Notes on the Sea and Ozymandias - 776 Words

Ozymandias Points to remember: 1. The statue of Ozymandias stands as a metaphor (symbol) of the temporal (not permanent) nature of political power. Time and history have a destructive power that brings all to an end. 2. The statue in the poem also symbolizes pride or ‘hubris’ (arrogance) of all humanity in any form it may take. 3. Material possessions do not last. 4. The poet points out to us that all that is left is art (the remains) and a few words (what is written on the pedestal). It seems therefore that art and language outlast the legacies of power. (see Shakespeare’s Sonnet LX) 5. In describing Ozymandias the poet distances him from our present reality in fact the narrator meets a traveller who describes the†¦show more content†¦Even the way the verses are placed like waves to completely immerse the reader into the atmosphere, shows imagination. In the first two stanzas the atmosphere at sea is wild and frightening. The poet describes the wild sea as if it is a ‘hungry dog’. This is a metaphor that carries along throughout the poem. The poet takes the qualities of a dog and transfers them to the sea, for example the sea is ‘giant and grey’ and it has ‘clashing teeth’ and ‘shaggy jaws’. The poet makes us imagine the atmosphere at sea when it is rough and dangerous. The repetition of the word ‘bones’ conveys an idea of rocks being eroded by the sea as it gnaws the rocks or else we are reminded of the bones of those whose life ended at sea. In the second stanza the rough sea becomes a stormy sea and the dog is now angry. The waves crash on the rocks and we can imagine the sea spray in the metaphor, ‘shaking his wet sides over the cliffs’. The poet also describes sounds in an imaginative way reminding us of the sounds made by a dog, ‘snu ffs and sniffs’ and ‘howls and hollos’. These alliterations emphasise the scary atmosphere with a kind of death-like omen. Even the moon in the sky seems to be ‘rocking’ because the wind is very strong and clouds are flying fast. There is a sudden contrast in stanza three, where the sea calms down and the ‘dog’ is sleeping peacefully. The atmosphere is calm and we imagineShow MoreRelated An Analysis Of British Literature Essay2728 Words   |  11 Pages/ Signifying nothing.quot; Macbeth thought life had no purpose and there was no afterlife. He compared life to being on quot;the banks and shoal of time,quot; because he life as an insignificant sand bank which would be covered over by the vast sea of time and eternity. Shakespeare used the character of Macbeth to show that if a person sacrifices his integrity and morals, religion is meaningless and the persons life has no purpose. Macbeths lack of belief in the afterlife was a sign of justRead MoreEssay On Anne Bradstreet2057 Words   |  9 Pagesnow in comparison to Biblical times. She feels that men just waste their limited days, â€Å"Living so little while we are alive.† While nature functions in cycles, man only has one chance. Once he dies, his time is over. As a Puritan, Anne Bradstreet notes that it is only man’s Earthly life that is brief, for â€Å"man was made for endless immortality.† In next section, the poet writes about sitting by a beautiful flowing river. She watches the fish swimming around and admires their ability to travel toRead MoreLiterary Group in British Poetry5631 Words   |  23 PagesAestheticism, and the Yellow 1890s 6.3 Comic verse 7 The 20th century 7.1 The first three decades 7.1.1 The Georgian poets and World War I 7.1.2 Modernism 7.2 The Thirties 7.3 The Forties 7.4 The Fifties 7.5 The 1960s and 1970s 8 English poetry now 9 Notes 10 See also 11 References 12 External links [edit]The earliest English poetry Main article: Old English poetry The first page of Beowulf The earliest known English poem is a hymn on the creation; Bede attributes this to Cà ¦dmon (fl. 658–680), who

The Free Market and European Union Law - Free Essay Example

Sample details Pages: 10 Words: 3031 Downloads: 1 Date added: 2017/06/26 Category Law Essay Type Essay any type Did you like this example? European Union (EU) legislation and the case law of the Court of justice (CJEU) attempt to ensure the free movement of goods within the internal market. In order to assess how well it ensures the free movement of goods, it is first necessary to identify what is meant by an internal market within the EU. Moreover, it is essential to ascertain how Treaty Articles, as well as, case law, regulate the EU as a customs union, since sometimes charges on imports and exports, within the internal market, may introduce restrictions to the free movement of goods. Don’t waste time! Our writers will create an original "The Free Market and European Union Law" essay for you Create order Finally, it is indispensable to pinpoint, how Treaty Articles and case law from the CJEU regulate quantitative restrictions on the free movement of goods within the union, due to the fact that quotas or even complete bans are restrictions to the free movement of goods. WHAT IS AN INTERNAL MARKET It is stated in Article 3(3) of the Treaty on the European Union (TEU) that à ¢Ã¢â€š ¬Ã…“the union shall establish an internal marketà ¢Ã¢â€š ¬Ã‚ . The internal market is defined under Article 26(2) of the Treaty on the Functioning of the European Union (TFEU).[1] Using a purposive approach to interpret this Treaty Article, it can be deduced that its aim is to achieve the free circulation of goods without the imposition of any restrictions within the Union. HOW TREATIES AND CASE LAW REGULATE THE EU CUSTOMS UNION à ¢Ã¢â€š ¬Ã…“It can be understood from Articles 26 and 28-32 of the TFEU that a customs union exists within the EU. This is because the EU has a common external ta riff, in addition to a free trade area.à ¢Ã¢â€š ¬Ã‚ [2] Article 30 TFEU restricts MS from imposing any custom duties on imports and exports, and any charges having an equivalent effect (CHEE). It also states that it covers à ¢Ã¢â€š ¬Ã…“all trade in goodsà ¢Ã¢â€š ¬Ã‚ . [3]The CJEU added clarity to the Treaty Article by providing a definition for à ¢Ã¢â€š ¬Ã…“goodsà ¢Ã¢â€š ¬Ã‚ . They were defined as à ¢Ã¢â€š ¬Ã…“products with monetary value and which are capable of forming the subject of commercial transactions.[4] A customs duty is comprised of two defining elements. To begin with, it is a pecuniary charge. Secondly, it is imposed on goods as a consequence of them crossing a border. It must be mentioned that custom duties can never be justified, due to the fact that they are a clear violation of Article 30. The prohibition of custom duties is a clear example of the EU ensuring the free movement of goods by using legislation in collaboration with case law from the CJEU. It has been provided by the CJEU that a duty may be classed as a CHEE, provided that it meets certain criteria: à ¢Ã¢â€š ¬Ã…“(a) it must be enforced unilaterally at the time of importation (b) it must be imposed only on a specific product which is imported from other MS whilst excluding such duties on similar domestic products; and (c) it must have the consequence of altering the price of the product.à ¢Ã¢â€š ¬Ã‚ [5] These criteria were further developed by the CJEU to include à ¢Ã¢â€š ¬Ã…“any pecuniary charge, however smallà ¢Ã¢â€š ¬Ã‚ .[6] Thus, it can be construed that there is à ¢Ã¢â€š ¬Ã…“no de minimis principle in relation to the Treaty articles relating to the free movement of goodsà ¢Ã¢â€š ¬Ã‚ .[7] Consequently, it can be argued that the EU safeguards the free movement of goods to a great extent, by restricting even the smallest CHEE. The CJEU has established its own set of rules on when charges can be made lawfully for services performed. An exam ple of such rules derived from rulings of the CJEU, was the one established in the case of Bresciani, where the rule that veterinary checks and charges implemented as a service are acceptable, was established. [8] Hence, the EU provides MS with some flexibility on when charges are justifiable, providing their primary motive is not the restriction of free movement of goods. The TFEU provides guidelines for taxes being placed on goods originating from other MS. The CJEU established that Article 90 EC (now 110 of the TFEU) was to have direct effect, and is an essential foundation of the Common Market. [9] Article 110 does not prohibit MS from imposing national taxation, however, it prohibits taxation that is deemed to discriminate between national products and imported products from other MS, either directly or indirectly. Furthermore, Article 110 prohibits MS from imposing internal taxations on imports in order to indirectly protect other products.[10] Further clarity to Article 11 0 was provided by the CJEU in Commission v France (Reprographic Machines), where the court provided a definition for à ¢Ã¢â€š ¬Ã…“taxationà ¢Ã¢â€š ¬Ã‚ . It was defined as à ¢Ã¢â€š ¬Ã…“a general system of internal dues applied systematically and in accordance with the same criteria to domestic products and imported products alikeà ¢Ã¢â€š ¬Ã‚ . [11] This is a clear example of how EU legislation and the CJEU ensure the free movement of goods. As abovementioned, Article 110 covers both direct and indirect discrimination. Direct discrimination is where nationally produced goods and imported goods, of a similar nature, are deliberately treated differently. Whereas indirect discrimination, ostensibly treats domestic and imported goods in the same way, however, the result is that imports are, in actual fact, disadvantaged. An example where the CJEU outlawed indirect discrimination was in the case of Humbolt v Directeur des Services Fiscaux.[12] In this case, the French system o f annual vehicle taxation, charged cars with lower power ratings with a lower tax than those with higher power ratings. Since France did not produce higher power rating cars, the French taxation methods were deemed to be a type of indirect discrimination. By catching both types of discrimination, this indicates that the EU ensures the free movement of goods by providing a wide scope for Article 110. It could be argued that, if Article 110 also prohibited MS from imposing national taxation, it would resolve all issues with regard to discriminatory taxation. However, MS are not willing to give up their sovereignty, thus, harmonization of internal taxations may actually be impossible. HOW TREATY ARTICLES AND CASE LAW REGULATE QUANTITATIVE RESTRICTIONS WITHIN THE INTERNAL MARKET Barriers to trade that do not involve direct payments of money, are referred to as quantitative restrictions. Articles 34-35 of the TFEU restrict MS from imposing quantitative restrictions on imports an d exports respectively. They also restrict MS from applying any measures having an equivalent effect (MHEE) on imports or exports. However, since restricting the free movement of exports is not a common occurrence, this essay will focus on Article 34 which regulates restrictions on imports. When it comes to identifying the scope of Article 34 of the TFEU, the CJEU has determined that it is directly effective, but only vertically against measures adopted by the state.[13] In some instances, the CJEU may be prepared to find that it also applies to private bodies where there is a substantial degree of state involvement or funding. This was certainly the case in Commission v Ireland (Buy Irish).[14] A campaign promoting domestically produced goods administered by the Irish Goods Council, but heavily subsidised by the government, was held to fall within the scope of Article 34 of the TFEU. This exemplifies the extent of Article 34, illustrating that the EU strives to achieve free move ment of goods in both public and private sectors of an economy. Similar to custom duties, quantitative restrictions are easy to identify. The CJEU clarified Article 34 of the TFEU by defining the term à ¢Ã¢â€š ¬Ã…“quantitative restrictionsà ¢Ã¢â€š ¬Ã‚  as à ¢Ã¢â€š ¬Ã…“measures that amount to a total or partial restraint of imports, exports or goods in transità ¢Ã¢â€š ¬Ã‚ .[15] Thus, illustrating that Articles 34 and 35 cover not only complete bans, but also quotas, showing that the EU attempts to ensure, not just partial, but complete free movement of goods. Measures having equivalent effect (MHEE) are harder to identify. However, clarifications are provided by secondary legislation and the jurisprudence of the CJEU. In the case of Dassonvile, the CJEU defined MHEE as à ¢Ã¢â€š ¬Ã…“all trading rules enacted by Member States which are capable of hindering, directly or indirectly, actually or potentially, intra-Community trade.à ¢Ã¢â€š ¬Ã‚  [16] This definition is exceedingly wide in scope, meaning that any measure which is capable of hindering imports or exports in any way will be caught by Article 34 or 35 of the TFEU. Tim Connor characterizes this definition as à ¢Ã¢â€š ¬Ã…“a potential weapon of mass destructionà ¢Ã¢â€š ¬Ã‚ .[17] This is because there existed an accumulating trend of persons involved in trade, calling upon Article 34 of the TFEU to challenge any rules which interfered with their commercial freedom.[18] Directive 70/50, even though now has expired, contains useful guidance on the scope of MHEE. The Directive recognises two classifications of MHEE. First under Article 2, it makes reference to measures which apply differently to domestic and imported goods. These measures are referred to as à ¢Ã¢â€š ¬Ã…“distinctly applicable measuresà ¢Ã¢â€š ¬Ã‚  due to the distinction made between domestically produced goods and imports. Secondly, under Article 3 the directive makes reference to measures that make no distinction be tween imported and domestic products. These measures are referred to as à ¢Ã¢â€š ¬Ã…“indistinctly applicable measuresà ¢Ã¢â€š ¬Ã‚  and may sometimes fall within the scope of Articles 34 and 35 of the TFEU. [19] The CJEU added the fundamental principle of à ¢Ã¢â€š ¬Ã…“mutual recognitionà ¢Ã¢â€š ¬Ã‚  to the free movement of goods in the case of Cassis de Dijon.[20] This principle provides that goods that are lawfully produced and marketed in one MS, should face no restrictions when being introduced into another MS. This is an example of the CJEU and its jurisprudence ensuring the free movement of goods within the internal market. EXCEPTIONS TO PROHIBITIONS OF QUANTITATIVE RESTRICTIONS AND MHEE Article 36 of the TFEU provides certain criteria where applying directly discriminatory quantitative restrictions may be acceptable. Such criteria include à ¢Ã¢â€š ¬Ã…“public morality, public policy or public security; the protection of health and life of humans, animals or plants; the protection of national treasures possessing artistic, historic or archaeological value; or the protection of industrial and commercial propertyà ¢Ã¢â€š ¬Ã‚ .[21] However, Article 36 goes further and states that the aforementioned justifications are subject to limitations. It states that à ¢Ã¢â€š ¬Ã…“such prohibitions or restrictions shall not, however, constitute a means of arbitrary discrimination or a disguised restriction on trade between Member States.à ¢Ã¢â€š ¬Ã‚ [22] Therefore, once again illustrating that even though MS are given certain leeway, the EU imposes restrictions to the derogations in order to ensure the free movement of goods. The aforementioned assumption of à ¢Ã¢â€š ¬Ã…“mutual recognitionà ¢Ã¢â€š ¬Ã‚  will sometimes be set aside if the à ¢Ã¢â€š ¬Ã…“rule of reasonà ¢Ã¢â€š ¬Ã‚  applies. It is provided by the à ¢Ã¢â€š ¬Ã…“rule of reasonà ¢Ã¢â€š ¬Ã‚  that barriers to trade resulting from product marketing provisions, that differ from those which apply in another MS, may be permissible so long as they satisfy one of the mandatory requirements. Mandatory requirements were listed in Cassis de Dijon by the CJEU as à ¢Ã¢â€š ¬Ã…“the effectiveness of fiscal supervision, the protection of public health, the fairness of consumer transaction and the defence of the consumerà ¢Ã¢â€š ¬Ã‚ .[23] On the other hand, this is a non-exhaustive list. The CJEU is prepared to accept other measures and interests which deserve protection being classed as mandatory requirements. An example of an additional measure which was accepted, was environmental grounds in the case of Commission v Denmark (Disposable Beer Cans).[24] It could be argued here, that this additional measure places a restriction on the free circulation of goods within the internal market. This is due to the fact that imported products would have to comply with Denmarkà ¢Ã¢â€š ¬Ã¢â€ž ¢s product marketing provisions in order for them to enter the Danish market. However, as characterised by Niamh Nic Shuibhne, justifications to the restrictions of free movement of goods are à ¢Ã¢â€š ¬Ã…“an evolving frameworkà ¢Ã¢â€š ¬Ã‚ . [25] Since environmental issues are of ever-growing societal concern, the CJEU has adapted to this by accepting environmental protection as a justification to MHEE. Taking a synoptic view, it could be argued that the CJEU, in such circumstances, places restrictions on the free movement of goods instead of ensuring it. As abovementioned, there existed an ever-growing tendency of trades calling upon Article 34 as a way of challenging any rules which contravened with their everyday commercial transactions. Such claims may have not even restricted the free movement of goods. Thus, the court considered the re-examination of case law, would be necessary to clarify the law concerning this matter, in order to limit the flow of unnecessary cases. Cases which came after Cassis uncovered a distinction separating à ¢Ã¢â€š ¬Ã… “indistinctly applicable measuresà ¢Ã¢â€š ¬Ã‚  into two categories. To begin with, there are rules which relate to goods themselves, known as à ¢Ã¢â€š ¬Ã…“dual burdenà ¢Ã¢â€š ¬Ã‚  rules. [26] The second set of rules, are concerned with the marketing of products. These are called à ¢Ã¢â€š ¬Ã…“equal burdenà ¢Ã¢â€š ¬Ã‚  rules. This because they impose the same burden (equal) on national and imported goods. This was articulated in the case Keck and Mithouard. In this case, Keck and Mithouard were prosecuted for breaking French competition law due to the fact that they were reselling goods at a loss. They had tried to use Article 34 as a defence, stating that this restricted the free movement of goods. However, the CJEU recognised that French legislation had restricted the total volume of sales. It added by stating that national efforts to prevent à ¢Ã¢â€š ¬Ã…“selling arrangementsà ¢Ã¢â€š ¬Ã‚  do not fall within the Dassonville formula for MHEE, à ¢Ã¢â€š ¬Ã…“provide d that those provisions apply to all affected traders operating within the national territory and provided that they affect in the same manner, in law and in fact, the marketing of domestic products and of those from other Member Statesà ¢Ã¢â€š ¬Ã‚ .[27] Provisions like these do not hinder market access for imports any more than they do for nationally produced goods, thus they fall outside of the scope of Article 34. However, even though they do not hinder market access to imports, it could be argued that this acts as an indirect discrimination on imports. This is due to the fact that national rules imposing a hypothetical, equal burden on imports and exports, nevertheless have a differential impact on each of them. Thus, creating uncertainty in the law. This was articulated by Advocate General Jacobs, where he stated à ¢Ã¢â€š ¬Ã…“the effect of the Keck judgement is still uncertain.à ¢Ã¢â€š ¬Ã‚  [28] Consequently, it can be construed that the CJEU justifies the discriminatory restrictions to the free movement of goods, thus, not ensuring the free movement of goods. On the other hand, it must be acknowledged that Keck only applies to à ¢Ã¢â€š ¬Ã…“selling arrangementsà ¢Ã¢â€š ¬Ã‚  such as, the opening hours of shops, [29]the types of retail stores that can sell certain types of goods, [30] as well as product advertising[31] but not to product characteristics. However, as aforementioned Keck specifies that a à ¢Ã¢â€š ¬Ã…“selling arrangementà ¢Ã¢â€š ¬Ã‚  will only be able to escape Article 34 if it applies to all traders that are affected in the nation. Thus, it could be argued that the EU, even though, it provides exceptions to the enforcement of Article 34, it places further restrictions on those exceptions, ensuring the free movement of goods. CONCLUSION In conclusion, it can be deduced that the EU does what it can in order to ensure the free movement of goods, whether it be through the passing of EU legislation, or through the jurispr udence of the CJEU. In 2013 intra-community trade was much higher than the level of exports to non-EU members.[32] This, gives the impression that a free circulation of goods is ensured within the internal market. On the other hand, cases concerning MS restricting the free movement of goods are still rising, giving the impression that a unified market still faces many obstacles. However the CJEU in coordination with EU legislation will overturn the situation and penalize those in breach of an EU fundamental principle, thus ensuring the free movement of goods. BIBLIOGRAPHY Connor T, à ¢Ã¢â€š ¬Ã‹Å"Accentuating the Positive: The à ¢Ã¢â€š ¬Ã…“Selling Arrangementà ¢Ã¢â€š ¬Ã‚ , The First Decade, and Beyondà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2005) 54 International Comparative Law Quarterly 127 European Commission, à ¢Ã¢â€š ¬Ã‹Å"Free Movement of Goods Guide to the Application of Treaty Provisions Governing the Free Movement of Goodsà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2010] Luxembourg: Publications Office of the European Union à ¢Ã¢â€š ¬Ã¢â‚¬ Ãƒ ¢Ã¢â€š ¬Ã¢â‚¬ , Free Trade Is a Source of Economic Growth (Luxembourg: Publications Office of the European Union 2013) à ¢Ã¢â€š ¬Ã‹Å"Eurostat- Statistics Explainedà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Eurostat) https://epp.eurostat.ec.europa.eu/statistics_explained/index.php/International_trade_in_goods#Intra-EU_trade Foster N, EU Law Directions (Oxford University Press 2012) Nic Shuibhne N, à ¢Ã¢â€š ¬Ã‹Å"The Free Movement of Goods and Article 28 ECÃÆ' ¢Ãƒ ¢Ã¢â‚¬Å¡Ã‚ ¬Ãƒâ€šÃ‚ ¯: An Evolving Frameworkà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2002) 27 European Law Review 408 Weatherill S, à ¢Ã¢â€š ¬Ã‹Å"FREE MOVEMENT OF GOODSà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2009) 58 International Comparative Law Quarterly 985 à ¢Ã¢â€š ¬Ã‹Å"Westlaw UK Online Legal Research from Sweet Maxwellà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Westlaw UK) https://legalresearch.westlaw.co.uk/ [1] Consolidated Version of the Treaty on the Functioning of the European Union [2008] Article 26(2) [2] Nigel Foster, EU Law Directions (Oxford University Press 2012) 264. [3] Consolidated Version of the Treaty on the Functioning of the European Union [2008] Article 30 [4] Case 7/68 Commission v Italy (Art Treasures) ECR 423 [5] Case 2-3/62 Commission v Luxembourg Belgium (Gingerbread) [1963] C.M.L.R. 199; [1962] 8 Recueil 813. [6] Case 24/68 Commission v Italy (Statistical Levy) [1969] ECR 193 [7] European Commission, à ¢Ã¢â€š ¬Ã‹Å"Free Movement of Goods Guide to the Application of Treaty Provisions Governing the Free Movement of Goodsà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2010] Luxembourg: Publications Office of the European Union 11. [8] Case 87/75 Bresciani [1976] ECR 129 [9] Case 57/65 Alfons LÃÆ' ¼tticke GmbH v Hauptzollamt Sarrelouis [1966] ECR 205 [10] Consolidated Version of the Treaty on the Functioning of the European Union [2008] Article 110 [11] C ase 90/79 Commission v France (Reprographic Machines) [1981] ECR 283 [12] Case 112/84 Humbolt v Directeur des Services Fiscaux [1985] ECR 1367 [13] Case 74/76 Ianelli and Volpi SpA v Meroni [1977] ECR 557 [14] Case 249/81 Commission v Ireland (Buy Irish) [1982] ECR 4005 [15] Case 2/73 Geddo v Ente Nazionale Risi [1974] ECR 865 [16] Case 8/74 Procureur du Roi v Dassonville [1974] ECR 837 [17] Tim Connor, à ¢Ã¢â€š ¬Ã‹Å"Accentuating the Positive: The à ¢Ã¢â€š ¬Ã…“Selling Arrangementà ¢Ã¢â€š ¬Ã‚ , The First Decade, and Beyondà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2005) 54 International Comparative Law Quarterly 127, 3. [18] European Commission (n 5) 12. [19] Commission Directive 1970/50/EEC 22 December 1969 based on the provisions of Article 33 (7), on the abolition of measures which have an effect equivalent to quantitative restrictions on imports and are not covered by other provisions adopted in pursuance of the EEC Treaty[1970] OJ L13/29 [20] Case 120/78 Rewe-Zentral AG v Bundesmonpolverwaltung fur Brantwein (Cassis de Dijon) [1979] ECR 649 [21] Consolidated Version of the Treaty on the Functioning of the European Union [2008] Article 36 [22] ibid [23] Case 120/78 Rewe-Zentral AG v Bundesmonpolverwaltung fur Brantwein (Cassis de Dijon) [1979] ECR 649 [24] Case 302/86 Commission v Denmark (Disposable Beer Cans) [1988] ECR 4607 [25] Niamh Nic Shuibhne, à ¢Ã¢â€š ¬Ã‹Å"The Free Movement of Goods and Article 28 ECÃÆ' ¢Ãƒ ¢Ã¢â‚¬Å¡Ã‚ ¬Ãƒâ€šÃ‚ ¯: An Evolving Frameworkà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2002) 27 European Law Review 408, 9. [26] Case 261/81 Walter Rau Lebensmittelwerke v De Smedt PVBA (Margarine) [1982] ECR 3961 [27] Cases 267-268/91 Keck and Mithuard [1993] ECR 6097 [28] Case 412/93 SociÃÆ' ©tÃÆ' © dImportation Edouard Leclerc-Siplec v TF1 PublicitÃÆ' © SA and M6 PublicitÃÆ' © SA [1995] ECR 179 [29] Cases 401-402/92 Tankstation t Heukske vof and J. B. E. Boermans [1994] ECR 2199 [30] Case 391/92 Commission v Greece [1995] ECR 1621 [31] Cases 34-36/95 Konsumentombudsmannen (KO) v De Agostini (Svenska) FÃÆ' ¶rlag AB [1997] ECR 3843 [32] à ¢Ã¢â€š ¬Ã‹Å"Eurostat- Statistics Explainedà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Eurostat) https://epp.eurostat.ec.europa.eu/statistics_explained/index.php/International_trade_in_goods#Intra-EU_trade.

What It Tkes to Be an Successful College Student Free Essays

What Does It Take To Be A Successful College Student? By: Vera Ioveino-Swett Some might say good grades and attending class is what it takes; however success is roe than just good grades and attendance. Success within life, education, or within anything we do comes through hard work and dedication. In our lifetimes we all have learned from our experiences as well as our education; success is one’s desire to become a better them, in addition to committing themselves to the path/journey which take them to their success of dreams and goals, something I like to call our finish line. We will write a custom essay sample on What It Tkes to Be an Successful College Student or any similar topic only for you Order Now We hold the key to succeed in our hands, as well as whether we succeed or fail lies and depends on us. Becoming a successful college student can be challenging at times and very frustrating. Many students attend college not fully knowing what it takes to be successful within their education, as well as that journey. Students who might have been an ‘A’ student in high school come to then find themselves just sot stressed and struggling with the challenges academically in college. Here are some strategies that will help you to achieve becoming the most successful student you can be. These are tips in which I follow, as well as only work for you as long as you dedicate yourself to them, and achieve what it is out of your education and life journey you seek. (If you can see it, you can achieve it). Strategies for College Success Strategy #1 – never be afraid to seek out help if and when you really need it. Strategy #2 – Create/develop a strategy plan that works within your learning style and preferences; in addition that will keep you focused and motivated. What might work for one, might not for another. Everyone is different. Strategy #3 – Make and set S. M. A. R. T Goals for yourself to ensure you reach what you would like to gain and achieve out of your term, semester, calluses, etc. They can consist of long-term, short-term or both. However, don’t make too many because it can become overwhelming, and distract you from achieving any or beginning them. You should also write your goals out on paper as well or on a sticky note so it is not just in your mind. This way seeing your goals in front of you on paper daily, will help you in becoming successful in accomplishing what it is you want to achieve. This can also help you not forget that you made a goal list. You can even reward yourself after each goal you accomplished/achieved to keep you motivated on knocking out the next one. It also helps develop goal-setting habits that will contribute to success within your life. Strategy #4 – Manage your time. Having good time- management, is key for success in college, but also adds a plus within your personal life as well as career. You can make a To Do List each day either for the week, month or both to help assist you remain, and stay on track. You also may want to after creating this list to find and delete/reduce your biggest time-wasters. Example – Instead of having a quick study session: create a 1 hour bock time to study that gives you 5-10 min breaks. Another would be – examine how much time you need for each class. So for let’s say an 3 credit hour class, you would want to give yourself around 6 hours of outside time each week; instead of trying to do it all at the last minute You will also gain a plus in this as well by remembering material effectively and longer. Another thing is to make sure to say NO to those who keep you away from your studies as well as activities like Facebook, or X-box, etc. Strategy #5 – Make sure to attend class as scheduled. Attending Seminar’s/class as scheduled will ensure you succeed in your classes because your professor can go over questions you may have as well as will go over material that just learning from your textbook doesn’t cut it or ensure remembering material or clarifying it. Being a part of an active class can also have you gain access to classmate’s questions or concerns which may be on a homework assignment or quiz in which your professor will go over and even may provide the answer to, or steps to how the answer is reached which is always a plus. Strategy #6 – Take notes. One way you may want to take notes is within a way that is systematic and becomes beneficial for exams, projects quizzes, etc. make sure to always date, and place the name of the class, Unit, Chapter, as well as titles and subtitles in your notes that are being discussed, and shown. Write down terms, definition’s, key points, examples, graphs, and diagrams; this will come in handy for review on/for tests, quizzes, projects, and studying later on. Do not write word from word as I do. Summarize discussions your professor is explaining in your own words except for terms and items mentioned above. Strategy #7 – READ! READ! READ! Make sure to preview the chapter rubrics, projects, assignments, etc. beforehand. It’s the same as when you preview a movie or a video game before purchasing it. This way you can get an idea of what the chapter, etc. will focus on. Then read the Introduction, and learning objectives in the chapter. This will give you a purpose to what you will achieve. One thing I found easier is to read a section first then go back to highlight the material. This will not just help with looing your spot, but also help to consume the material from your STM to your LTM since you will be reciting the material again as you highlight. You can then read out loud, important points, ideas, etc. , to ensure you understand the material and even have a family member or friend test you. Strategy #8 – Preparing for your Midterms/Finals. You are being prepared for your big tests from the very start of the first day of class. So everything from there on is to prepare you for what’s to come. First day I would open and copy the rubrics to Midterm, Final, exams then view each of them. One to two weeks before exams, consolidate all your notes (textbooks, seminar, discussions etc. ), review, and even place your rough draft threw the Writing Center for suggestions, and advice on grammar, formatting, citations, and sentence structure. The Writing Center pap0er review is a great way to ensure success for your finals, midterms, projects, as well as all written papers. When it comes to your tests/finals/midterms, make sure to always be prepared. Read all instructions and follow each one according to your professor’s rubrics. Don’t spend a lot of time on one question, you can always come back to it later on, and remember to always stay calm, though some anxiety is completely normal. Have Fun! Being organized, focused, and determined as you find your strategy plan, will bring you 100% success within and along your educational journey. Here’s a quote I live by and that helped me to get here today: In order to succeed you must fail, so that you know what not to do next time. – Anthony J. D’Angelo- How to cite What It Tkes to Be an Successful College Student, Essay examples

Business Information System Gaining and Sustaining

Question: Discuss about the Business Information System for Gaining and Sustaining. Answer: Introduction As the number of people who actively seek jobs are growing, with that companies who make professional and creative resume will be in demand. This report will first present a Resume, in the second part analysis of the business would be done using Porters five forces and generic strategy framework. Finally, a data dictionary has been proposed. Resume I am seeking a dynamic organization where I enhance my professional skills and use my experience and education to achieve the organization objectives. Educational history: Duration Degree Stream Name of institution 1993-1997 Bachelor degree Marketing and Commerce Melbourne University 1998- 2000 Masters Degree Marketing London University 2001 Managers course Management University of Geelong Previous employment: 1. Lecturer of discipline of marketing in Victoria University during 2000 2002. 2. Lecturer of discipline of marketing in Monash University during 2002 2005. 3. Marketing, Media and Business Development Manager in Hudson Incorporated during 2006 - 2011. 4. Marketing and Development Coordinator in Jazz Company, Melbourne during 2012 -2014. Publication record J Brown, M Hearne, S Lim, (2007) Knowing Your Customers: How Salesperson Perceptions Influence your profit. Journal of Marketing, Vol. 76, No. 3, pp. 34-56 J Brown, X Lee, Z Fin, and J Asara (2013) Marketing Effectiveness and Price Discounts. American Journal of Marketing, Vol. 20, No. 6, pp. 120-141. J Brown, M Hane, B Long, (2000) Marketing and Communication. ANZ Journal of Marketing, Vol. 12, No. 1, pp. 22-33 Awards: Got Scholarship for Research at Melbourne University in 1997 Marketing Australia prize in 2008 by Marketing Association of Australia Marketing and management prize in 2009 by Marketing Association of Victoria Hobbies: Fishing Painting Woodwork Porters five force model and three generic strategy Porters competitive forces in relation to Resume writing Threat of new entrants to the market: There are very few resume making organizations present in market. Barriers to entry like investment, licensing, infrastructure required are not very significant and with the option of eCommerce, threat of new entrant is quite high in this market. Therefore, large number of companies wants to entre in this segment and barriers to entry are also relatively low (Roy, 2011). If resume-making organization wants to overcome this threat organization shall maintain the cost advantage, specialist knowledge, new technology adoption and economy of scale. By adopting this organization can mitigate the hurdle for new entrants and get distinct position in the marketplace. The substitute products: Sometime organization suffers big losses due to the substitute products. Customer chose substitute product when they found substitute is more lucrative such as when the cost of product of organization is higher than substitute product and they do not perceive any relative value in paying premium pricing. For resume making organizations, substitute products are various resume making software and mobile applications that are available in market with low cost. Therefore, Performance and quality of resume making origination is also influenced due to availability of its substitutes. This affects the market share and profitability of the resume writing organization. Knowledge and bargaining power of the customer: Customer is the person who can affect the business of the organization. In present world, customers have a good knowledge about the market environment and products, so they can choose product that is best and cheaper. Price sensitivity is one of the major thing that customer gave focus on it. In resume making organization, the value of customer is very high because the number of customers is limited. As well, the option before the customer is available in form of other companies and switching cost is also insignificant (Koontz andWeihrich 2015). Organization cannot bear the switching of single customer to another organization. This affects the organizations strategy and market share. Suppliers bargaining power: Sometime supplier can do changes in the prices and it affects adversely the organization in terms of increased production cost. Supplier does this when they have some uniqueness in their product and number of suppliers is less in the market. In resume writing organization, suppliers are the brokers that gave clients to the organization. So, the probability of number of suppliers is less in the market. This states that the bargaining power of supplier is high to resume writing organization. It affects pricing strategy of the resume writing organization. Rivalry among the competitors: This thing happens when the number of business players is large in the market. In the concern of the given industry, the number of players is increasing however, quality and effective customer services are still key differentiators. Qualities of product, market price of product are same for close sompe. In this situation, the customers have large amount of options, if they do not find right quality and price, then the can switch the organization. In resume making organization, the product that organization offering are same. So, quality of product and the price of the product are the two things that differentiate their product. The quality is dependent on the efficient work done by the employees. So, resume making organizations have to give proper training to their employees to overcome this problem. Porters three generic strategies for competitive advantage The three competitive advantages of porter are cost leadership, differentiation, and focus. These three strategies are the heart of business management. The cost leadership is the strategy in which organization focuses to cut down the cost of production to sell the product at cheaper rate in comparison to its competitors. Cost leadership increases the earning of the organization but sometimes it affects on the quality of production. While reducing the cost of product organization sometime reduce quality measure (Young and Burgess 2010). Under cost leadership, organizations focus on quantity and earning rather than quality and efficiency. Differentiation is also one of the major competitive strategies to get success in business. Under differentiation, organization makes some innovations in the product and makes them unique and different (Magretta, 2013). Differentiation strategy create distinct image of the company in the market. If organization has differentiation in their product, then they can sell the product on high cost also. Apple is the live example that is using differentiation strategy. Focus is the competitive strategy in that organization focuses on particular things. These things are targeting to particular market, age group customers. Under this competitive strategy, organization is trying to find out the need and desires of the particular group and area (Barney, 1997). Basically, in these strategy, organizations main focus is to maintain the brand loyalty in the market, so they capture good market share and maintain their image in the market. Competitive strategies adopted by resume making organization. Resume making organization can use differentiation strategy to get growth. In market, there are very low number of resume making organizations are there. So, there is possibility of coming of new entrants in the market. The consumers of resume making organization are also well educated they have a great ability to analyze the product. So, organization should make some innovation, differentiation in the product to get some uniqueness in the product. Along with this there are also various tools of resume making are available in market such as various software that are available free of cost or at lesser cost (Rothaermel, 2015). Hence, customer can make ordinary resume easily. He only goes to organization if he thinks or found something unique or different in their product. The competitors are also trying to grape the customers by providing the various options and designs to attract them. Therefore, to overcome the problem of competitors and maintain a good cliental, it is very necessar y for resume making organization to adopt the porters differentiation competitive strategy. Basic data dictionary for your database Data dictionary is a dictionary about data, which is stored in a database. It is a collection of a description of data objects. It contains all the information about the data object like tables, columns, functions, constraints, views, triggers etc (Ooi et al, 2014). It also contains how much space is allocated to data objects and how much space is use by them, so data dictionary provides physical information like where the data is stored in a database table. Below is the sample data dictionary view of the client table. Table name Field name Data type Data size Client Client_id int 10 Client Firstname varchar 10 Client Middlename varchar 10 Client Lastnmae varchar 10 Client Gender char 10 Client Email_id varchar 25 Client Address varchar 40 Client DOB date 8 Client Careereobjective varchar 50 Client Collegename varchar 25 Client Year_of_graduation date 8 Client Schoolname varchar 25 Client Year_of_schooling date 8 Client Stream varchar 25 Client Mobilenumber bigint 10 Client Nationality varchar 15 Client Year_of_first_job date 8 Client Previous_company varchar 30 Client Department varchar 25 Client Workexperience varchar 200 Client Awards varchar 100 References: 50MINUTES.COM(2015)Porter's Five Forces: Stay ahead of the competition.USA: 50 Minutes. Barney, J.(1997). Gaining and sustaining competitive advantage (pp. 134-175). Reading, MA: Addison-Wesley. Koontz,H. andWeihrich,H. (2015) Essentials of Management: An International, Innovation, and Leadership Perspective. USA: McGraw-Hill Education. Ooi, Li, F., zsu, B.C., and Wu, S. (2014) Distributed data management using MapReduce. ACM Computing Surveys (CSUR), 46(3), p.31. Magretta, J. (2013)Understanding Michael Porter: The Essential Guide to Competition and Strategy.USA: Harvard Business Press. Rothaermel, F.( 2015). Strategic management. USA: McGraw-Hill. Roy, D. (2011) Strategic Foresight and Porter's Five Forces. Germany: GRIN Verlag. Young,L. and Burgess, B. (2010) Marketing Technology as a Service: Proven Techniques that Create Value. USA: John Wiley Sons.