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Watch the speech in full, below.
The MTV EMA's are taking place tonight at SSE Arena Wembley, and the show has been nothing short of amazing. Eminem kicked things off with a live premiere of his new single "Walk On Water" and also collected the award for Best Hip-Hop. Kendrick Lamar has landed the award for Best Video with "Humble" while Shawn Mendes has walked away with the award for Biggest Fans.
30 Seconds To Mars are now on the list of winners, taking home the award for Best Alternative Act.
You can watch Leto's EMAs speech, below.
The band recently announced a massive 2018 European tour in promotion of their upcoming fifth album. Check out the list of dates below!
What do you think of 30 Seconds To Mars winning Best Alternative Act? Let us know in the comments below.


Wedding is a special bond that is for all the rest of life. So you must congratulate and wish your loved ones who are newly married or old couples in a special way using these quotes and Anniversary Wishes For Couples. We have a good collection of Anniversary Wishes For Couples. You can post these quotes on their timeline. You can also write them on the wish cards. You can generate more ideas and then use them as well. These lovely quotes are something that can show your care and love for your relatives and friends. You can also tag them on the Facebook and can also post on any social media.


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On our cover: Owen Pallett's musical palette on display at New Creations. Spring brings thoughts of summer music education! (It's never too late.). For Marc-Andre Hamelin the score is king. Ella at 100 has the tributes happening. All; this and more.
CBC Radio Two: The
CBC Radio Two: The Living Legacy Centrediscs: The Little Label That Could Canadian Classical Composition and the JUNOs DAVID JAEGER For the first time in the history of Centrediscs, the small but significant record label operated by the Canadian Music Centre (CMC), two of its recent recordings have current JUNO nominations in two different categories. Dark Star Requiem by composer Andrew Staniland and poet Jill Battson is nominated in both the Best Classical Recording, Vocal or Choral and in the Best Classical Composition categories. Christos Hatzis' full-length ballet, Going Home Star: Truth and Reconciliation, is nominated in both the Best Classical Composition and Best Classical Recording, Large Ensemble or Soloist(s) with Large Ensemble Accompaniment. This is a significant milestone for Centrediscs, a label created in 1983 by then CMC Executive Director John Miller. "The idea of Centrediscs was originally proposed by my predecessor, John Peter Lee Roberts," Miller told me, "but it fell to me to make it work." Miller certainly found ingenious ways to nurture the new recording label. He formed a working group, of which I was a member, to advise on the mechanics and technical aspects of running a label. Harold Redekopp was Head of CBC Radio Music at the time and he and Miller agreed that the Radio Music Department would, up to a practical limit, provide production and technical personnel to make the recordings. And, in return for doing so, CBC music programs would have the right of first broadcast. This arrangement provided Two New Hours, the national network new music program I had created in 1978, additional new productions of recent performances of Canadian music to blend with the concert recordings that were the core of our broadcasts. In those first few years of Centrediscs we recorded soloists and ensembles who specialized in contemporary repertoire, like the Canadian Electronic Ensemble, clarinetist James Campbell, the Purcell String Quartet, violist Rivka Golani and Anton Kubalek. We made LPs of these artists playing the works of CMC Associate Composers, and soon added the first records devoted entirely to the music of a single Canadian composer. These included titles such as Vivier, music of Claude Vivier; RA, with excerpts of Murray Schafer's night-long ritual; Louis Riel, the opera by Harry Somers, recorded at the Kennedy Center in Washington DC; and Chalumeau, chamber music of Harry Freedman. Many of these were later reissued on CD, and those original LPs are, in fact, now highly valued collectibles. In 1986, Centrediscs released its first recording on CD, Impact, a production of performances by percussionist Beverley Johnston. In fact, Impact was manufactured in three media: CD, LP and audio cassette. The composers represented on it were Serge Arcuri, Gary Kulesha, Alexina Louie and Jean Piché, and the disc attracted rave reviews. In the Centrediscs catalogue, Impact is described as: "A tour de force of percussion and electroacoustic music, the disc has often been used by stereo component stores to demo new hi-fi lines, because of the high audiophile quality of the recording." The performances were included more than a few times in Two New Hours programming and, on occasion, Jean Piché's Steal the Thunder, the lead track in the album, served as the program's opening theme. In 1989 the CMC decided to submit one of the tracks from Impact to the JUNOs in the recently created category of Best Classical Composition. It earned a nomination but didn't win the JUNO. – Alexina Louie's Songs of Paradise on CBC Records did. It was a remarkable statement as to how far the Centrediscs label had come in just a few years. The JUNO category, Best Classical Composition, introduced in 1987, came about when representatives of classical labels, who formed a separate classical committee within the Canadian Academy of continues to page 86 Sunday March 26, 2017 (Fundraising Event) Tony Arnold soprano | Movses Pogossian violin Gallery 345 | 345 Sorauren Ave. | RSVP 416.961.9594 Doors open @ 7:00 with complimentary refreshments; Performance @ 8:00 Friday April 28, 2017 Tony Arnold, György & Marta Kurtág, Movses Pogassian Benjamin Butterfield tenor | William Aide piano Accordes Quartet | NMC Ensemble | Robert Aitken direction Introduction @ 7:15 | Concert @ 8:00 | Trinity St. Paul's Centre | 427 Bloor Street W. www.NewMusicConcerts.com Kurtág's "Kafka Fragments" celebrating beckwith Photo: André Leduc 10 | March 1, 2017 - April 7, 2017 thewholenote.com
Up Close with Marc-André Hamelin Inspirational and Aspirational Marc-André Hamelin sometimes thinks that music should have its own semantics. "Deep down I would like the public to be affected by music and respond to music as they would respond to something which has a narrative structure and a message to deliver," he told me in a February 10, 2017 phone conversation. "And I've always said that a performer should be able to express almost any adjective in the dictionary through their playing. Even though it's kind of a fantasy, it's a nice goal, a good aspiration." We were chatting in advance of Hamelin's appearance March 23 in a recital presented by Music Toronto. The occasion was a follow-up to my profile of the master pianist that appeared in the December 2015 WholeNote. Hamelin was his usual affable, thoughtful and convivial self. We spoke about his ambitious all-sonata program for the concert – a late Haydn, the first two sonatas by the little-known Russian pianist-composer Samuel Feinberg, Beethoven's Appassionata, Scriabin's White Mass and Chopin's Second which is built around a funeral march. Hamelin was describing his connection to the Chopin sonata on the program, which he had recorded for Hyperion in 2008, prompting my question about how his relationship with that particular work has evolved over the years. "You know, it's something that I've known literally all my life," he said. "We've talked about this before I'm sure. Because of my dad, listening to these things all the time, recordings were playing all around the house. I think he probably played it a little bit himself although it's a very difficult piece. It's been in my ear since I was a boy so I came to it already sort of knowing it. I didn't have to explore the score to find out about it. I already knew it. Although when I started to play it of course, there were many things that the score revealed to me that had not been apparent to me when I heard the piece through recordings." Indeed the importance of his father to Hamelin's musical aesthetic and his reputation, right from the start, as an ambassador for late 19th and early-20th-century pianist-composers, many of whom had been formerly unfamiliar to a wider audience, was a key component of my earlier article. "But as far as the evolution [of his relationship to the Chopin sonata], my God, what to tell you, I don't know. I've always considered it one of the towering masterpieces of the repertoire, one which curiously enough I think is open to a variety of views, a variety of different interpretations, a variety of ways of expressing it. But it's always appeared to me, perhaps even more now, as one of the darkest and most disturbing statements ever written for the piano." I asked for an elaboration. "Well, you know Schumann's quote saying that Chopin put four of his maddest children under one umbrella and published this sonata. The four movements are – if you consider the [third movement] Funeral March the heart of it – you could perhaps consider the first two movements as sort of working towards the funeral march and the fourth being sort of an illustration, an afterthought or a consequence of it, as much of a dark mood as the third movement but also expressed completely differently with different means. "It's very hard to talk about because it's something that I've known PAUL ENNIS for so long that it's hard to take some steps back," he said, laughing. When he plays it, he said, it's like he's reciting a poem. A case in point in terms of his aspirational fantasy: "a narrative structure and a message to deliver." Our conversation soon turned the topic of the importance of the score in his pianistic approach. ("The score is still my ideal," he had told me back in the fall of 2015.) This time, we were discussing Samuel Feinberg as pianist. ("Give a listen to his Well-Tempered Clavier," he said. "It's the best that's ever been produced. It was reissued on CD at least three times and I'm sure you can hear all of it on YouTube if you look hard enough.") I then commented on Feinberg's playing of the Appassionata, and then asked what Hamelin's approach was. He paused before saying with a slight sigh that he plays it and he's probed it but that his main thrust has been to discount and ignore all outside influences including performing tradition and recordings. "My arbiter, my one guiding spirit is always and will always remain, the score," Hamelin said. "Because, especially when I tackle repertoire that everyone knows, I want a fresh perspective. And being a composer yourself gets you to appreciate a lot more the letter itself and what the composer directly tries to communicate. And that kind of thing, the act of communication of your intentions as a composer is a very arduous process and you never know if you're going to be understood or not. And of course you have to worry about your intentions being disregarded as often happens, because sometimes performers think they know better," he laughed generously. "I've been guilty of that a few times myself. But composing really teaches you respect of the score and that's where I go to first and foremost." When I pointed out that sometimes it takes years or generations for composers to be understood he mentioned Feinberg as an example of someone who will never be a household name or really enter the standard repertoire but that doesn't mean that one shouldn't hear him. In fact, Hamelin has a long-term project to remedy the shortage of recordings of Feinberg's work. "Right now I'm concentrating on the first six sonatas which are a fascinating corpus," he said. "I've already played the first two quite a number of times. And people have actually responded to them with great delight. Which I'm happy to hear." Hamelin is playing those sonatas in Toronto in March. I asked when he first discovered the composer's music. "Oh, I've had his scores since the 80s," he said. "When you're interested in out-of-the-way repertoire as I've always been, his name inevitably comes up. The problem was at the time, indeed for the entire 20th century, scores had been impossible to get in the West, so we just didn't know what the music looked like. The only two things that were published in the West as far as I'm aware were his Sixth Sonata and a set of preludes. And that was because Universal Edition in Vienna put them out. And I think they're still available. But he wrote 12 sonatas and a host of other pieces – three piano concerti, a violin sonata and some songs. "Now it's almost all available through IMSLP so it's not a problem," he said. "But what is also a stumbling block perhaps for anybody who's taken the trouble to look at the music, is his style itself which is really very complex and very, very chromatic. In a way, in a certain sense, it could be said that he takes his point of departure from SIM CANETTY-CLARKE thewholenote.com March 1, 2017 - April 7, 2017 | 11
Page 1: PRICELESS Vol 22 No 6 MARCH 1 - APR
Page 4 and 5: Sunday April 2, 2017 8:00 pm Concer
Page 6 and 7: FOR OPENERS | DAVID PERLMAN The Tim
Page 8 and 9: MONICA CORDIVIOLA at Trinity-St. Pa
Page 12 and 13: Scriabin, but aside from a couple o
Page 14 and 15: COVER STORY: | In with the New Goin
Page 16 and 17: Beat by Beat | Classical & Beyond B
Page 18 and 19: 7 and 9: Another major programming
Page 20 and 21: Beat by Beat | Jazz Stories Big Ban
Page 22 and 23: incredible musicians over the past
Page 24 and 25: Beat by Beat | On Opera Several Rar
Page 26 and 27: Beat by Beat | Art of Song Magnus O
Page 28 and 29: Beat by Beat | Early Music Bosch'
Page 30 and 31: Beat by Beat | Choral Scene The Mar
Page 32 and 33: in Canada. Here they perform a run-
Page 34 and 35: LISTINGS The WholeNote listings are
Page 36 and 37: Centre for the Performing Arts, 102
Page 38 and 39: Tuesday March 7 ●●10:15am: Youn
Page 40 and 41: ●●8:00: Aga Khan Museum/Tirgan.
Page 42 and 43: Verrette, violin. Grace Church on-t
Page 44 and 45: St. Luke's United Church, 353 She
Page 46 and 47: Workshop. Amateur recorder players
Page 48 and 49: ●●7:30: University of Toronto F
Page 50 and 51: B. Concerts Beyond the GTA Wednesda
Page 52 and 53: and guitar students. Cairns Hall, F
Page 54 and 55: MUSE MOHAMMED Beat by Beat | Mainly
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Deadline: July 17, 2017 Cost: Music
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If you are NOT a U.S. Citizen you may be eligible to receive Supplementary Security Income (SSI). However, you must meet the requirements of the laws regulating noncitizens that went into effect on August 22, 1996 as well as meeting all of the other requirements for SSI eligibility, such as the limits on income and resources.
You were receiving SSI on August 22, 1996 and are lawfully residing in the U.S.
Please note that if you entered the U.S. on or after August 22, 1996, you may not be eligible for SSI for the first five years even if you have 40 qualifying quarters of earnings.
If you are a current or former SSI recipient subject to SSI eligibility, under the seven-year time limit, you may expedite processing of your pending naturalization or adjustment of status application. You may also waive fees for the cost associated with filing your application.


Abstract: In this paper we introduce an enhanced notion of extremal systems for sets in locally convex topological vector spaces and obtain efficient conditions for set extremality in the convex case. Then we apply this machinery to deriving new calculus results on intersection rules for normal cones to convex sets and on infimal convolutions of support functions.
Talk by Naomi Borwein at Jonathan Borwein's funeral, 10 August 2016.
Jonathan was a complicated figure, of profound and intense contradiction, and a formidable and DEVOTED father. He cared deeply, thought deeply, and felt deeply about most things. A lot of people will be discussing the impact and scope of Jon's academic output or his sheer brilliance — his genius. But, year after year his work evolved as I watched from the sidelines. So, I am going to share a snapshot of Jon as a fixture of my daily life, through the lens of the everyday.
Jonathan was a great man and a great mathematician and his death represents a great loss to mathematics,throughout the world.
As a mathematician he was original innovative and inspirational. As a scientific colleague he was respectful, courteous and generous.
My brother Jon was a remarkable and unusual talent. He was also an unusual and remarkable brother.
I have fond memories of growing up with Jon, as young boys in St. Andrews, Scotland.
An early memory of Jon is of us fishing off the pier in St. Andrews with our dad David. We would catch rock cod, and make my mother Bessie clean them and make fish cakes. This delighted Jon.


The letter designer allows you to create a letter, conveying a message of your choice, and doing a mail merge within admin.
Have the Director and Administrator defined in the District Details.
Have the District and School address and phone number filled in.
You can design as many warning letters as needed. The General Warning letter can be generated for students of your choosing based on a balance or selected criteria.
The Warning Letter 1-6 will generate based on the settings in the district tab.
You can design any of these letters to convey a message to your parents. The message does not necessarily have to be related to the letter name.
Use the keywords on the right to personalize the letter with the students information and the location.As you type in the letter and you get to a position where you would like to use a keyword, double click on it and it will be inserted where you stopped typing.
If you right click on the screen, it will bring up a larger view of the letter and you can make adjustments as you would in a word document.
When you have completed the letter, select Save.
Select Rename Letter and you will receive a screen to allow you to do so.
Enter the name of your new letter and continue to design it.
The box at the bottom allows you to enter a disclaimer which will appear on any letter generated from this section.


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News Defence & security Policy & business
Weapons demo
By System Administrator	 11th November 2008 2:00 pm 16th December 2015 4:19 am
Saab Bofors Dynamics has successfully completed the first demonstration of NLAW as part of its contract to supply next generation anti-tank weapons for the British army.
Sweden's Saab Bofors Dynamics has successfully completed the first demonstration of NLAW as part of its contract to supply next generation anti-tank weapons for the British army.
The NLAW demonstration took place in Sweden and was attended by 50 guests from 13 countries. Experts from existing customer countries Finland, Sweden and the UK fired missiles at moving targets to demonstrate the system's high accuracy rate.
The SEK4bn (£0.32bn) contract with the UK was won in 2002 on the condition that British industry will be involved in the production. The project currently has around 20 sub-contractors throughout the UK. Development work is conducted at Saab with final assembly taking place at Thales in Northern Ireland.
Michael Ekenstedt, project manager for NLAW, said: 'NLAW is a unique weapons system that does not have any direct competitors. This is shown by the fact that Finland came on board as a customer in 2007, before the system was fully developed.
'We are now looking forward to starting a number of sales campaigns at the end of the year and during next year. Hopefully, several of these will also generate contracts.'
Sweden and Finland have already had a number of systems delivered for testing and the UK is due to receive its first order at the beginning of November. Deliveries for operational use to Sweden and Finland will begin in 2009.
The B-EP2 and the B-EP4 from Toshiba
10th November 2008 12:00 am 16th December 2015 4:21 am
In-depth Rail & marine
Subsea saviours
10th November 2008 12:00 am 12th March 2019 2:12 pm
Haldex Concentric opens new 40,000 sq. ft. extension to its factory in Pune, India
NEW SOFTWARE MAKES LITE WORK OF TEST ANALYSIS
Finger post
11th November 2008 3:00 pm 16th December 2015 4:19 am
Opinion Software
Adopting Digital Twins: Tackling industry barriers
18th January 2022 2:00 pm 18th January 2022 12:12 pm


Going Green! Earth Day Events and More!
See an award-winning, family-friendly short film about the problems caused by single-use plastic. Presented by Mass Audubon's Wellfleet Bay Wildlife Sanctuary and the Wellfleet Harbor Actors Theater.
Ameri-Corps Cape Cod and the U.S. Army Corps of Engineers have joined forces for an Earth Day Celebration. Help clean up the Cape Cod canal, and participate in educational activities. Food will be provided to volunteers.
Earth Day or any day!
Volunteer to help beautify the gardens and trails, and explore the sanctuary.
The Harwich Conservation Department will be giving out tree, shrub, and flower seedlings.
Help clean up Harwich, and get a free lunch!
Participate in a trash pick-up, lunch and celebration, a puppet show with AmeriCorps, and a nature walk in Dennis.
Join the Cotuit-Santuit Civic Association in cleaning up various areas of the village.
Volunteer with the Harwich Conservation Trust at the Herring River.
« Story Slam: How We Met – In Pictures!


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Ben & Jerry's Schweddy Balls Selling Well Despite Boycott
Ben & Jerry's Schweddy Balls ice cream is Missing In Action in action since it was first announced. Supporters and members of the One Million Moms group appears to be having an impact on the new ice cream flavor.
That Mississippi-based moms organization has been putting the heat on retailers to keep Schweddy Balls out of their freezers and encouraging parents to ask the Vermont-based Ben & Jerry's to stop production of the item, saying the name is nothing but locker room humor which is not appropriate for young children.
The flavor which features fudge-covered rum balls was named after an inneundo-ripe skit featuring actor Alec Baldwin as baker Pete Schweddy in 1998 on a now-famous Saturday Night Live skit. In the skit Baldwin promises "No one can resist my Schweddy balls."
Stores chains not wishing to risk coming under fire by the boycotting groups are not stocking the limited edition flavor. The store chains are keeping mum about their decision not to carry the flavor. They're not saying if their decision is based upon One Million Moms but many believe the group has had a definite impact on the Ben & Jerry's controversial ice cream flavor.Ben & Jerry's spokesman Sean Greenwood said Thursday that Schweddy Balls has quickly become the most popular limited-edition flavor the company has produced.
Greenwood said about one-third of the retailers that carry its other products are offering Schweddy Balls, about the same as any other specialty flavor it has produced — though this one has outpaced those in sales at the stores and the company's "Scoop Shops."
Could it be because it is a flavor ripe with controversy? Or maybe it's those yummy fudge-covered rum balls are making the flavor a best seller for Ben & Jerry's.
Boycott Of Ben & Jerry's Ice Cream
Ben & Jerry's - Brilliant PR Or Corporate Death Wish?
Tiger's Hair Ball
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DIAMOND, Dennis
Age 92, of Englewood, Ohio, passed away peacefully Thursday, February 18, 2021. He was born November 5, 1928, to his parents Dewey Lee and Iona Spillman Diamond of Louisa, Kentucky. He was predeceased by his beloved wife of 65 years, Betty Meek Diamond, in 2013. He is survived by his
loving daughter Carol Diamond Dempsey and his son-in-law
William Dempsey of Morris Plains, New Jersey. He worked at Frigidaire, division of General Motors, for over 39 years.
Dennis was an accomplished golfer and bowler, in 1967
bowling an officially certified perfect game in league
competition. Devoted to his family and friends, Dennis took from the hardship and experiences of his early life a strength of character that is rare and admirable. His memory will be an inspiration to many. Private burial will be held in Louisa,
Kentucky. A memorial service will be held at a later date.
Arrangements entrusted to Baker-Hazel & Snider Funeral Home. Memorial contributions may be made to: The
Community Relief Fund of Middle Tennessee (Check Memo Line) The Hickman Holler Appalachian Relief Fund, PO Box 440225, Nashville, TN 37244. Online memories may be left for the family at www.bakerhazelsnider.com.
Sign the guestbook at Legacy.com
View the obituary on Legacy.com
Funeral Home Information
Baker-Hazel & Snider Funeral Home
5555 Philadelphia Drive
https://www.bakerhazelsnider.com/?utm_campaign=legacytraffic&utm_source=legacy&utm_medium=referral
ADKINS, David
MAHONEY, Marian
HADICK, Russel
ANDERSON, Linda
CLODFELTER, Robert


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Where Is the Strike Zone? Arguing for a Uniformly Narrow Interpretation of the Prison Litigation Reform Act's "Three Strikes" Rule
Samuel B. Reilly
Parent Category: Criminal Justice and Racism
Category: Prison Industrial Complex and Mass Incarceration
Excerpted From: Samuel B. Reilly, Where Is the Strike Zone? Arguing for a Uniformly Narrow Interpretation of the Prison Litigation Reform Act's "Three Strikes" Rule, 70 Emory Law Journal 755 (2021) (Comment) (318 Footnotes) (Full Document)
Indigent prisoners in the United States have limited access to the courts. Section 1915(g) of Title 28 of the United States Code states that indigent prisoners who have filed three "frivolous" actions in federal court and had them dismissed--thereby accumulating "three strikes"--are statutorily barred from bringing a civil claim in federal court, unless they are in "imminent danger of serious physical injury" or can pay the filing fees out of pocket. While this "three strikes" rule was passed to reduce the number of cases on the federal docket, it has instead created myriad conflicting interpretations in federal courts and placed unnecessary obstacles before indigent prisoners seeking justice. The law's effects conflict with the importance of access to the courts, which both Congress and the Supreme Court have consistently championed. This Comment provides a remedy that will ensure that (1) indigent inmates have access to courts, (2) courts limit frivolous litigation, and (3) judges adhere to sound statutory interpretation.
The statutory culprit in this Comment is the Prison Litigation Reform Act (PLRA). The PLRA was passed in 1996 in an effort to decrease the number of filings in federal court and improve the quality of those filings. The pertinent provision of the PLRA that this Comment examines is the "three strikes" rule, which sharply reduced indigent inmates' access to the courts. The "three strikes" rule is a mandatory prohibition against filing any "litigation in forma pauperis (without prepayment of fees) if three or more actions or appeals have been dismissed as frivolous, malicious, or for failure to state a claim." While this may seem like a difficult bar to meet, the vast majority of prisoners file their actions pro se, are not legal professionals, and rely on outdated prison law libraries, so they often lack the requisite knowledge to avoid filing errors and can accumulate strikes even while trying to bring an otherwise meritorious claim. Further, the rule has no statute of limitations, so a strike is permanent, no matter when it is issued. Once prisoners have accumulated those three strikes, they are not able to file a claim--regardless of its merit--unless they are in imminent danger of serious physical harm or can afford to pay the hundreds of dollars out of pocket.
When interpreting the "three strikes" rule, federal courts have failed to find consensus on three broad issues. First, courts are split as to what counts as a "dismissal" deserving of a strike. Second, courts have failed to find a universal definition as to what constitutes "imminent danger." Finally, courts are split as to whether a prisoner can appeal their third strike in forma pauperis. The stakes of interpretation are high. For example, when the rules as to what constitutes a strike are construed liberally, strikes are more likely to be applied, even if the dismissal is not for one of the statute's enumerated grounds. Or, when courts narrowly interpret the "imminent danger" exception, prisoners' claims of harm will be dismissed if there is no "nexus" between the alleged injury and the legal claim. Thus, the likelihood that an indigent prisoner will not be able to bring a civil claim can increase enormously-- including claims of religious discrimination under the First Amendment and claims of cruel and unusual punishment under the Eighth Amendment--even when the claim is meritorious, solely because of a court's interpretation of the "three strikes" rule. Even worse, if the inmate is barred from appealing their third strike, they are bound by the district court's ruling, whether correctly or incorrectly decided.
This Comment contends that there exists a way to properly interpret 28 U.S.C. § 1915(g) that serves the government's interest in providing efficient judicial services, while also ensuring that indigent inmates are not barred from the courts. Thus, this Comment proposes a three-part solution that the Supreme Court should adopt the next time it has the opportunity to grant certiorari on this issue. First, courts should narrowly interpret what it means to "dismiss" a case, creating clear rules for whether a strike should be awarded. Second, courts should broadly define what it means to be in "imminent danger." Finally, courts should permit indigent prisoners to appeal their third strike in forma pauperis.
Part I examines the passage of the PLRA, its purpose, and its effects, ultimately finding that Congress scapegoated prisoners in an attempt to remedy a problem that Congress itself created. Part II analyzes the Court's interpretation of the fundamental right to access courts, including when federal courts have directly addressed the constitutionality of the PLRA.
Part III then assesses the three questions of interpretation that have plagued federal courts. First, section A surveys how courts have interpreted what it means to dismiss a case and argues for a narrow, text-based interpretation. Second, section B analyzes courts' definitions of what it means to be in imminent danger of serious physical harm and argues for a broadly construed definition. Finally, section C discusses whether to allow a prisoner to appeal their third strike in forma pauperis, arguing that prisoners should be able to do so.
Throughout Part III, this Comment argues that a faithful application of the tools of statutory interpretation mandates that courts interpret dismissals narrowly, interpret the imminent danger exception broadly, and allow inmates to appeal their third strike to avoid unnecessarily inhibiting inmates' access to the courts.
Part IV analyzes the implications arising from the proffered solution, finding that a narrow statutory interpretation of § 1915(g) properly strikes the balance between limiting frivolous litigation and ensuring indigent inmates' court access.
Congress passed the Prison Litigation Reform Act to reduce the increasing amount of inmate litigation in federal courts, but the PLRA was an incorrect solution to a problem of Congress's own making. Claims per inmate stayed relatively stagnant--even dropping from the highwater mark in 1981--but the number of those incarcerated spiked. The plight of the indigent inmate, who finds it nearly impossible to obtain the necessary funds to pay a court filing fee, was made more difficult by the PLRA.
The constitutionality of the PLRA has been upheld but has not been recently challenged. In the nearly twenty-four years since its passage, courts have not settled on how to interpret the statute's different provisions. Many courts have gone beyond the statute to apply strikes to inmates on grounds that are not provided in the statute itself. Consequently, § 1915(g) is in jeopardy of becoming unconstitutional because it is restricting inmates from filing meritorious actions. This is even more true after the Supreme Court's decision in Lomax v. Ortiz-Marquez.
This Comment presents a way forward based on sound, text-based statutory interpretation, and it seeks to fulfill the PLRA's purpose without overburdening our nation's incarcerated population. The narrower interpretation provides uniformity and clarity, which would reduce litigation surrounding the statute. The result is that inmates will be able to successfully file meritorious claims in forma pauperis. America's inmates do not lose their fundamental right to access the courts by virtue of being incarcerated, and the narrower interpretation of the statute ensures its constitutionality by protecting inmates' right to access the courts.
J.D. Candidate, Emory Law School 2021; B.A., Vanderbilt University 2016; Editor-in-Chief, Emory Law Journal


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Tag Archives: goods
Poverty Changes
£14,000 is quite a large amount of money. Enough for 70,000 Freddos, a decade's worth of holidays, two new Nissan Pixo's, several thousand potatoes or a gold standard racing pigeon. However, if you're trying to live off just that amount in modern Britain, it quickly seems quite a lot smaller. Half of that could easily disappear on rent, whilst the average British family will spend a further £4,000 on food (significantly greater than the European average, for one reason or another). Then we must factor in tax, work-related expenses, various repair bills, a TV license, utility & heating bills, petrol money and other transport expenses, and it quickly becomes apparent that trying to live on this amount will require some careful budgeting. Still, not to worry too much though; it's certainly possible to keep the body and soul of a medium sized family together on £14k a year, if not absolutely comfortably, and in any case 70% of British families have an annual income in excess of this amount. It might not be a vast amount to live on, but it should be about enough.
However, there's a reason I quoted £14,000 specifically in the figure above, because I recently saw another statistic saying that if one's income is above 14 grand a year, you are one of the top 4% richest people on planet Earth. Or, to put it another way, if you were on that income, and were then to select somebody totally at random from our species, then 24 times out of 25 you would be richer than them.
Now, this slightly shocking fact, as well as being a timely reminder as to the prevalence of poverty amongst fellow members of our species, to me raises an interesting question; if £14,000 is only just about enough to let one's life operate properly in modern Britain, how on earth does the vast majority of the world manage to survive at all on significantly less than this? More than 70% of the Chinese population (in 2008, admittedly; the rate of Chinese poverty is decreasing at a staggering rate thanks to its booming economy) live on less than $5 a day, and 35 years ago more than 80% were considered to be in absolute poverty. How does this work? How does most of the rest of the world physically survive?
The obvious starting point is the one stating that much of it barely does. Despite the last few decades of massive improvement in the living standards and poverty levels in the world in general, the World Bank estimates that some 20% of the world's populace is living below the absolute poverty line of surviving on less than $1.50 per person per day, or £365 a year (down from around 45% in the early 1980s- Bob Geldof's message has packed a powerful punch). This is the generally accepted marker for being less than what a person can physically keep body and soul together on, and having such a huge proportion of people living below this marker tends to drag down the global average. Poverty is something that the last quarter of the century has seen a definitive effort on the part of humanity to reduce, but it's still a truly vast issue across the globe.
However, the main contributing factor to me behind how a seemingly meagre amount of money in the first world would be considered bountiful wealth in the third is simply down to how economics works. We in the west are currently enjoying the fruits of two centuries of free-market capitalism, which has fundamentally changed the way our civilisation functions. When we as a race first came up with the concept of civilisation, of pooling and exchanging skills and resources for the betterment of the collective, this was largely confined to the local community, or at least to the small-scale. Farmers provided for those living in the surrounding twenty miles or so, as did brewers, hunters, and all other such 'small businessmen', as they would be called today. The concept of a country provided security from invasion and legal support on a larger scale, but that was about it; any international trade was generally conducted between kings and noblemen, and was very much small scale.
However, since the days of the British Empire and the Industrial Revolution, business has got steadily bigger and bigger. It started out with international trade between the colonies, and the rich untapped resources the European imperial powers found there, moved on to the industrial scale manufacture of goods, and then the high-intensity sale of consumer products to the general population. Now we have vast multinational companies organising long, exhaustive chains of supply, manufacture and retail, and our society has become firmly rooted in this intense selling international economy. Without constantly selling vast quantities of stuff to one another, the western world as we know it simply would not exist.
This process causes many side effects, but one is of particular interest; everything becomes more expensive. To summarise very simply, the basic principle of capitalism involves workers putting in work and skill to increase the value of something; that something then gets sold, and the worker then gets some of the difference between cost of materials and cost of sale as a reward for their effort. For this to work, then one's reward for putting in your effort must be enough to purchase the stuff needed to keep you alive; capitalism rests on the principle of our bodies being X% efficient at turning the food we eat into the energy we can use to work. If business is successful, then the workers of a company (here the term 'workers' covers everyone from factory floor to management) will gain money in the long term, enabling them to spend more money. This means that the market increases in size, and people can either sell more goods or start selling them for a higher price, so goods become worth more, so the people making those goods start getting more money, and so on.
The net result of this is that in an 'expensive' economy, everyone has a relatively high income and high expenditure, because all goods, taxes, land, utilities etc. cost quite a lot; but, for all practical purposes, this results in a remarkably similar situation to a 'cheap' economy, where the full force of western capitalism hasn't quite taken hold yet- for, whilst the people residing there have less money, the stuff that is there costs less having not been through the corporation wringer. So, why would we find it tricky to live on less money than the top 4% of the world's population? Blame the Industrial Revolution.
Standard | | Tagged absolute poverty, annual income, £14 000, bills, Bob Geldof, booming economy, brewers, Britain, British Empire, budgeting, business, capitalism, chains of supply, China, civilisation, colonies, concept, consumer products, cost of sale, country, Earth, economics, efficient, effort, energy, European average, exchanging, expenses, expensive, fact, family, farmers, food, Freddos, free market, general population, global average, goods, heating, high intensity, holidays, humanity, hunters, income, industrial revolution, industrial scale, industry, interesting question, international economy, international trade, invasion, keep body and soul together, kings, law, legal, live, living standards, local community, majority, manufacture, marker, materials cost, modern britain, money, multinational companies, Nissan Pixo, noblemen, People's Republic of China, petrol, pooling, potatoes, poverty, poverty levels, poverty line, practical purposes, prevalence, price, quarter of a century, racing pigeon, reminder, rent, repair, resources, retail, reward, richest, security, shocking, side effects, small businessmen, small-scale, species, spending money, statistic, summarise, survive, tax, transport, TV license, untapped resources, utilities, west, western economy, western world, work, work-related expenses, workers, world bank | 0 comments
History is a funny old business; an endless mix of overlapping threads, intermingling stories and repeating patterns that makes fascinating study for anyone who knows where to look. However, the part of it that I enjoy most involves taking the longitudinal view on things, linking two seemingly innocuous, or at least totally unrelated, events and following the trail of breadcrumbs that allow the two to connect. Things get even more interesting when the relationship is causal, so today I am going to follow the trail of one of my favourite little stories; how a single storm was, in the long run, responsible for the Industrial revolution. Especially surprising given that the storm in question occurred in 1064.
This particular storm occurred in the English Channel, and doubtless blew many ships off course, including one that had left from the English port of Bosham (opposite the Isle of Wight). Records don't say why the ship was making its journey, but what was definitely significant was its passenger; Harold Godwinson, Earl of Wessex and possibly the most powerful person in the country after King Edward the Confessor. He landed (although that might be overstating the dignity and intention of the process) at Ponthieu, in northern France, and was captured by the local count, who subsequently turned him over to his liege when he, with his famed temper, heard of his visitor: the liege in question was Duke William of Normandy, or 'William the Bastard' as he was also known (he was the illegitimate son of the old duke and a tanner). Harold's next move was (apparently) to accompany his captor to a battle just up the road in Brittany. He then tried to negotiate his freedom, which William accepted, on the condition that he swear an oath to him that, were the childless King Edward to die, he would support William's claim to the throne (England at the time operated a sort of elective monarchy, where prospective candidates were chosen by a council of nobles known as the Witengamot). According to the Bayeux tapestry, Harold took this oath and left France; but two years later King Edward fell into a coma. With his last moment of consciousness before what was surely an unpleasant death, he apparently gestured to Harold, standing by his bedside. This was taken by Harold, and the Witengamot, as a sign of appointing a successor, and Harold accepted the throne. This understandably infuriated William, who considered this a violation of his oath, and subsequently invaded England. His timing of this coincided with another distant cousin, Harald Hardrada of Norway, deciding to push his claim to the throne, and in the resulting chaos William came to the fore. He became William the Conqueror, and the Normans controlled England for the next several hundred years.
One of the things that the Norman's brought with them was a newfound view on religion; England was already Christian, but their respective Church's views on certain subjects differed slightly. One such subject was serfdom, a form of slavery that was very popular among the feudal lords of the time. Serfs were basically slaves, in that they could be bought or sold as commodities; they were legally bound to the land they worked, and were thus traded and owned by the feudal lords who owned the land. In some countries, it was not unusual for one's lord to change overnight after a drunken card game; Leo Tolstoy lost most of his land in just such an incident, but that's another story. It was not a good existence for a serf, completely devoid of any form of freedom, but for a feudal lord it was great; cheap, guaranteed labour and thus income from one's land, and no real risks concerned. However the Norman church's interpretation of Christianity was morally opposed to the idea, and began to trade serfs for free peasants as a form of agricultural labour. A free peasant was not tied to the land but rented it from his liege, along with the right to use various pieces of land & equipment; the feudal lord still had income, but if he wanted goods from his land he had to pay for it from his peasants, and there were limits on the control he had over them. If a peasant so wished, he could pack up and move to London or wherever, or to join a ship; whatever he wanted in his quest to make his fortune. The vast majority were never faced with this choice as a reasonable idea, but the principle was important- a later Norman king, Henry I, also reorganised the legal system and introduced the role of sheriff, producing a society based around something almost resembling justice.
[It is worth noting that the very last serfs were not freed until the reign of Queen Elizabeth in the 1500s, and that subsequent British generations during the 18th century had absolutely no problem with trading in black slaves, but they justified that partly by never actually seeing the slaves and partly by taking the view that the black people weren't proper humans anyway. We can be disgusting creatures]
A third Norman king further enhanced this concept of justice, even if completely by accident. King John was the younger brother of inexplicable national hero King Richard I, aka Richard the Lionheart or Couer-de-Lion (seriously, the dude was a Frenchman who visited England twice, both to raise money for his military campaigns, and later levied the largest ransom in history on his people when he had to be released by the Holy Roman Emperor- how he came to national prominence I will never know), and John was unpopular. He levied heavy taxes on his people to pay for costly and invariably unsuccessful military campaigns, and whilst various incarnations of Robin Hood have made him seem a lot more malevolent than he probably was, he was not a good King. He was also harsh to his people, and successfully pissed off peasant and noble alike; eventually the Norman Barons presented John with an ultimatum to limit his power, and restore some of theirs. However, the wording of the document also granted some basic and fundamental rights to the common people as well; this document was known as the Magna Carta; one of the most important legal documents in history, and arguably the cornerstone in the temple of western democracy.
The long-term ramifacations of this were huge; numerous wars were fought over the power it gave the nobility in the coming centuries, and Henry II (9 years old when he took over from father John) was eventually forced to call the first parliament; which, crucially, featured both barons (the noblemen, in what would soon become the House of Lords) and burghers (administrative leaders and representatives of the cities & commoners, in the House of Commons). The Black Death (which wiped out most of the peasant population and thus raised the value of the few who were left) greatly increased the value and importance of peasants across Europe for purely economic reasons for a few years, but over the next few centuries multiple generations of kings in several countries would slowly return things to the old ways, with them on top and their nobles kept subservient. In countries such as France, a nobleman got himself power, rank, influence and wealth by getting into bed with the king (in the cases of some ambitious noblewomen, quite literally); but in England the existence of a Parliament meant that no matter how much the king's power increased through the reign of Plantagenets, Tudors and Stuarts, the gentry had some form of national power and community- and that the people were, to some nominal degree, represented as well. This in turn meant that it became not uncommon for the nobility and high-ranking (or at least rich) ordinary people to come into contact, and created a very fluid class system. Whilst in France a middle class businessman was looked on with disdain by the lords, in Britain he would be far more likely to be offered a peerage; nowadays the practice is considered undemocratic, but this was the cutting edge of societal advancement several hundred years ago. It was this 'lower' class of gentry, comprising the likes of John Hampden and Oliver Cromwell, who would precipitate the English Civil War as King Charles I tried to rule without Parliament altogether (as opposed to his predecessors who merely chose to not listen to them a lot of the time); when the monarchy was restored (after several years of bloodshed and puritan brutality at the hands of Cromwell's New Model Army, and a seemingly paradoxical few decades spent with Cromwell governing with only a token parliament, when he used them at all), parliament was the political force in Britain. When James II once again tried his dad's tactic of proclaiming himself god-sent ruler whom all should respect unquestioningly, Parliament's response was to invite the Dutch King William of Orange over to replace James and become William III, which he duly did. Throughout the reign of the remaining Stuarts and the Hanoverian monarchs (George I to Queen Victoria), the power of the monarch became steadily more and more ceremonial as the two key political factions of the day, the Whigs (later to become the Liberal, and subsequently Liberal Democrat, Party) and the Tories (as today's Conservative Party is still known) slugged it out for control of Parliament, the newly created role of 'First Lord of the Treasury' (or Prime Minister- the job wasn't regularly selected from among the commons for another century or so) and, eventually, the country. This brought political stability, and it brought about the foundations of modern democracy.
But I'm getting ahead of myself; what does this have to do with the Industrial Revolution? Well, we can partly blame the political and financial stability at the time, enabling corporations and big business to operate simply and effectively among ambitious individuals wishing to exploit potential; but I think that the key reason it occurred has to do with those ambitious people themselves. In Eastern Europe & Russia, in particular, there were two classes of people; nobility who were simply content to scheme and enjoy their power, and the masses of illiterate serfs. In most of Western Europe, there was a growing middle class, but the monarchy and nobility were united in keeping them under their thumb and preventing them from making any serious impact on the world. The French got a bloodthirsty revolution and political chaos as an added bonus, whilst the Russians waited for another century to finally get sufficiently pissed of at the Czar to precipitate a communist revolution. In Britain, however, there were no serfs, and corporations were built from the middle classes. These people's primary concerns wasn't rank or long-running feuds, disagreements over land or who was sleeping with the king; they wanted to make money, and would do so by every means at their disposal. This was an environment ripe for entrepreneurism, for an idea worth thousands to take the world by storm, and they did so with relish. The likes of Arkwright, Stephenson and Watt came from the middle classes and were backed by middle class industry, and the rest of Britain came along for the ride as Britain's coincidentally vast coal resources were put to good use in powering the change. Per capita income, population and living standards all soared, and despite the horrors that an age of unregulated industry certainly wrought on its populace, it was this period of unprecedented change that was the vital step in the formation of the world as we know it today. And to think that all this can be traced, through centuries of political change, to the genes of uselessness that would later become King John crossing the channel after one unfortunate shipwreck…
And apologies, this post ended up being a lot longer than I intended it to be
Standard | | Tagged 1064, administrative leaders, agricultural labour, ambitious individuals, barons, battle, Bayeux tapestry, big business, Bosham, Britain, Brittany, burghers, businessman, candidates, captor, card game, causal, chaos, cheap, Christian, Church, class system, coma, commodities, connection, consciousness, Conservative Party, control, cornerstone, corporations, costly, Couer-de-Lion, council, council of nobles, count, democracy, dignity, disagreements, disdain, drunken, Duke William of Normandy, Earl of Wessex, Eastern Europe, Edward the Confessor, elective monarchy, England, English channel, English Civil War, enjoy, entrepreneurism, equipment, exploit, fascinating, feudal lords, feudal system, feudalism, feuds, financial stability, First Lord of the Treasury, fluid, foundations of democracy, France, free peasant, freedom, French Revolution, Frenchman, fun, funny, genes, gentry, George Stephenson, god-sent, goods, Hanoverian, Harald Hardrada, Harold Godwinson, harsh, heavy taxes, Henry I, Henry II, history, Holy Roman Emperor, House of Commons, House of Hanover, House of Lords, ideas, illegitimate, illiterate, income, industrial revolution, influence, innocuous, intention, intermingling, invasion, Isle of Wight, James II, James Watt, John Hampden, justice, king, King Charles I, King John, King Richard I, King William I, kings, labour, land, legal documents, legal system, legally bound, Leo Tolstoy, levy, Liberal Democrats, Liberal Party, liege, living standards, London, Magna Carta, make money, malevolent, middle class, middle classes, military campaigns, monarchy, money, moral opposition, negotiate, New Model Army, nobility, noblemen, Norman king, Normans, northern France, Norway, numerous wards, oath, Oliver Cromwell, overlapping, paradoxical, Parliament, patterns, peerage, political chaos, political factions, political force, political stability, politics, Ponthieu, population, potential, power, primary concerns, Prime Minister, prospective candidates, Queen Elizabeth, ramifications, rank, ransom, relationships, religion, rent, repeating, representatives, Richard Arkwright, Richard the Lionheart, risks, Robin Hood, Russia, serfdom, serfs, sheriff, ships, slavery, stories, storm, Stuarts, study, successor, tanner, temper, temple of democracy, The Black Death, throne, Tories, totally unrelated, traded, trail of breadcrumbs, ultimatum, undemocratic, unpleasant, unpopular, unprecedented change, unsuccessful, uselessness, View, visit, wealth, western democracy, Whigs, William III, William of Orange, William the Bastard, William the Conqueror, Witengamot | 0 comments
Money- what the &*$!?
Money is a funny old thing- the cornerstone of our way of existence, the bedrock of modern-day life, and the cause of, and solution to, 99% of all life's problems. But… well, why? When you think about it, money doesn't actually mean anything- it is an arbitrary creation brought in for convenience's sake, and yet it as an entity has spiralled into so much more than a mere tool. Now how on earth did that happen?
Before about two and a half thousand (ish) years ago, money just about not exist. To the best of my knowledge, coinage only became commonplace in Europe with the rise of the Roman Empire- indeed, when they left Britain in the 5th century AD, much of the country went back to simply bartering- trading goods and services for other goods and services. This began to change as time went on however, and by the time of William the Conqueror's invasion, the monetary system was firmly established across Europe. Coins were a far more efficient system than bartering- trading stuff for one another is a highly subjective process, and it can be hard to get a sense of value and to what extent you were being ripped off. By giving everything a fixed, arbitrary value (ie a price), everything suddenly had a value relative to one another. More importantly, this allowed for goods and services to be traded for the potential to buy more goods and services of equal value in coin form, rather than the things themselves, which was both easier and more efficient (there was now no risk of carrying a lampshade to the supermarket to exchange for a pint of milk, because a wallet is far easier to carry). The idea of money representing the potential to buy things can be seen by anyone looking on a British note, where it reads "I promise to pay the bearer on demand the sum of…" however many pounds (this is in fact a callback to the days when banks stuck to the gold standard, when you could theoretically walk into the Bank of England and ask for five pound's worth of gold for your fiver).
However, with coins representing potential to buy things, they instantly took on a value of their own, and here things start to get confusing. Because, when money itself takes on a value, it instantly becomes a commodity just like any other- just as people trade in gold bullion, oil and bits of companies, so people trade with money itself. And this… actually, I've got ahead of myself- let me take a step backward.
The input of human effort can be used to increase the value of various bits of the world we live in. For example- a heap of planks may be bought for £50 from a sawmill, but once you have gone home and spent 6 hours swearing at a hammer, you may now have a bench or something worth £500 or more. The materials themselves have not changed, but since a bench is more useful, better looking, and is better appreciated by people than a few planks, people set more value by it. Because more value is set by it, so it is worth more money.
This, at a base level, is how the economic system works- human effort is used to turn raw materials, which we don't want, into products, which we do. Because people want these products, they pay money for them, and because they need this money to pay for them, they get a job. Because they are providing human effort to their boss (which itself has a value for its ability to raise the value of raw materials), their boss pays them the money they need. The boss gets the money he uses to pay his employees from selling things to people, which makes money because the human effort put in to make his final product raises the value of his final product above that of the raw materials he bought in order to make it- and thus we are back at the beginning of the cycle.
If we study this process, we can see that the only way the boss can make any money out of it is if the value of his final product (F) is greater than the value of its raw materials (M) plus however much he pays his employees for the effort they input (E)- ie, F>M+E. However, pretty much by definition, F should equal M+E- thereby the only way he can make money is by paying his workers less than their human effort is actually worth in the context of the product (A communist would seize on this as evidence of corporations exploiting the masses, but I refuse to go into this argument here- it is far too messy). This is the only way that any money actually gets produced in an economy, and the result is inflation. If inflation did not exist, then the only way anyone could make any money would be by spending less- but this automatically means that somebody else will not be getting your money, and so will be losing some. Thus inflation is vital to ensure that everybody in an economy gains money, and although this does lead to the gentle devaluation of currency, it allows the human race to stay one step ahead of a potential vicious cycle of decline- and inflation can only be generated by an economy manufacturing things.
But why do we need our level of money to continually rise? Well, imagine you have a steak worth £5 (It's just an example, don't judge me on my figures). When you eat that steak, something of value £5 has been turned into the contents of your gut, and ultimately into what comes out the other end- which is clearly worth a lot less than the steak. Thus, the human race consuming resources reduces the overall value of planet earth, just as making stuff increases it. Nature in fact has an inbuilt system to prevent this from turning into a cycle of endless decline- reproduction. If the cow you ate your steak from had had a calf, then nature has ensured that your consumption of the steak has not, in the long run, decreased the overall steak value of the world due to the steak potential existing in the calf (I've just realised I'm making all these terms up on the fly- my apologies). I could go into the whole energy from calf <- energy from grass <- energy from sun <- universe in general etc. thing here, but this is extrapolating the economic problem somewhat. However, suffice it to say that ensuring our overall monetary value continues to rise via inflation is our version, from an economic perspective, of reproduction, balancing out our consumption of finite resources in terms of value.
Phew- this is getting longer than I anticipated. My apologies once again for it turning into a semi-coherent ramble, I only hope you could follow it. There is still quite a lot more to get through, so I think I'll try to wind this all up on Wednesday (after another Six Nations post Monday- COME ON ENGLAND!). If you have been able to follow all of that then congratulations- you now understand core economics. If you haven't then also congratulations- you are sufficiently normal to not understand my way of thinking.
Standard | | Tagged arbitrary value, bartering, coinage, coins, commodity, cycle, economic system, economy, effort, employees, employers, gold standard, goods, I promise to pay the bearer on demand the sum of, inflation, input, monetary system, money, nature, potential goods & services, reproduction, resource consumption, Roman Empire, services, trading, value, William the Conqueror | 0 comments