RMail v. Amazon.com: Can Invalidity Based on 35 U.S.C. ? 101 Be ...

The America Invents Act?(my how I hate that title!) has caused much change and rethinking about how patent law will be practiced in the future, especially patent prosecution in the USPTO.? A slew of new (and in some cases, recast) procedures will be instituted to permit validity challenges, both pre-grant and post-grant.? One of those new procedures is post-grant review which permits (under new 35 U.S.C. ? 321(b)) a ?request to cancel as unpatentable 1 or more claims of a patent on any ground that could be raised under paragraphs (2) or (3) of section 282 (relating to invalidity of the patent or any claim).?? As those familiar with patent infringement litigation recognize, section 282 (aka, 35 U.S.C. ? 282) referred to by new 35 U.S.C. ? 321(b) also defines what defenses in may be raised in patent litigation ?involving the validity or infringement of a patent?:

(1) Noninfringement, absence of liability for infringement, or unenforceability,

(2) Invalidity of the patent or any claim in suit on any ground specified in part II of this title as a condition for patentability,

(3) Invalidity of the patent or any claim in suit for failure to comply with any requirement of sections 112 or 251 of this title,

(4) Any other fact or act made a defense by this title.

In step with these new procedures authorized by the AIA, the USPTO has promulgated corresponding rule packages at a ?fast and furious? pace.? As part of the post-grant review rules package, the USPTO has interpreted what new 35 U.S.C. ? 321(b) means in terms ?grounds? that may be raised.? See Ken Nigon?s Post Grant Review, Inter Partes Review and Transitional Program for Covered Business Method Patents.? Interestingly, the USPTO post-grant review rules package has interpreted new 35 U.S.C. ? 321(b), and more specifically 35 U.S.C. ? 282(2), to mean that not only are 35 U.S.C. ? 102 (novelty) and 35 U.S.C. ? 102 (obviousness) proper grounds for a post-grant review request, but so is 35 U.S.C. ? 101 (inventions patentable).

This interpretation by the USPTO that post-grant review requests may include challenges for patent-eligibility under 35 U.S.C. ? 101 has caused a ?renaissance? of rethinking about what the actual language of 35 U.S.C. ? 282(2) says and means.? See Professor Hricik?s post entitled ?Are the Courts Correct in Their Assumption that a Patent Issued on Non-patentable Subject Matter is Invalid?? on Patently-O.? By its literal words, 35 U.S.C. ? 282(2) says that the invalidity of the patent or claim may be based on ?any ground specified in part II of this title [i.e., Title 35] as a condition for patentability (emphasis added).? ?So what is a ?condition for patentability? under part II of Title 35?? Ah, that?s the rub.? The only sections of part II that are specifically characterized (by their headings) as ?conditions for patentability? are 35 U.S.C. ? 102 and 35 U.S.C. ? 103.? By contrast, 35 U.S.C. ? 101 is not characterized as a ?condition for patentability.?? (I might also add that 35 U.S.C. ? 101 at the end says that it is ?subject to the conditions and requirements of this title? which may subtly suggest that this section is not a ?condition for patentability.?)

With this new rethinking about what are ?conditions for patentability? in the post-grant review context, it was just a matter of time before this ?elephant? would poke its ?nose? into the patent litigation ?tent.?? In the pending case of RMail, Limited v. Amazon.com, Inc., one of the accused infringers (PayPal) moved for partial summary judgment of invalidity of all of the asserted claims of U.S. Pat. No. 6,571,334 (the ?334 patent) and U.S. Pat. No. 6,182,219 (the ?219 patent for which the ?334 patent is the parent) directed to apparatus and methods for authenticating electronic messages (i.e., that a sender has sent certain information via a dispatcher to a recipient) based on patent-ineligibility under 35 U.S.C. ? 101.? One of the asserted claims (independent Claim 1 of the ?334 patent) recites this method for authenticating electronic messages as follows:

A method of authenticating a dispatch and contents of the dispatch transmitted from a sender to a recipient, comprising the steps of:

sending content data representative of the contents of the dispatch, and, a destination of the dispatch associated with said recipient, to an authenticator functioning as a non-interested third party with respect to the sender and the recipient, to be forwarded to said destination;

receiving a representation of authentication data that has been generated by said authenticator, said authentication data comprising a representation of the following set A of information elements: a₁?comprising said content data, and dispatch record data elements a₂, . . . , a_n which includes at least an indicia a₂ relating to a time of the dispatch which is provided in a manner resistant to or indicative of tampering by either of the sender and the recipient, and an indicia a₃ relating to said destination of the dispatch,

wherein at least part of said authentication data is secured against tampering of the sender and the recipient, and

wherein said authentication data includes a set B comprising one or more information elements b₁, . . . ,b_m generated by respectively applying functions F₁, . . . ,F_m to subsets S₁, . . . ,S_m comprising selected portions of said set A, where said functions F₁, . . . ,F_m can be different from one another and said subsets S₁, . . . ,S_m can be different from one another, and wherein said authentication data does not comprise an encrypted representation of said content data and said dispatch record data which is encrypted with a secret key, either symmetric or asymmetric, associated with said recipient.

In opposing this partial summary judgment motion, the patentee (RMail) made the usual responses as to why the asserted claims of the ?334 patent and ?219 patent were, in fact, patent-eligible under 35 U.S.C. ? 101.? Where RMail?s response gets interesting is in the Part VI argument entitled ?CONGRESS DID NOT PERMIT SECTION 101 TO SUPPLY A LITIGATION DEFENSE.?? Recognizing the audaciousness and potential ?heresy? of this Part VI argument, RMail acknowledged ?that this argument is for the good faith extension or modification of existing caselaw.?? Even so, RMail further boldly stated that the ?Courts until now have uniformly overlooked Congressional will on this question.?

RMail?s argument for why patent-eligibility under 35 U.S.C. ? 101 is not a proper invalidity defense in litigation is straightforward:

1. Patent defenses are statutory.? Only patent defenses enumerated by Title 35 exist, citing the 2008 Federal Circuit case of Aristocrat Technologies Australia Pty Limited v. International Game Technology.

2. 35 U.S.C. ? 282 states what these defenses are.? Only the defenses enumerated in paragraphs (2) and (4) are arguably applicable.

3. Paragraph (2) does not apply because it requires that the ground be specified in part II as a ?condition for patentability.?? Only 35 U.S.C. ? 102 and 35 U.S.C. ? 103 are identified as a ?condition for patentability,? as confirmed by their headings.

4. Paragraph (4) does not apply because ?the statutory language must clearly demarcate a fact or act as a litigation defense for it to apply.?

Instead, RMail characterized patent-eligibility determinations under 35 U.S.C. ? 101 as ?appropriate in Patent Office application proceedings,? and asserted that ?this Court lacks any statutory basis for analyzing Section 101 issues as a litigation defense.?

So what?s different about ex parte examination by the USPTO of patent-eligibility under 35 U.S.C. ? 101?? Well, 35 U.S.C. ? 131 governs the ex parte examination of applications by the USPTO (actually the Director of the USPTO but obviously delegated to the patent examiners).? 35 U.S.C. ? 131 says that the examination of the patent application must determine whether ?the applicant is entitled to the patent under the law.?? The requirement under 35 U.S.C. ? 101 that the invention be a ?new and useful process, machine, manufacture, or composition of matter? (or any ?new and useful improvement thereof?) is obviously something ?under the law.?? So if what is claimed by the application isn?t in one of the statutory classes specified in 35 U.S.C. ? 101, it certainly isn?t entitled to a patent ?under the law.?

As pointed out astutely by RMail (and what is also pretty startling once you realize it) is that the Supreme Court jurisprudence on patent-eligibility under 35 U.S.C. ? 101 (since its enactment in the 1952 Patent Act) have primarily involved ex parte prosecution appeals from the USPTO:? Gottschalk v. Benson; Parker v. Flook; Diamond v. Diehr; Diamond v. Chakrabarty; and Bilski v. Kappos.? There are only two instances involving patent litigation I?m aware of where the Supreme Court squarely determined patent-eligibility under 35 U.S.C. ? 101:? the recent case of Mayo Collaborative Services v. Prometheus Laboratories, Inc. (ruling that the claimed method was patent-ineligible under the ?law of nature? doctrine); and the 2001 case of Pioneer Hi-Bred International v. JEM AG Supply (which ruled that sexually reproduced plants qualified as either ?manufactures? or ?compositions of matter? under 35 U.S.C. ? 101).? But as RMail correctly observed ?no one seems to have pointed out to the Supreme Court [in Prometheus] this important threshold issue of statutory construction, and statutory limitations on the powers of the federal courts.?? Accordingly, Prometheus ?does not bar this Court from issuing a correct ruling in the present adversarial context.?

RMail?s attorneys also did their legal research homework to address ?but everyone (including the courts) has assumed beyond question for years that patent-eligibility under 35 U.S.C. ? 101 was an invalidity defense in patent infringement litigation.?? As poignantly stated by the RMail, ?[e]ven long-term statutory misconstruction will not bar restoring the patent system to its statutory limits.?? In this regard, RMail cited the 1994 Supreme Court case of Central Bank of Denver v. First Interstate Bank of Denver which overruled 60 years of allowing a certain statutory cause of action ?because Congress had not expressly provided for that cause of action.?? The selection of the Central Bank of Denver case was also likely very deliberate as 35 U.S.C. ? 101 has also now been in existence for 60 years.

One potential ?fly? in RMail?s ?ointment? that patent-eligibility under 35 U.S.C. ? 101 isn?t a proper invalidity defense in patent litigation comes out of the Aristocrat Technologies case.? Judge Linn (writing for the Federal Circuit panel) in Aristocrat Technologies ruled that an alleged improper revival of a patent application for ?unintentional delay? could not be raised as an invalidity defense in a patent infringement action.? Judge Linn reviewed 35 U.S.C. ? 282, again focusing on what paragraphs (2) and (4) authorized as invalidity defenses.? After that review, Judge Linn concluded that neither paragraph (2), nor paragraph (4) of 35 U.S.C. ? 282 recognized an invalidity defense based on improper revival of a patent application for ?unintentional delay.?

But that wasn?t all that Judge Linn said in Aristocrat Technologies.? In construing when paragraph (2) of 35 U.S.C. ? 282 applied, Judge Linn observed that ?[i]t has long been understood that the Patent Act set out the conditions for patentability in three sections:? 101, 102, and 103,? citing the seminal 1966 Supreme Court case of Graham v. John Deere Co. which stated the following:

?The [1952 Patent] Act sets out the conditions of patentability in three sections.? An analysis of the structure of these three sections indicates that patentability is dependent upon three explicit conditions: novelty and utility as articulated and defined in ? 101 and ? 102, and nonobviousness, the new statutory formulation, as set out in ? 103.?

Judge Linn went even further in footnote 3 of his Aristocrat Technologies opinion to say:?? ?Although the Supreme Court in Graham referred only to the utility requirement aspect of section 101, as we often do, it is beyond question that section 101?s requirement, that the invention be directed to patentable subject matter, is also a condition for patentability (emphasis added).?

Judge Linn?s reliance upon Graham for patent-eligibility under 35 U.S.C. ? 101 to be a ?condition for patentability? for the purposes of 35 U.S.C. ? 282(2) is problematic.? When it comes to patent law, the Supreme Court is all too often very long on ?rhetoric,? but very short when it comes to rigorously analyzing the language of the patent statutes.? And this citation by Judge Linn from Graham is no exception.? Nowhere do you find in Graham any discussion or analysis of what the Supreme Court?s statutory basis was for treating 35 U.S.C. ? 101 as a ?condition for patentability? and especially as a ?condition for patentability? within the meaning of 35 U.S.C. ? 282(2) to make 35 U.S.C. ? 101 a proper invalidity defense in patent infringement litigation.? Likewise, ?squint as we may,? Prometheus says not one word about the statutory basis that permits 35 U.S.C. ? 101 to be asserted as an invalidity defense in patent infringement litigation.

The Federal Circuit is also not immune from glossing over what the patent statutes say and mean.? One Federal Circuit judge who might well consider this question of proper invalidity defenses under 35 U.S.C. ? 282(2) to be a highly relevant point is Judge Newman.? Judge Newman is a real stickler for paying attention to what the patent statutes say (and especially what they mean), and I completely agree with her approach.? All too often Judge Newman (in dissent) has scolded her Federal Circuit colleagues about overlooking what the patent statutes say, and especially what they mean.? Witness the 2004 case of Honeywell International Inc. v. Hamilton Sundstrand Corp. where Judge Newman railed against her Federal Circuit colleagues en banc for essentially reading paragraph 4 (?a claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers?) out of 35 U.S.C. ? 112 in the context of prosecution history estoppel.

PayPal?s Reply to RMail?s part VI argument was fairly terse.? Basically, PayPal cited Judge Linn?s quote in footnote 3 of Aristocrat Technologies lock, stock, and barrel.? But RMail didn?t shy away in their Surreply.? First, RMail asserted that PayPal?s Reply agreed that ?the answer [to patent-eligibility under 35 U.S.C. ? 101 as a proper invalidity defense] turns on whether subject matter eligibility is a ?condition for patentability.??? Second, RMail asserted that PayPal reached the ?wrong result because they incorrectly rely on Federal Circuit dicta,? i.e., Judge Linn?s quote in footnote 3 of Aristocrat Technologies.? In that regard, RMail is correct that Judge Linn?s quote in footnote 3 of Aristocrat Technologies is dicta (and definitely obiter) because it is completely unnecessary to the holding in that case.

Third, and most significantly, RMail points to the more recent 2012 Federal Circuit case of Myspace, Inc. v. Graphon, Inc. which said that ?[t]he two sections of part II that Congress has denominated ?conditions of patentability? are ? 102 (?novelty and loss of right to patent?) and ? 103 (?nonobvious subject matter?).? RMail also observed that Graham ?at the outmost periphery? had suggested ?utility? as a so-called ?condition of patentability.?? But RMail also noted that ?missing from both Myspace and Graham is any statement that ?subject matter eligibility? is a ?condition for patentability? as used in Section 282(2).?

So am I saying that RMail is going win on the question of whether patent-eligibility under 35 U.S.C. ? 101 is a proper invalidity defense in patent infringement litigation?? Not at all.? But the argument that RMail presents for why patent-eligibility under 35 U.S.C. ? 101 is not a ?condition for patentability? under part II of Title 35 (and therefore not a proper invalidity defense) is both plausible and consistent with the language of 35 U.S.C. ? 282(2).? What is more disturbing to me is that the courts (including the Supreme Court) have assumed ?beyond question? for 60 years that patent-eligibility under 35 U.S.C. ? 101 is a proper invalidity defense, but without ever engaging in any rigorous analysis of what, exactly, is the statutory basis (including 35 U.S.C. ? 282(2)) for it being an invalidity defense.? I can just imagine Judge Newman shaking her head over this one.

For more on this please see Patently-O?s article, which also provides copies of the briefs filed.

*? 2012 Eric W. Guttag.? Posted September 13, 2012 on IPWatchdog.com.

Source: http://www.ipwatchdog.com/2012/09/13/rmail-v-amazon-com-can-invalidity-based-on-35-u-s-c-%C2%A7-101-be-properly-raised-as-a-defense-in-litigation/id=28033/

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Equity International CEO resigns, Sam Zell to take over: WSJ

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First pediatric study to look at the role of vitamin D in critical illness

Public release date: 12-Sep-2012
[ | E-mail | Share ]

Contact: Adrienne Vienneau
avienneau@cheo.on.ca
613-737-7600 x4144
Children's Hospital of Eastern Ontario Research Institute

OTTAWA, Canada, September 12, 2012Vitamin D is increasingly being recognized as important for good health. Vitamin D is a hormone made in the skin following sun exposure or acquired from diet and supplement intake. Previous medical research has shown that low body levels of vitamin D make people more susceptible to problems such as bone fractures, poor mental health and infections like the common cold. Until recently, there had been little consideration given to the role of vitamin D in more severe diseases, which is why Dr. Dayre McNally's recent publication in the esteemed scientific journal Pediatrics is so compelling.

"This is the first study to report on vitamin D levels in a large group of critically ill children," said Dr. McNally, a clinical researcher and intensivist at the Children's Hospital of Eastern Ontario (CHEO) and assistant professor in the Department of Pediatrics at the University of Ottawa.

The study, led by Dr. McNally at the CHEO Research Institute, included over 300 children and teenagers at six hospitals in Ottawa, Toronto, Hamilton, Edmonton, Saskatoon and Vancouver. These children were admitted to an Intensive Care Unit (ICU) with severe infections, significant trauma or conditions requiring major surgery, such as congenital heart defects.

Their study found that in three of every four critically ill children, blood vitamin D levels were below the target considered safe by many experts and medical societies. Further, those with lower vitamin D levels were noted to be sicker, requiring more life-sustaining therapies (breathing tubes, medications to support heart function) and staying in the ICU for longer periods of time.

"Although these findings are of concern, we are very encouraged because we've discovered something that is modifiable," explained Dr. McNally. "There are simple ways to prevent this problem, and it may be possible to rapidly restore vitamin D levels at the time of severe illness."

###

This study was conducted by Dr. Dayre McNally, Dr. Kusum Menon, Dr. Pranesh Chakraborty, Lawrence Fisher, Kathryn Williams, Dr. Osama Al-Dirbashi and Dr. Dermot Doherty. It was funded by the Canadian Institutes of Health Research (CIHR) and the CHEO Research Institute.

About the CHEO Research Institute:

Established in 1984, the CHEO Research Institute coordinates the research activities of the Children's Hospital of Eastern Ontario (CHEO) and is one of the institutes associated with the University of Ottawa Teaching Hospitals. The Research Institute brings together health professionals from within CHEO to share their efforts in solving pediatric health problems. It also promotes collaborative research outside the hospital with partners from the immediate community, industry and the international scientific world. For more information, please visit www.cheori.org.

About the University of Ottawa:

The University of Ottawa is committed to research excellence and encourages an interdisciplinary approach to knowledge creation, which attracts the best academic talent from across Canada and around the world. The University is an important stakeholder in the National Capital Region's economic development.

---

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?

AAAS and EurekAlert! are not responsible for the accuracy of news releases posted to EurekAlert! by contributing institutions or for the use of any information through the EurekAlert! system.

Public release date: 12-Sep-2012
[ | E-mail | Share ]

Contact: Adrienne Vienneau
avienneau@cheo.on.ca
613-737-7600 x4144
Children's Hospital of Eastern Ontario Research Institute

OTTAWA, Canada, September 12, 2012Vitamin D is increasingly being recognized as important for good health. Vitamin D is a hormone made in the skin following sun exposure or acquired from diet and supplement intake. Previous medical research has shown that low body levels of vitamin D make people more susceptible to problems such as bone fractures, poor mental health and infections like the common cold. Until recently, there had been little consideration given to the role of vitamin D in more severe diseases, which is why Dr. Dayre McNally's recent publication in the esteemed scientific journal Pediatrics is so compelling.

"This is the first study to report on vitamin D levels in a large group of critically ill children," said Dr. McNally, a clinical researcher and intensivist at the Children's Hospital of Eastern Ontario (CHEO) and assistant professor in the Department of Pediatrics at the University of Ottawa.

The study, led by Dr. McNally at the CHEO Research Institute, included over 300 children and teenagers at six hospitals in Ottawa, Toronto, Hamilton, Edmonton, Saskatoon and Vancouver. These children were admitted to an Intensive Care Unit (ICU) with severe infections, significant trauma or conditions requiring major surgery, such as congenital heart defects.

Their study found that in three of every four critically ill children, blood vitamin D levels were below the target considered safe by many experts and medical societies. Further, those with lower vitamin D levels were noted to be sicker, requiring more life-sustaining therapies (breathing tubes, medications to support heart function) and staying in the ICU for longer periods of time.

"Although these findings are of concern, we are very encouraged because we've discovered something that is modifiable," explained Dr. McNally. "There are simple ways to prevent this problem, and it may be possible to rapidly restore vitamin D levels at the time of severe illness."

###

This study was conducted by Dr. Dayre McNally, Dr. Kusum Menon, Dr. Pranesh Chakraborty, Lawrence Fisher, Kathryn Williams, Dr. Osama Al-Dirbashi and Dr. Dermot Doherty. It was funded by the Canadian Institutes of Health Research (CIHR) and the CHEO Research Institute.

About the CHEO Research Institute:

Established in 1984, the CHEO Research Institute coordinates the research activities of the Children's Hospital of Eastern Ontario (CHEO) and is one of the institutes associated with the University of Ottawa Teaching Hospitals. The Research Institute brings together health professionals from within CHEO to share their efforts in solving pediatric health problems. It also promotes collaborative research outside the hospital with partners from the immediate community, industry and the international scientific world. For more information, please visit www.cheori.org.

About the University of Ottawa:

The University of Ottawa is committed to research excellence and encourages an interdisciplinary approach to knowledge creation, which attracts the best academic talent from across Canada and around the world. The University is an important stakeholder in the National Capital Region's economic development.

---

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?

AAAS and EurekAlert! are not responsible for the accuracy of news releases posted to EurekAlert! by contributing institutions or for the use of any information through the EurekAlert! system.

Source: http://www.eurekalert.org/pub_releases/2012-09/choe-fps091212.php

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Shirley, 'Airplane' can't be funniest movie

Warner Bros.

Mel Brooks and Harvey Korman in "Blazing Saddles."

Humor is subjective, but that doesn't mean certain comedies don't strike a chord with almost everyone. "A Christmas Story" is as popular as holiday presents, and who hasn't quoted "Airplane!" in appropriate situations?("Shirley, you can't be serious?") And then there are the Monty Python films. And semi-universal favorites such as "Caddyshack."?You get the picture...

A recent British survey?declared "Airplane!" the funniest movie of all time. That survey gets technical, even calculating?the exact number of supposed laughs per minute. For most of us, though, our reactions aren't quite so scientific. If it's funny, we laugh, and certain films just hit our funny bone over and over again.

We asked a few of our staffers to share their favorite funny flicks, and want to hear from you about the films that make you laugh the most.?

'Blazing Saddles'
"Blazing Saddles" burns its way across the comedic landscape of the Old West with stereotypes, puns, wordplay, sight gags and even racial jokes (designed to disarm as much as entertain). ?The film's rightfully famous for several scenes, including bean-laden cowboys doing what bean-laden cowboys do around a campfire, and when muscle-bound henchman Mongo enters town and punches a horse to the ground. During the film's climax, horses go flying, fists go flying and reality flies right off the rails as the hordes of fighting outlaws and townsfolk invade first the film lots, then Hollywood, no doubt killing more men than Cecil B. DeMille.? ?--David Gostisha

?Team America: World Police?
It?s tasteless and profane and I would be mortified my mom was sitting next to me while it was on, but ?Team America: World Police? is undeniably hilarious. And when it came out in 2004, just a few years after the 9-11 attacks, it was kind of cathartic, too. The team destroys Paris while fighting terrorists and celebrates while Parisians stand horrified in the rubble of their city. Kim Jong Il?s black panthers of death turn out to be adorable housecats. Middle Eastern puppets mimic the Cantina Band scene from ?Star Wars.? Puppets die bloody, flaming deaths and have really weird puppet sex. And the soaring, wonderfully jingoistic anthem ?America! (Bleep) Yeah!?, which praises American institutions from Starbucks to slavery, is an F-word filled classic. ?How is this not our national anthem?? writes one YouTube commenter. How indeed? ? ?Gael Fashingbauer Cooper

'A Christmas Story'
A confession: I just can't look at, or even think about, the tongue-meets-icy-flagpole scene in "A Christmas Story." If you grew up in an icy climate like me, even if you were never triple-dog-dared to lick a metal flagpole, you know all too well that unnerving, creepy feeling when wet skin accidentally meets below-zero metal. But that aside, this has to be the funniest holiday movie ever. The pink bunny suit. "You'll shoot yer eye out!" The Major Award. The Bumpuses' dogs and the Old Man's beloved turkey. "A crummy COMMERCIAL?" Ralphie's holiday frustrations are enough to make anyone say "Fudge!" ? ?--G.F.C.

?

?His Girl Friday?
Movies didn?t always rely on fart jokes and bodily excretions to get a laugh. Back when screwball comedy reigned, words were the weapons designed to split sides. And there was no better example in 1940 than ?His Girl Friday,? a film that perfectly matched an athletic Cary Grant mugging as newspaper editor Walter Burns and a?mischievous?Rosalind Russell as his ex-wife/star reporter Hildegard ?Hildy? Johnson. She?s about to get remarried to Bruce Baldwin (Ralph Bellamy), the sappiest of saps, and leave the profession, and Walter won?t have it. Meanwhile, a condemned man has escaped from prison on the eve of his execution and Walter enlists Hildy to cover the story for old time?s sake. The pair run, flail, throw things and generally make a hectic mess of the courthouse press room as they trade verbal barbs with such crisp speed that it?s impossible to catch them all on a first go-round. Witty and smart, it?s a rollicking tale designed for the ADD generation. Stop the presses and check it out, now! ? ?--Randee Dawn

?

?Anchorman: The Legend of Ron Burgundy?
Because the real news is often the furthest thing from funny, give credit to Will Ferrell for elevating this spoof on a TV newsman in 1970s San Diego. Ron Burgundy is hilarious because of his overblown sense of confidence and self-worth in the face of repeated acts of stupidity. He?s only outdone in those categories by his cast of co-workers, including Brick Tamland (Steve Carrell) and Brian Fantana (Paul Rudd). Christina Applegate is perfect as Veronica Corningstone, the new female reporter ?who brings ?diversity? -- no that?s not a Civil-War era wooden ship -- to the newsroom. From the jazz flute scene to beloved dog Baxter getting kicked off a bridge, it?s clear why ?Anchorman? is kind of a big deal in comedy. ? ? --Kurt Schlosser

What's your favorite funny movie? Tell us on Facebook.

Related content:

Source: http://entertainment.nbcnews.com/_news/2012/09/12/13733540-airplane-team-america-anchorman-whats-the-funniest-movie?lite

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Chesapeake gets breathing room with $6.9 billion asset sale

(Reuters) - Chesapeake Energy Corp's $6.9 billion deal to sell gas fields and pipelines should help stabilize the troubled company for the rest of the year and give it time to figure out how it will fund 2013 operations.

With agreements to sell most of its assets in the Permian Basin to Royal Dutch Shell Plc and Chevron Corp, as well as nearly all of its remaining infrastructure network, Chesapeake will now have to rely more heavily on a smaller number of assets to grow.

Chief Executive Aubrey McClendon built Chesapeake into the second-largest natural gas producer in the United States through aggressive land purchases and development of so-called unconventional resources around the country. But the company has been struggling recently due to slumping natural gas prices, as well as controversial land deals in Michigan and personal loans taken out by McClendon.

Chesapeake has been selling assets this year to meet an estimated $10 billion funding gap. It plans to use some of the proceeds from Wednesday's announcement to trim its $14.33 billion debt load by $4 billion. The company's market value is roughly $13.27 billion.

The deals keep the company afloat for 2012. Still, they do not significantly close the gap between the amount Chesapeake needs to spend in the future to maintain its current growth and its projected revenue.

Chesapeake will need to fill a funding gap of at least $4 billion in 2013, Barclays analysts estimate.

"They are fine from a funding point of view for 2012," said Morningstar analyst Mark Hanson, who estimates the company will finish the year with a surplus.

He estimated that based on the company's current growth plan, "they are in the hole already for 2013 ... They probably need to sell a not insignificant amount of assets in 2013 to plug that gap."

The company sold its pipeline network for more than analysts had expected, but got less for its Permian assets than expected, Argus Research analyst Phil Weiss said.

"When you look at the acquirers - Chevron and Shell - I certainly wouldn't expect them to overpay," Weiss said.

The company holds 1.5 million acres in the Permian Basin, a vast source of oil and natural gas in the western part of Texas and southeastern New Mexico.

"There's no way at this point in time to know what these reserves are really worth," said David Dreman, chairman of Dreman Value Management, which owns about 1 million shares of Chesapeake. "It doesn't look like this was a buyers war."

Chesapeake's Permian sales work out to about $3,200 per acre, less than half the $7,500-an-acre average that sellers in the Permian had reaped in 10 previous sales during 2011 and 2012, said Morningstar analyst Mark Hanson.

Given the quality of Chesapeake's assets in the Permian, though, Hanson had expected a price of around $3,750 an acre.

Chesapeake's shares fell 1 percent to at $19.89 on Wednesday. The stock has dipped 10.8 percent so far this year.

The deal is part of the company's strategy to shift away from cheap natural gas into more lucrative crude oil. It also comes after a Reuters report in June showed Chesapeake and Encana Corp had colluded in 2010 to avoid bidding against each other in Michigan land deals.

That report has led to an investigation by the U.S. Department of Justice into possible criminal antitrust violations.

'SIGNIFICANT STEPS'

Chesapeake's chief executive, Aubrey McClendon, said the company had reached about 85 percent of its goal to sell $13 billion to $14 billion of assets this year.

"These transactions are significant steps in the transformation of our company's asset base to a more balanced portfolio among oil, natural gas liquids and natural gas resources and production," McClendon said in a statement.

Chesapeake has been working to sell assets in the Permian Basin since February. Depressed natural gas prices have crimped cash flow at Chesapeake and many other energy companies, leaving asset sales as a good way to raise cash.

Chesapeake is selling about 618,000 acres in the southern Delaware Basin portion of the Permian Basin to Shell, which said it is paying $1.94 billion.

Another 264,000 acres in the Permian is being sold to Chevron. Terms of that deal were not disclosed

Chesapeake is keeping 470,000 acres in the Permian.

In total, Chesapeake is raising about $3.3 billion from the sale of Permian Basin assets.

Chesapeake said in May that more than 10 companies had looked at the Permian acreage. Investment bankers said some potential buyers had blanched at the assets because of concerns about levels of natural gas liquids in the package as well as the need for an aggressive drilling program to hold on to some of the land.

Also Wednesday, Chesapeake said it would raise $3 billion from selling nearly all of its remaining pipeline and related assets in several transactions.

The company previously announced the largest of the transactions - a $2.7 billion deal pending with Global Infrastructure Partners - when it signed a letter agreement with the infrastructure company in June. [ID:nL4E8H88RP] It said then that the deal would bring in more than $2 billion.

The company is also selling some land in Ohio's Utica shale formation for some $600 million in four separate deals. After the deals close, Chesapeake will have about 1.3 million acres left in the Utica.

MISSISSIPPI LIME

Chesapeake is still looking for a joint venture partner for its holdings in the Mississippi Lime in Oklahoma and Kansas. It said earlier this year that its total holdings there could be worth $14 billion to $16 billion, based on an assumption of $7,000 to $8,000 an acre.

Joint ventures have been quite popular with foreign companies looking to gain a foothold in and expertise with North American shale plays.

But one investment banker said that there is currently "a little bit of 'JV fatigue,'" in the energy industry, noting that some companies might be wary of linking up with the precariously positioned Chesapeake.

"I think that's very true as it relates to Chesapeake, which has a bit of an asterisk beside their name at this point. I think people have found their experience with Chesapeake has been unrewarding," said the banker, who spoke on the condition of anonymity due to lack of approval to speak on the record..

Reuters reported earlier this year that McClendon has taken $1.1 billion in personal loans against his stakes in Chesapeake wells during the past three years.

The loans, which came mostly from an investment management company that also did business with Chesapeake, had not been disclosed to shareholders. The Securities and Exchange Commission and the Internal Revenue Service have launched inquiries.

(Reporting by Ernest Scheyder and Michael Erman in New York and Swetha Gopinath in Bangalore; Editing by Sofina Mirza-Reid, Bernadette Baum, Maureen Bavdek and Phil Berlowitz)

Source: http://news.yahoo.com/chesapeake-energy-raise-6-9-billion-asset-sale-111422291--finance.html

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Adobe Photoshop Touch 1.3 (for iPad)

Adobe Photoshop Touch does an impressive job of bringing features from the leading desktop imaging application to the iPad. And as its name suggests, not only do you image tools that have made Photoshop famous, but the app makes ground-breaking use of the iPad's multitouch interface. With the latest update, the $9.99 app now supports the new iPad's Retina display, as well as larger image sizes?up to 12 megapixels. It also adds a couple new effects, such as"pixel nudging" for better precision, smoother animation, and support for iCloud Photo Stream.

Adobe has no shortage of mobile apps: First we saw Photoshop.com Mobile, a free, basic photo editor and enhancer that later became Photoshop Express. Next came Carousel, later renamed to Revel, and then came some tablet apps designed to work with Photoshop on the desktop. ?In all, the company at this point offers 18 different mobile apps, and was even cited back in 2009 by Gartner as a visionary for its mobile consumer app strategy. But as the mobile version of the company's flagship app, Photoshop Touch has a special place in this constellation of mobile apps.

Given the depth, power, and complexity of the desktop version of Photoshop, you may be surprised by the number advanced features that make it into Photoshop Touch?including Clone Stamp, Layers, Magic Wand, and even Curves. Perhaps even more surprising is how easy these features are to use on a tablet, thanks to Adobe's smart use of the touch interface. I tested the app on a new Apple iPad (it requires an iPad 2 or later and iOS 5 or later), but it's also available for tablets running Android 3.1 and later.

Getting Started
Right off the bat, Photoshop Touch comes to your aid by offering full, clear, helpful tutorials on the start screen. There are 15 in all, covering topics such as "Add a dramatic flare," "Paint with effects," "Add people to images," and "Drop Shadow Text." The one I tried first called "Clean up a background," has you remove a distracting person in the background so that it doesn't distract from your subjects. The technique uses some familiar Photoshop tools, though in a newfangled mobile interface.

Adobe somehow manages to smush a wealth of these tools and controls into the limited space of a tablet screen, while still maintaining a neat, uncluttered appearance. The interface sports some familiar options along a left-edge toolbar?Marquee selection box, Lasso selection, Magic Wand, brushes, Clone stamp, eraser, and Blur tool. An arrow at the bottom lets you hide the toolbar, touching an icon flies out related tools, and tapping on an icon moves it to the top and fills the toolbar with options for the selected tool.

Along the top, another icon menu offers image opening, cut & paste, selection options (feather and inverse, for example), rotation, and resizing. Adjustments, effects, full-screen, and even more standard tools are up here too. Along the right, just as in big Photoshop, are your image layers. You can hide and show these with the tap of a button, and set opacity and blend mode.

You can open new images from your tablet's local photo storage, from Creative Cloud, Google image search, or Facebook. Or you can just shoot a picture with your iPad's built-in iSight camera. One thing I'd asked for in version one and subsequently got is the ability to start without any photo, and just draw and add text to a blank canvas; the Plus sign at the bottom of the welcome page does this. You can also, add an empty layer and hide all others. You can move layers down in the stack with a simple swipe. New for version 1.3 is the ability to use high-res photos up to 12 megapixels and from iCloud Photo Stream.6

Even if you don't start with a tutorial, helpful overlays get you started by indicating what the major tools around the edges can do. Undo and redo arrows are always at your disposal, should you mess up or decide you like an edit after all. And as you'd expect, you can pinch and unpinch to zoom out and in on your image. Since there's no hand tool, moving is done with two fingers, which can be tricky to do without unintentionally zooming. New for version 1.3 is the ability to view an image at 100 with a three-finger tap, a definite convenience, and the fact that doing so again takes you back to the screen-fit size is nearly as useful.

Removing Background Distractions
I was able to remove distracting stuff in the background of a photo of a friend by first protecting his head by selecting it with the Lasso tool and then using the Clone Stamp tool to overwrite the distractions with similar background matter nearby. The process took a little doing, as the face of my friend occasionally crept into my stamping material. I also tried selecting with the magic wand, but for my test image, this involved a lot of selection adding. Selection with the lasso was also trickier than in desktop Photoshop, since there isn't a Magnetic option.

Much better and easier was then new Scribble selection tool. This let me draw on parts of the images to keep in green "fingerpaint" and parts to remove in red. But the Clone Stamp tool is still not as powerful as the Content Aware patch you get in desktop Photoshop, making removing background clutter harder.

Source: http://feedproxy.google.com/~r/ziffdavis/pcmag/~3/oWg2AgItDrA/0,2817,2403607,00.asp

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The Best Way To Surpass Your Rheumatoid arthritis - Coast Business

Although rheumatoid arthritis is present in several types, all of them result in ache. It is not easy to cope with something that provides everyday discomfort. The good news is, techniques are available for reducing this soreness. Here are some ideas about handling joint disease.

Seek advice from your doctor after a minimal trauma. A good easy angle or sprain can produce scar tissue cells that may become worse arthritis signs or symptoms. Enable your doctor to display screen for little fractures and to bandage injured areas as a technique to avoid scar cells from developing.

Established a specific intention regarding how very long you will take steps. As an example, when cleaning up your house set up a clock for five to ten moments then take a rest. Lots of people continue their discomfort and then try to complete the work within a chance, but this can be hazardous.

Joint inflammation sufferers experienced some accomplishments in eliminating pain by engaging in reduced-impact exercise routines, like skating and jogging. If doing exercises frightens you with your situation, consult with your personal doctor first.

Work with a home heating cushion that is certainly moistened to sooth influenced important joints should an abrupt flare-up happen. Agonizing joint disease inflammations answer properly to both humidity and also heat. Using the mat for 10-20 minutes or so is sufficient thwart an strike of rheumatoid arthritis and comfort unpleasant joint parts.

Make the effort in applying an agenda to manage your joint disease therapy technique. Because there are numerous types of joint inflammation, and countless sufferers, the anguish ranges, signs or symptoms and needs are boundless. You should be aware the treatment options that can be found, and personal-conscious enough being useful when you are coordinating the correct versions to your requires.

Pursue all therapy and treatment selections for your kids when they are suffering from juvenile rheumatoid arthritis symptoms. Also, ensure that you analysis any medication that may be offered. With out placing an excessive amount of anxiety on the important joints, juvenile arthritis affected individuals have to urged into flexibility and action.

Coping with joint disease is a huge challenge, but if you take it one step at a time you may continue to be motivated. Maintaining robust with your heart is the most important fight of most!

Keep in mind exactly how much foods you might be ingesting. Several rheumatoid arthritis victims basically have problems with undiagnosed foods sensitivities. Keep a journal of all things you eat, and be aware when flare-up signs occur. You will probably find that you find out which distinct foods object is bothering you.

When you have chronic joint inflammation, you should do homeopathy. Acupuncture has been proven to help relieve the pain related to joint disease. If you are using these strategies, keep doing them to accomplish optimum final results.

Always make the joints overall health a high priority. In case you have rheumatism, it is crucial that you steer clear of putting unnecessary anxiety on your own bones. This may make the soreness more extreme.

If rheumatism can make everyday duties difficult, get an individual to assist you reorganize your own home to work close to related restrictions. Place the most significant products in a region where one can gain access to them very easily. Like that, when you are having an rheumatoid arthritis flare-up, you may continue to reach the things that you need.

The industry of treatment is evolving at an unparalleled price, so you will discover a substantial chance of an arthritis heal getting designed in the foreseeable future. Right up until on that day, do everything you should to lower its effects. The advice supplied in this article can instruct you how to control the challenges that joint disease creates. That by itself is a huge support.Assist Your Arthritis Pain With This Particular Advice

Arthritis can be a severe condition that may have an effect on many kinds of people. Joint inflammation brings about unpleasant important joints and bones, among other things. These signs and symptoms can seriously slow down a person?s daily life.

Smoking cigarettes tobacco cigarettes can cause a decline in overall flexibility, and can make arthritis signs or symptoms worse. Even though it?s tough to stop smoking, it could assist to consider the way in a negative way affects your joint disease.

Take into consideration attending mental personality treatment method. This kind of therapies will allow you to change your negative behaviours and instruct you on to modify the way you consider. Therapy can enhance existence for all those using a lifestyle-extended health issues.

Only take sunscreen, and stay protected from Ultra violet rays. If you have rheumatoid arthritis, this makes your body more prone to get diseases like Lupus which can be due to exposure to the sun. Hide with garments or sun block, but be sure to still get healthy amounts of sunlight with out overdoing it, for the main benefit of your joint disease together with your health generally.

Scientific research have shown that modest consuming alcohol is not going to make joint disease worse. Remarkably, these research alternatively got to the final outcome that drinking reasonably could lessen the concentration of symptoms.

For those who have osteoarthritis in your leg important joints, it may be worth speaking with your personal doctor about electric powered activation treatment method. This treatment has been proven to lower discomfort from rheumatoid arthritis by reduction of inflammation.

Be well prepared. Arthritis can begin troubling you virtually whenever, so it is important to be prepared for in the event it occurs. Crack your work into small components allowing you to have the chance to acquire breaks.

Aquatic activities and drinking water aerobics are perfect workout routines for joint disease victims. Exercising under water is a great way to expand muscle tissues and bones, and getting into tepid to warm water also calms painful important joints. In the event you can?t go swimming, why not join a class?

Should you suffer from arthritis, be sure to put on high quality shoes or boots when exercising. Shoes or boots which are at the conclusion of their existence lead to your body bodyweight to be dispersed unevenly. This will increase the risk for discomfort within your important joints to intensify. Make sure to look at the put on on your shoes on a regular basis and replace them whenever you locate they are unequal.

Shedding additional weight can tremendously assist to ease arthritis pain. By eating a healthy diet plan full of food items who have contra?inflamation related components, it will help your stress and also joints irritation. This is certainly beneficial when you find yourself handling rheumatism.

Get lots of healthy proteins. Ingesting healthy proteins is very important to joint disease endures simply because once you have this disorder, the body will usually use more protein than the normal man or woman. In case you have preferred a vegan way of living, it is important that you find healthy health proteins resources and try to eat them usually to ease the indications of joint inflammation.

Your physician can prescribe several things that will help you handle joint disease. Start using these medications as your physician instructs, so that they can ease your discomfort. In case you are nonetheless experiencing plenty of soreness while on the medicine, you should talk to your medical doctor again to determine if nearly anything can be achieved.

There is a lot to understand when you are striving to deal with joint disease, and the only way become familiar with is to put in the effort and time to gain the maximum amount of knowledge as you can. Utilize this ideas as a place to start on your own journey to fight your joint disease.

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Source: http://www.welcometocoastcity.org/the-best-way-to-surpass-your-rheumatoid-arthritis.php

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Transform Your Desires Into Truth With Personal Loans British - Dom?

On-line Payday Loans Have Benefits
Its also wise to employ a banking accounts to receive the loan inside. Genuine for that loan should be no fewer than 18 years. Instant loans are created to give you cash which range from &pound100 to &pound1500 to get a shorter-period of two weeks, prior to your following payday. Though your paycheque may easily settle the loan about the due date, you're also allowed to flip the loan in the event that you choose the loan for an extended quantity of 30 days. You can use the loan for almost any personal function. You must not be concerned about your past cases of missed installments, defaults or CCJs, as we can organize important loans that don't in the least need any credit assessments from the creditors. So, you may receive the cash even with your small credit standing. loans bad credit The advantages of instant cash no appraisal of creditworthiness wanted loan Just one internet site affirms almost everything: regardless of whether your credit is good or bad credit, whether or not you've got no credit rating or you will just have slow credit history-this does not matter any more. Absolutely no generally advantageous to shoot for a flawless credit rating (all charges settled promptly, all loans completed inside final target time), people be taken in by immediate monetary recessions or tuition fee will increase. Due to big situations, we will lose out on our dues and repayments. And the next step is any time a time cash no appraisal of creditworthiness loan is most required. You'll discover quick demands that come up which make us to get a large amount of funds to your certain have to have. A crash, a death, a college need, or simply repayment for that mortgaged property or home. These matters out of the blue search from nowhere as well as leaving folks wondering-and having an anxiety attack-- whilst contemplating strategies to clear up their economical worries. It may help to master until this standard bank or a dependable loan company could provide you cash.
Instant Cash Loan: Benefit from the Appropriate Option Income
Review On the internet Payday Lenders - How to Find a Respectable Payday Loan You should assess online payday lenders just before getting them as some on-line payday loan merchants can provide an improved rate than others. When you need speedy cash with an net cash loan than it is essential to see exactly what the current market will give you around the interest rate that you'll be energized. It is suggested you don't go instantly to a payday loan financial institution but look for a web site who's going to be associated with a number of on the internet loan companies as the web pages have established to supply a rate plan for the client. All confronted by a very demands to have a payday loan is definitely an open up account in somewhat superior standing up, a comfortable revenue stream, and detection. Loan providers do not conduct the complete credit check needed or seek advice to find out if your customer can afford to repay the loan. The internet loan creditors will commonly provide about Usd100 - Usd1,500 and therefore are normally rather versatile in along repayment.
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Source: http://finance.test-web.cz/subdom/finance/content/transform-your-desires-truth-personal-loans-british

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Iraqi VP says innocent, terror trial a sham

BAGHDAD (AP) ? Iraq's fugitive Sunni vice president on Monday declared his "absolute innocence" in a terror trial that had sentenced him to death on charges of masterminding the murder of rivals, and rejected the conviction against him as a politically motivated sham.

Tariq al-Hashemi, who fled Iraq after the government brought charges against him, said he will not return to appeal the verdict unless he can be assured of a fair day in court.

Speaking from his exile in Turkey, al-Hashemi said a fair trial would be impossible in Baghdad and accused Prime Minister Nouri al-Maliki ? a Shiite and the vice president's longtime foe ? of manipulating the courts against him as part of a political vendetta.

"The verdict is unjust, politicized, illegitimate and I will not recognize it," al-Hashemi told reporters in the Turkish capital, Ankara. "But I put it as a medal of honor on my chest because it was al-Maliki, not anyone else, behind it. I'm proud that it is al-Maliki, and not anyone else, to target me."

"The death sentence is a price I have to pay due to my love for my country and my loyalty to my people," he added. "I reiterate that I'm innocent, and am ready to stand before a fair judicial system and not a corrupt one that is under al-Maliki's influence."

Asked directly if he will return to Baghdad within 30 days to seek a retrial, as is his right under Iraqi law, al-Hashemi said: "I'm not going, regardless of the time scale that has been offered to me."

Spokesmen for al-Maliki and the Iraqi government could not immediately be reached for comment Monday.

Al-Hashemi fled to Turkey after Iraq's Shiite-led government issued the terror charges against him in December, the day after U.S. troops withdrew from the country. He would receive a retrial if he agrees to return to Baghdad, but al-Hashemi has refused, saying he will never get a fair hearing in a Baghdad court.

The politically charged case sparked a government crisis and fueled Sunni Muslim and Kurdish resentment against al-Maliki, whom critics say is monopolizing power.

On Sunday, Baghdad's criminal court convicted al-Hashemi and his son-in-law, Ahmed Qahtan, of organizing the murders of a Shiite security official and a lawyer who had refused to help the vice president's allies in terror cases. In a third case, the two defendants were acquitted of the killing of a security officer due to a lack of evidence.

The charges were the first against al-Hashemi to go to trial among the government's allegations that he played a role in 150 bombings, assassinations and other attacks from 2005 to 2011 ? years in which the country was mired in sectarian violence that followed the 2003 U.S.-led invasion that ousted Saddam Hussein's Sunni regime. Most of the attacks were allegedly carried out by al-Hashemi's bodyguards and other employees, and largely targeted government officials, security forces and Shiite pilgrims.

The Baghdad court sentenced both al-Hashemi and Qahtan in absentia to death. They have 30 days to appeal the verdict and could win a retrial if they return to Iraq to face the charges.

Sunday's verdict was announced as Iraq reeled from a daylong pounding of bombings and shootings that left 92 people dead and more than 360 wounded in nearly two dozen attacks across the country. On Monday, in a statement posted on a militant website, al-Qaida's branch in Iraq claimed responsibility for the wave of violence and vowed there will be more "black days ahead."

Most of the court evidence against al-Hashemi came from 10 of his former bodyguards who testified they were ordered by Qahtan, and then paid, to carry out killings in small groups. Qahtan managed al-Hashemi's vice presidential office.

Al-Hashemi has long accused the government of torturing the bodyguards into giving false statements. His defense team did not offer any witnesses or testimony during the trial's ten hearings.

Al-Hashemi ? who has been in office since 2006 ? is on Interpol's most-wanted list, but Turkey has shown no interest in sending the vice president back to Baghdad, straining diplomacy between the two neighboring nations.

Al-Hashemi appeared defiantly upbeat at the packed press conference. "I am not worried about my life," he said. "I am worried about the future of my country."

___

Associated Press Writer Chris Torchia in Istanbul contributed to this report.

Source: http://news.yahoo.com/iraqi-vp-says-innocent-terror-trial-sham-083508712.html

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Keys to Business Marketing | Business Marketing

If you are new to the world of business marketing, you probably want to know more about how to do it, and do it in a productive manner. Here are some ideas to keep in mind as you start marketing your business.

Be genuine. Business marketing requires that you be genuine, because you want to establish trusting relationships to build on the long term for your business. Become actively involved in the business networks, and work to develop steady, strong, relationships.

Determine your goals. Before getting too deep into business marketing, it important to decide what your goals are so you can take the right steps and use the right tactics to take your business where you want it to go with marketing. It is important to become involved with networking as part of your business marketing strategy.

Become active in several networking groups. There are several different [business networking sites] you can become involved in to reach current customers, along with potential customers and even potential employees. Find groups your customers use to communicate with their friends and family, such as Facebook and Twitter. Use business specific networks such as LinkedIn, to help you connect with other businesses.

Volunteer. Become an active volunteer in your local community. This way, you can increase business exposure while giving back to those who have helped you, and those who need it the most. Volunteer at events and with organizations that are close to your business and choose a cause that matches your business goals.

Avoid yes or no questions. When networking with others during business marketing you don?t want to ask yes or no questions, because open ended questions will do more to help you learn about each other and build a foundation for the relationship.

Understand. Understand who and what you are as a business, what you do and why you do it. Understand how you do it so you can set yourself apart from the competition. A lack of clear understanding about what, when, where, and how you do it, will prohibit you from properly communicating with people you?re marketing with.

Quickly respond to referrals. When you are given a referral, it is important to follow up within 24 to 48 hours, to make sure you capture them at the peak of their interest. If you don?t follow up quickly, they will forget, or assume you have forgotten, either abandoning the idea, or moving to a competitor.

Keeping these things in mind when starting a business marketing campaign will help you be successful. It is important to market with a purpose to ensure you are on the right track to accomplish your business goals.

Source: http://www.a2ft.org/297-keys-to-business-marketing-2.html

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PPC Expert Gauher Chaudhry Grills Shaqir Hussyin of - SBWire

London, UK -- (SBWIRE) -- 09/10/2012 -- Gauher Chaudhry, a ?pay per click? (PPC) expert and well-respected authority on paid traffic, recently interviewed Shaqir Hussyin, the founder of SoloAdsAgency.com, on how it is possible to get two thousand leads a day.

Chaudhry is well-known throughout the industry as a leading expert on the topic of paid traffic, and specifically PPC traffic. He has almost 10 years of experience in this field of work, and has developed a well-deserved reputation as the premiere authority in this arena.

As an entrepreneur and internet marketing expert, Hussyin was thrilled to speak with Gauher Chaudhry on the methods he uses for lead and traffic generation, which includes the option to buy solo ads. The fact that he was interviewed by such a well-known PPC authority is a testament to Hussyin?s level of expertise in the paid traffic, solo ads traffic, and lead generation areas.

As a solo ads expert, Hussyin prides himself on providing the most premium high quality leads to advertisers, including through the Empower Network solo ads. He and his team of email marketing experts actively recruit, manage and optimize publishers, who help ensure that their clients? ads are being shown compliantly and are reaching the correct demographics.

?SoloAdsAgency leverages our network of premium email publishers to deliver targeted advertising to qualified prospects across multiple verticals and English-speaking regions,? an article Hussyin?s company?s website noted, adding that he and his staff are able to leverage their ?unique? access to over 100 million active email addresses that they and their partners utilise.

?We allow advertisers to efficiently increase their online reach through our strategic partnerships with online email publishers stretching across multiple countries and all domains. Ourselves, with our partners, have collectively spent well over $100 million in advertising.?

About SoloAdsAgency.com
For over the past three years, Shaqir Hussyin has taught thousands of home business owners simple yet little-known marketing strategies and techniques that have literally skyrocketed their income. As a Solo Ads Traffic Specialist and Founder of SoloAdsAgency.com, Hussyin has trained some of the largest internet marketing communities in the world, and has coached hundreds of people to new levels of success through seminars, private high-level workshops he has held, and webinars that have had over 7,500 registrants. Hussyin also offers his clients personal one-on-one consulting and mentoring. To listen to this free interview and learn more about done for you solo ad traffic, please visit http://www.soloadsagency.com/gauher-chaudhry-interviews-shaqir-hussyin-solo-ads-exposed

Source: http://www.sbwire.com/press-releases/ppc-expert-gauher-chaudhry-grills-shaqir-hussyin-of-soloadsagency-on-how-to-get-2000-leads-daily-162893.htm

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Make the Most of Your College Fees

The sticker price of a college education often includes a handful of mandatory fees to cover on-campus services.

At the University of California--Irvine, students pay a "campus spirit" fee, for example, and students at the University of California--Los Angeles are assessed a "green initiative" fee.

While some schools list out each fee--common charges include technology, health, building, and student activity fees--others lump them into one flat-rate tuition charge, and students typically pay for these services whether they use them or not.

To make your university fees work for you, check in with your resident adviser or stop by the office of the dean of students to find out about free and discounted services available both on and off campus. The following tips can also help college students ensure they're getting the most out of their tuition dollars:

1. Student health: Campus health centers aren't just for sick students. Revamped clinics offer everything from acupuncture to counseling for little to no cost.

"The campus health clinic isn't as exciting as access to a swimming pool or recreation area but it can have an enormous impact on general wellbeing," says University of Oregon alum Chris Grow. "It's a tremendous resource for STD tests, ... vaccinations, and general health concerns. They're also useful for getting a pulse on what viruses are going around campus."

[Find out what the Affordable Care Act means for college students.]

As colleges become smoke and tobacco free, health centers are also aiming to help students who want to quit smoking, says Paula Staight, director of health promotions at the University of Oregon, which gives students free nicotine patches or gum to help them kick their habit.

2. Technology: Computer labs and campus-wide wireless services are now commonplace at most colleges and universities, but there are other tech services available to students at many schools.

At the University of Iowa, for example, the ITS Help Desk will troubleshoot students' computer issues and resolve software or operating-system problems. For most repairs, the cost is covered by the university's mandatory technology fee.

[Discover new options for free online courses.]

Many colleges and universities also offer software such as anti-virus programs or Microsoft Office to students either free or deeply discounted.

3. Transportation: Students at urban schools often rely on public transportation for their campus commute, and some colleges charge a transportation fee that subsidizes transit system passes.

[Freshmen: Learn how to start college out on the right foot.]

University of Wisconsin--Madison's bus pass fee helps pays for on-campus bus and safe-ride services, but also gives students a pass for all bus routes on the Madison Metro Transit System.

Students at Amherst College in Massachusetts also get free access to the public bus system, which connects them to other area colleges--University of Massachusetts--Amherst, Hampshire College, Smith College, and Mount Holyoke College--and nearby towns.

Transportation services can also help students get off campus. Students at the University of California--San Diego can take advantage of a free airport shuttle during school breaks. Grinnell College in rural Iowa offers a similar service to its students, transporting them to the nearest airport, as well as downtown Chicago, at a discounted rate.

At the University of Texas--Austin, the Texas Express offers weekend shuttles with nonstop service to Dallas, Houston, and San Antonio. Round-trip tickets range from $40.50 to $55 for UT students and staff, and the Express typically offers two drop-off points in each city.

Students seem to be big fans of the Texas Express, as most weekend shuttles fill up well in advance, says Josh Cook, assistant director of communication at UT--Austin.

Searching for a college? Get our complete rankings of Best Colleges.

Source: http://news.yahoo.com/most-college-fees-144354021.html

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Consumer group sues FDA over Aricept safety

TRENTON, N.J. (AP) ? A consumer group pressing the Food and Drug Administration to remove the highest dose of an Alzheimer's disease drug from the market is suing the agency for what it calls "foot-dragging."

Public Citizen said Wednesday that the FDA's own medical and statistical reviewers found that high-dose Aricept doesn't work better at controlling symptoms of moderate-to-severe Alzheimer's than two low doses.

However, the group said the high dose has more-dangerous, potentially deadly side effects including vomiting, which in Alzheimer's patients "can lead to pneumonia, massive gastrointestinal bleeding, esophageal rupture or death." Other side effects more common at the high dose are nausea, diarrhea, anorexia and confusion.

Public Citizen filed a petition in May 2011 with the FDA. The group urged the agency to halt sales of the 23-milligram dose of Aricept and put safety warnings about the high-dose risks on two low doses, 5 and 10 milligrams. The low doses are available under both the Aricept brand, made by Japan's Eisai Co. Ltd., and as inexpensive generic pills.

The FDA has yet to act.

The lawsuit, filed in federal court in Washington, asks the court to declare the FDA's failure to act unlawful and to order the agency to decide within 30 days of the court's ruling whether to approve Public Citizen's request. The suit also seeks attorneys' fees and other reasonable costs.

"By ignoring Public Citizen's petition for more than a year, the agency has ignored (its) responsibility," Dr. Sidney Wolfe, director of Public Citizen's Health Research Group, said in a statement. "During the past year alone approximately 350,000 prescriptions have been filled in the U.S. for Aricept 23."

"Allowing Eisai to exploit and harm vulnerable patients with Alzheimer's disease is unconscionable," Wolfe added.

An FDA spokeswoman said Wednesday in an email that the agency doesn't comment on pending litigation. Last December, the associate policy director in its Center for Drug Evaluation and Research, Jane Axelrad, notified Public Citizen the FDA was doing a detailed evaluation of the case.

"FDA has been unable to reach a decision on your petition because it raises significant issues requiring extensive review and analysis by agency officials," she wrote. "We will respond to your petition as soon as we have reached a decision on your request."

Marcia Diljak, a spokeswoman at Eisai's U.S. subsidiary, Eisai Inc. of Woodcliff Lake, N.J., said the company was aware of the complaint filed against the FDA but won't comment on the litigation.

"We stand by the FDA's decision" to approve high-dose Aricept as a safe, effective Alzheimer's treatment, she wrote in an email.

According to Public Citizen, Eisai sought approval of the higher Aricept dose ahead of the November 2010 expiration of the patents for the two low doses. The ensuing generic competition would have slashed their sales.

The lawsuit states that the FDA required the company to prove in a study that the high dose improved patients' mental and physical functioning, but the study failed to show the high-dose "has any clinically meaningful benefit."

That led FDA's medical reviewer to recommend against approving the high dose, but the head of FDA's division of neurology products decided to approve the product anyway, the lawsuit states. The high dose was approved on July 23, 2010, extending Eisai's patent protection for an additional three years, the suit notes.

Associated Press

Source: http://hosted2.ap.org/APDEFAULT/bbd825583c8542898e6fa7d440b9febc/Article_2012-09-05-Alzheimer's%20Drug-FDA%20Lawsuit/id-52209a3af4dc40e89c5b6e9d4fdc66fb

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Social Media Marketing Strategy-How to Product One for Your ...

[unable to retrieve full-text content]You are here: Home / Internet Marketing / Social Media Marketing Strategy-How to Product One for Your Business ... Your business can use online social photo sharing websites such as Flickr and Facebook to its benefit.

Source: http://imspringboard.org/2012/09/09/social-media-marketing-strategy-how-to-product-one-for-your-business/

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Instagram For Video?Massive Market Opportunity, Yes! Done Right, No!

Oh, to become the Instagram for video! THAT is the dream of scores of new tech start-ups. And, that is the holy grail for all the VCs who continue to plow money into those companies. After all, Facebook just dropped a cool $1 billion on Instagram (well, actually closer to $700 million) ? and each of us can now easily capture pristine HD video on our smart phones that we carry at all times. That means personal HD video capture anytime, anywhere, and without any pre-planning. The sheer volume of personal UGC video has exploded. The potential market opportunity is massive. And, it is ripe. If it only were that easy.

Source: http://feedproxy.google.com/~r/Techcrunch/~3/fhftKIvg4bE/

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