the public to think that Future Enterprises products that has the name mark of Mac is associated to McDonald. Dispute and Resolution Mechanism: Singapore has its own hierarchy of Courts when dealing with Criminal and Civil Law. (Refer to appendices Section A, A: 5 for the diagram of Singapores hierarchy of Courts) Singapore Law system is very strict and serious to trade mark offences, it has imposed a fine of up to $100,000 and/or imprisonment for a maximum term of 5 years for criminal liability in infringement act. For civil infringement, the court can award statutory damages of up to $1million. Usually, the High Court in the hierarchy of Singapore Court system will deal with intellectual property disputes and infringement. Referring to the Case Study, the case is dealt in High Court but due to appeal, the case is later brought into the Court of Appeal in resolving the case. Laws and their relevancy to the case Relevant laws and their application: Under s12(1) of the Act that the respondents claim to proprietorship of the three marks was not made in good faith as it had copied the common distinctive prefix of the appellants family of marks, namely, Mc; Under s15 of the Act that the registration of the three marks would likely deceive or cause confusion to the public; and Under s23(1) of the Act that the application marks were identical with or nearly resembled the trade marks belonging to the appellant. Fairness and unfairness: First case: (Refer to appendices Section B, B: 1 for Scenario of first case) It was decided in the first case that McDonald was unable to stop Future Enterprise form producing their products due to infringements of trademarks. I believed that the decision was fair as many evidence was provided to prove that Future Enterprise had made an effort to make their products distinctive to prevent confusion to the public. The evidence, from the article says that the products Future Enterprise produced were packaged with an eagle logo and it was sold mainly at NTUC FairPrice and Mustafa supermarkets in Singapore. This evidence enhances the point that Future Enterprise and McDonald were selling products targeted at different audiences from different markets. Furthermore, the article also showed that Future Enterprise has had its own product logos and color schemes different from McDonald. This point further showed that the marks were different whether it is in the aspects of appearance, sound or concept. Thus, it proves that customers/consumers had more ways to differentiate between the products of these 2 organizations, which further enhance the fairness of the judgment for this case. Last but not least, McDonald further protested that it had spent millions of dollars to create goodwill for it Mc series of marks, but evidence showed from the article says that Future Enterprise had also spent substantial time and resources in order to gain recognition from global market leaders. Therefore, it is fair to say that Future Enterprise did not cause loss whether in goodwill or financial damages, thus I think it is fair to say that fair judgment were made in this case. Second case: (Refer to appendices Section B, B: 2 for Scenario of second case) In the second case, Future Enterprise was brought up to court by McDonald again as they wanted to update their product design by dropping off their eagle logo. McDonald felt that their marks and naming conventions would be relatively similar which could cause confusion if Future Enterprise were to take out the distinctive eagle logo. Evidence from the article says that the two names sounded and looked too alike, and a substantial amount of average Singaporean would be confused with these two products. And also, the concept too was proved to be similar whether it is the products they are selling or the locations that they are selling the products. But, in our own opinion, we felt that there was unfairness presented in this judgment. In the first Court case between McDonald and Future Enterprise, it was judged that there were too many differences between McDonald and Future Enterprise whether it is in their logo, the products they sells or the audience they targeted. Thus, MacCoffee was able to be registered as a trademark and McDonalds appeal were dismissed. Yet, in the second court case, Future Enterprise loses the chance for its MacCoffee to be registered as a trademark name as they decided to drop their distinctive eagle logo. The first case stated that there were unanimous decisions in believing that products from Future Enterprise were not similar, whether in visual, sounds or concept, in comparison with products from McDonald. And also, evidence from the first case stated that the audience they targeted was remarkably different and the products they sold were also different. The judgment of the second case said that their marks were too similar and it would cause confusion after they drop the eagle logo. The appeals were dismissed with $10,000 payment made from Future Enterprise to McDonald. We felt that this judgment were unfair as there were contradictions which existed within this two cases. The products they sold were relatively different, ready-to-drink beverages from McCafe, and 3-in-1 coffee mix from MacCoffee. This presented a huge contrast between the products sold by the 2 organizations. Also, since it was decided in the first court case that the logos, type font, color schemes and targeted audiences were different for products of this 2 organizations, it should be brought up in the second case too in order to ensure fairness in this case. Thus they should take it into consideration of all these differences in the second court case rather than just concentrating on the similarities caused by the removed logos. Steps to further protect intellectual property rights For McDonald Corporation: Increase the monopolization of the prefix Mc into other service area that their business might want to expand into or have influence on. This is because the use of Mc is only subjected to McDonald in hotel and restaurant service and they might consider the use of this prefix into other service area thus, McDonald can maintain the rights of this prefix in other areas and future companies wont make use of the prefix in the same service area. For Food Empire Holdings: Food Empire Holdings could distinguish itself to McDonalds on the MacCoffee and McCafe by using back their earlier registered mark which appears below an eagle device, on its coffee products. This eagle device can play a part in determining whether the application mark is the same as McDonalds. (Refer to appendices Section B, B: 1 for the picture of Food Empire packaging) Recommendation As a consultant engaged by a big advertising company Do-It-Right Limited, we are responsible to report on the state of intellectual property protection in Singapore and to generally advise them whether there is an inherent and prevailing culture that respects other persons intellectual property rights. Thus, to start with it, we will recommend Do-It-Right Limited Company to advice their multinational clients to understand their own country intellectual property laws and the procedures of registering the trademark. In Singapore Intellectual Property Law, it is categorized into 6 main areas of: Copyright and Neighboring Rights, Industrial Designs, Patents, Confidential Information/Trade Secrets, Trade Marks and Passing Off. These are the 6 main areas under that Intellectual Property Law where the client ought to have a general knowledge of as understanding the laws in each area will be able to help clients to know the ways or methods to safeguard their intellectual properties by knowing which the areas of laws they should look into. To further protect clients intellectual property rights, it is a best advice for client to register their product. For Example: If an organization know that their property or design can be register under the Trademark protection, it is best to register in order to be under law of protection instead of limited protection. This is to ensure when an issue arise of a rival company copying the organization product or design. Organization in this case can use passing off law to protect their rights but this will result them to have limit law of protection if they fail to register their product design. Moreover, Trademark Law offer a great degree of protection comparing to Passing Off Law as Passing off Law require the breaching of Goodwill, Misrepresentations and Damage in order for the Law to take into consideration or effect. Thus in conclusion, it is important for Client to register their product or design under the Intellectual Property Law of protection to have more coverage of protection Lastly, we will also advice them to research on their competitors logo and name to avoid any misinterpretation and misunderstand of their own logo and name to their competitors. It is strongly recommended to use a unique and distinct design for their logo and name, which will lessen the chances of their competitors imitating their name and logo. Conclusion Through our case study on Mc Donald Corporation and Future Enterprise, we have a deep understanding about Intellectual Property Law in Singapore and how it can truly save guard our own personal property. We are also able to analyze the cases and discuss whether the Singapore Courts had made a right judgment. We had gained knowledge of Singapore Courts dealing with cases that involved the Intellectual Property Rights and know the importance of Intellectual Property that under the coverage of law to protect the important asset of an organization. References 1McDonalds Corp v Future Enterprises Pte Ltd 2Food Empire Holdings Ltd 3 McDonalds Wikipedia, the free encyclopedia 4 Welcome to McDonalds 5 McDonalds Singapore 6 Singapore Intellectual Property Law#section5 7 Trademark Wikipedia, the free encyclopedia 8 Passing off Wikipedia, the free encyclopedia 9 McDonalds Corp v Future Enterprises Pte Ltd 10 Rules of Court Appendices Extra Information Section A: A: 1 Statute Law Statue Law is written law that is created by governing authority like the parliament in the form of legislation to state out the civil order of the country and to implement and clarify the policies and operations of the government. Statute Law is also the law that state the consequences or punishments for committing a certain criminal or civil crime such as the Trademark Act or Passing off Act; new law can be introduced and existing law can be taken away in order to accommodate to the nation. A: 2 Common Law Common Law is unstated or unwritten law that is created by judges through court decisions. The decisions made by the judges on current case will depend on the decisions made in similar previous cases that took place. In other word, similar infringements and disputes, that have taken place in previous cases, will result the current case to follow the decisions and reasoning that being used. Common Law system is complicated, as the de cisions made in previous cases will affect the law in future cases and is totally distinguish from Statute Law. Moreover, the decisions made are bounded within a limited given jurisdiction. E.g. Decisions made in higher court such as Court of Appeal will affect the decisions in lower court. A: 3 Case(s) referred to (Common Law): Australian Woollen Mills Limited v F S Walton and Company Limited [1937] 58 CLR 641 (refd) Auvi Pte Ltd v Seah Siew Tee [1992] 1 SLR 639 (folld) Bali Trade Mark [1969] RPC 472 (refd) Beck Koller Company (England) Limited, In the Matter of an Application by [1947] 64 RPC 76 (fold) Brown Shoe Company Inc, Application by [1959] RPC 29 (folld) Carnival Cruise Lines Inc v Sitmar Cruises Ltd [1994] 120 ALR 495 (folld) Compatibility Research Ltd v Computer Psyche Company Ltd [1967] FSR 63 (refd) Future enterprise Pte Ltd v Tong Seng Produce Pte Ltd [1998] 1 SLR 1012 (refd) Genette Trade Mark [1968] RPC 148 (folld) Harrods Limited v Harrodian School Limited [1996] RPC 697 (refd) Karu Pty Ltd v Jose [1994] 30 IPR 407 (folld) Kellogg Co v Pacific Food Products Sdn Bhd [1999] 2 SLR 651 (folld) Lever Brothers Ltd v Bedingfield [1899] 16 RPC 3 (folld) Lifestyle 1.99 Pte Ltd v S$1.99 Pte Ltd [2000] 2 SLR 766 (folld) McDonalds Corporation v McBagels Inc (85 Civ 7868, 10 December 1986) (refd) McIndians, In the matter of an application to register the mark (UK Patent Office 16 August 1996)(refd) McMint, Opposition by McDonalds Corporation to the registration of the trademark (Australian Trade Mark Office, 7 November 1997) (folld) McSalad and McFresh, Opposition by McDonalds Corporation to the registration of the trademark (Australian Trade Mark Office, 1 May 2000) (not folld) McVeg, Opposition by McDonalds Corporation to the registration of the trademark (Australian Trade Mark Office, 10 November 1997) (folld) PB Foods Ltd v Malanda DairyFoods Ltd (1999) 47 IPR 47 (distd) Pianotist Company, In the Matter of an Application by (1906) 23 RPC 774 (folld) SEMIGRES Trade Mark [1979] RPC 330 (folld) Shell Co of Australia Ltd v Esso Standard Oil (Australia) Ltd (1963) 109 CLR 407 (folld) Shell Co of Australian Ltd v Rohm Haas Co (1949) 78 CLR 601 (refd) Smith, Hayden Coy Ld, In the Matter of an Application by (1946) 63 RPC 97 (refd) Soldan Holding + Bonbonspezialitaeten GmbH, Re Application by (Singapore Trade Marks Registry, 20 July 2001) (refd) Sports Cafà © Ltd b Registrar of Trade Marks (1998) 42 IPR 552 (folld) Super Coffeemix Manufacturing Ltd v Unico Trading Pte Ltd [2000] 3 SLR 145 (folld) Tiffany Co v Fabriques de Tabac Reunies SA [1999] 3 SLR 147 (folld) UNIMAX Trade Mark [1979] RPC 469 (folld) Vitamins Lds Application, In the Matter of [1956] RPC 1 (folld) Wagamama Ltd v City Center Restaurants plc [1995] FSR 713 (refd) Yuen Yu Kwan Frank v McDonalds Corporation [2001] WL 1422899 (refd) A:4 Summary of cases for Common Laws Summary of Case refers corresponding to Section 12: Tiffany Co opposed the registration of the mark Tiffany by Fabriques de Tabac Reunies SA on cigarettes though; Tiffany Co has no monopoly in cigarettes industries. This may results in confusion as the entire word mark Tiffany was being copied over and the public might think that the cigarettes sold is produced or has connection to Tiffany Co upon seeing the Tiffany band of cigarettes. Summary of Case refers corresponding to Section 15: McDonald Corporation objected the use of McBagel in bagel bakery restaurant, as it would create confusion in public that people might think that McBagel is somehow associated with McDonald Corporation. Moreover, a survey was conducted and numerous people believed that McBagel was associated to McDonald Corporation due to the use of the prefix Mc. A.5 Diagram of Singapores hierarchy of Courts Section B: B: 1 Scenario of first case: McDonald had wanted to stop listed Future Enterprises from distributing products named MacNoodles, MacTea and MacChocolate. However, the court of appeal decided in a unanimous decision that the three trademarks were not deceptively similar to McDonalds Mac or Mc prefix. Thus in this case, the laws of protecting trademarks did not help McDonald to stop Future Enterprise from distributing their products, and also Future Enterprise were able to win this case as they did not breach the law of passing off. B: 2 Scenario of Second case: The dispute continues as Future Enterprise, a subsidiary and core unit of listed Food Empire Holding decided to updates it product design, MacCoffee to drop its original eagle design. McDonald objected as the similarity now existed when Future Enterprise decides to take out its distinct eagle design. After objection arose, Future Enterprise appealed for the MacCoffee brand to be registered as trademark, which in the end the appeal was dismissed. The laws of protecting trademark in this case were being carried out. MacCoffee were not distinct enough to be registered as a trademark, thus the appeal was dismissed. Also, after removing the eagle design, it was judged that goodwill was breach in terms of causing confusion to the public with similar products. Thus McDonald had successfully won this case with the appeal and Future Enterprise appeals were all dismissed and they were to pay a sum of $10,000 to McDonald to cover their loss. Section C: C: 1 Pictures of Food Empire MacCoffe packaging Old Packaging New Packaging Schedule of Meeting Date Discussion 28th May 2008 Analyze the cases Facts Inter-relationship Tasks allocated to each of the members 30th May 2008 Discuss the research done Singapore Laws (Statute Law Common Law) Singapore Courts Intellectual Property Rights Started the report writing 5th June 2008 Continuation of the report Modification of report Error Checking Rephrasing 9th June 2008 Finalization of the report Work Plan 3.1 Description of Assignment The objective for this final report gives us more understanding of the Singapore Laws that can be applied to these two cases. We are able to apply our basic knowledge learned in the lecture to discuss whether the cases had been judge fairly. 3.2 Team Members Nur Afidah Binte Afandi, Mark Heng Kok Hoong, Teo Lay Hoon, Goh Kok Jui Kelvin, Chai Guo Wei Problems encountered and Solutions 4.1 Problem: Time Consume Solution: Planning out the schedule what we should do first and what should we do next helps to cut down the time wastage.

divorce Essay -- essays research papers

Divorce  Ã‚  Ã‚  Ã‚  Ã‚     Ã‚  Ã‚  Ã‚  Ã‚  Divorce rates in the United States have increased dramatically over the past 25 years. Researchers have found that more than 40 percent of all marriages among young Americans end in divorce resulting in its acceptance in today’s family structure and behavior (â€Å"Demographics†). Divorce has become such a painless process that the moment a couple hits the rocks it is easier and less stressful for them to divorce rather than going through the trouble of trying to work things out. However, even though a couple may be unhappy getting a divorce is not always the best option because of its unfortunate effects on all those involved.   Ã‚  Ã‚  Ã‚  Ã‚  The most common hardship that married couples experience when a divorce takes place is caring for any children involved. One of the hardest things for a child to go through when they are young is divorce. It effects them in so many ways that they do not have control over. Sometimes these children have more difficulty in school, more behavior problems, more negative self-concepts, more problems with peers, and more trouble getting along with their parents. The parental support needed during these times is often lacking, because parents are so wrapped up in their own problems during a divorce that their ability to function as parents diminishes (Wallerstein and Blakeslee 125). All of these issues affect children because of the stress, conflict, and difficulty th...

Roles of Women in the Early Europe

In early, medieval Europe, everyday life and the duties of people were greatly different than they are today. Obviously, there was no technology and life was a lot simpler. However, some of the former ways of life are not always praised as something good. For example, women during the time were treated very inadequately. Yes, this has happened in just about every society in history, but it seems like most women during this period were used and disrespected more notably than in others. In Philippa Gregory’s novel, The Other Boleyn Girl, this theme is seen greatly. In the story, the narrator, Mary, is defending her sister, Anne, after she is sentenced to death for producing an incest baby instead of a son for the king, King Henry. Mary, pleading for her sister, yells out â€Å"We did nothing more than that was ordered. We only ever did as we were commanded. Is she to die for being an obedient daughter? †(Pg. 650). During this time period, many women in the royal courts were used to produce male heirs, mainly to keep the name of the king and the family continuing. I strongly agree with the quote by Mary because killing a human being for a reason such as that is immoral and women are not just objects for men. In the story, Henry did have a choice to kill Anne or not, but I understood why he did end up taking her life. When Mary claims that the two Boleyn girls â€Å"did as they were commanded†, something drew to my attention. Mary was completely valid in saying that. Anne and Mary were mainly just used to birth a son. Several members of their family, including their uncle, demanded for one of them to bed the king. At first it was Mary who had an affair with the already married king. Even though Mary produces two children, one being a boy, it is not legitimate due to the fact that Mary is merely a mistress and not the queen. When he was done with Mary, King Henry moved on to Anne, who was more determined to become queen and have the child be legitimate. She eventually becomes the Queen of England, but it is proven that Henry was just using her for her child after he kills her. I do not agree with this concept by any means. However, this was a common role for women at the time. Kings and royal families were so concerned about keeping their name going in the court that they would risk the lives of women in doing so. You would think that one of King Henry’s seven wives would pick up on this trend at some point, or any woman in any court for that matter. It seems like women were treated as objects in the royal courts. The women were the croc pot that prepared the kings’ stew. And, if that stew was not one hundred percent correct, the croc pot would be set aside and replaced with a new one. I do not feel this is morally acceptable at all. I understand that kings wanted to have a male heir to keep the name going, but they should have had to complete that task so viciously. In this case, I do not agree with King Henry’s tactics at all, but I understand why he killed Anne. I believe that it was so common to banish or kill a wife for such crimes as adultery or incest that Henry had no choice, but to kill her. He was a very strong, determined man with a bold reputation for being so. By beheading Anne, he was retaining his reputation, but also proved that it was never true love between him and Anne. He had women lined up to take the place of Anne. â€Å"He is at her house every night. He is as he was in the old days, when it was her. † (656). This quote just proves the fact that Henry wanted nothing more of Anne than a son, which is a common theme of the roles of women during this time period. I do not agree with the concept of using women for the production of male heirs because it is immoral and women should not be viewed as objects. That is a major theme in The Other Boleyn Girl by Philippa Gregory. It is prevalent throughout the story and in history that King Henry of England used women as devices used to produce male heirs. This was also seen throughout history. Kings were so determined to keep their name going that they would execute their wives for such faults as not producing a boy, or in this case, birthing an incest baby. The kings had to maintain a strong reputation. I understand that, but do not agree with how they did so.

Treatment Rehabilitation of Grade II Medial Collateral Ligament (MCL) Injury The WritePass Journal

Treatment Rehabilitation of Grade II Medial Collateral Ligament (MCL) Injury Introduction Treatment Rehabilitation of Grade II Medial Collateral Ligament (MCL) Injury IntroductionGeneral Knee AnatomySpecific   Medial Collateral Ligament AnatomyBiomechanicsMechanism of InjuryPhysical Examination/Clinical AssessmentRadiographClassification of InjuryTreatment and Rehabilitation ObjectivesInflammatory Phase (up to 72 hours post injury)Proliferation Phase (3-21 days post injury)Increased range of motion was also enhanced by using a stationary bicycle (Wilk et al., 1996).A.  Ã‚  Ã‚  Ã‚  Ã‚   Basic ExercisesProprioceptionConclusion/SummaryReferencesRelated Introduction The superficial medial collateral ligament (MCL), and other medial knee stabilisers (most notably the deep medial collateral ligament and the posterior oblique ligament) are the most commonly injured ligamentous structures of the knee (Grood, et al., 1981; Hughston, 1981; Phisitkul, et al., 2006; van der Esch, et al., 2006). The majority of MCL tears are isolated and predominantly occur in young people participating in sports activities. Typically, the mechanism of injury involves valgus knee loading, external rotation or a combined force vector- particularly prevalent in sports such as football and skiing which involve these type of forces and repetitive knee flexion (Peterson, et al., 2000). In the United States, occurence of these types of injuries to the knee has been reported to be 0.24 per 1000 during any given 12 month cycle and to be twice as high in males 0.36 compared with 0.18 in females (Daniel, et al., 2003). In actual fact, the incidence of these types of injury is probably much higher than reported as many minor MCL injuries are never even assessed or treated by medical personnel. In terms of treatment, the approach to medial knee injuries has changed dramatically over recent years. As the understanding of the anatomy, biomechanics, and causes of medial knee injuries has evolved, as has the treatment.   Whilst in the 1970’s and 1980’s surgical treatment for MCL injuries was common place, today most MCL injuries are treated conservatively with early rehabilitation (Phisitkul, et al., 2006). In general, all isolated Grade I and II tears and even the majority of Grade III tears can be treated non-operatively with a supervised, functional, rehabilitation program. Excellent results can be expected with return to full pre-injury activity level being the norm (Bradley, et al., 2006). This paper will research and interpret some of the relevant literature that is available to us, with the aim of developing and implementing a functional rehabilitation plan (in keeping with the principles of soft tissue healing) that is suitable for the treatment of a Grade II MCL injury of a 33-year-old, male, semi-professional footballer (the patient). General Knee Anatomy The knee joint, is the largest and most complex synovial joint of the human body (Bradley, et al., 2006). Figure 1: Anterior view of the patellofemoral joint. Hawkins (2009) The patella, patella ligament and femur combine to form the patellofemoral joint (Saladin, 2001). The patella itself is a triangular-shaped sesamoid bone that is attached to the quadriceps tendon. This tendon inserts into the trochlear groove on the femur and primarily acts to increase the ‘mechanical advantage’ of the quadriceps muscle group (Hamill Knutzen, 1995). The lateral and posterior aspects of the knee joint are encapsulated by a joint capsule whilst the anterior section of the knee is protected by the patella ligament (and its retinacula). The quadriceps and the hamstrings are the prime movers of the knee joint knee ‘extensors’ and ‘flexors’ respectively. The quadricep group of muscles are located on the anterior part of the thigh and comprise of the rectus femoris, vastus lateralis, vastus medialis, and vastus intermedius. They converge on the patella tendon, travel over the patella and insert onto the tibial tuberosity. In addition to knee extension, the quadriceps group of muscles (in combination with the iliopsoas) are also responsible for flexion of the hip (Saladin, 2001). The hamstring muscles are found on the posterior section of the thigh and comprise of the biceps femoris, semimembranosus, and semitendinosus. They are responsible for the flexion of the knee joint and (together with the gluteus maximus) the extension of the hip joint (Saladin, 2001). The main stabilisers of the knee are the quadriceps tendon (to front of the thigh) and the semimembranosus tendon (at the back of the thigh) (Saladin, 2001). The medial and lateral collateral ligaments are primarily responsible for preventing the knee from rotating during extension (Saladin, 2001). The anterior cruciate ligament and the posterior cruciate ligament stop anterior and posterior translation of the tibia relative to the femur (Saladin, 2001). Specific   Medial Collateral Ligament Anatomy Medial knee stability is provided, for the most part, by its ‘medial static’ and its ‘dynamic’ stabilisers. The medial static stabilisers, which work as an integrated unit, are the superficial MCL, the posterior oblique ligament and the middle third of the deep MCL. The dynamic stabilisers are the per anserinus tendons most notably the semimembranosus tendon (Peterson Renstrom, 2001). The superficial MCL is, on average, 11cm long and 0.5cm wide. It originates from the medial femoral condyle (anterior to the tubercle) and travels, distally, to insert 5-7cm below the joint line on the anteromedial tibia (just below the insertion of pes anserinus tendons). The anterior fibres of the superficial MCL tense during knee flexion whilst its posterior fibres slacken. The superficial MCL is tight during external rotation of the knee (Peterson Renstrom, 2001). The middle third of the deep MCL is a short structure about 2-3cm long and is attached to the meniscus underlying the MCL. This part of the ligament is relatively ‘slack’ to facilitate knee motion whilst short enough to hold the meniscus firmly in position. In terms of injury, the deep MCL can be ruptured both proximally and distally to the meniscal attachment (regardless of the location of the tear of the superficial MCL). The posterior oblique ligament is a thick capsular ligament originating just behind the superficial MCL (at the condyle just below the joint line). The posterior oblique ligament becomes ‘slack’ during knee flexion (Peterson Renstrom, 2001). Biomechanics Biomechanical studies show that the MCL’s main function is to resist valgus (outward side motion of the leg) and external rotation forces of the tibia in relation to the femur . The superficial MCL has been found to be responsible for 57% of medial stability at 5Ëš of knee flexion and up to 78% at 30Ëš knee flexion. The deep MCL accounted for 8% at 5Ëš and 4% at 30Ëš whilst the posterior oblique accounted for 18% and 4% respectively. Mechanism of Injury The player reported to the clinic approximately 24 hours after the injury occurred. The player was able to weight bear. When asked how the injury occurred the player stated that he was running at pace to ‘close down an opposing player’ and then described performing a ‘change of direction’ or ‘cutting’ manoeuvre. He stated that as he planted and pushed off his right leg, he experienced a sudden excruciating localised pain and an immediate lack of stability in his right knee. This caused him to collapse. As stated, the primary mechanism of injury to the MCL is most commonly a valgus stress (Fetto, et al., 1978). However, due to the position of the knee and the force vectors involved, a combined flexion/valgus/external rotation injury is usually the end result (Hayes, et al., 2000). The vast majority of MCL injuries are from a lateral force to the distal femur with the foot being fixed to the ground, although non-contact valgus external rotation injuries are common the latter being particularly prevalent in sports such as football and skiing (Perryman, et al., 2002; Pressman, et al., 2003). Because of the complexities of knee injuries, it is important to perform a complete knee examination in order to rule out other potential problems such as fractures, cruciate ligament tears, menisci ruptures or chondral cartilage damage (Bradley, et al., 2006). Physical Examination/Clinical Assessment The best time for examination of the knee is immediately after the injury before muscle spasm occurs   (Phisitkul, et al., 2006). Unfortunately, as in this case, that is not always feasible. However, a 24 hour period of rest and immobilisation (which the patient undertook) is usually sufficient for muscle spasm to subside and relaxation to occur (Hughston, et al., 1976). This allows an effective examination and assessment of the injury. The injury was examined and assessed through a combination of subjective and objective approaches. Important initial information obtained through speaking with the patient and preliminary observations included the location of pain, the ability to ambulate after the injury, time and onset of swelling, the presence of deformity, and the immediate site of tenderness (Indelicato Linton, 2003). The location of oedema and tenderness can accurately identify the injury site of the superficial collateral ligaments in 64% and 76% of cases respectively (Hughston, et al., 1976). The exact location of injuries of the deep MCL and the posterior oblique ligament are more difficult to palpate because of their deep-seated position, but pain and tenderness in this area can at least indicate the presence of injury to these posteromedial structures (Sims Jacobsen, 2004) On asking the patient to indicate the most painful spot, he pointed to the medial aspect of the right knee joint. The area indicated by the patient suggested injury to the MCL. Contralateral comparison of the knees was carried out in order to identify areas of oedema and/or deformity. Significant swelling and slight discolouration was observed on the medial aspect of the right knee joint. Upon palpation of both knee joints, a noticeable heat differential was felt in the affected area. While keeping the patient relaxed, a valgus stress test   (MCL test) was performed with the knee in 30Ëš of flexion (figure 1), and compared to the contralateral knee as a control. The examination was then repeated with the knee in 0Ëš of flexion to recruit the function of remaining posteromedial structures (figure 2). The valgus stress test proved positive in contralateral comparison in 30Ëš of flexion and negative in 0Ëš of flexion. The absence of laxity in the second test reduced suspicions of any associated injuries to the secondary restraints such as the cruciate ligaments and the posterior capsule. In addition, a number of other tests were carried out to assess whether any injuries, commonly associated with MCL injuries, were prevalent (bone bruises, ACL tears, lateral collateral ligament tears, medial meniscus tears, lateral meniscus tears, and posterior collateral ligament tears). Anteromedial rotatory instability (often present when there is evidence of anterior subluxation of the medial tibial plateau during a valgus stress test with the knee in 30Ëš of flexion) was assessd by performing the anterior drawer test (figure 3) whilst holding the tibia in external rotation. This proved negative and therefore ruled out the possibility of a posterolateral knee injury rather than a medial knee injury. Lachman’s test (figure 4) and the Pivot shift test (figure 5) were also performed to negate the existence of any ACL rupture whilst Murray’s test (figure 6) was carried out to assess the integrity of the Meniscus cartilage. All these tests also proved negative. The results of the assessment supported the initial belief that the patient was suffering a superficial MCL injury with the posterior oblique ligament still intact and no associated damage to either the cruciate ligaments or meniscus cartilage of the knee. Radiograph In accordance with the Ottawa knee rules (Stiell, et al., 1997) it was decided that radiographs were not required for this injury. More recent work has shown the Ottawa knee rules to be very successful in reducing unnecessary radiography, whilst ensuring a high level of recognition fractures (Bachman, 2003). The Ottawa knee rules state that a radiograph is required only in patients who have an acute knee injury with one or more of the following: Age 55 years or older Tenderness at head of fibula Isolated tenderness of patella Inability to flex to 90 ° Inability to bear weight both immediately and in the emergency department Classification of Injury In 1976 (revised in 1994) Hughston standardised MCL injury classification into two related systems the severity system (Grade I, II III) and the laxity system (grade 1+, 2+ 3+). Under this combined classification system, Grade I involves a few damaged fibres resulting in localised tenderness but no instability or laxity. A Grade II injury involves a disruption to substantially more fibres, with more generalised tenderness but still no instability (although it is not uncommon for a degree of laxity with the knee in 30Ëš flexion). A Grade III injury is a complete tear of the ligament with resultant instability and laxity. Grade III injuries are then sub-classified according to the extent of laxity (determined by the amount of absolute joint separation from valgus stress with the knee in 30Ëš of flexion). Grade 1+, 2+, and 3+ laxities indicate 3-5 mm, 6-10 mm, and more than 10 mm of absolute medial separation respectively. Fetto and Marshall (1978) defined Grade I injuries as those without valgus laxity in both 0Ëš and 30Ëš of flexion, Grade II injuries as those with valgus laxity in 30Ëš of flexion but stable in 0Ëš of flexion, and Grade III as those with valgus laxity in both 0Ëš and 30Ëš of flexion. The injury was subsequently classified as an isolated Grade II MCL injury in accordance with Hughston (1976 1994) and Fetto Marshall (1976). Using a full return to sport as an indicator of a successful end point, Ellsasser et al (1974) treated 74 professional football players with incomplete tears of the MCL using a functional rehabilitation program. In this study, a success rate of 98% was found compared with a 74% success rate for a separate group treated surgically. In the non-operative group, return to play occurred between 3 and 8 weeks. Return to play was even quicker in a study by Derscheid and Garrick (1981). They treated football players with Grade I and Grade II injuries with a specific rehabilitation programme. Players with Grade I MCL injuries returned to full play in an average of 10.6 days, whereas those with Grade II MCL injuries returned in an average of just 19.5 days, with neither group showing a propensity for injury reoccurrence. Based on this research, a consensus on the time it would take for the patient to return to full sporting activeity would be 3-8 weeks. Treatment and Rehabilitation Objectives An appropriate treatment and rehabilitation plan is required to restore normal function to the knee joint and the surrounding soft tissues with a view to enabling the patient to return to his sport as early and effectively as possible with no residual symptoms and a minimal risk of injury reoccurrence All soft tissue injuries, regardless of their nature and severity, undergo the same three stages of healing the inflammatory phase, proliferation phase and the remodelling phase. The time required to complete each healing stage is dependent up on the nature and severity of the injury. However, of note, numerous investigations comparing surgical and non-surgical treatment have reported no advantages of surgical intervention over non-surgical intervention (Quarles Hosey, 2004; Phisitkul et al., 2006). The following treatment and rehabilitation plan was designed and implemented to address the needs of the patient. Inflammatory Phase (up to 72 hours post injury) The inflammatory phase is characterised by heat, redness, swelling and pain generally leading to a loss of movement and function. The goals of treatment at this stage were: Protect injury Control oedema Prevent associated muscle atrophy Regain range of motion Increase weight bearing capacity Maintain general fitness/strength P.R.I.C.E (Protection, Rest, Ice, Compression and Elevation) The P.R.I.C.E. regimen is employed following injury with a view to controlling the haemorrhage, decreasing inflammation, reducing tissue metabolism and minimising secondary hypoxic injury, cell debris and oedema.   Research has suggested that the sooner after injury that cold therapy (cryotherapy) is started, then the more beneficial the reduction in metabolism will be (Knight et al., 2000). Elevation has been shown to have a significant effect on reducing effusion (O’Donohue, 1976). The patient reported that he had already applied ice intermittently during the 24 hour period between injury occurrence and assessment approximated to have fulfilled 4 x 20 minute applications of crushed ice at 2 hourly intervals with the knee in an elevated position in line with commonly agreed protocol. He also reprted that he had kept the injured limb elevated for sustained periods. Measurement On inspection the right knee was swollen over the lateral aspect with a small amount of visible bruising. At this time the patient was asked to indicate his level of pain using a visual analogue scale (VAS). Measurement of the girth of the knee was also taken using a tape measure whilst active flexion and was also assessed using a goniometer. These measurements would be continually reassessed throughout the rehabilitation process in order to assess progress and outcomes. Continued active flexion was also encouraged at this time. Simple ‘knee bend and straighten’ exercises, with the patient lying in a supine position on an exercise mat the movement repeated 10-20 times,   3 times a day, with a view to increasing active range of movement (figure 1) . The patient was also instructed in different exercises to maintain cardiovascular fitness and upper body conditioning. The patient also received a massage to the upper and lower leg (particularly the quadriceps group of muscles) in an elevated position using effleurage techniques to aid removal of waste products via the lymphatic system reflexive muscular inhibition of the quadriceps has been thought to be the result of the pain associated with MCL injury (Dixit, et al., 2007). The knee was then strapped. Strapping The knee was strapped to assist healing and reduce the risk of aggravating the injury. The knee was strapped in a position of 30Ëš flexion with the lower leg partially rotated inwards (figure 1). A combination of ‘lower leg and thigh anchors’, ‘medial cross’ and ‘medial straight line’ taping techniques, using   zinc oxide tape and elastic adhesive dressing,   were employed to provide suitable support for the patient and reduce and valgus stress (figure 2). Experience has shown that this type of strapping is preferable to the use of a knee braces in Grade II MCL injuries as the strapping can be re-applied whenever required with the correct level of compression and support required. There is some concern that functional braces may expose athletes to additional risk by imparting a false sense of confidence. It is reported that lower extremity muscle strengthening, flexibility improvements, and technique refinement are more important than functional bracing in treating ligamentous knee injuries (Christenson, 2010). The patient was advised to continue elevating the limb, as much as possible, for the following 24 to 48 hours. Anti-inflammatory medication Non-steroidal anti-inflammatory medication (ibuprofen) was prescribed to the patient, via NHS Direct, two hours after injury. Whilst some studies have shown no early adverse affect of nonsteroidal anti-inflammatory drugs on the strength of healing torn MCL’s (Moorman, et al., 1999), it remains controversial as to whether inhibiting the inflammatory response is uniformly advantageous. Pain and disability following injury are in part due to the inflammatory response and, whist it is suggested that decreasing the inflammation decreases the symptoms (therefore allowing earlier rehabilitation) (Weiler, 1992), it is also important to consider that inflammatory cells are responsible for clearing away cell debris and necrotic fibres and without this phagocytic function regeneration may not be able to begin (Reynolds et al., 1995, Almekinders et al., 1986, Jones 1999). As the patient reported that the pain had subsided over the last 24 hours (measured using a visual analogue scale), he was advised to continue taking the non-steroidal anti-inflammatory medication only when necessary. Proliferation Phase (3-21 days post injury) The proliferation stage involves the repair and regeneration of the injured tissue (development of new blood vessels, fibrous tissue formation, re-epithelialisation and wound contraction) and begins approximately 72 hours after injury. The goals of this rehabilitation phase included: ââ€" Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Decrease effusion ââ€" Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Decrease pain ââ€" Ã‚  Ã‚  Ã‚  Ã‚   Restore full range of motion ââ€" Ã‚  Ã‚  Ã‚  Ã‚   Enhance joint strength ââ€" Ã‚  Ã‚  Ã‚  Ã‚   Introduce proprioceptive exercise ââ€" Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Achieve full pain free weight bearing statu Maintain general fitness and strength levels It has been stated that ligaments heal with a stronger and more organised collagen fibril architecture when early mobilisation and exercise is employed during the healing process (Osborne and Rizzo, 2003). Therefore, in addition to continuing the treatments introduced during the inflammatory phase (ice, intermittent compression, and massage), manual joint mobilisation techniques were also employed at this stage. Comprehensive zinc oxide and elastic adhesive strapping, removed and re-applied by the patient whenever necessary (particularly during active flexion exercises), was also continued. Pain scale assessment, ankle girth measurement and goniometer measurements were continually monitored throughout the proliferation phase. As stated, n the proliferation phase, the goals are to continue re-establishing full range of motion, increase muscular strength/power/endurance, and adding in functional activities. Exercises include isotonic exercises to isolate and strengthen particular muscle groups, such as in the hip and thigh regions (knee extension, leg press, hamstring curls and hip exercises). In order to re-establish the dynamic stability of the knee joint, it is crucial to strengthen the hip and calf musculature, with an emphasis on progressive Closed Kinetic Chain exercises (such as wall squats, step-ups, lateral lunges and stair climbing) that foster proprioception (Wilk et al., 1996). Range of Movement (RoM) Range of movement exercises were significantly progressed from the inflammatory phase. Active and passive movements continued with the addition of manual mobilisation techniques for the knee joint. The following advanced knee stretches were utilised with a view to restoring movement to the joint and improve flexibility of muscles crossing the knee. The patient was advised to carry out each separate muscle group stretch 3 times daily (provided they do not cause or increase pain). i.  Ã‚  Ã‚   Quadriceps Stretch Treatment couch was used for balance. Heel taken towards your bottom, keeping knees together and back straight until patient felt a stretch in the front of their thigh (figure 1). Held for 15 seconds and repeated  4 times at a mild to moderate stretch (pain free). ii. Hamstring Stretch Patient’s foot was placed on chair. With knee and back straight, patient leant forward at hips until he felt a stretch in the back of his thigh/knee (figure 2). Held for 15 seconds and repeated 4 times at a mild to moderate stretch (pain-free). iii.   Calf Stretch With patient’s hands placed against the wall, his leg was stretched behind him as demonstrated in figure 3. Keeping his heel down, knee straight and feet pointing forwards, the patient gently lunged forwards until he felt a stretch in the back of his calf/knee. Held for 15 seconds and repeated  4 times at a mild to moderate stretch (pain-free). iv. ITB Stretch Patient’s leg was placed behind his other leg and taken as far away from him as was comfortably possible. Patient then pushed his hips to the side of his leg until he felt a stretch in the outer thigh/hip (figure 4). Back was kept straight throughout. Held for 15 seconds and repeated  4 times at a mild to moderate stretch (pain-free). v. Adductor Stretch Standing tall, and with back straight, pateint’s feet were placed approximately twice shoulder width apart. Patient then gently lunged to  one side, keeping his  other knee straight, until he felt a stretch in the groin of his straight leg (figure 5). Held for 15 seconds and repeated  4 times at a mild to moderate stretch (pain-free). Increased range of motion was also enhanced by using a stationary bicycle (Wilk et al., 1996). Strengthening Strengthening work for the lower limb musculature continued in a progressive form (as pain allowed). The following knee strengthening exercises were designed and implemented with a view to improving the strength of the muscles surrounding the patient’s injured knee. The patient began with the basic  knee strengthening exercises, advanced to intermediate  knee strengthening exercises and eventually undertook the advanced knee strengthening exercises. A.  Ã‚  Ã‚  Ã‚  Ã‚   Basic Exercises To begin with, the following basic knee strengthening exercises were performed approximately 10 times each, 3 times a day, during the first week of rehabilitation. As knee strength improved, the exercises were progressed by gradually increasing the repetitions and strength of contraction. i. Static Inner Quadriceps Contraction Patient was instructed to tighten his quadriceps muscle group by pushing his knee down into a rolled towel (figure 1). Placing his fingers on his inner quadriceps (vastus medialis) allowed the patient to feel the muscle tighten during contraction. Held for 5 seconds and repeated 10 times as hard as possible pain free. ii. Quads Over Fulcrum Patient was instructed to lie on his back, with a rolled towel under his knee, and told to relax the knee (figure 2). Patient then slowly straightened his knee as far as possible tightening the front of his thigh (quadriceps). Held for 5 seconds and repeated 10 times as hard as possible pain free. iii. Static Hamstring Contraction Patient began this exercise by sitting with his knee bent to about 45Ëš (figure 3). He then pressed hisr heel into the floor tightening the back of his thigh (hamstrings). Held for 5 seconds and repeated 10 times as hard as possible pain free. B. Intermediate Exercises The following intermediate knee strengthening exercises were generally performed 1-3 times per week (during weeks 2 and 3 of the rehabilitation programme). Ideally they were not performed on consecutive days, to allow muscle recovery. As the knee strength improved, the exercises were progressed by gradually increasing the repetitions, number of sets  and/or resistance of the exercises  provided they did not cause or increase pain. iv. Knee Extension in Sitting vs. Resistance Band Patient sat with with his knee bent and a resistance band was tied around his ankle (figure 4). Keeping his back straight, patient slowly straightened his knee, tightening his quadriceps. He performed 3 sets of 10 repetitions on each occasion. v. Hamstring Curl vs. Resistance Band The patient was instructed to lie on his stomach with a resistance band tied around his ankle as shown (figure 5). He then slowly bent his knee whilst tightening his hamstrings (figure 6). He performed 3 sets of 10 repetitions on each occasion vi. Squat with Swiss Ball Patient stood with his feet shoulder width apart and facing forwards. A Swiss ball was placed between the wall and his lower back to add an element of proprioception (figure 7). Patient then slowly performed a squat, keeping his back straight. His knees were kept in line with his middle toes and did not move forward past his toes. Performed 3 sets of 10 repetitions on each occasion. vii. Lunges Patient stood with his back straight in the position shown (figure 8). He then slowly lowered his body until the front knee was at a right angle (figure 9). His knee was kept in line with his middle toe and his feet facing forward. Performed 3 sets of 10 repetitions on each occasion. viii. Heel Raises Patient used treatment couch for balance (figure 10). Whilst keeping his feet shoulder width apart and facing forwards, patient slowly move up onto his toes raising his heels as far as possible and comfortable without pain. Performed 3 sets of 10 repetitions on each occasion. C.  Ã‚  Ã‚  Ã‚  Ã‚   Advanced Exercises The following advanced knee strengthening exercises were generally performed 1 3 times per week (from week 4 of the rehabilitation programme onwards). Ideally they were not performed on consecutive days, to allow muscle recovery. As the knee strength improved, the exercises were progressed by gradually increasing the repetitions, number of sets  or resistance  of the exercises provided they  did not cause or increase pain. ix. Single Leg Squat with Swiss Ball Patient stood on one leg with his foot facing forwards. A Swiss ball was placed between the wall and his lower back to incorporate a proprioceptive element (figure 11). Patient slowly performed a squat, keeping his back straight. Patient ensured his knee did not bend beyond 90Ëš and was in line with his middle toe. His knee didn’t move forward past his toes. Performed 3 sets of 10 repetitions on each occasion. x. Lunges with Weight Patient stood holding light weights, with his back straight in the position shown (figure 12). He slowly lowered his body until the front knee was at a right angle. Knee was kept in line with his middle toe with feet facing forward. Performed 3 sets of 10 repetitions on each occasion. xi. Single Leg Heel Raises Patient stood on one leg with treatment couch for balance (figure 13). Keeping his foot facing forwards, patient slowly moved up onto his toes, raising his heel as far as possible and comfortable without pain. Performed 3 sets of 10 repetitions on each occasion. xii. Hamstring Curl on Swiss Ball Exercise began with patient lying on his back with a Swiss ball under his legs as demonstrated (figure 14). Keeping his back straight, patient slowly bent his knees and tightened the hamstrings. Performed 3 sets of 10 repetitions on each occasion. Proprioception ‘The awareness of position, movement or balance of the body or any of its parts’ (Prentice, 1994). As observed in the ‘Strengthening’ section of the proliferation phase, early proprioception exercises are started at this point. Many of the more basic strengthening exercises identified were progressed by getting the patient to close his eyes closed and/or changing the surface that he was standing on e.g. mini trampoline, air filled cushion, sponge cushions, wobble and rocker boards. During the proliferation phase all proprioceptive work is undertaken with the injured joint strapped with zinc oxide strapping providing confidence to the patient by its perceived level of support. Other specific proprioception exercises used at this stage included: Balance on swiss ball (figure 1) Balance on trampette (figure 2) Balance during leg press (figure 3) Dips on uneven surface (figure 4) Balance on Bosu ball (figure 5) Balance while throwing ball to alternate hands (figure 5) The exercises were progressed by time and/or by increasing the repetitions. All exercises would be performed bilaterally. Variations for proprioceptive exercise were almost endless a vital element in avoiding patient and therapist boredom. It was also important to this rehabilitation programme that exercises could also be carried out at home (as patient also had a full time job). Cardiovascular fitness and general strengthening was also addressed at this time using circuit training, swimming and cycling. Remodelling Phase (21 days to 12 months post injury) The remodelling phase of healing is a long-term process often taking years to complete (Prentice, 1994). Factors that can impede the rate of healing are varied and include surgical repair, poor vascular supply, infection, disease, wound size, health, age and nutrition In terms of rehabilitation, during this phase more aggressive strengthening and mobilisation was required to ensure optimum tissue realignment and strength. The goals of treatment in the remodelling phase were: ââ€" Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Regain full strength ââ€" Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Ensure full pain free range of motion ââ€" Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Maintain overall conditioning ââ€" Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Prepare for return to full participation Range of Motion (RoM) exercises continued with a greater emphasis being placed on ‘hands on work’ in the form of joint mobilisation to ensure full movement is achieved. The strengthening work that was started in the proliferation phase was continued and progressed (in terms of resistance, speed and repetitions) whilst further emphasis was placed on general fitness at this time introducing more sport specific activities. Running drills were progressed from linear to exercises involving change of direction at high pace with and without a ball. Specifically, when the patient was able to run at 75% of maximum speed, figure 8 drills were used beginning with 20m and then 10m figure 8’s. Advanced cutting drills at 45Ëš and finally 90Ëš were also added. Proprioception exercises will be progressed, with a more sport specific content. This involved hopping onto various unstable surfaces (figure 1), hopping on a mini trampoline whilst side foot volleying a ball (figure 2), hopping forwards, sideways and backwards over hurdles at varying pace (figure 3) and practising the kicking action whilst planting the foot on an unstable surface (figure 4). Throughout this phase and when returning to full function the patient continued to wear zinc oxide and elastic adhesive strapping to minimise the possibility of recurrence of injury. Ice was used predominantly after exercise to guard against recurrent pain and swelling. When an athlete achieves the goals of the remodelling phase, they are close to returning to full participation. As earlier identified, Derscheid and Garrick treated 23 Grade II MCL patients and all were returned to playing football within 19 days (4 to 19 day range, 10.6 day mean). However, many of these athletes did not feel they were 100% for several weeks. For this reason, further rehabilitation including strengthening, dynamic knee stabilisation, plyometrics, SAQ drills and proprioception exercises should be completed until the athlete feels 100% and is able to play without inhibition (Wilk et al., 1996). Maintenance exercises, even after return to sport, that promote continuation of strength, endurance, and function are also vitally important to consider (Wilk et al., 1996). Pre Discharge The pre-discharge stage is vital. It is the time for the therapist and patient to decide whether or not a return to full unrestricted activity can take place. Return to full activity was allowed once the following were achieved: Ligamentous examination is normal Quadriceps strength is 90% or greater than the contralateral limb Sport/activity specific agility testing causes no pain To achieve these requirements, the patient was asked to do everything that is expected of him when returning to their chosen sport, including replicating the conditions in which the injury was caused. In this case the patient was required to run, sprint, jump, tackle, pass the ball over varying distances, change direction at speed and be able to withstand full physical contact. 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