Liability of ISPS for Content Hosted by Them

June 22nd, 2008 by medriasherlock

By Nasir Ayyaz Our society has now evolved as an Information Society. Now the paper based newspapers are being replaced by the dynamic websites, which are sometimes being managed by intelligent agents. Where at one hand where this evolution has brought us the knowledge explosion and now access to information is easier than ever before, on the other hand new issues have also emerged and legislator is confronted with new challenges. One of these issues is the question regarding liability of intermediaries (ISPs) for the infringements over the internet. There are no boundaries and anything which is published on internet becomes worldly public the next moment. This ease of worldwide publication has invoked new threats to the society as well. It has disturbed the whole system of copyrights, civil liberties, protection against ethnic and religious exploitation, law of defamation, child pornography and cyber-terrorism. In such a situation it may not be easy to let ISPs go without any liability for the material hosted on them. However, at the same time it may also not be an easy task for the ISPs (even if they want to do so) to keep a check on all the materials hosted with them. The situation becomes even more trivial when it comes to territoriality of law. The situation is yet be addressed by the legislator in Pakistan. This article is an attempt to highlight the issues concerning the liability of ISPs consequent to the material hosted by them and remedies adopted by the Europe and America. What is an ISP:In general Internet Service Providers (ISP) perform various functions and offer a variety of services like access to internet, hosting of information on internet, network services etc. EU Directive 2000/31/EC has defined service providers as any natural or legal person providing information society services. The term information society services is further elaborated in Article 1(2) of the Directive 98/34/EC as any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services.However, for the purposes of this article only the aspect regarding hosting of information on the internet will be discussed. Nature of Liability of ISPs: It is important to understand that ISPs are usually not a direct beneficiary of the crimes/civil wrongs committed by their subscribers. They are usually remunerated for their services regardless of the content published over the internet. There can be two instances of liabilities for the material hosted on internet:i. Criminal Liability: Criminal liability of ISPs may arise out of the crimes committed over the internet. These may include child pornography, cyber-terrorism, infringement of copyrights etc. ii. Civil Liability: Civil liability refers to instances where ISPs may be sued by private persons or organizations for infringements of their civil rights. Instances of civil liability may include an action for defamation, copyright infringement etc. Both criminal and civil liabilities have their own requisites, which sometimes also vary in a great deal for specific wrongs. In order to constitute criminal liability two elements are very necessary to be there: i. Mens Rea : Mens rea refers to a guilty mind. In order to constitute a person liable for a criminal wrong it is important to establish that the act was done with an intent to do it in a harmful way. However, the requirements to establish mens rea vary according to the definition of wrong. It purely depends on the ingredients of a specific crime that what may constitute mens rea. It ranges from an act done recklessly to the clear dishonest intentions. ii. Actus Rea: Along with a guilty mind the presence of actual act is also necessary. This act can be an act of abetment or helping and aiding a crime or can be actual commission of the crime. Unlike a criminal act, a tort does not require the presence of guilty mind and it may be a tort may sufficiently be proved if the commission of an act falling under the definition of a tort (or a civil wrong) has been proved. Of course, there always exist the exception to both criminal and civil wrongs and one has the defenses warranted by law. Like an act done in self-defence or contributory negligence etc. A detailed discussion of each wrong is necessary as to decide the question of imposition of liability on ISP in each respective case. However, this is not the aim of this article and the author shall endeavor to discuss the question of holding ISP liable from its jurisprudential point of view. During the discussion reference will also be made to the EU and American laws on the subject. Requisite for Imposing a Liability on an ISP: Responsibility follows liability and liability arises out of responsibility. In order to impose a liability, it is necessary to decide whether ISPs can be assigned the responsibility of checking the material hosting with them. Where means are not within reach of the subject, the responsibility automatically gets frustrated. Therefore, this responsibility is to be within the powers and limitations of ISPs. The question implies a consideration of economical, technological as well as social aspects of the same. Economical Aspects:Information over the internet is very dynamic and the owner of websites are at liberty to change the contents every moment and in most of the cases it also happens so. Secondly the size of the information hosted with the ISP is in terra bytes and it may scrutinize several months. Even if the ISPs higher enough human resource to keep a track of ever changing information over the internet (although it is next to impossible), the cost of the same is going to touch sky. The burden will automatically going to be shifted to the consumer and thus ultimately resulting in an obstruction to free flow of information. Technological Aspects:ISPs are not yet equipped with requisite technology to avoid the violations over the internet. This requires high-tech language and image processing and surely the technology is so far not that advanced to cop with the problem by embedding technological measures in the servers of ISPs. Social Aspects:By assigning a responsibility to ISPs to monitor the content hosted with them, we may empower ISPs with an unjustified power of censorship and ISPs may ultimately get into a position from where they can regulate the information over the internet according to their own wishes and whims. These ISPs may become judicial institutions while deciding which information is to be published and which is not.Secondly, the flow of information over the internet may become very slow and ultimately result internt as a static world and society thereby lose its interest in the same causing the whole web to fall down.It is important to note here that the internet is totally different from paper world where publishers can easily scrutinize the contents of publication. Internet is meant to be a dynamic world where information is updated every next moment. Without this ability internet will no more be of interest. In view of the above discussion it is very clear that we cannot assign this responsibility to ISPs in this regard and we have to find different solutions while compromising with the situation. What is the Basic Idea:One point to start the process of thinking can be with the question, what we really want. Is this the imposition of liability on ISP what we really want. Is this a goal or a mean to achieve some other more specific goal? This question maybe differently answered by different stakeholders. From the perspective of copyright owners, the answer is simply a YES. Because they want to be compensated for the damage caused to them by the unauthorized publication of copyrighted material over the internet where copying is just a matter to on click. Usually the person actually publishing the copyrighted material over the internet is an ordinary person who is not so wealthy to compensate the loss done to the owner of copyrighted material and therefore, the copyright owner will be more interested in suing the respective ISP who is usually a rich company and much can be recovered from it. However, the idea is not to hold ISPs liable but to avoid commission of offences/wrongs over the internet. Holding ISPs liable is not an end to achieve but a mean to achieve other ends. So in this situation we must have to consider other possible solutions to the problem as well and if we fail to find any other possible solutions then it may be our final resort because law has to provide protection to the rights granted by it. However, in authors opinion there exist certain solutions to this problem, which may provide adequate level of security to all the stakeholders without adversely affecting the freedom of expression and the ultimate theme of internet. Possible Types of Liability of ISPs: In view of the above discussion following can be the possible options before us. These options were considered in during the passing of Digital Millennium Copyrights Act. This article is focused only few main points of the discussion in this regard. i. Strict Liability:According to Strict Liability criteria, ISPs may be held responsible for all the material hosted with them irrespective of their level of knowledge. One argument in support of imposition of strict liability can be that the ISPs are remunerated for the services provided by them and therefore, like all the other big publishers and distributors are under a responsibility to review the material hosted on them.However, the argument against the imposition of strict liability can be that the situation of ISPs is very different from the distribution companies as ISPs are dealing with the electronic environment where information is changing every second and it is not possible to review this changing information. ii. Vicarious Liability:Vicarious liability can be defined as the liability imposed on a defendant in the circumstances when he had the right and ability to supervise the infringing activity and had direct financial gain from the same.The imposition of vicarious liability is hit by the argument that there does not exist any employer servant relationship between the subscribers and ISPs and furthermore, that the ISPs are remunerated for their services irrespective of the content of the service i.e. ISPs are not directly benefited (besides those special cases where an ISP is itself owns a particular website) from the activities performed by the subscribers. iii. With Fault Liability:This is an instance where an ISP has the knowledge about the infringing material.There are mainly two different standards of knowledge constructive knowledge and actual knowledge. ISPs being the host of the infringing material are presumed to have constructive knowledge of the material so hosted. Therefore, ISPs argue that the standard of knowledge to be applied must be actual knowledge. iv. No Liability:The fourth option in this regard can be no liability. In such case, ISPs may not be held responsible for an infringing activity even if they have the actual and informed knowledge of the same. EU Law: Article 14 of the said Directive regulates the liability of the service provider for the information stored on them as under: 1. Where an information society service is provided that consists of the storage of information provided by a recipient of the service, Member States shall ensure that the service provider is not liable for the information stored at the request of a recipient of the service, on condition that: (a) the provider does not have actual knowledge of illegal activity or information and, as regards claims for damages, is not aware of facts or circumstances from which the illegal activity or information is apparent; or (b) the provider, upon obtaining such knowledge or awareness, acts expeditiously to remove or to disable access to the information. 2. Paragraph 1 shall not apply when the recipient of the service is acting under the `authority or the control of the provider. 3. This Article shall not affect the possibility for a court or administrative authority, in accordance with Member States’ legal systems, of requiring the service provider to terminate or prevent an infringement, nor does it affect the possibility for Member States of establishing procedures governing the removal or disabling of access to information. Information Society Services are defined in Directive 98/34/EC as:2). service: any Information Society service, that is to say, any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services.For the purposes of this definition:- at a distance: means that the service is provided without the parties being simultaneously present,- by electronic means: means that the service is sent initially and received at its destination by means of electronic equipment for the processing (including digital compression) and storage of data, and entirely transmitted, conveyed and received by wire, by radio, by optical means or by other electromagnetic means,- at the individual request of a recipient of services: means that the service is provided through the transmission of data on individual re It is interesting to note here that even if the service provider may have the knowledge of the illegal activity or defamatory material, it may not be held responsible if the illegal activity has been removed or access to information has been disabled. Furthermore, under Article 15 of the same directive, the member States are also debarred from imposing any general liability on ISPs to monitor the content hosted with them. American Law-Digital Millenium Copyright Act: In America, the liability of intermediaries over the internet is regulated by Digital Millenium Copyright Act of 1998 Section 512(c) limits the liability of service providers for infringing material on websites (or other information repositories) hosted on their systems. It applies to storage at the direction of a user. In order to be eligible for the limitation, the following conditions must be met: o The provider must not have the requisite level of knowledge of the infringing activity.o If the provider has the right and ability to control the infringing activity, it must not receive a financial benefit directly attributable to the infringing activity.o Upon receiving proper notification of claimed infringement, the provider must expeditiously take down or block access to the material. In addition, a service provider must have filed with the Copyright Office a designation of an agent to receive notifications of claimed infringement. The Office provides a suggested form for the purpose of designating an agent (http://www.loc.gov/copyright/onlinesp/) and maintains a list of agents on the Copyright Office website (http://www.loc.gov/copyright/onlinesp/list/). The terms actual knowledge, information society services and expeditiously have their own judicial meanings and require separate and detailed elaboration. However, the space does not allow author to go into the details of these terms. But it is note worthy that the idea behind both the legislations is same and that is to hold ISPs liable only if they have the actual knowledge of the infringing material and fail to disable access to same expeditiously. The actual knowledge criterion as opposed to constructive knowledge does not generate much ambiguity, as it is a well-established principle within the member states that actual knowledge means that the defendant actually knew about the infringing material. It is also pertinent to mention here that the actual knowledge criteria may also shift the burden of prove on the plaintiff, where plaintiff may be required to prove the actual knowledge of the ISP about the infringing activity or information. While concluding the above discussion it can be said that the limited liability imposed on ISPs is well-justified and serves the purpose without obstructing the free flow of information and damaging the theme of internet. However, one must not forget that nothing is permanent in this dynamic world except change, and therefore, as the technology emerges new solution to the said problem may be proposed. One aspect of which can be embedding of technology into the ISPs servers in order to detect the copyrights infringements by the material being hosted on them and therefore, restricting the publication of the same. The digital certificates may also be considered as a useful mean to avoid infringements in this regard. Reference: Please see Liability of Intermediaries for Copyright Infringement in the Case of Hosting on the Internet by Jonina S. Larusdottir published in Scandinavian Studies in Law Vol.47 IT Law. www.copyright.gov/legislation/dmca.pdf http://europa.eu.int/eur-lex/lex/en/index.htm The Author is a law graduate presently studying LL.M. (IT Laws) at Stockholm University, Sweden. In addition to legal education author has also done M.Sc. in computer sciences. He is also a practicing lawyer in Pakistan and can be contacted at nasirayyaz@yahoo.com. Article Source: http://EzineArticles.com/?expert=Nasir_Ayyaz http://EzineArticles.com/?Liability-of-ISPS-for-Content-Hosted-by-Them&id=89471 payday cash advance interest rates on personal loans cash advance on credit card sba 504 loan program

Women And There Obsession With The Scale

June 15th, 2008 by medriasherlock

By William Mackie Far too often, I hear women complain after starting to workout with weights that their body weight is not going down or may even be going up a bit. What these women have to understand, especially thin women is that they are now adding on quality muscle which initially will add body weight or prevent them from losing weight. This is because muscle has significant weight value. However, in the long term women who workout with weights will be better off than those that do not. Lean muscle helps to increase the bodys metabolism helping a person to burn calories and fat through out the day even when not working out thus keeping there bodies lean and avoiding weight flux even during times when not working out. Though I am not recommending it, a person who has more lean muscle can get away with having cheat meals occasionally because the muscle they have developed are like a furnace that is constantly burning up those calories twenty four seven. Everyone needs to cheat occasionally, but thats a story for another time. Lean muscle also makes the body look more appealing. A person may weigh significantly more than they appear to others when they have more lean muscle. Those with lean muscle will seem more toned and will have much less excess fat and skin hanging loose off of the body. Women can obtain tight lifted butts, arms and a lean looking midsection through weight training that cardiovascular exercise can not do alone. Those that focus on cardiovascular alone will achieve weight loss if done properly, but will notice a large amount of excess skin and have flabby common areas often found on women such as behind the arms and in between the thighs. Women in the beginning of starting a weight training program should pay more attention to how there clothes fit and measure themselves in inches instead of pounds. The scale should not be of too much concern. The weight will come off the scale soon enough, just be patient and understand the value of the calorie. Women, including those that are so concerned with what the scale reads can lose body weight by understanding calorie intake and expenditure. Not just women, but anyone that increases there cardiovascular exercise and/or decrease there calorie intake can achieve fat loss. Making small changes in the number of calories taken in or expended can achieve this. However, these changes must be done carefully and slowly. Maintaining an adequate nutrient intake of vitamins is very important even while trying to lose weight. Calories only need to be reduced enough to cause weight loss. Once one reaches a plateau in which weight loss is not occurring then further small increments of the reduction of calorie intake or increase in calorie expenditure is needed. This can be done until one reaches there desired healthy weight goal. The key word here being when one reaches there healthy weight goal. Seeking a weight loss goal that is disproportionate to ones height is not advised and can be very harmful to there health. Also, starvation will not achieve weight loss goals in the long term. The body needs adequate nutrients through out the day and if it thinks it is starving, it will hold on to every bit of fat it possibly can at a certain point. Also, a person will feel extreme fatigue and agitation, along with many other serious potential health problems. Long term weight training is very beneficial to women and will help to make there bodys lean and tight all over. Weight training is a crucial compliment to a proper weight loss cardiovascular program and healthy eating plan. Did I mention the hundreds of other benefits of weight training? This includes stronger bones, greater strength and endurance to help accomplish daily tasks, reduction in cancer risk and other illness, easier birth delivery for pregnant women and so much more. Get a full weight loss plan from a certified personal trainer at http://www.upstarttrain.com/ Good Luck, William C. Mackie CPT, M.S. William C. Mackie has been in the fitness industry for over five years and has ten years of personal exercise experience. He holds a bachelors degree in History and a Master’s of Science degree in Recreational Administration. He has also completed numerous exercise science courses from Human Nutrition to Human Anatomy, and is a nationally certified personal trainer through the National Exercise and Sports Trainers Association (N.E.S.T.A.). Willam Mackie holds certifications in Cardio-kick boxing, Senior Fitness, and Pilates. He has a wide range of experience in many other types of fitness class instruction, personally training an entire spectrum of ages, body types and goal aspirations with great success. He works with numerous athletes as well. He has written numerous online health and fitness articles, worked both as an independent professional and as a program coordinator, trainer and class instructor at a leading fitness and recreation center. Article Source: http://EzineArticles.com/?expert=William_Mackie http://EzineArticles.com/?Women-And-There-Obsession-With-The-Scale&id=491287 credit loan military payday problem personal loans & private lenders & toronto ontario how much taxes are deducted from a paycheck boston massachusetts guranteed payday loans

Embellishing and Customizing Your Cell Phone

June 7th, 2008 by medriasherlock

By [http://ezinearticles.com/?expert=Lydia_Quinn]Lydia Quinn There are many ways to customize and embellish your cell phone to make it reflect your personality and lifestyle. Here are a few of the most popular ways to customize and embellish your new cell phone: Ringtones A new cell phone comes with a boring standard cell phone ring. Fortunately, you can change your cell phone’s ring to a different ring, called a ringtone. Ringtones are available in many different types including standard midi music type rings, actual audio of songs, a sound or speech. You can even set your phone to use a different ringtone for different incoming callers. Mainstream music ringtones are available and very popular. You can get a ringtone for just about any current popular song and many older songs as well. You can download these to your phone online or using your phone. Wallpaper Most phones have wallpaper backgrounds that can be changed. There are wallpapers available depicting symbols, nature, wildlife, landscapes, cities, people, TV and music stars, movie stars, and you can even make your own very easily should your phone be equipped with a camera. Screensavers Some phones use a screensaver, which traditionally were used on computers to prevent screen burn in from images present on computer monitors for many hours or days at a time. Today, screesavers are available with animation, music, photos and slideshows. Skins There are also skins or stickers available for many cell phone models. These encase you phone in an image or color and can come in officially licensed versions for sports teams, tv series, cartoons, movies and more. Usually made of flexible vinyl, they can be taken off if needed. Jewelry There’s all kinds of jewelry you can stick on your phone, including rhinestones in all shapes, sizes and colors, faux pearls, faux colored stones plus fake flowers and frilly ribbons. Decorate your phone with clear rhinestones to add a diamond like sparkle to your cell phone. Accessories Phone straps are available in many colors and styles and even in Hello Kitty themes. There are also neck straps, pouches and toys that are available to attach to your cell phone or cell phone case. Downloads & Settings Don’t forget to set up your phone to give you the latest weather, sports scores, horoscope and news according to your interests. You can also download games for when you are stuck at the airport waiting for a flight or stuck in traffic. Whatever customizations and embellishments you choose, make sure they reflect you and your unique personality and sense of style. Lydia Quinn writes for Free-Ringtones.uk.net, where you can get ringtones for your cell phone for free. Visit us at: http://www.free-ringtones.uk.net/ Article Source: http://EzineArticles.com/?expert=Lydia_Quinn http://EzineArticles.com/?Embellishing-and-Customizing-Your-Cell-Phone&id=396302 approvalcardcreditonline payday form phoenix homes for rent no credit check 5000 cash loan duluth mn bad credit auto loan

Peer Pressure- Decisions That We Make In Unprepared Times

June 1st, 2008 by medriasherlock

By Andrew Borodin Have you ever been in a situation where your friends have asked you to perform something that you knew was wrong? Yet you went out and did it, so that you could be a part of that group. Did you feel right about it, was it worth the effort? We have all gone through some form of Peer Pressure in our lives. Is Peer Pressure bad or good? Peer Pressure is the pressure to do certain things, to act in a particular way, and to look like you belong to a specific group. It is an influence to fit into a particular lifestyle. Depending on the type of influence Peer Pressure can be good or it can be bad. When someone is encouraging and supportive and is trying to influence you to do the right thing, where it will improve you and not harm you or others, then it is a good thing. On the other hand when you are encouraged to do wrong things, then it is bad. How do we help our children to deal with Peer Pressure? Better still, we as adults also have to deal with this issue, what is the best way to go about it? We have to decide what we let influence our lives and what is good for our families. From a family point of view we need to keep the communication channels open and talk to our young people and discuss important issues and how to deal with these issues when they come up. Then the children will have a standard to apply to the Peer Pressure that is being applied to them. Strong beliefs help and are an advantage. Knowing what is good and right will give a clear direction to act and not desire to choose the wrong action. From a Religious view the key is to always put Godly principles first then other influences will have the right perspective. I for one have encouraged young people to know what is right and wrong, and if it does not feel good when you think about it, Dont Do It! While teaching a class of ten year old children, we had a role play where the kids in the groups applied pressure to one child to act out a specific role to be a part of a Cool group. They had to perform an act like stealing a mars bar from the local shop. The children wanted to belong to the group so much that they did not think about the implications of their actions. In the heat of the excitement, the children were confused and were unsure, but due to the encouragement and egging on from their peers the children went through with the deed. It was only in the debrief the children realised what they did was wrong. After that the children decided that it was wrong to steal and they would not do it to just belong to a Cool group. Since that role play the children have encountered other pressures and they have been prepared to act on their beliefs by doing the right things and not reacting to Peer Pressure.Understanding and knowing the moral values helps people and children deal with peer group pressures. Encouraging peer group pressure can be helpful. It helps to improve self worth, confidence, outlook, and further develop meaningful friendships. Comments that inspire others to achieve and to complete the allotted task are very positive and they do make a difference to the person who is being encouraged. Praise is wonderful, and it is one of the great positive Peer Pressures available to all groups. More people need to use it. The results from this one little sincere act of admiration can move mountains. Peer Pressure is only a problem when the person that it is applied to is unprepared to deal with it. Children who understand and know what is right and wrong are more able to react to Peer Pressure in the right manner. Tell your child if others ask you to do something wrong, and it feels wrong then Dont Do It. Andrew Borodin is a retired teacher who enjoys helping kids and their parents build stronger family ties for their lifetime.http://www.parent-child-help.com Article Source: http://EzineArticles.com/?expert=Andrew_Borodin http://EzineArticles.com/?Peer-Pressure–Decisions-That-We-Make-In-Unprepared-Times&id=246616 west virginia payday loan payday loan store company namesbad credit personal loans cash advance limits for ohio

Restore Israeli Sovereignty Over the Temple Mount

May 29th, 2008 by medriasherlock

By David Ben-Ariel The Wakf, the militant Muslim authority that oversees Jerusalem’s Temple Mount, Judaism’s holiest site and Islam’s alleged third holiest site (following Mecca and Medina) continue to show blatant disregard for Jewish, Christian and biblical history and non-Muslim sensitivities. Matti Friedman’s AP article — “At Temple Mount Holy Site, What Is Treasure?” — exposes how the Wakf engaged in unsupervised and illegal gouging of the Temple Mount (the holy site of both Solomon’s Temple and Zerubbabel Temple enlarged by Herod that Jesus and the apostles worshipped in), removing tons of its historically rich soil and callously dumping it in the nearby Kidron Valley (that I’ve walked through many times, climbing the Mount of Olives). Such atrocious acts reveal a serious lack of proper respect for archaeology and other religions and serve as an indictment against the Wakf and the Israeli government for looking the other way. However, this serious breach of religious respect and tolerance for non-Muslims is nothing new, as a Muslim mob overran the biblical patriarch Joseph’s Tomb, site of a synagogue, burnt the Torah scrolls and murdered the rabbi who supervised the site, as well as a Druse officer trying to protect it, and utterly trashed the holy place. And who can forget the Muslim terrorists holed up in the Church of the Nativity in Bethlehem, using the baptismal font as a latrine and abusing the New Testaments there? Not to mention the daily religious discrimination upon the Temple Mount where they illegally forbid Christians and Jews from praying or reading the Bible. These are the concrete actions of the leaders of the “Palestinian” community, documented actions that are in stark contrast to the virtues they profess to the Western media about religious tolerance and freedom of access to religious sites within “Palestine.” It’s past time the Israeli government act responsibly and change the deplorable status quo upon the Temple Mount, and restore Judaism’s holiest site as the Temple Mount, hosting a “a House of Prayer for all peoples” as envisioned by the Prophets. David Ben-Ariel is a Christian-Zionist writer and author of Beyond Babylon: Europe’s Rise and Fall. With a focus on the Middle East and Jerusalem, his analytical articles help others improve their understanding of that troubled region. Check out the Beyond Babylon blog. Article Source: http://EzineArticles.com/?expert=David_Ben-Ariel http://EzineArticles.com/?Restore-Israeli-Sovereignty-Over-the-Temple-Mount&id=363716 texas online car loan payday ok george forman payday advanced electronic cash

Viagra: A Wonder Drug with Multi-Benefits

May 26th, 2008 by medriasherlock

By [http://ezinearticles.com/?expert=Naore_Rome] Naore Rome With the men folk absorbed in talks of spicing up their sex life with Viagra, the other benefits of Viagra to the human body take a backseat. People’s view of Viagra is straitjacketed. They consider it just as an oral pill that can overcome ED, with some side effects. But apart from sizzling up your sex life and taking care of your erectile dysfunction, it has other benefiting effects on your body. Reports coming from researchers in different areas of health at various universities have come up with exciting facts about Viagra. Researchers in Saarland University found out that Viagra can easily reduce the symptoms of Raynaud’s phenomenon, a circulatory disorder. 16 patients who didn’t respond to the standard medicaments of Raynaud’s phenomenon were asked to take either Viagra or Placebo for four weeks and then switched to the opposite drug for another four weeks. The results strongly favored Viagra as the better treatment. Patients who took Viagra had an average of 35 Raynaud’s attacks as compared to the average of 52 attacks among patients who took placebo. Even the duration of the attacks differed. Patients taking Viagra had an average of 581 minutes of attack while the attacks lasted for 1046 minutes in the patients taking placebo. Another research team has published a report that Viagra can help patients with a fatal pulmonary arterial hypertension that is affecting around 100,000 people the world over. According to Ian Adatia, Ch.B. M.B, associate professor of pediatrics at the University of California San Francisco Children’s Hospital, children with pulmonary arterial hypertension (PAH) walk farther and breathe easier when they take Viagra over the course of a year. 14 children with PAH, who were given Viagra for a period of one year could increase their six minutes walking time by more than 500 feet. Viagra could come to the aid of mountaineers, who frequently face the wrath of deadly cardiovascular effects at high altitudes. Proper use of Viagra helps in reducing the high blood pressure to a great extent and facilitates the easy transportation of oxygen in the blood. It can enhance the ability to exercise at high altitudes too. Viagra can also improve circulation in the lungs. In fact mountaineers have many reasons to benefit from Viagra. A finding of the Medicine Society of North America says that it can help in curing benign prostrate hyperplasia (BPH). Kevin V. McVary, M.D., professor of urology at Northwestern University Feinberg School of Medicine, who led the study, said patients that were given Viagra showed encouraging signs of improvement in their erectile problems. The researchers also noticed a concomitant decrease in both the irritative and obstructive symptoms of BPH too. A statement of researchers in John Hopkins University claims that fifty percent of the hormonal stress on the heart can be reduced with the use of this oral tablet. A test conducted on pregnant rats at the Vermont College of Medicine suggests that Viagra aid maternal uterine vascular adaptation and fetal health in hypertensive pregnancy. All these reports and findings go on to prove that Viagra is not just about getting an erection, it could prove to be beneficial in other matters of health too. Naorem is a freelancer who writes on various aspects of erectile dysfunnctio. Visit [http://www.viagrathunder.com] http://www.viagrathunder.com, [http://www.buy-viagra-with-us.com] http://www.buy-viagra-with-us.com and [http://www.viagracare.com] http://www.viagracare.com for the latest tidbits on erectile dysfunction Article Source: [http://ezinearticles.com/?expert=Naore_Rome ] http://EzineArticles.com/?expert=Naore_Rome [http://ezinearticles.com/?Viagra:-A-Wonder-Drug-with-Multi-Benefits&id=181460 ] http://EzineArticles.com/?Viagra:-A-Wonder-Drug-with-Multi-Benefits&id=181460 tampa cash loans apartment private money loans education minnesota short term loans paycheck stub samples

Is Your Fertilizer Poisoning You?

May 17th, 2008 by medriasherlock

By Jason Willkomm A little known loophole in state and federal regulations has been skillfully manipulated for profit at your expense. Actually, at your health’s expense. Environmentally polluting companies have deceptively declared they are recycling in order to divert millions of pounds of toxic industrial waste from expensive EPA disposal facilities to fertilizer production facilities. It is another loophole (fertilizer labeling regulations) and soft money contributions that enable these companies to profit while they poison hundreds of thousands of people and saddle them with serious health problems. Labeling is inadequate, because fertilizer labeling laws only require beneficial nutrients like zinc or phosphate to be listed. fertilizers are sold directly to the public without warnings or information that informs consumers about the presence or quantity of toxic metals. It was the mayor of a small Washington state town, Patty Martin, who initially uncovered the disturbing truth. Her book “Fatal Harvest” details the story and sparked an investigative report by the Seattle Times which has brought the entire matter to a head. The Times documented nationwide use of fertilizers containing cadmium, lead, arsenic, dioxins, radionuclides and other hazardous waste. Between 1990 and 1995, 600 companies from 44 states sent 270 million pounds of toxic waste to farms and fertilizer companies accross the country. Tests by the State of Washington found that some fertilizers contained levels of dioxin 100 times greater than the level allowed for treated Superfund sites in the state. Besides the obvious immediate health concerns, one must consider the long term environmental damage done to millions of acres of farmland. Fruit and grain crops have been proven to uptake lead, and wheat crops and lettuce will uptake cadmium. These companies are producing fertilizers from toxic wastes that farming facilities are spreading over millions of acres of food crop producing land in this country. These fertilizers contain 9 metals, like arsenic and lead, that are known to cause cancer. 10 of the metals, such as mercury, are linked to birth and developmental defects. At least three metals- lead, cadmium, and mercury, are toxins which persist for very long periods of time and can accumulate in the tissues of humans and wildlife over time to become a toxic condition even at lower levels. Another group, the California Public Interest Research Group (CALPIRG), conducted a study that illuminated just how serious and widespread the problem really is. They tested 29 fertilizers from 12 states for 22 toxic metals. All 29 fertilizers were shown to contain all 22 fertilizer samples. In 20 of the samples, the levels were higher than levels for concern. In conclusion, when I first learned of this I got a sick feeling. The Washington State Department of Agriculture has just recently set up a division to have every fertilizer in their state tested and the results published on the internet. I suggest you do as I did, and go to the WSDA website (below) immediately to check every fertilizer you use. http://agr.wa.gov/PestFert/Fertilizers/FertDB/Product1.asp?action=ViewTable&ltr=Mml Visit me, Jason, at http://www.jasons-indoor-guide-to-organic-and-hydroponics-gardening.com/. I have ten years experience growing indoors under lights. I guarantee that every product and fertilization method I recommend, I have also used myself, and has passed my thorough check for product safety. Article Source: http://EzineArticles.com/?expert=Jason_Willkomm http://EzineArticles.com/?Is-Your-Fertilizer-Poisoning-You?&id=127546 big payday lending legal document assistant bonds no credit check ca military overseas payday loans seven eleven pay day pay off

Bextra and Vioxx — Alternative Medications Have Warnings, Too

May 14th, 2008 by medriasherlock

By [http://ezinearticles.com/?expert=Charles_Essmeier] Charles Essmeier At the urging of the Food and Drug Administration, the drugs Vioxx and Bextra have both been voluntarily withdrawn from the market by their manufacturers. Studies show that these drugs, part of a family of non-steroidal anti-inflammatory drugs (NSAID) known as COX-2 inhibitors, may be linked to increased chances of heart attack or stroke. Since these two drugs were heavily prescribed for treatment of arthritis pain and inflammation, many users have suddenly found themselves without their prescription medication and without relief. The automatic response to this might be to reach for a traditional anti-inflammatory, such as ibuprofen or naproxen. Alternatively, patients may opt to take the lone remaining prescription drug in the COX-2 family of NSAIDs, Celebrex. Before reaching for that over-the-counter pain reliever, patients would be well-advised to do some further research, or, on newer bottles, read the label. While the majority of the news reports regarding NSAIDs have covered Bextra and Vioxx, the FDA warnings include all NSAIDs, including the over-the-counter varieties, which include naproxen and ibuprofen. These drugs are now required to have a black box warning on the bottle, which outlines the fact that patients taking these medications may be at increased risk of having a heart attack or stroke. Many physicians in the medical profession are quick to point out that the warnings come as a result of a rather limited study, and that further studies are necessary to fully determine the degree of risk that one assumes when taking these medications. Such studies will be done, but in the meantime, the warnings on the label should not be taken lightly. Patients should be aware that taking such medications either in large doses or over prolonged periods of time could pose certain risks. As always, patients who have questions regarding these or any medications should consult with their physician. Copyright 2005 by Retro Marketing. Charles Essmeier is the owner of Retro Marketing, a firm devoted to informational Websites, including Bextra-Info.net, a site devoted to the withdrawn drug taret=_New [http://www.Bextra-Info.net/] Bextra and StructuredSettlementHelp.com, a site devoted to [http://www.structuredsettlementhelp.com/] structured settlements. Article Source: [http://ezinearticles.com/?expert=Charles_Essmeier ] http://EzineArticles.com/?expert=Charles_Essmeier [http://ezinearticles.com/?Bextra-and-Vioxx-----Alternative-Medications-Have-Warnings,-Too&id=34104 ] http://EzineArticles.com/?Bextra-and-Vioxx—–Alternative-Medications-Have-Warnings,-Too&id=34104 person x applies for personal loan from y bank project payday review short term payday loans loan money to friend for something in return

Growing Up On A Delaware Farm

May 9th, 2008 by medriasherlock

By Mr Jody Hudson Growing up on a Delaware farm was a wonderful and rewarding experience for me. I grew up in an area where a couple of dozen families in an area of about hundred square miles had farmed, married each other and been a stable community for centuries, along Delaware Rout One just north of Lewes. In my early youth, I grew up on a farm where we had 33 cows, 18 we milked twice a day, 3 horses, some chickens, 60 acres of corn, hay and pasture. It was a farm that my maternal grandparents owned. There were barns, tractors, long hours and Sundays in church. We grew corn, hay and pasture. We had a large garden and some fruit trees. We hunted, foraged, and grew what we ate and used in most cases. We ate duck, goose, pigeon, muskrat, fish, crabs, shell fish, groundhog, mustard greens, collards, wild garlic, onion, persimmons, wild cherry, wild strawberries, blueberries, figs, mint, wild carrots, herbs and wild spices. We had plenty of beef, chicken, milk, cream and our own homemade butter, as well as at least two kinds of handmade soap. We cooked on a woodstove which also heated the house. I slept under quilts and on feather beds that were over a hundred years old. We had a little coal furnace but coal was expensive and that was only for the coldest times. We had electric and a phone too. We shucked and shelled corn, some of which we traded to neighbors for pork, veal or turkey. I lived on my grandparents farm and my great grandmother lived with us as well. My grandmother and great grandmother were both school teachers by profession. I was doted upon, taught and encouraged to read several hours a day. The home was filled with old books and I was the only student they had at home. In the attic were books handed down through the family from the 1500s and since. We lived on land, some pieces of which had been in our family ownership for hundreds of years and is now divided down from thousands of acres to small pieces. We lived much the same as people lived on farms in the late 1800s and early 1900s. Yet, we had phone and TV, neither of which was used much. My grandfather taught me much; to milk cows by hand and by machine and much more. I shoveled tons of sloppy manure, fed the cows and horses and learned to carpenter, make tools, and to keep things repaired. I learned to make do and keep it going. I learned to mend harness, to render pine resin from the sap of local trees and mix it with bees wax to treat the home-made linen thread that was used to mend harness. I learned to do minor animal surgery such as castration, dehorning and at least once I helped pull an infected tooth in a cow. I learned to make my own knife at age 4. By 5 I was driving the old Ford some. At 6, I was able to drive the tractors and the truck. By 7 I could work a full day in the field by myself driving the largest tractor Dad had. Dad bought the adjacent farm when I was five and later bought several other adjacent or nearby farms and timber land as it came available. He eventually owned and rented over 3,000 acres by the time I left the farm. We lived well from Dads industrious work and his advanced techniques. My grandparents were not very modernized. Dad was not a usual person for his time either. He was 20 to 50 years ahead of his time in farming. I helped out on Dads farms once I started school. By eleven I worked at least 20 hours a week during the school year, often 40. By age 12 my summer weeks were typically 60 hours or more and sometimes over 100 hours. I tried to go for 120 to 130 hours a week for the added money. Many nights I slept in the dirt, in the field, to eliminate going home to sleep so I could make more money. I learned to go to sleep in a matter of seconds and to be up, dressed and working in less than four minutes when I slept at home. Summertime, when there was no school, and being paid for the long hours I worked — I made considerable income even at the low hourly wage. I saved most of it. I didnt have much time or opportunity to spend it. As a teenager, I made more, many months than some grown men of our area and I had few expenses. We didnt work all the time but we enjoyed work. I dont recall anyone that didnt like working. I arranged to do the hardest and least popular jobs, mostly hauling hay and irrigation. Doing the hardest jobs gave me job security. We got Sundays off to go to the little country church that our family founded and built on the farm. We worked hard and loved the work and the life it earned us! Dad, ahead of his time, had irrigation, high density crops, no-till farming, airplanes to spray the crops, and used every modern or experimental tool and technique available or being tested. As a youngster, I was accustomed to Dad being in or on the cover of some magazine nearly every month it seemed. Some of the things he helped pioneer 30-40 years ago are becoming customary and ordinary now, some will be more common later. Dad grew his farm from nothing and by the time I was a teen he was farming over 3,000 acres, seeking to profit from the economies of scale and mechanization. Smaller farmers were often making far less than minimum wage by the 70s. He rented thousands of acres of farm land but owned many hundreds of acres of tillable land as well. Sure I miss the rural farming that I grew up in. We decided, several years too late, to sell most of our farm land into development when the government decided to make pawns of farmers, farms and farm products. First went the domestic farm commodities market with one crop after another and then in the international market with the corn, wheat, soybean debacles with Russia and China where our government contracted to feed the USSR and China for decades with our farm products. This contractual agreement multiplied the need and value of American farm products. The smell of diesel fuel may be the smell of life in some cases. I dont like the smell of it either and starting at 7 years old I pumped a lot of it into our tractors and burned it long hours as I drove those tractors. Its probably some sort of illegal activity to let kids work on the farm today. There was a lot more diesel in the air before the developments were here. The tractors are gone now for the most part. And they seldom wake up the late rising city folks anymore. Our democratic interests dont allow any manufacturing down here in Sussex so we have no high income support base. The highest income employment we have is banking and outlet manager jobs. Other than that we have self employment, waiting on tables, minimum wage and production based income and its not usually farming. We have a few, very few people who have been able to stay here and serve non-farm interests. Few remain who still farm and those few have either other income, extreme government subsidy with our tax dollars of some sort or will be gone soon. Copyright 1999-2005 by www.JodyHudson.com Source of this article: http://www.kate-jody.com/essays/growingupfarm.html Article Source: http://EzineArticles.com/?expert=Mr_Jody_Hudson http://EzineArticles.com/?Growing-Up-On-A-Delaware-Farm&id=3282 banks issue payday loans san antonio bad credit new car loan bad credit car loan illinois kentucky pay day cash advance llc

Principles Of Secure Settings In Treatment

May 4th, 2008 by medriasherlock

By [http://ezinearticles.com/?expert=Kate_Gardens] Kate Gardens As a professional nurse, looking after the human rights of the patient is very important. For example, prior to any treatments, medication, and or therapy, health professionals must seek a valid consent from the patient. In case the patient is not in a proper mental condition to make decisions, a third party such as his / her mother or father must be informed about the medical procedures that is intended to be performed to the patient. The non-maleficence is based on the principle that health care providers are obliged to protect the patient from further physical or mental harm. This principle is usually applicable to children, mentally incompetent, and unconscious patients. Basically those individuals who can not protect themselves within a certain time frame. On the other hand, beneficence is a principle that demands all health care providers to do only what is good for the patient. Related to health care professions are the principles of fidelity and veracity. Fidelity is related to the professional obligation of nurses with regards to their responsibility and commitment in their chosen profession. Veracity is about honestly and truthfulness. Thus, a nurse should never deceive or mislead a patient. Among the long list of responsibility of the health care professionals is to keep the patients health records confidential. The principle of justice is about providing a fair obligation to all. It means that social benefits and burdens have to be balance in accordance with the demands of justice. For example, the license of a nurse can be revoked in case he / she is proven to falsify his / her nursing documents. Kate Gardens is a custom essay writing expert writer and UK customers support consultant at Customessays.co.uk. Get more details for [http://www.customessays.co.uk/marketing.php ] marketing essays writing, [http://www.customessays.co.uk/management.php ] management essay writing and find more tips for [http://www.customessays.co.uk/medic.php ] medicine essay writing. Article Source: [http://ezinearticles.com/?expert=Kate_Gardens ] http://EzineArticles.com/?expert=Kate_Gardens [http://ezinearticles.com/?Principles-Of-Secure-Settings-In-Treatment&id=454654 ] http://EzineArticles.com/?Principles-Of-Secure-Settings-In-Treatment&id=454654 get an unsecured loan with a very low credit score cash now loans payday predatory lending and the elderly deleware cash advance no teletrak no verify no fax all approved