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Non Statutory Assessment Of Costs | Power To Order A Final Bill And Breakdown
Having accepted (or failed to argue otherwise) in the course of defending a claim for unpaid fees that the invoices in question were (or at least were capable of being treated as) statute bills and, consequential upon that, having consented to "an inquiry into and assessment of the sum payable" by way of non statutory assessment it was not open to the defendant to argue in the course of that non statutory assessment that those same invoices were not statute in nature.
Where a solicitor has delivered a discounted bill and the client has applied under section 70 of the 1974 act for detailed assessment, the solicitor is entitled to produce a breakdown showing the full, undiscounted value of the work done and disbursements incurred. The client will then have to shoulder the burden of showing, by reference to the full breakdown, that the solicitor's reasonable fees and disbursements are less than the amount of the bill actually delivered. If the breakdown is reduced by one fifth or more, but the bill is not, then the "one-fifth rule" embodied in section 70(9) of the 1974 Act will operate in the solicitor's favour, not the client's.
On a non-statutory assessment, the court has the power to order a breakdown of the solicitor's bill. The court's case management powers under the Civil Procedure Rules are not limited by 19th century authority. The court can make any order it sees fit in order to achieve the overriding objective. That includes the delivery of a breakdown, if a breakdown is needed for the efficient and fair assessment of the solicitor's bill.
Speculative Retainer Challenges And Requests For Disclosure 16/01/2022
Fee Remissions And Inter Partes Assessments 05/01/2022
Interim Costs Payment Refused In Liability Admitted High Value MT Case 04/01/2022
Informed Consent And Alleged Termination Of Retainer | High Court Appeal 02/01/2022
New Guideline Hourly Rates Relevant To Work Done Prior To 1 October 2021 12/12/2021
Master Leonard declines to order delivery of a final statute bill and accompanying breakdown as to do so would constitute a radical change of position and a collateral attack upon the agreed order of Deputy Master Nurse awarding judgment to the Claimant for a sum (if any) to be assessed by way of a non statutory assessment of costs.
"Even assuming that no statute bills had ever been rendered by the Claimant under the General Retainer, it does not seem to me that it would be appropriate now to make an order that would unpick the agreed arrangement embodied in the order of Deputy Master Nurse solely because the Defendants, years into the litigation, now wish radically to revise their position. To do so would be, as the Claimant contends, to support a collateral attack upon the Deputy Master's order."
"…the Defendants have already accepted for the purposes of these proceedings that the Claimant's General Retainer invoices, whether individually or collectively, had the status of a statute bill or bills, and both parties are now in consequence bound by a judgment that can only have been given on that basis. It is, as Mr Slade has said, too late for them to pursue another case now."
The Master also made some observations concerning the sometimes under appreciated distinction between and a 'bill' and 'breakdown' of costs in the context of solicitor and client assessments, the purpose and effect of the latter and the Court's power to order one.
BLACKLION LAW LLP V AMIRA NATURE FOODS LTD & ANOR [2021] EWHC B22 (COSTS) (11 NOVEMBER 2021)
SOLICITOR AND CLIENT | SOLICITORS ACT 1974 | SOLICITOR AND CLIENT ASSESSMENTS | DETAILED ASSESSMENT | STATUTE BILLS | NON STATUTE BILLS | STATUTORY ASSESSMENT | NON STATUTORY ASSESSMENT | BREAKDOWN OF COSTS
Richard Slade & Co v Boodia [2018] EWCA Civ 2667
Adams v Al-Malik [2003] EWHC 3232 (QB)
Rutter v Sheridan-Young [1958] 1 WLR 444
Re Park [1887] Ch 326
Devaynes v Noble (1816) 1 Mer. 572
Parvez v Mooney Everett Solicitors Ltd [2018] EWHC 62 (QB)
Ainsworth v Stewarts Law LLP [2020] EWCA Civ 178
BLACKLION LAW LLP V AMIRA NATURE FOODS LTD & ANOR (DELIVERY OF A STATUTE BILL) | KEY EXCERPTS
Ordering the Delivery of a Statute Bill
"Even assuming that no statute bills had ever been rendered by the Claimant under the General Retainer, it does not seem to me that it would be appropriate now to make an order that would unpick the agreed arrangement embodied in the order of Deputy Master Nurse solely because the Defendants, years into the litigation, now wish radically to revise their position. To do so would be, as the Claimant contends, to support a collateral attack upon the Deputy Master's order." [73]
Bills and Breakdowns
"This takes me to the important distinction between the statute bill delivered by a solicitor and the breakdown that may be ordered by the court under CPR 46.10. I agree with Mr Slade that a non-statutory assessment is an assessment of the solicitor's bill or bills, but only because all solicitor/client detailed assessments, whether statutory or not, are assessments of the bill that has been delivered. The breakdown is nothing more than a tool to assist the assessment of that bill. It does not replace it." [76]
"…where the solicitor has delivered a discounted bill and the client has applied under section 70 of the 1974 act for detailed assessment, the solicitor is entitled to produce a breakdown showing the full, undiscounted value of the work done and disbursements incurred. The client will then have to shoulder the burden of showing, by reference to the full breakdown, that the solicitor's reasonable fees and disbursements are less than the amount of the bill actually delivered. If the breakdown is reduced by one fifth or more, but the bill is not, then the "one-fifth rule" embodied in section 70(9) of the 1974 Act will operate in the solicitor's favour, not the client's." [77]
"I do not accept Mr Slade's contention that on a non-statutory assessment, the court does not have the power to order a breakdown of the solicitor's bill. The court's case management powers under the Civil Procedure Rules are not limited by 19th century authority. In my view, the court can make any order it sees fit in order to achieve the overriding objective. That includes the delivery of a breakdown, if a breakdown is needed for the efficient and fair assessment of the solicitor's bill." [78]
Whether the General Retainer Invoices are Statute Bills
"the Defendants have already accepted for the purposes of these proceedings that the Claimant's General Retainer invoices, whether individually or collectively, had the status of a statute bill or bills, and both parties are now in consequence bound by a judgment that can only have been given on that basis. It is, as Mr Slade has said, too late for them to pursue another case now." [84]
Link to Judgment
BLACKLION LAW LLP V AMIRA NATURE FOODS LTD & ANOR (DELIVERY OF A STATUTE BILL) | FULL SUMMARY AND DECISION
Relevant Background
These proceedings started in the Chancery Division (Business and Property Courts) in April 2018.
The Claimant solicitors took proceedings against the Defendants in respect of the unpaid balance of a number of invoices.
The invoices related to two retainers
The first was a general retainer (the "General Retainer") covering a variety of matters, described by the Claimant as corporate and commercial, litigation, employment and other incidental work.
The second retainer ("the Avatar Retainer") concerned services relating to a proposed bond issue which never took place.
The proceedings before the SCCO were concerned only with invoices rendered under the General Retainer.
Between 5 December 2016 and 1 December 2017, the Claimant had rendered ten invoices under the General Retainer. Two of them (296 and 301) were set off against each other so as, in effect, to represent a single invoice for the same period.
In chronological order the invoices were numbered 274, 285, 296/301, 302, 304, 312, 314, 322 and 1179. In total they came to £441,073.51, against which, in a series of payments between January and July 2017 had been paid £239,882.70.
After deducting a number of credit notes issued between February and June 2017 against invoices 302, 304, 312 and 314, the Claimant claimed an outstanding overall balance of £118,510.81.
The claims under the General Retainer and the Avatar Retainer were defended, and a counterclaim in negligence was made (and subsequently discontinued) in relation to the Avatar Retainer.
The Defence
The first Defendant's Defence did not take issue with the terms of the General Retainer, the delivery of the Claimant's General Retainer invoices, the amounts of those invoices, the assertion in the Particulars of Claim that they were all supported by detailed time narratives and details of disbursements incurred, or the amounts paid against them. The Defence instead relied upon the proposition that an alleged lack of particularity in relation to the services rendered failed to establish that the Claimant had the right to render the invoices and the Defendant an obligation to pay them.
In the absence of such particulars the Defendants asserted that they could offer no meaningful response to the claim, whilst at the same time saying that first Defendant had, in correspondence with the Claimant, raised a dispute in relation to whether the fees in these invoices had been properly incurred and made an open offer to resolve the General Retainer dispute on the basis that it would release more shares to the value of £118,510.81 following "a formal, binding, assessment of the Claimant's invoices under the General Retainer by a mutually agreed costs draftsman".
The Defence did not deny, or put the Claimant to proof that, the Claimant's General Retainer invoices were valid statute bills.
On 15 February 2021 the Claimant obtained an order from Deputy Master Nurse for summary judgment for the sum, "if any", found due in respect of the General Retainer (the dispute over the Avatar Retainer continues in the Chancery Division).
The wording of the order, insofar as relevant, is as follows:
"… UPON the parties agreeing that the General Retainer issue should be referred to the SCCO for the assessment provided for below….
1. On the Claimant's application… (1) there be judgment for the Claimant in the sum (if any) found due in respect of the General Retainer issue on the assessment provided for by paragraph 2 of this order…
2. … there be an inquiry into and assessment of the sum payable to the Claimant in respect of its invoices 304, 312, 314, 322 and 1179 relating to the General Retainer, as adjusted by any relevant credit notes, which shall be undertaken by a Costs Judge in accordance with the directions in paragraph 3 below…
3. The following directions shall apply to the inquiry and assessment:
(1) the First Defendant shall by 4pm on 19 March 2021 serve Points of Dispute on the Claimant setting out its objections to any items in accordance with paragraph 8.2 of PD 47
(2) the Claimant shall by 4pm on 16 April 2021 serve on the First Defendant its Replies to the objections by the First Defendant;
(3) by 4pm on 23 April 2021 the parties shall apply to the Costs Judge for the listing and disposal of the inquiry and assessment (and shall lodge a copy of this order and their combined Points of Dispute and Replies in support of that application);
4. Pursuant to CPR 25.7, the First Defendant shall pay to the Claimant the sum of £40,000 on account of the sum payable to the Claimant by virtue of paragraph 1(1) of this Order pending the outcome of the inquiry and assessment…"
The costs of that part of the claim for which the Claimant had obtained summary judgment were reserved to the Costs Judge.
The Assessment Proceedings
Following service of Points of Dispute and Replies, on 4 May 2021 the Claimant filed at the SCCO its application for the disposal by a Costs Judge of the enquiry and assessment.
On 20 May 2021, Master Leonard arranged a 30 minute appointment for directions on 8 July
On 22 June 2021. the Defendants' solicitors wrote to Richard Slade & Company proposing that directions should incorporate provision for "a bill of costs … [breakdown] in respect of every invoice claimed"; that the Claimant either supply or allow inspection of its files; and that revised Points of Dispute and Replies be served, as necessary. They also asked the Claimant to state its position on whether "statute bills" had been delivered to the Defendant under the General Retainer
The Defendant replied on 28 June to the effect that the court had ordered a common law assessment, not a statutory assessment; that the points of Dispute and Replies had already been served without the need for any further breakdown; that the Claimant was out of time to apply for a statutory assessment; and that the court had no power to require the Claimant to disclose its files.
On the afternoon of 2 July 2021 the Defendant filed an application for an order to the effect that the Claimant prepare and deliver to the Defendants a final bill in chronological spreadsheet format, in two parts. The first would cover invoices 274, 285, 296/301 and 302, to be assessed pursuant to the Solicitors Act 1974, and the second invoices 304, 312, 314, 322 and 1179, to be assessed pursuant to the Order of Deputy Master Nurse. The order sought was also to provide for the Defendants to be entitled to inspection of the Claimant's file pertaining to the General Retainer, for further Points of Dispute and Replies, and the service of any witness evidence upon which the parties would wish to rely.
MASTER LEONARD:
The Claimant's General Retainer and Terms of Business
30. The terms of the General Retainer are recorded in a letter dated 2 November 2016. In the letter, the first Defendant is referred to as "the Company". Insofar as pertinent it reads (including some minor spelling errors that I have not corrected):
"… I enclose our Terms of Business that apply to all the services which we provide to you as our client…
We have agreed that we will charge the Company a minimum retainer fee of £25,000 per month for three months subject to review at the end of this period. Any time incurred about the retainer will be
invoices separately with supporting time recording…
We usually charge clients on the basis of hourly charging rates…."(A list of hourly rates, with review provisions and some discounts, follows.)
"… The Company will be invoiced for our fees monthly by reference to the time spent in the previous month. At regular intervals we will provide you with updates as to our fees and disbursements. We will also ensure that billing procedures are streamlined to best meet your requirements.
We intend to try and agree our invoices with you. However if you have a question about any invoice please let me know. If you are still concerned, then you may be entitled to have the bill assessed externally under Part III of the Solicitors Act l974. We will be entitled to charge interest on all, or part of, any unpaid invoice.
Our invoices are payable immediately upon receipt and we draw your attention to the provision in our Terms of Business that we reserve the right to cease acting in the event of non-payment."
31. The Terms of Business say:
"… These terms will apply to all dealings between us unless supplemented or varied by other terms of business issued by us, or otherwise varied in writing…We will normally bill you at monthly intervals where a matter is expected to take longer than three months to be concluded or where costs incurred are significant…
A final bill will be issued on completion or conclusion of a matter once the full amount of costs applicable has been ascertained… All bills issued are payable on delivery and interest is payable after thirty days at the rate of 1.5% per month for any amount unpaid… If you have any query on a bill this should be raised with us immediately on receipt… You may be entitled to object to a bill by making a complaint to the Legal Ombudsman and/or by applying to the court for an assessment of the bill under Part III of the Solicitors' Act 1974…"
32. The three-monthly minimum retainer fee arrangement is reflected in the first four of the Claimant's invoices. Invoices 274 (5 December 2016), 275 (9 January 2017) and 206 (31 January 2017), cover the three-month period to 31 January 2017. Each charges the monthly fixed fee of £25,000 along with miscellaneous disbursements. Invoice 301, dated 19 April 2017, covers the period 1 to 31 January 2017 and charges fees of £45,020 from which is deducted the £25,000 fee charged in invoice 206 (which covers the same period). In other words, invoice 301 represents the balance of the Claimant's monthly fees for January 2017 over the agreed monthly minimum retainer fee of £25,000.
The Defendant's Evidence
33. As I have mentioned the second Defendant Mr Chanana, who is chairman of the first Defendant, has given evidence in support of the application. He says that the Claimant's retainer does not provide for interim bills to be statute bills. He was not informed at any time by the Claimant that the bills under the General Retainer should be treated as statute bills, nor that time would be running in respect of any application to have them assessed under the 1974 Act, nor of the procedure to follow to obtain such an assessment.
34. Mr Chanana says that he expected that any issues with costs or disputes about charges would be resolved later, when a final bill was provided. Had he known of any requirement to challenge each invoice within a given time, he would have done so because he was concerned with perceived overcharging by the Claimant. There was correspondence between the parties on the matter between 2017 and 2018, including the Defendant's offer to go to an independent assessment.
35. Mr Chanana says that the credit notes (amounting, as they do, to over £80,000) provided by the Claimant represent a concession to the effect that the first Defendant was overcharged, in particular for WhatsApp messages. The form in which the invoices have been presented by the Claimant make them "incredibly difficult" to review and see whether other time has been recorded fairly and accurately. He continues, he says, to be extremely concerned that significant inappropriate overcharging may be concealed within block time recording entries such as "various emails and correspondence with…" which, he says, forms most of the narratives in the invoices.
36. Mr Chanana argues that the first Defendant's payments were not made in respect of any specific invoices, and the Claimant simply chose to allocate them as it thought fit, so that what seems to be an arbitrary distinction has been made between paid and unpaid bills. He says that it would not be fair to have just those invoices which the Claimant deems unpaid bills to be assessed without also checking those they chose to consider paid bills. His previous solicitors prepared Points of Dispute in general terms in respect of the unpaid bills only, but his current advisers do not consider that this will be sufficient for the court to undertake a proper assessment.
37. Mr Chanana says that he did ask his previous advisers to open up all of the General Retainer invoices, not just those treated as unpaid, to scrutiny. He suggests that the summary judgment procedure may have disrupted this.
38. Much of Mr Chanana's witness statement offers submissions rather than evidence, presumably reflecting advice he has received from his current legal advisers. Even some assertions of fact appear to be based upon advice, such as this paragraph:
"I also understand that the Claimant has not provided full narratives or evidence of time recording in respect of every Unpaid Bill, nor have we been given access to our matter files. Under the guidance of our previous legal advisors, Points of Dispute were therefore prepared on a very general basis and only in respect of the Unpaid Bills, but we understand from our current advisors that this is not sufficient for a proper assessment to be conducted by the Court".
39. This is on the face of it a rather odd statement. Mr Chanana does not identify the source of his stated understanding, but surely he would be in a position to know first-hand what costs information had been supplied to the first Defendant. The Defence does not deny that each of the General Retainer invoices had been supported, as the Particulars of Claim put it, by "detailed time narratives and details of disbursements incurred". The correspondence I have seen also indicates that the first Defendant requested and received timesheets in support of all of the Claimant's General Retainer invoices, and discussions between the parties as to what was properly chargeable (which led to the issue of the credit notes) were based upon those timesheets. Further copies were appended to the Claimant's Reply and Defence to Counterclaim in these proceedings.
40. Bearing that in mind, I can only interpret this part of his evidence as meaning that Mr Chanana has been told by his current advisers that the time records and other details supplied by the Claimant do not provide the information they would wish to have for the purposes of the assessment.
41. That takes me to the witness statement of Mersedeh Safa, a costs lawyer with Clyde & Co, made in support of the first Defendant's application.
42. Ms Safa states that no attempt was made by the Claimant to deal with this dispute via the Senior Courts Costs Office, which she describes as the usual procedure for Solicitor and Client disputes.
43. I will mention now that I cannot agree with that. It depends on the nature of the dispute. It is commonplace for solicitors to issue Part 7 proceedings for unpaid bills, and the SCCO could not have dealt with the first Defendant's counterclaim.
44. Ms Safa describes the preparation of a breakdown of the Claimant's invoices as an essential step for assessment and is concerned that Points of Dispute and Replies been prepared by the parties on the basis of the Claimant's invoices, which do not contain the requisite information to make the assessment a straightforward process. It is very difficult, she says, to ascertain from the invoices what matters under the General Retainer are being dealt with by the Claimant on behalf of the first Defendant.
45. There is, Ms Safa adds, no comprehensive reconciliation of items which have been credited. She argues that the detailed assessment needs a proper breakdown, incorporating a narrative of all the related workstreams and how each item claimed for in the invoices falls within them, so as to avoid the Court having to "jump from" the pleadings and witness statements from the Chancery Division proceedings. It would allow identification of items billed, credited or discounted and allow the first Defendant to sensibly consider whether the time claimed is reasonable and in accordance with client instructions.
46. Ms Safa argues that if the assessment proceeds on the invoices alone, the process is likely to be unnecessarily protracted and costly, as there is insufficient detail in the invoices to satisfy the Defendants' legal team without a "deep dive" at the assessment hearing.
47. Given that credit notes were provided, which Ms Safa attributes to errors and overcharging in both paid and unpaid invoices, the Claimant would also benefit, she argues, by having a specialist costs lawyer review their invoices to ensure there are no further issues with items billed and claimed from the Defendants.
48. Ms Safa suggests that the Claimant produce an electronic breakdown of costs, to assist the parties and the Court in managing the assessment and putting the parties on equal footing in accordance with the Overriding Objective.
49. With regard to inspection of the Claimant's files, Ms Safa says that it does not appear that the Defendants have been advised of their potential entitlement to obtain a copy of their file, or at least those parts of the file to which they are entitled as of right, held by the solicitor and/or to inspect those documents in the alternative in advance of preparing the Points of Dispute.
50. As to the status of the invoices rendered under the General Retainer, Ms Safa's evidence is rather equivocal. She does not positively assert that they are not statute bills, but says rather that it has been difficult to establish whether they were interim statute bills or requests for payments on account, with a final bill being due to the Client "on completion/termination of the matter".
51. Ms Safa suggests (as I read her evidence) that if the General Retainer invoices were not initially accompanied by any detailed records that would point to their being non-statute bills, but as I have observed, that is inconsistent with the Defendants' pleaded case, and it would depend upon the circumstances, in particular the information otherwise available to the Defendants. The Claimant asserts that the Defendants initially did not require timesheets. In any case, if that was an omission it was remedied before these proceedings began.
52. Mr Jones for the Defendants confirms that they accept that they cannot go behind Deputy Master Nurse's order for a non-statutory assessment of invoices 304, 312, 314, 322 and 1179, which has not been appealed. He argues however that an order for enquiry into and assessment of those invoices does not dispose of the question of whether the Claimant has actually delivered any statute bills, whether final or interim, in respect of work undertaken under the General Retainer. The Claimant has not done so, and the Claimant should now be ordered to render a final bill so that an assessment can proceed on properly particularised information. The application for such an order is not, he says, a collateral attack on the order of Deputy Master Nurse.
53. Mr Jones submits that any statute bill should be complete and final in respect of the period covered by the bill: Richard Slade & Co v Boodia [2018] EWCA Civ 2667. Further, because of the very strict time limits applicable to applications by clients for the assessment of bills under the 1974 Act, in the words of Fulford J in Adams v Al-Malik [2003] EWHC 3232 (QB) (at paragraph 48):
"In particular the party must know what rights are being negotiated and dispensed with in the sense that the solicitor must make it plain to the client that the purpose of sending the bill at that time is that it is to be treated as a complete self-contained bill of costs to date…"
54 Costs Judge Rowley applied the principle in this way in Masters v Charles Fussell & Co LLP [2021] EWHC B1 (Costs) (at paragraphs 28-29):
"The difficulty in a client suing his solicitor while still instructing him is immediately apparent and does not really require High Court authority. It is often prayed in aid as a special circumstance when the challenge is outside the initial month. It seems to me to be self-evident that most clients would expect any issues with costs of this sort to be dealt with either by communicating with the solicitor to resolve perceived problems or at the end of the case when the inevitable conflict between solicitor and client would be less problematic. Whether a proactive approach of approaching the solicitor was undertaken or the client simply waited till the end of the case, the one month time limit would have been long gone by the time the client considered whether to challenge the bill in court…
It is for this reason that in order to "make it plain" to a client that he is receiving an interim statute bill, it seems to me that the information given at the outset needs to make clear that there are time limits and indeed give some indication of what those time limits are. The idea that several months, or, in this case, years after the engagement letter and terms and conditions were provided, the client ought to be alive to the fact that he has an entitlement under the Solicitors Act if he challenges bills promptly, seems to me to be far-fetched. There is no mention of the Solicitors Act on the invoices even to prompt such a recollection. …"
55. In this case, says Mr Jones, neither the General Retainer nor the Claimant's terms of business so much as referred to the existence of time limits under the 1974 Act. The invoices make no reference to the Act at all. It follows, he says, that the invoices rendered by the Claimant cannot have had the status of interim statute bills. A statute bill remains outstanding and delivery of such a bill should be ordered. It makes obvious sense that that bill should be drafted in such a way as to identify clearly the work represented by the invoices which are to be subjected to a non-statutory assessment. The rest of the work covered by the statute bill, once delivered, can be assessed under the 1974 Act.
56. Mr Jones argues that the arrangements currently in place for the assessment of the Claimant's charges are unsatisfactory. The invoices themselves are entirely devoid of detail, and it would not be workable to supply the relevant surrounding detail through witness statements or time recordings in relation to work carried out between four and five years ago. There are particular concerns to be addressed: the Claimant appears to have charged for multiple WhatsApp messages in six-minute units, an issue partly addressed by the issue of credit notes which cannot however be attributed to any particular invoices.
57. Because the information currently before the court is not sufficiently detailed to assist either the parties or the court in conducting a detailed assessment, the Defendant is entitled to inspection of the Claimant's General Retainer files in the usual way and should be provided with the opportunity to file Points of Dispute to a properly particularised bill.
58. Mr Slade for the Claimant points out that the first four invoices in the series fall within the 3-month minimum monthly retainer arrangement and argues, depending on the nature of the work done, that the General Retainer could properly be considered to be a contentious or non-contentious business agreement. Referring to Rutter v Sheridan-Young [1958] 1 WLR 444 he argues that the Defendants do not have a right to require the delivery of a statute bill. In any event, the court's power to order the delivery of a statute bill is an exercise of the court's inherent jurisdiction and as such, of necessity, discretionary. It is not justified on the facts of this case.
59. That aside, the General Retainer invoices are statute bills and the statutory time limits for any order for assessment have expired. The General Retainer stated expressly that the first Defendant was to be invoiced monthly, by reference to the time spent in the previous month, and that there would be a right to assess those bills under the 1974 Act. These provisions did make it plain that the first Defendant would be receiving statute bills.
60. Even if that were not the case, a natural break can be identified from the point when the Claimant ceased working for the Defendants, from December 2017 onwards. It was plain that the final invoice, dated 1 December 2017, was the last in the sequence and that the Claimant's work had concluded. The Defendants understood that the retainer was at an end and would have expected that last invoice to be the Claimant's final bill.
61. All the invoices in relation to which the Defendants now seek a statutory assessment were paid at least three years ago. By virtue of section 70(4) of the 1974 Act there is an absolute bar on the statutory assessment of paid bills after 12 months. As for unpaid bills, section 70(3) provides that no assessment may be made of a bill after 12 months from delivery except in special circumstances. No such circumstances are made out, or even alleged. The Defendants are out of time to apply for the statutory assessment of the paid General Retainer invoices.
62. Further, they are not in a position to resile from the contractual agreement reached before Deputy Master Nurse, as embodied in the terms of his order; to demand a revision of the terms of the order; or to appeal it. Any entitlement to a statutory assessment expired when the Claimant obtained judgment for the outstanding balance of the General Retainer invoices, as did the Defendant's opportunity to take issue with the statutory status of the General Retainer invoices.
63. If the Defendants did not take the opportunity to have the Claimant's invoices reviewed by an experienced costs lawyer prior to filing their points of dispute, that is a matter between them and their advisors, but the presence of leading counsel at the hearing before Deputy Master Nurse suggests that the Defendants were not without expert assistance.
64. As for the supply of a breakdown, Mr Slade argues that the authorities on non-statutory assessment make it clear (In re Park [1887] Ch 326) that, unlike a statutory assessment, the court must assess by references to the solicitor's bills themselves. The court has no power to order a breakdown.
65. The Claimant has he says supplied to the Defendants those documents from its file which are properly its client's property. There is no basis for any order for disclosure, which would only be of any use if the court would take the view that new points of dispute should be ordered. Otherwise, the Claimant will file its papers in support of its bills prior to the assessment hearing in the usual way.
66. This court has an inherent jurisdiction (extended, but not created, by section 68 of the 1974 Act) to order a solicitor to deliver a bill of costs. Whatever the relevance of Rutter v Sheridan-Young to the circumstances of this case (and I suspect that it may be limited, as I am not at all sure that the 1974 Act provides for a hybrid contentious/non contentious business agreement) that must be, as Mr Slade says, a discretionary remedy.
67. An obvious example of circumstances in which it would be appropriate to make such an order would be where a solicitor has been paid by a client for services, but has refused to render a statute bill, thereby denying the client the opportunity, if so advised, to ask the court to assess the reasonableness of the amount charged for those services. One of the questions I have to address is whether, if as the Defendants argue no statute bills have ever been delivered under the General Retainer, this would be a case in which it would be right and fair to make such an order.
68. In that context, I should first deal with Mr Chanana's assertion that the Claimant has arbitrarily applied payments received from the Defendants to the earliest in the series of invoices rendered under the General Retainer. I do not see that as arbitrary at all. Where a series of invoices has been rendered over a period of time, it is an established principle that payments received should be applied to them in date order, so that the earliest are treated as paid. "Clayton's case", Devaynes v Noble (1816) 1 Mer. 572, is at the root of that principle, which is particularly important if (as in this case) the solicitor's retainer provides for interest to accrue upon unpaid invoices.
69. That aside, the parties have in effect accepted that the monies received by the Claimant should be applied in that way. They have taken over three years from the termination of the Claimant's retainer to implement through the order of Deputy Master Nurse an agreed arrangement whereby the earliest in the series of invoices rendered under the General Retainer have effectively been treated as paid and settled, and the remaining wholly or partly unpaid invoices are to be subjected to the scrutiny of the court. The latest of the invoices treated as paid, number 302, was rendered in April 2017, some 4½ years ago.
70. The Defendants could at any time over the three-year period between the termination of the retainer and the Deputy Master's judgment have taken an entirely different line, challenging the status of the invoices as statute bills, applying for the delivery of a final statute bill and applying for that bill to be assessed, or at least taking the position that they wanted all of the General Retainer invoices to be subjected to a non-statutory assessment. They did not.
71. I have not lost sight of the fact that Mr Chanana asserts that he did want his advisers to procure an order for the assessment of all of the General Retainer invoices, but I do not find his brief and rather vague evidence in that respect persuasive. Nothing to that effect seems to have been communicated to the Claimant. On the contrary, following the hearing before Deputy Master Nurse Mr Slade provided a draft order to Mr Williams QC which listed the invoices to be assessed. Mr Williams offered some quite extensive amendments but did not take issue with the list of invoices to be assessed, which duly found its way into the final, sealed order.
72. I find it difficult to accept that communications between the Defendants and their former advisors could have broken down so badly that their advisors failed to mention to the Claimant that the Defendants wanted all of the General Retainer invoices to be assessed. I can see that they might have thought it best not to press for assessment of the paid bills, if only to avoid running up time and costs on some of the arguments I have heard. If however it is indeed the case that they failed to implement Mr Chanana's instructions, that would be something for him to take up with them.
74. For those reasons, even if the Defendants are right to say that the Claimant has never delivered a final statute bill, I am not persuaded that it would be appropriate for me to make an order that the Claimant must now do so.
75. I should add that I do not believe that it is open to me to order that the Claimant deliver a statute bill in a format dictated by me, whether in the spreadsheet form contended for by the Defendants or otherwise. I would refer to the judgment of Mr Justice Soole in Parvez v Mooney Everett Solicitors Ltd [2018] EWHC 62 (QB), at paragraphs 57 and 58: only a solicitor can determine the content and terms of that solicitor's claim for payment. Neither the client nor the Court can make that determination on the solicitor's behalf.
76. This takes me to the important distinction between the statute bill delivered by a solicitor and the breakdown that may be ordered by the court under CPR 46.10. I agree with Mr Slade that a non-statutory assessment is an assessment of the solicitor's bill or bills, but only because all solicitor/client detailed assessments, whether statutory or not, are assessments of the bill that has been delivered. The breakdown is nothing more than a tool to assist the assessment of that bill. It does not replace it.
77. That is why, for example,
where the solicitor has delivered a discounted bill and the client has applied under section 70 of the 1974 act for detailed assessment, the solicitor is entitled to produce a breakdown showing the full, undiscounted value of the work done and disbursements incurred. The client will then have to shoulder the burden of showing, by reference to the full breakdown, that the solicitor's reasonable fees and disbursements are less than the amount of the bill actually delivered. If the breakdown is reduced by one fifth or more, but the bill is not, then the "one-fifth rule" embodied in section 70(9) of the 1974 Act will operate in the solicitor's favour, not the client's.
78. I do not accept Mr Slade's contention that on a non-statutory assessment, the court does not have the power to order a breakdown of the solicitor's bill. The court's case management powers under the Civil Procedure Rules are not limited by 19th century authority. In my view, the court can make any order it sees fit in order to achieve the overriding objective. That includes the delivery of a breakdown, if a breakdown is needed for the efficient and fair assessment of the solicitor's bill.
79. The first observation to make in this context is that the proposition that the General Retainer invoices are not statute bills is inconsistent with each party's Statement of Case and with each party's conduct of the proceedings to date.
80. By that I mean that the Claimant has issued CPR Part 7 proceedings (of which the assessment before me is a part) for the recovery of the costs and disbursements represented by the General Retainer invoices; that the Defendants have not challenged the status of the General Retainer invoices as statute bills, which could potentially have defeated the General Retainer claim completely; that, expressly, the only issue between the parties on the summary judgment application before Deputy Master Nurse was whether the first Defendant had already paid all that was due under the General Retainer invoices; that the Claimant now has judgment for any outstanding, unpaid balance of all of those invoices, supported by a substantial payment on account; and that an enquiry and assessment has been ordered to establish what that balance is, the outcome of which will bind both parties.
81. None of that is consistent with the proposition that the General Retainer invoices are mere requests for payment on account. As I have said, one cannot issue proceedings for the recovery of the costs due under a bill that is not a statute bill. The Claimant's action for recovery was by definition based upon the proposition that the General Retainer invoices, whether individually or collectively, are statute bills and it was incumbent upon the Defendant to say that that was not accepted.
82. I would add that even if the court has an inherent jurisdiction to order a non-statutory assessment of an invoice that is not a final statute bill (which seems unlikely, given that the invoice would have no legal force) I find it impossible to conceive of any circumstances in which that would be appropriate. It would, equally, be pointless to order an enquiry and account into a solicitor's charges before they have been finalised.
83. For those reasons the Defendants' revised position, if accepted, would make nonsense of the agreed terms of Deputy Master Nurse's order. It represents a challenge to that order which it is not open to me to entertain.
84. In summary
85. That being the position, it is for present purposes immaterial whether the General Retainer invoices should properly be treated as a Chamberlain series rather than as a collection of individual statute bills. As Mr Slade says, if the General Retainer invoices are to be treated as stand-alone statute bills, a statutory assessment of the paid bills is barred by section 70(4) of the 1974 Act. If they are a Chamberlain series concluding with the last, delivered on 1 December 2017, then they would be treated as a single, partly paid bill, delivered several years ago and in respect of which the Claimant has obtained judgment. Any order for a statutory assessment may, by reference to section 70(3), only be made under special circumstances, which have not been established. On the contrary, everything the Defendants have done to date militates against making an order for a statutory assessment.
86. I am not in a position to take a final view on the extent to which the Defendants' concerns (or rather, those of their current advisers) as to the practicability and efficiency of the assessment of invoices 304, 312, 314, 322 and 1179, as currently arranged, might be justified. I have seen nothing in the Points of Dispute that suggests that the person responsible for drafting them felt unable to analyse the information provided and to extract from it appropriate objections, including a spreadsheet identifying specific contested items. An example offered by Mr Jones, at general point 2, seems to me only to show that some of the time entries (listed, I believe, in a spreadsheet that I have not yet seen) are criticised as vague and inadequate to support the sums charged, which if justified may well result in costs being disallowed (unless the Claimant's files offer adequate support).
87. I note that the Claimant's Replies argue, relying on Ainsworth v Stewarts Law LLP [2020] EWCA Civ 178, that the Points of Dispute are not adequately particularised but (subject to any submissions I might hear) I would observe that the Claimant cannot have it both ways. Ainsworth v Stewarts Law LLP was a statutory assessment in which the client's representative had received a full breakdown and inspected the files. If in this non-statutory assessment the Claimant is not obliged either to descend to the level of particularity that would be furnished by a breakdown or to allow an inspection of its files, then the Defendants cannot be expected to respond in Ainsworth detail.
88. I do not necessarily see it as problematic that the Claimant's credit notes are not attributable to any particular invoice. Whilst bound by the final amount of its invoices as reduced by its credit notes, the Claimant is entitled on assessment to show the full value of the work done. It does not have to set a credit off against any particular part of it.
89. For the reasons I have given I am not satisfied that it is appropriate to make an order unravelling the process that has already been put in place and substituting another that is more to the Defendants' liking. In particular I am not persuaded that it is necessary or appropriate to order the delivery of a breakdown.
90. I am however minded to undertake a review of all of the detailed information that has been supplied in support of the Claimant's bills and of the Defendant's full responses, including the spreadsheet of detailed objections, which I do not believe that I have seen. Once I have reviewed that information for myself I can take a view on whether any further directions may be needed to render the detailed assessment process as efficient and cost-effective as possible. Subject to any submissions the parties may wish to make, I propose to make an order that that information be filed for review by me, following which if necessary I will arrange a directions hearing to discuss how best to move matters forward (I know, for example, that Mr Slade had it in mind that some witness evidence might be needed).
91. I cannot entirely rule out the possibility that I might, at that stage, require the Claimant to provide more detailed information, whether by way of breakdown or otherwise, but I would be reluctant to do anything that means that the work done to date on Points of Dispute and Replies is wasted.
File Inspection
92. Ms Safa says that it would appear that the Defendants have never been advised on such rights as they have to obtain copies from or to inspect the Claimant's files, whereas Mr Chanana, who ought to know what advice was given, says nothing about it. Under the circumstances I can only accept Mr Slade's assurance that the Claimant has supplied to the Defendants all the documents to which they have a right. In the light of that, and the other conclusions I have reached, I would not consider it appropriate (assuming that I have the power to do so) to make an order for the inspection of the Claimant's files by the Defendant's new advisers.
Summary of Conclusions
93. Even if this were a case, as the Defendants argue, in which the Claimant has never delivered a statute bill it is not a case in which it would be appropriate to exercise the court's discretion to order that such a bill now be delivered. To do so would be to support a collateral attack upon the order made by Deputy Master Nurse on 15 February 2021, which sets out an agreed arrangement by which the earlier invoices rendered by the Claimant are to be treated as paid and settled, and the unpaid remainder are to be subjected to the scrutiny of the court. Nor do I have the power to order that the Claimant deliver a statute bill in any particular form.
Both parties have, from the outset of this litigation to the judgment obtained by the Claimant on 15 February 2021, conducted these proceedings on the basis that all of the invoices rendered by the Claimant under the General Retainer had the status, whether individually or collectively, of a statute bill or bills. The judgment obtained by the Claimant, which sets out the terms of this assessment, is inconsistent with any other conclusion. It is too late for the Defendants now to attempt to argue a different case before me.
95. If the General Retainer invoices are individual statute bills rather than a Chamberlain series, this court does not have the power to order the statutory assessment of those paid more than 12 months ago. If they do form a Chamberlain series, no order for statutory assessment could be made except under special circumstances, and no such circumstances have been shown.
96. I am not persuaded that it is appropriate for me to restart the process of assessing invoices 304, 312, 314, 322 and 1179 by making an order either for the inspection of the Claimant's files or for the Claimant to deliver a breakdown, but subject to submissions I do propose to review the information provided in support of the Claimant's bills and the objections taken to them, to determine whether further directions may be needed.
All/Case Law/News
Speculative Retainer Challenges And Requests For Disclosure
Fee Remissions And Inter Partes Assessments
Interim Costs Payment Refused In Liability Admitted High Value MT Case
Informed Consent And Alleged Termination Of Retainer | High Court Appeal
Hourly Rates In Court Of Protection (And Other) Cases
Significant Developments And The New Precedent T
How Relevant Is The SCCO Guide To Hourly Rates?
Are you ready for the electronic bill of costs…?
Costs Of And Incidental To Proceedings In The Case Of Compulsory Purchase And Analogous Orders
Calderbank Offers Not To Be Equated To Part 36 In Split Trial Cases
Part 36 Offer | Service By Email Validated But Not Without Consequence
Keynote Address by Lord Justice Jackson – The Review of Fixed Recoverable Costs
Proportionality bites again… on entire costs claim
NHSLA wins third additional legal costs liabilities dispute against Irwin Mitchell
83rd Update coming into force April 2016
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Toby Moreton
Interim Statute Bills And Special Circumstances Under s70(3) Solicitors Act 1974
Interim Statute Bills Versus Requests For Payment On Account
CPR 46.9 | Fiduciary Duties And Informed Consent
Interim Statute Bills | Does Your Retainer Allow Them?
Suing For Unpaid Fees? | Statute Bills And The Client's Right To Challenge
s70(3) | 'Exceptional Increase' In Hourly Rates Gives Rise To Special Circumstances
breakdown of costs, Interim statute bills, non statutory assessment, Requests for payment on account, Solicitor and client, Solicitor and client assessments, Solicitors Act 1974
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How do I use the Blue Book?
We cannot say it often enough: Good will and perseverance are the foundation, which lead to trust and thereafter faith, hope and love and quite often miracles. The Holy Mother will guide you each step of the way through Her messages. She will tell you exactly what She wants from you and how you will obtain the greatest value from Her messages. Remember, to effect positive change, invite Her and consult Her at least several times a week, preferably daily.
Pray with your heart. Then read Her messages with care and attention. Her messages are always pertinent and relevant. They are written in plain language. At times the grammar may seem awkward to you. Do not preoccupy your mind with such intellectual trifles. Without any doubt, the meaning and relevance of each message will come to you if you are open and reflective. Do not let your ego clutter the clarity of your soul and the beauty of your heart. Let Her messages reach you rather than find foolish human arguments to discard them.
The Merciful Madonna is, first and foremost interested in your soul, its brightness and cleanliness and your heart, which She wants to be an inviting, beautiful garden that bears many fruits. Yet, because God gave you free will, you need to decide for Her and for Her Son Jesus by the way of Her words. Otherwise, how can the Holy Mother help you overcome your challenges on earth?
Try to be truthful with yourself. She knows you perfectly. There is no way to trick Her. Do not try. Quietness, focus and solitude also help enormously in this process of prayer, inspiration and devotion. Therefore, your results depend on your effort, your sincerity, your willingness, your honest and good intentions. During your struggles, She will give you strength and sustain you with Her love. The rewards are far greater than anything you could imagine, but She wants your fidelity, your desire and devotion.
If you love and honor Her and Her Son with prayer, your being and your life, you may realize one day, that She, through and with God and Her Son, will do all. Remain faithful and patient and continue to pray. In time the Holy Mother will become an integral part of your life. She will protect you from evil and reorient your life.
You will be able to access Her and Her unlimited power if it fits God's plan for your life. You will realize that your self-effort, especially when confronting insurmountable problems, is foolish, even a hindrance in relation to Her infinite resources, Her ability to resolve all your difficulties. She will intercede for you if your intentions are pure and pleasing to God and when you have become and remain Her devoted and loving child.
The current version of our Lady's Book of Messages has a central message in bold letters and supportive text for each day of the year. These sections include invaluable instructions on how to reach deep within your heart and your soul to develop and bring to life your very best qualities.
The unifying theme is love as expressed in our Holy Mother's maternal touch for you and her overriding desire to bring you closer to Her, Her Son and therefore God. The messages are at times encouraging, full of hope and promise. At times they may appear critical even ironical or demanding to you, but they are always constructive and full of love.
They are all designed to render your soul more beautiful, purify your very being and encourage you to live more by Her Son's luminous example. The Holy Mother wants you to experience love and lead a virtuous, fulfilling and purposeful existence during your time on earth. She will help and guide you each step of the way towards peace and purpose and later on true happiness.
You are strongly advised to follow the instructions outlined in the beginning and towards the end of our Lady's Book of Messages before reading your first of many messages. Your results will be far better if you pray prior to opening the our Lady's Book of Messages and if you consult her every day. The Holy Mother has no interest in your intellect. She wants your heart, sincerity, good will, perseverance and love.
She wants you to invite Her into your life. You are not alone! Never! She will come to you. She always does. She is simply waiting for you to say with sincerity and true desire: please come, I need you, please help me. She has helped millions of souls. If you apply yourself, She will certainly help you. To avail yourself of Her supernatural powers, Her immense love, strength and grace decide for Her. This is your choice. No one can make that choice for you. Please come. The Merciful Madonna is your greatest advocate, the most compassionate and most loving Mother. Please come.


ICYMI Taylor Swift will be starring in the new Cats movie adaptation.
The 29-year-old singer posted a coupla ~meow~ selfies from inside her trailer, letting fans know that she has begun filming.
This trailer courtesy of Cats the film. Cat hair on my jacket courtesy of actual cats, Meredith and Olivia.
"This trailer courtesy of Cats the film. Cat hair on my jacket courtesy of actual cats, Meredith and Olivia," she wrote.
Last week Swifty teased that she will play the part of Bombalurina which coincidentally is the love interest of Jason DeRulo's character - juicy!
We look forward to seeing this one, let's just hope Meredith and Olivia get a cameo.


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Section: Arts
Gallery lets students decorate with new art-loan program
by Bailey Blaker
Have you ever wondered what's missing from those beige walls that enclose your single in Old Kenyon? Perhaps a sketch by artist Nan Freeman? A Picasso-esque painting by Todd McKie?
This week, the Gund Gallery launched its new Art Loan Program, which is designed to expand student involvement with art on campus by allowing them to display fine artworks in their residences. The program began on Monday with an exhibition of the available works in the Buchwald-Wright Gallery accompanied by a drawing box, which students may enter their names into until this Sunday at 5 p.m., when 38 students will be selected at random to borrow select pieces of art from the collection. The gallery extended the final day to enter the lottery from yesterday, its original deadline, into this weekend. Students will be able to choose their pieces of art on Tuesday, February 9 during common hour.
Robin Goodman, collections manager and registrar of the Gund Gallery, worked alongside Christopher Yates, the gallery's assistant director, to curate the collection up for loan.
"Some of the works were donated specifically with the idea of going into an art loan program; some of the works were pieces that had been here on campus," Goodman said.
The program includes a $10 loan fee to be paid up front by the students chosen. "That money will go into framing costs and the future purchase of more items for the art loan program," Goodman said. "The idea is that the program will grow and that we will keep adding pieces over time."
In her role as Gund Gallery associate, Amelia Barnes '16 was involved in preparing the pieces to be installed in dorms across campus. She is hoping the new lending project will give students a chance to engage more fully in the art world. "It should hopefully foster a sort of sense of responsibility and adulthood, and just a general respect for art," she said.
Selected students may keep the works through the rest of the semester, with pieces due back by May 4.
Bailey Blaker
Bailey Blaker '18, an English major from Morenci, Mich., was the Arts Editor for the '15/'16 year. Currently she is abroad in England on the Kenyon-Exeter program. She works as…More from Bailey
gund gallery

redpajama_set_name: RedPajamaCommonCrawl


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Home | Overview of the Profession | Usability Overview | Dec. 16th Program Summary | Definitions | Resources | Articles
December 16, 2002 Program Summary by Adele Sommers
"If You Build It, Can They Use It? Ensuring the Usability of Interface Designs" was the third event in a three-part Fall professional development series entitled, "Solving Information Challenges in the Workplace."
Summary: The engaging presentation by computer science professor, researcher, and educational technology developer Dr. Erika Rogers struck a meaningful chord among the enthusiastic attendees who, as software users, have all had first-hand experience with software usability! Erika's sweeping overview of the methods and principles behind usability engineering revealed what distinguishes it from more traditional approaches. A spirited discussion ensued as we explored how user-centered software engineering:
Focuses on users and how they perform tasks, rather than on how the system manipulates data.
Engages multiple disciplines, drawing on knowledge from diverse areas such as art, psychology, technical communication, and computer science.
Relies on an iterative lifecycle that uses evaluation during every stage of development -- during task analysis, requirements definition, conceptual design, prototyping, and implementation. The stages occur repeatedly rather than in a once-only, linear fashion, refining the interface with each pass.
During the course of the evening, we also learned that:
Usability represents the ease, speed, and pleasantness with which intended people can use a product.
HCI practitioners are the intermediaries who study and listen to users, then communicate those needs to the software developers. (HCI refers to "human-computer interface.")
User and task analyses involve investigating the characteristics, goals, tasks, jobs, environments, and workflows of intended users. Their purpose is to contribute to a user profile around which to model the interface design.
Usability specifications target both performance measures (for example, the ability of a user to complete a task in X minutes), and preference measures (for example, the % of user satisfaction with a given set of features).
Prototypes offer a valuable way of incrementally assessing the usability of an interface design. Prototypes can consist of disposable, low-fidelity mockups or more realistic, high-fidelity models that embody working functionality.
Usability evaluation of prototypes or actual systems typically involves real sample users, expert evaluators, or both. User reactions can be collected via surveys, interviews, think-aloud recordings made while users perform a task, on-screen video capturing of pointer movements, role playing, focus groups, and more. Expert reviews can entail simulations, walkthroughs, and a variety of inspections for adherence to standards and heuristic guidelines.
No way to 'ensure' usability! Rather, usability engineering is a probabilistic attempt to achieve the greatest level of user satisfaction within the finite constraints of the project.
Erika has been teaching a variety of courses at Cal Poly on user-centered interface design and development as well as related topics. Plans are now forming to expand the program into the community with "short course" offerings on how to perform usability evaluations. These courses might be of particular interest to technical communicators as well as to businesses who want to develop in-house experts.
The Cal Poly Usability Laboratory is an important resource that Erika and her department are trying to initiate to offer usability testing and evaluation services to the business community. Such a facility could be used locally, as well as in a virtual mode across the country or in any location. In May 2002, Erika conducted a general interest survey to determine how many local businesses might want to use the lab's services. Whereas the survey responses were favorable, funding now presents the greatest challenge. The Computer Science Department would like to tap grants and other funding sources in order to make a physical laboratory a reality.
Stay tuned! We are now forming a chapter strategic partnership with Erika in relation to usability. The first product of this partnership is a new section of our Web site on Usability that now appears under the section called "Overview of the Profession." This section hosts articles contributed by topic sponsors (what's a topic sponsor?), definitions, resources, and other information that we intend to expand over time. Erika has already contributed dozens of links to the section on resources. To visit this new section, please go to http://www.slostc.org/topics/usability/overview.html.
Decisions, decisions!
A little holiday cheer
Embarking on our usability overview
Puzzling over the problem
Engaged in a good discussion
Now that's a great question!
Topic 3:
"If You Build It, Can They Use It? Ensuring the Usability of Interface Designs"
Date: Monday evening, December 16, 2002
Speaker: Dr. Erika Rogers, professor of computer science at Cal Poly, researcher in human-centered computing and usability, and developer of educational technology projects including multimedia-based courseware for industrial training.
"If You Build It, Can They Use It? Ensuring the Usability of Interface Designs" examined the usability of software -- specifically, interfaces -- of Web sites, multimedia productions, information portals, business tools, instructional programs, or any other environment that requires a person to interact with a system on a piece of equipment. Usability has received acute attention in recent years as exasperated customers continue to struggle with poorly designed interfaces, in small software programs to enterprise-wide systems. On the flip side of the coin, stellar examples of good design enable people with little or no expertise in a field such as accounting to do their own books and taxes, often without outside help. So, what makes the difference? This information-packed presentation explained.
Door Prize: "Usability Engineering: Scenario-Based Development of Human Computer Interaction" by Mary Beth Rosson and John M. Carroll.
Introduction and announcements
Part 1: Welcome to Usability 101!
This segment answered these important questions:
• What is usability? How do you measure it?
• What key principles support user-centered (or usage-centered) design?
• What are some examples of very good -- and very bad -- interface designs?
• What is the role of usability engineering and testing in system development?
• Is usability testing for software only, or does it include Help, documentation, and tutorials?
Part 2: Exploring the details -- how does it work in practice?
This segment addressed these key areas:
• What does a software usability testing laboratory do?
• What benefits will a software usability testing lab bring to our community?
• What are some of the tools and methods used in usability testing?
• What types of research designs are employed?
• Examples or demonstrations of the process
• Informal Q&A


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Главная › News › Starbucks reported 40% drop in global sales
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Starbucks reported 40% drop in global sales
05.08.2020 News
Shares of Starbucks have lost more than 15% since the beginning of the year, rose 5.7% after the publication of the results of the 3rd quarter, which ended on June 28, and forecasts for the 4th quarter and the whole of 2020.
For Starbucks, as for the entire global restaurant market, the three months from April to June 2020 were a trial. Initially, restaurants in China, then in the United States and around the world were closed due to quarantine during the COVID-19 pandemic, the number of visitors was limited and was much lower, as many were transferred to remote work, study or lost their jobs. According to Starbucks management, the pandemic resulted in a loss of $ 3.1 billion.
For the 3rd quarter, the company reported a loss per share of $ 0.46, which is a sharp decrease compared to previous quarters, but better than analysts estimate a loss of $ 0.59 per share.
The global network of coffee shops posted a net loss of $ 678.4 million compared to a profit of $ 1.37 billion a year earlier. Profits were affected by increased costs of paid leave for staff and security measures dictated by quarantine rules.
Total revenue decreased from 38% to $ 4.2 billion, but was higher than analysts' estimates of $ 4.06 billion.
Global sales of comparable stores (open for at least a year) fell by 40%, falling in North and South America was 41%, but it was less than analysts forecast a decrease of 42.05% and 42.82%, respectively.
The number of active participants in the reward program also decreased by 5% compared to last year, because regular customers ordered coffee very rarely. However, the situation needs to improve as the network recently introduced new cost-effective payment methods to participants.
The growth was positive for the services of delivery and mobile replacement, as 22% of the foreign transactions in the quarter were sold.
Despite the epidemic, Starbucks during the quarter have been opened 130 new festooned cafes all over the world. The company also voiced, that there are more points with the service of a car "pickup", for the analogue of McDrive in McDonalds.
The Starbucks Company is optimistic about future, considering that July trends show a good rate of recovery in sales in the United States.
The company raised the profit forecast for the fourth fiscal quarter, believing that "the impact of the pandemic in the current quarter will be significantly mitigated." Earnings per share for the fourth quarter changed from $ 0.15 $ 0.40 to $ 0.18 $ 0.33, against $ 0.27, according to analysts.
Starbucks also changed an annual global sales forecast from a 10% -20% decline to a 12% -17%.
Executives expect sales in comparable stores in China and the United States to grow significantly by the end of the first and second financial quarters, about a year after the crisis, unless there is a new wave of sickness or a serious economic crisis. Starbucks expects to make a profit in the next two quarters.
"We still have a long way to go before we can fully recover, our optimism based on the strength of our brand, and also the strategies and initiatives which we need to increase in sales," said Starbucks CFO Pat Grismer.
Exxon Mobil announces record depreciation of its gas assets by $ 20 billion
The American oil and gas giant Exxon Mobil had one of the worst years in its history. Exxon shares have fallen by 45.36% since the beginning of 2020. The company has lost money for three quarters in a row, and in August they were excluded from the benchmark index of "blue chips" Dow Jones Industrial […]
10.12.2020 Next
McDonald's will cook burgers in a new way
McDonald's F 32 has officially announced changes in the process of cooking its burgers. The buns will become softer and darker, and the company will bake them according to three different recipes. McDonald's promises they will not have flavor enhancers: only natural ingredients to improve texture, frying and taste. The size of the buns was […]
AirBaltic will resume flights to Ukraine
Latvian airline AirBaltic will resume flights to Ukraine on December 1 and will start a new flight Vilnius-Kiev to Boryspil airport. The schedule includes departures twice a week on Tuesdays and Saturdays on Airbus A220-300. Flights from Vilnius will depart at 09:00, from Kiev – at 11:15. "Vilnius Airport can be used for transit to […]
WHO has announced a new record weekly increase in COVID-19 cases
Last week, from November 16 to 22, more than 4 million people in the world became infected with the new type of coronavirus, which is a record number since the beginning of the pandemic. This was announced on Tuesday, November 24, the press service of the World Health Organization. According to the WHO, in these […]
Citigroup predicted the dollar to fall by 20% next year
If coronavirus vaccines become widely available and help restore international trade and economic growth, the dollar is likely to fall by 20% in 2021. Bloomberg reports that this forecast was made by Citigroup Bank. If the forecast comes true, it will be a record drop since 1985, when the DXY index fell by 18.5% over […]
Weekend quarantine: named losses of restaurants
During the first weekend of weekend quarantine, catering establishments lost 27% of turnover. This is as of Monday, November 16, according to the platform Opendatabot, citing data from Poster, a restaurant automation company. It is noted that during the week the turnover of cafes and restaurants fell by 10% compared to the previous week. In […]
The Moderna vaccine has been tested. It can be approved at an accelerated rate
Reuters reported, In Switzerland, the procedure of accelerated testing of Moderna vaccine has started. This will allow to approve the drug if it passes all clinical trials. "Swissmedic can get an initial idea of the benefits and risks of vaccine candidates before the study is completed. This speeds up the review process and at the […]
The WHO hopes to radically change the situation with the coronavirus by March
The World Health Organization expects that by the spring of 2021, the situation in the fight against the coronavirus pandemic could change significantly. The main hope is the invention of vaccine against the disease. This was stated by Adviser to the Director-General of the WHO Bruce Aylward. He noted that by March the situation could […]
Tiffany sued LVMH over the delay in the merger deal
The multinational jewelry company Tiffany has filed a lawsuit in the court of the state of Delaware (USA) against the French luxury goods manufacturer LVMH (Louis Vuitton Moet Hennessy) for delaying the latest merger process. This was announced on Wednesday by the press service of the jewelry company. According to press service, LVMH group intentionally […]
Coca-Cola sells the manufacturer of "Yarilo" kvass
The Antimonopoly Committee gave the permission to the Nova Trade LTD Baileys company for the acquisition of more than 50% stake of the company "Kvass Beverages", which is the part of the Coca-Cola Company Group. This is said in a statement of the regulator. The "Kvass Beverages"Company from Zaporizhzhya produces kvass of live fermentation under "Yarilo" […]
Analysts have named the next global reserve of the currency
Chinese yuan in the next ten years could become the third global reserve currency after the dollar and euro. Such conclusion was reached by analysts of Morgan Stanley, writes CNBC. The growth of investment in the Chinese economy is called to be the reason for the increase in demand for the yuan. Currently, it accounts […]
The NBU named the reasons for hryvnia rate fluctuations
Last month, the demand for foreign currency increased and the hryvnia exchange rate adjusted. This is stated in the macroeconomic and monetary review of the National Bank in June. It is noted that for most of June 2021 in the foreign exchange market supply exceeded demand. This took place against the background of favorable external […]
BMW's 9 months net profit fell 1.7 times
The net profit of the German automaker Bayerische Motoren Werke AG (BMW) for January-September 2020 decreased almost 1.7 times year on year and amounted to 2.11 billion euros. Adjusted earnings per share were € 3.2 against € 5.37 a year earlier. Annual revenue decreased by 7.1% to last year's level – to 69.508 billion euros. […]
Allseeds contests in court the decision of the Odessa Regional State Administration
Allseeds Group of companies, contests in court decisions of the Odessa Regional State Administration and the Vizirskyi village council (Odessa region) about the allocation of lands for berths of "Energy Products Co., Ltd." (Odessa) in the"South" Port, – it is reported by "Interfax-Ukraine". "We were asking the Odessa regional administration and local authorities to allow […]
Court resolves not to give money for IOUs
If the promissory note is not specified by the time when the borrower is obliged to return the money, the court may grant derogation from the obligations under this document. In order to get money for the receipt, it is necessary to properly arrange it, Vesti reported. Do not give money on the receipt, in […]
Johnson & Johnson suspends the study of the COVID-19 vaccine due to unexplained disease in the participant
Shares of the Johnson & Johnson may slow because the last stimulus to it was the company's transition to the final clinical trial of the vaccine against COVID-19 on September 23, after which the shares rose by more than 5%. However, as of Tuesday, before the opening of trading, the price of J&J shares did […]
ATB will open 100 new stores in 2016
ATB-Market LLC (Dnepropetrovsk), completed 2015 with a turnover of 46.7 billion UAH (including VAT) by increasing the rate for 16.5% comparing the level of 2014. This was stated by the chairman of the board of the directors, CEO of the "ATB" Boris Markov in an interview to "Business" from 29 February 2016. According to him, […]
Gas stations were obliged to warn of rising fuel prices
The Cabinet of Ministers has introduced a mandatory declaration of an increase in retail prices for gasoline and diesel fuel by more than 1%. Now the price increase must be reported in 20 days. This is stated in Government Resolution №450 of March 29, 2021, which was updated. The list of socially significant goods to […]
EY starts the Accelerating Entrepreneurs Program in Ukraine
EY Company provides an Accelerating Entrepreneurs Program, which helps to fast-growing startups to develop their business.Participants, who have passed the competition, will get the opportunity to take part in the complex program. It is included the personal consultations, networking and experience exchange. The program also is annexed the access to the strongest and extensive entrepreneurial […]
The international manufacturer of raw materials for confectionary industry built a plant in Ukraine
The international manufacturer of goods and raw materials in the bakery, patisserie and chocolate sectors Puratos built a plant in Odessa region. "Puratos will launch its own production of ingredients for the baking and confectionery industry in the Odessa region ", – said in the statement. The business of the company focused on meeting the […]
Wizz Air can expand flights to Ukraine
The Hungarian-Polish low-cost airline has decided to return to the Ukrainian market. The Loukost Wizz Air is seriously considering the possibility of expanding its presence in the Ukrainian market. This was told by the CEO of the airline Jozsef Varadi in an interview to the Polish portal fly4free.pl. "We see that the situation in Ukraine […]
Who will become the new manager of Novus?
Ukrainian Network of supermarkets Novus gets a new CEO in the person of Mark Petkevich. His predecessor, Ihor Landa is leaving the post. The new ruler of Novus Ukraine, which has held the position of executive director of the network since September 2015, will enter the status of the General on January 19 this year. […]
Alibaba invests in the largest hypermarket operator in China
The largest Chinese Internet company Alibaba Group Holding Ltd. will acquire from Auchan Retail International shares of the largest Chinese hypermarket operator Sun Art Retail Group for $ 3.6 billion, according to the press release from Alibaba. "Alibaba is investing $ 28 billion ($ 3.6 billion) to acquire … 70.94% of Auchan Retail's stake in […]
An analogue of a Turkish drone is expected in Ukroboronprom
The Ukrainian Sokil-300 drone is an analogue of the Turkish Bayraktar and it may join the army next year. The head of Ukroboronprom Igor Fomenko announced it in an interview with RBC-Ukraine. "This is an analogue of the same Turkish Bayraktar. With funding it may already be adopted in a year," he said. Fomenko says […]
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Known today as the Mellon Independence Center Building, Philadelphia residents know this historic building as the Lit Brothers Department Store, which occupied the building for nearly a century. This beautiful building was added to the National Register of Historic Places in 1979 and currently houses the regional headquarters for the Mellon Bank with retail space on the ground level.
There is a common misconception that parking design is synonymous with boring design. Yet, with the use of innovative building materials, parking facades can be not only aesthetically pleasing but serve numerous functionalities such as solar management, daylighting, and natural ventilation. These functions allow for energy and cost efficiency, giving all the security of concrete without the burden of mechanical ventilation.


I don't know the reason why MTN Nigeria has decided to cut down their data volume at this time when 1GB data for N300 with a month validity and the uninterrupted 4G network is knocking the door from TStv Africa.
Recall that, The MTN data plans were reviewed in May 2016and it was then the data plan of N1000 increased to 1.5GB, the data plan of N2000 increased to 3.5GB etc, but a few months back, I noticed that MTN reduced the 1.5GB data to 1GB, though they added the bonus of 500MB to it.
For those using double data, if you noticed when subscribed to the data plan of N1000, instead of receiving 3GB data, you will be given 2GB + bonus of 500MB, making 2.5GB in total. After that, MTN went the way of "a greedy wolf" who consumes customers' data as if their life depends on it to extend that no matter how you manage their data, the 2.5GB won't even last you for 7days talk less of 30days.
Now, MTN still wants to reduce their Monthly 1.5GB for N1000 data plan to 1GB (Plus 500MB 1am -7am), 3.5GB for N2000 to 2.5GB (Plus 1GB 1am-7am) as well the weekly 750MB for N500 to 500MB (Plus 250MB 1am -7am).
MTN has started sending messages to their subscribers that starting from October 7th, they will be modifying their data plans. If you haven't seen the message, maybe yours will arrive later, probably before the date. Below is a sample of that SMS.
Let take N1000 data plan for example, it means if you exhaust the 1GB during the day, you won't be able to use the 500MB bonus to browse until it's night from 1am till early morning 7am. MTN why this?
Is this not going to chase away their subscribers? I have switched to Airtel 1+1 offer of 6GB for N1,500 combined with9Mobile Night and Weekend Data Plan of 5GB for N2000 ever since I noticed MTN data zapping and for now, I'm very ok with the combination of both the data plans.


Every dollar you spend at PrideFest has an impact on LGBTQ Milwaukee.
This year, our all-volunteer team delivered the largest LGBTQ event in Wisconsin history.
Tonight's grand finale features The B-52s, DJs from Mars, Roxi Copland, Trannika Rex, Dita Von and many, many more!
Don't drive! Take the Shuttle to Pride!
PrideFest Milwaukee is bringing beloved bars back to life — with a limited edition T-shirt line supporting the Milwaukee Pride Parade.
Meet the 2018 VIP Experience Winner!


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Tag: Kudankulam nuclear power plant in Tamil Nadu
SC poses searching queries to Centre on Kudankulam
Posted on September 21, 2012 | by Legal India Admin | Leave a Comment on SC poses searching queries to Centre on Kudankulam
The Supreme Court on Thursday wanted to know from the Centre as to what would be the guarantee that there would be no radio active substance in the spent fuel to be stored at the controversial Kudankulam nuclear power plant in Tamil Nadu to prevent any accident.
Posing a host of searching queries to the Centre on the functional safety of the power plant, a bench of justices K S Radhakrishanan and Deepak Misra also asked if any environmental impact assessment was done on the project.
The bench posted the matter for further hearing on next Thursday, saying that it would pass appropriate orders after examining the issue at length.
"It is not adversarial. We are concerned with the people's rights and interests. It is in public interest. What will be the guarantee that there will be no radio active material in it?
"In 1984 there was the Bhopal gas tragedy. But the problem of waste is still there. If there is a problem, how to meet it?" the bench asked Solicitor General Rohinton Nariman and Additional Solicitor General Mohan Parasaran, who appeared for the Centre.
The bench was dealing with the petition filed by social activist G Sundarrajan challenging the Madras high court's decision not to impose any restraint against the plant, despite the alleged non-compliance of several safety measures recommended by the Atomic Energy Regulatory Board.
Appearing for the petitioner, counsel Prashant Bhushan told the bench that not only 11 out of the 17 recommendations made by the AERB were violated by the government but even minimum statutory norms like environmental assessment impact and disaster management study and measures have been overlooked for loading the fuel in the plant.
"Was any environmental impact assessment done?" the bench asked the Centre to which Parasarn nodded in the affirmative.
(Source : PTI)
Posted in Top Law News | Tagged Additional Solicitor General Mohan Parasaran, Atomic Energy Regulatory Board, Bhopal gas tragedy, counsel Prashant Bhushan, G Sundarrajan challenging the Madras high court's decision, impose any restraint against the plant, justices Deepak Misra, justices K S Radhakrishanan, Kudankulam, Kudankulam nuclear power plant in Tamil Nadu, radio active substance, SC poses searching queries to Centre on Kudankulam, social activist G Sundarrajan, Solicitor General Rohinton Nariman
Plea for stalling Kudankulam nuke project reaches SC
Posted on September 12, 2012 | by Legal India Admin | Leave a Comment on Plea for stalling Kudankulam nuke project reaches SC
The row over setting up the Kudankulam nuclear power plant in Tamil Nadu reached the Supreme Court with a petition, which sought its directions to restrain the Union government and other authorities from commissioning the controversial project.
The Special Leave Petition (SLP) by social activist G Sundarrajan against the Madras High Court's Aug 31 decision refusing to impose any restraint has claimed that non-implementation of various recommendations formulated by the Government's Task Force "puts to grave risk the safety of millions of citizens."
The petition, filed through counsel Prashant Bhushanand Pranav Sachdeva, said the high court had given a go ahead to the nuclear power plant without first ensuring that the 17 critical safety features recommended by the Central government's expert task-force are put in place.
It complained that in complete violation of the absolute liability principle evolved by the apex court, the government has absolved the Russian company supplying the nuclear reactor of any liability in case of an accident.
"The government has also brutally cracked down on the local community peacefully protesting against the plant and has slapped sedition cases against thousands of protesters. "Thus it is absolutely clear that the government intends to push the project through without any consideration of the safety, costs, environmental impact and other concerns regarding the project," the petition said.
The petitioner urged the court to pass an "ex-parte ad-interim injunction against the respondents from further proceeding with Initial Fuel Loading and/or Commissioning the Unit 1& 2 of the KudankulamNuclear Power Project till the recommendations of the task force regarding the said project are fully implemented."
According to the petition, the government's Task Force had made a detailed review of the safety measures of the project in the light of inadequacies of Fukushmia plant which suffered due to lack of alternative fresh water storage and want of back-up power system.
The Task Force had sought implementation of its 17 recommendations before commissioning units 1 and 2 of KKNPP, the petition said.
The important recommendations among other things related to the provision of alternative fresh water storage system and emergency pumping equipment, which are yet to be implemented even today, it added.
It said the Atomic Energy Regulatory Board (AERB) now states that implementation of these measures would take six months to 2 years.
"If, by chance, any natural disaster happens before the said measures are implemented, there is every chance of a meltdown and huge leakage of radiation that would make a large area uninhabitable for decades and would need evacuation of millions of people," the petition said.
The petitioner said the AERB could not act independently in the matter because it is under the Atomic Energy Department and hence is unable to act firmly.
"India's nuclear safety regulator AERBis a body under the control of the very department it is supposed to regulate and merely acts as a rubber-stamping authority, and thereby, it has put to grave risk the rights of the citizens under Article 21 of the Constitution," the petition said.
The petitioner said with the Civil Liability for Nuclear Damage Act, 2010 coming into force from Sept 21, 2010, the liability of the nuclear plant operator and supplier has been pegged at a meagre Rs 1,500 crore "in complete violation of the absolute liability principle" propounded by the apex court in its earlier judgements on environmental issues.
"Russia claims that it is exempt from even this minimal liability since their contract with the Indian government states that they would not be liable," the petition said.
Posted in Top Law News | Tagged Atomic Energy Regulatory Board, Central government's expert task-force, Civil Liability for Nuclear Damage Act, counsel Pranav Sachdeva, counsel Prashant Bhushan, ex-parte ad-interim injunction against the respondents, Government's Task Force, Kudankulam nuclear power plant in Tamil Nadu, Kudankulam Nuclear Power Project, Kudankulam nuke project, Plea for stalling Kudankulam nuke project reaches SC, project in the light of inadequacies of Fukushmia plant, social activist G Sundarrajan against the Madras High Court, Special Leave Petition


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ICLR | 2023
Eleventh International Conference on Learning Representations
Year (2023)
Conference Help
Merge Profiles
Contact ICLR
My Stuff/Registrations
Code of Conduct Journal to Conference Track Diversity & Inclusion Future Meetings Press Exhibitor Info ICLR Blog Proceedings at OpenReview
Tweets by ICLR
Call For Tiny Papers
Call For Blog Posts
Area Chair Guide
VISA and Travel Info
Visiting Kiagali
ICLR Board
Call for Tiny Papers, a DEI initiative
If you are interested in helping review, organize, volunteer, and generally contribute to this intiative, kindly fill out this form.
Accepted conference papers at ICLR represent a high level of scientific quality. The other side of the coin is that they can be out of reach for those starting out, or from different backgrounds. We want paper publishing to be not only a showcase of achievements, but also a marker for valuable learning experiences made accessible to beginners and outsiders. Devising more ways to mark milestones and measure growth in an individual, or community's maturity, is greatly conducive to both continually pushing the frontiers of science, and lifting people up in this process.
Researchers from underrepresented backgrounds are not necessarily equipped with the same resources to publish full papers from the start of their scientific journeys. To create a more inclusive ICLR community, we as organizers need to create more pathways, and reasons for people from various backgrounds to enter, stay, and grow in the machine learning community.
To that end, we are launching a more approachable format to publish, kick-start, and collaborate on ideas, "Tiny Papers," and to be presented in the DEI workshop at ICLR 2023, with the hope to attract more underrepresented, under-resourced, and budding researchers to join the community in a meaningful way. Not only will this additional, and different, venue to publish usher in new researchers, it will also serve as an efficient platform for disseminating ideas, findings, and opinions.
The objective of the new "Tiny Papers" track at ICLR is threefold:
Creating alternative, complementary, and diverse entry points to research. And in particular, creating approachable avenues for beginners to enter and enjoy the ICLR community.
Celebrating intermediate breakthroughs in machine learning.
Efficiently disseminating ideas, findings, and opinions.
As the Tiny Papers in the DEI workshop is a Diveristy, Equity and Inclusion (DEI) initiative, orgnized by the DEI Chairs of ICLR 2023, we require every submission to have at least one key author that meets the underrepresented minority (URM) criteria.
Despite the wide range of topics that could benefit from the Tiny Papers format, we focus the type of submissions to be the following:
An implementation and experimentation of a novel (not published elsewhere) yet simple idea, or a modest and self-contained theoretical result
A follow-up experiment to or re-analysis of a previously published paper
A new perspective on a previously published paper
Submission portal opens: February 1st, 2023
Submission deadline: February 28th, 2023 AoE
Notification of acceptance: March 31st, 2023
Camera-ready deadline: April 15th, 2023
Tiny Papers Showcase Day: May 5th, 2023
Underrepresented minority (URM) criteria
Each Tiny Paper needs its first or last author to qualify as an underrepresented minority (URM). Authors don't have to reveal how they qualify, and may just self-identify that they qualify.
In addition, underprivileged researchers and first-time submitters also qualify:
Underprivileged: not affiliated with a funded organization or team whose primary goal is research
First-time submitters: have never submitted to ICLR or similar conferences
Submissions have to include a "URM Statement" section which acklnowledges meeting the URM criteria. See the corresponding section in our provided LaTex teamplate for examples. The URM Statement section does not count into the page limit.
Formatting and author guidelines
The guidelines and restrictions for this Tiny Papers track are:
Write a paper with the same structure as seen in full papers, but with at most 2 pages of main text. References, Appendices, and URM Stement sections do not count towards the page limit, but we do not recommend dissecting a regular length paper into a tiny paper by moving the majority of the content into appendices.
It is recommended to have 1-2 figures, 1 table, and 4-5 sections. But authors are free to use their own structure.
The submission portal, hosted at OpenReivew, opens Feb 1st, 2023. Please check back on this page, or watch @iclr_conf on Twitter.
All Tiny Papers should comply with the conference paper formatting requirements. We provide a slightly edited LaTeX template for authors to use. Authors should submit their Tiny Paper with the authors names and affiliations anonymised, as in the conference paper track.
Can "Tiny" Papers Be Good?
Some may be skeptical that it is really possible to say something meaningful in just two pages. To quote Alexander Soifer:
"[We] respectfully disagree that a short paper in general … merely due to its size must be "a bit too short to be a good … article." Is there a connection between quantity and quality?" [source]
For inspiration and as examples of exemplary short papers from a range of disciplines, we provide the following list:
Conway, J. and Soifer A., "Can unit equilateral triangle cover an equilateral triangle of side , say ?, link
Nash, J. F., "Equilibrium points in n-person games", PNAS, 36 (1) 48-49, 1950, link
Watson, J., Crick, F., "Molecular Structure of Nucleic Acids: A Structure for Deoxyribose Nucleic Acid", Nature 171, 737–738, 1953, link
Gettier, E.L., "Is Justified True Belief Knowledge?" Analysis, 23, 6, 121-123, 1963, link
Weinberg, S., "A Model of Leptons", Phys. Rev. Lett. 19, 1264, 1967, link
Lander, J. and Parkin, T. R., "Counterexample to Euler's Conjecture On Sums of Like Powers", Bull. Amer. Math. Soc. 72, 1079, 1966, link
Streitwieser, A., "Chlorination of Fluorene with Sulfuryl Chloride", J. Am. Chem. Soc. 1944, 66, 12, 2127, link
Malmasi, S., "Discriminating Similar Languages: Persian and Dari", Tiny ToCS Vol. 4, link
ICLR 2023 DEI Chairs
Krystal Maughan (University of Vermont)
Rosanne Liu (ML Collective, Google Brain)
Thomas F Burns (OIST)
Email: iclr.dei.2023@gmail.com
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