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Foss v. Roby
Gibbons v. Hansch
Numerous authorities to that effect are cited in 28 C.J. 739, § 12. Massachusetts holds to the contrary if it…
Tobin v. Cody
Old Corner Book Store v. Upham, 194 Mass. 101, 106-107. Foss v. Roby, 195 Mass. 292, 296-297. We think that…
Full title:LEWIS T. FOSS another vs. FRED F. ROBY
Court:Supreme Judicial Court of Massachusetts. Suffolk
81 N.E. 199 (Mass. 1907)
81 N.E. 199
Supreme Judicial Court of Massachusetts. Suffolk
January 15, 1907.
Present: KNOWLTON, C.J., MORTON, LORING, BRALEY, SHELDON, JJ.
Assignment. Sale. Good Will. Contract, Validity, Construction. Dentist. Equity Pleading and Practice, Injunction, Damages.
A sale and conveyance by the trustee in bankruptcy of a dentist, who had purchased from a former partner and owned at the time of his bankruptcy the good will of the practice of the former partnership, of "all the interest which" the bankrupt "may have in any right of action or any contractual rights against any one at the time of bankruptcy" includes and conveys such good will.
Where one of two partners engaged in the practice of dentistry, having an established practice carried on at an office in a certain city, in consideration of the payment of a sum of money sells to his copartner by a bill of sale in writing his half interest in the fixtures, office furniture and other personal property owned by the partners and used by the partnership "in carrying on the dental business" in the office named "together with the good will of said business," without any express agreement on the part of the seller to refrain from competition, the sale of the good will includes an implied agreement by the seller not to practise dentistry so as to injure the business he has sold.
In a sale for a sum of money by one of two partners to the other of the good will of a practice in dentistry established at an office in a certain city, the implied promise of the seller not to compete in the practice of dentistry within a restricted area is not invalid because unlimited in time.
In a suit in equity by a dentist against his former partner in carrying on the practice of dentistry at an office in a certain city, who had sold his half interest in the good will of the business to the plaintiff for a sum of money, to restrain him from violating his implied contract not to practise dentistry so as to injure the business he had sold, if it appears that, although the former partnership business was carried on wholly at the office in the city, it was not derived wholly from that city but included patients who came to the office from other cities and towns, and that the defendant opened a competing office for the practice of dentistry in the city in which the office of the former partnership was established, sent out printed circulars to former patients of the old firm and solicited their custom, that he thus obtained many of the patients of the old firm and that his business consisted substantially of this patronage, the plaintiff is protected sufficiently by an injunction restraining the defendant from practising dentistry within the limits of the city, and, unless some reason for doing so is shown affirmatively, it is not necessary to enjoin the defendant from practising dentistry anywhere in the entire area within which former patients resided. The plaintiff in such a case is entitled, in addition to his injunction, to a decree for such money damages as he has sustained from the defendant's breach of contract.
BILL IN EQUITY, filed in the Superior Court on October 6, 1903, by Lewis T. Foss and Elmer J. Marston, copartners under the firm name of Foss and Marston, engaged in the practice of dentistry at 101 Tremont Street in Boston, against Fred F. Roby, a former partner of the plaintiff Foss, who together with the plaintiff Foss formerly practised dentistry in Boston and its vicinity under the firm name of Foss and Roby at an office at 132 Court Street in Boston, and who on December 1, 1900, by a bill of sale in writing sold to the plaintiff Foss for the sum of $2,500 all his interest in the partnership property and in the good will of the dental business carried on by the firm, to enjoin the defendant from practising the business of dentistry in Boston and its vicinity when such practice would injure the good will of the business formerly of Foss and Roby sold by the defendant to the plaintiff Foss; praying also that an account might be taken of all damages suffered by the plaintiffs by reason of the defendant's solicitation of the patronage and business of the former patients and patrons of the plaintiffs and of the plaintiff Foss, and by reason of the defendant's unlawful interference between such patients and patrons and the plaintiffs, and by reason of any other injury done by the defendant to the good will of the business sold by him to the plaintiff Foss; and that the defendant might be ordered to pay to the plaintiffs such sum of money as might be found to be due to the plaintiffs by reason of such solicitation, interference and injury; and for further relief.
The agreement of dissolution of partnership between the plaintiff Foss and the defendant, a copy of which was annexed to the bill, began as follows:
"Know all men by these presents, that
"Whereas, Lewis T. Foss formerly of Boston, county of Suffolk and Commonwealth of Massachusetts, but now of West Somerville, county of Middlesex and Commonwealth aforesaid, and Fred F. Roby of said Boston, have heretofore carried on the dental business at 132 Court Street in said Boston, as copartners, under the firm name and style of Foss and Roby; and —
"Whereas, said copartners have this day dissolved their said copartnership by mutual consent; and —
"Whereas, said Fred F. Roby has this day conveyed to said Lewis T. Foss his entire right, title and interest in the furniture, fixtures, machinery, tools, stock, books of account, registers, accounts, good will and other property of said copartnership;
"Now therefore, it is hereby mutually covenanted and agreed by and between the said parties hereto, as follows: —
"(1) Said Lewis T. Foss is to have the right to continue said dental business, in his own name and for his sole benefit, profit and advantage, as successor to the said firm of Foss and Roby; but is not authorized to use the name of Foss and Roby in any other way except as hereinafter provided."
The bill of sale, of which a copy was annexed to the bill, was as follows:
"Know all men by these presents that I Fred F. Roby of Boston, county of Suffolk and Commonwealth of Massachusetts in consideration of Twenty-five Hundred (2500) Dollars paid by Lewis T. Foss of West Somerville, county of Middlesex and Commonwealth aforesaid the receipt whereof is hereby acknowledged, do hereby grant, sell, transfer, and deliver unto the said Lewis T. Foss the following goods and chattels, namely, All my right, title and interest in and to six (6) dental chairs, four (4) dental engines, four (4) dental lathes, two (2) stoves, one (1) `Diebold' safe, a quantity of extracting forceps and laboratory tools, office furniture, fixtures, carpets, pictures, tools, implements, books of account, registers, accounts and stock, both manufactured and unmanufactured, and all other matters and things not specifically enumerated or mentioned, contained in the building numbered one hundred and thirty-two (132) on Court street in said Boston, and heretofore owned by myself and the grantee as copartners and used by said copartnership in carrying on the dental business in said premises under the firm name and style of Foss and Roby; together with the good will of said business.
"To have and to hold all and singular the said goods and chattels to the said Lewis T. Foss and his executors, administrators, and assigns, to their own use and behoof forever.
"And I hereby covenant with the grantee that I am the lawful owner of the said goods and chattels; that they are free from all incumbrances, that I have good right to sell the same as aforesaid; and that I will warrant and defend the same against the lawful claims and demands of all persons,
"In witness whereof I the said Fred F. Roby hereunto set my hand and seal this First day of December in the year one thousand nine hundred.
[25 cent Internal Revenue Stamp.] "Signed, sealed, and delivered in presence of "Fred F. Roby (Seal.) Lewis T. Foss."
The fourth paragraph of the bill, referred to at the beginning of the opinion, was as follows:
"4. On or about February 20, 1903, the said Foss was duly adjudged a bankrupt by the U.S. District Court for the District of Massachusetts, and William C. Rogers of said Boston was subsequently duly appointed trustee of his estate in bankruptcy; and as such trustee on May 15, 1903, said Rogers sold and conveyed to Frederick L. Briggs of said Boston `all the interest which said Foss may have in any right of action or any contractual rights against any one at the time of bankruptcy,' together with certain other property, as appears by the bill of sale, a copy of which is annexed marked `D,' and said Briggs on the same date sold and conveyed the same to the said Foss, who at once contributed and conveyed the same to said copartnership. The said Foss Marston now are and ever since said May 9, 1902, have been copartners as aforesaid, excepting only such momentary interruption of the continuance of the copartnership as may have resulted by operation of law from the bankruptcy of said Foss, said partners upon such adjudication having immediately renewed the copartnership relations which may have been so interrupted."
In the Superior Court the case was heard by Hardy, J., who found that certain allegations contained in the bill, including those in the fourth paragraph of the bill, were sustained by the evidence. He also found that the tools, implements and office furniture conveyed by the bill of sale did not exceed in value $500; that the defendant on or about April 1, 1903, opened an office at No. 88 Boylston Street for the practice of dentistry and was continuing and intended to continue such practice in Boston and its vicinity; that he had sent out circular letters to the former patients and patrons of Foss and Roby in Boston and its vicinity; that such patients and patrons were mostly regular customers of Foss and Roby; that there were very few transient patrons, not exceeding ten per cent of the whole number; and that such patrons and patients were to be found within a radius of sixty miles from Boston.
The judge made a final decree that the bill be dismissed, with costs to the defendant; and the plaintiffs appealed.
C.P. Weston, for the plaintiffs.
F.H. Williams, for the defendant.
BRALEY, J.
The title of the plaintiffs to maintain their bill, although questioned by the defendant, is not affected by the intervening bankruptcy of Foss, for by the conveyances described in the fourth paragraph of the bill the firm has become vested with his interest. Lothrop Publishing Co. v. Lothrop, Lee Shepard Co. 191 Mass. 353. Jenkins v. Eliot, 192 Mass. 474.
The evidence taken by a commissioner not having been reported, the case is before us on the pleadings, the interrogatories and answers, and the findings of fact. It appears that the plaintiff Foss and the defendant were partners engaged in the practice of dentistry at 132 Court Street in the city of Boston, and, upon a dissolution of the firm, the defendant sold to the plaintiff Foss his interest in the office furniture and dental equipment with the good will of the business. The plaintiff Foss having formed subsequently a partnership with the plaintiff Marston, to whom he conveyed a half interest in the personal property, including the good will, they carried on business at 101 Tremont Street. After the lapse of about three years, the defendant opened an office at 88 Boylston Street, where he has since carried on the practice of his profession. By solicitation, he has obtained many of the patients of the old firm, and his business substantially consists of this patronage. The important questions for decision are, whether the defendant is precluded by his agreement from setting up a competing business, and the measure of relief to which the plaintiffs are entitled. By the contract of sale, while the defendant explicitly conveyed his interest in the good will, he did not expressly covenant to refrain from competition either as to time or territory. But the sale being of an established practice, described in the instrument as "the dental business" then carried on at "Court Street in said Boston," it was implied, even if not expressed, that thereafter the defendant would so practise his profession as not to injure and perhaps destroy the business he had sold. Dwight v. Hamilton, 113 Mass. 175. Munsey v. Butterfield, 133 Mass. 492.
In a mercantile partnership the sale of the good will conveys an interest in a commercial business, the trade of which may be largely, if not wholly, dependent upon locality, and the right which the vendee acquires under such a purchase is the chance of being able to retain the trade connected with the business where it has been conducted. Bassett v. Percival, 5 Allen, 345. Hoxie v. Chaney, 143 Mass. 592. Webster v. Webster, 180 Mass. 310, 316. Hutchinson v. Nay, 187 Mass. 262. Trego v. Hunt, A.C. 7. But in a partnership for the practice of dentistry, the personal qualities of integrity, professional skill and ability attach to and follow the person not the place. Dwight v. Hamilton, ubi supra. Austen v. Boys, 2 DeG. J. 626. See Smale v. Graves, 19 L.J. Ch. 157; Palmer v. Mallett, 36 Ch. D. 411.
The object to be obtained was the protection of the vendee, and the agreement is to be construed as if the defendant had expressly covenanted to render the old practice secure by not competing himself under conditions by which it might either be impaired or destroyed. If this were permitted, then, while retaining the consideration, the defendant also might deprive the plaintiffs of the benefit of their purchase by regaining the customers. Neither is the agreement, under this construction, invalid because unlimited in time, for the consideration paid must be treated as having been accepted by the defendant as a full equivalent for a release of his right to compete within a restricted area, if by such competition the good will sold was or might be rendered insecure. Dwight v. Hamilton, ubi supra. French v. Parker, 16 R.I. 219. Bunn v. Guy, 4 East, 190. Nor is any principle of public policy violated by unduly restricting lawful competition. Gilman v. Dwight, 13 Gray, 356. McClurg's appeal, 58 Penn. St. 51. Whittaker v. Howe, 3 Beav. 383. See Rousillon v. Rousillon, 14 Ch. D. 351; Underwood v. Barker, 1 Ch. 300.
Upon resuming practice the defendant sent out printed circulars to former patients, giving the name of the old firm, with the street and number, and announced, that, having opened an office in the city, he solicited their custom. By this scheme of advertising he sought to regain the good will with which he had parted, and, his efforts having been successful, the defendant has deliberately broken his implied covenant by setting up a rival business. While the plaintiffs should be granted adequate relief for this breach of his contract, the remedy, upon the facts found, should not be broader than is reasonably necessary for their protection. Old Corner Book Store v. Upham, 194 Mass. 101. Doty v. Martin, 32 Mich. 462, 468, 469. The business of the old firm was conducted in Boston, which is the only locality referred to in the agreement, although the practice was not wholly derived from the place where patients were treated, but had been acquired from other cities and towns throughout the eastern and interior sections of the State. But, until it becomes affirmatively manifest that the plaintiffs are likely to obtain some substantial advantage or protection from such an extension, the vicinage ought not to be extended by implication to include the entire area within which former patients resided. Doty v. Martin, ubi supra. See Butler v. Burleson, 16 Vt. 176. The preservation of this territorially diversified patronage in the form in which it had been established was the object contemplated by the parties, and with which the defendant agreed not to interfere. By practising dentistry at his present location in the manner described, the defendant competes with the plaintiffs by obtaining former resident patrons, and also those who when coming to the city for dental treatment resort to him, when otherwise they might have employed the plaintiffs. They are, therefore, amply protected by an injunction enjoining the defendant from practising his profession within the limits of the city.
The decree of the Superior Court must be reversed, and a decree awarding an injunction, with costs, is to be entered. And, it being further shown that the larger part of the defendant's present practice has been derived from these patients, if the plaintiffs request, such money damages as they may have sustained from this breach of the contract also may be assessed. Gregory v. Spieker, 110 Cal. 150. Moorehead v. Hyde, 38 Iowa, 382. Taylor v. Howard, 110 Ala. 469.
So ordered.


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After a long lull in Book Notes, and to create a possibly unsuitable (though related) break from the tragic invasion of Ukraine, it seemed a good idea to go back to this genre and mention "Twilight of Democracy." Its author, Anne Applebaum, now writing for The Atlantic, is well-known for her liberal outlook and excellent books on the Communist era in Central & Eastern Europe, notably the highly recommended "Iron Curtain – The Crushing of Eastern Europe 1944-1956" (one of my favorites on the topic), and Pulitzer Prize-winning "Gulag: A History."
Twilight of Democracy (2021) addresses the rise of populist parties in the West, which is a very timely topic as Viktor Orban was reconducted as Hungarian leader in April while Marine Le Pen failed but came closer to be the next French President and upend the future of France, NATO, possibly the EU and the Euro – and clearly the world as we know it, even if clearly already being altered by Putin's Russia. In many ways, this book is why this blog exists as it was started by the rise of both populist-flavored Brexit and then Trump, rightfully two of the six chapters of Twilight of Democracy – also a good fit given Applebaum's roots in both Britain and the US, not to mention Poland, one of the two current populist hotspots of Europe. Twilight of Democracy projects very strong views on populism, some of which covering Brexit or Central Europe, may possibly be seen as extreme or one sided by some readers.
A very personal history of broken friendships. The subtitle of her book is "The failure of politics and the parting of friends", the latter is very fitting as she recalls the New Year's Eve party in their Chobielin home in Northern Poland that she and her husband, former minister Radek Sikorski, had held to celebrate the passage to the new millennium. It was a time of joy, a decade or so after Poland had made the transition to both democracy and market economy. They had a lot of friends joining them, many no longer speaking to them twenty years later as they gradually espoused the nationalist and undemocratic views that prevail among the Law & Justice party members that has been fully in power in Warsaw since 2015. She has great stories to tell about two well-known Polish brothers with different career success, which describe how the challenged one used his old association to deceased Polish President Lech Kaczynski to get the top job at the leading Polish TV operator and totally changed it as if it were an official conduit for the ruling Law and Justice Party. In this telling example of how populists operate when in power, Applebaum also stresses how the under-achievers in our modern democracies can use politics and indeed populism to get to prominence, all the more when what matters to elected autocratically-flavored rulers in a European context is obedience and not skills, as also seen in Russia today. She then recalls the tragic crash of the Polish presidential plane in 2010 on its way to a commemoration of the Soviet Katyn massacre of thousands of Polish officers that was then gradually used as a conspiracy theory to put the blame on political opponents without any rationale (the President had forced the plane to land totally unsafely in atrocious weather conditions). Applebaum, borrowing from Yale historian Timothy Snyder, introduces us not to the Big Lie of the Soviet days but to the Medium-sized Lies used by current European autocrats to weaken democracy and liberalism when elected to public office, like today in Poland or Hungary and for a while Italy during the Salvini days. She goes into another old friendship that had turned sour with Maria Schmidt, the curator of Terror Haza, the Budapest museum focused on the dreadful aspects of the Communist area. Her lost friend being a typical example of an anti-communist individual espousing autocratic features, tainted of anti-Americanism and (unlike in Poland for obvious historical reasons) benign admiration for Putin's Russia. Such individuals, who battled communism, formed part over the last decade of the corps of self-serving (also financially) "clercs" (she uses the French word for clerks) who made possible for leaders like Viktor Orban, another liberal 25 years ago, to succeed in governing while suppressing many individual and constitutional rights gained in the post-Communist era. These examples are very interesting for readers not living in Poland or Hungary, two countries which benefitted from huge EU subsidies (especially Poland, the perennial top financial assistance receiver from Brussels), who can also see their leaderships struggling with the EU in terms of fights over judicial appointments if not court structures. As Applebaum stresses, these should not be dismissed as "regional stories" involving "hard to pronounce names."
Going back to the roots of populism. Applebaum notes there was no anti-democratic wave after the Communist transition in Central Europe, while populist leaders and ideas strongly emerged only in the last decade also as a link to the refugee crisis of 2015-16. She stresses rightly that the "Eastern European problems" we see now, also through the disputes with the EU, are not unique to former Communist countries experiencing a long hangover from 1989. She notes from her discussions with a Greek sociologist that polarization is normal in our Western societies and that history in our times is circular with its liberal and more autocratic phases. Angry, resentful and vengeful are the characteristics of the populist leaders and movements that are "against elites," have dreams of "cleansing violence" and support an apocalyptic cultural clash, altogether with attacks on the rule of law, free press and academia. There is a commonality of image between the Marxist-Leninist states of old and the new nationalist regimes or parties, from the Polish Law & Justice party or the Hungarian Fidesz to the Venezuelan Chavistas or the French Lepenistes and even some hardline Brexiters. In many ways the Western world of today increasingly represents, via its growing extremist parties in their modus operandi, the Eastern Europe of the past. This is perhaps the key lesson of her book, which may not have been clear to many of us.
Brexit as the great populist success. Applebaum spends a chapter on Britain – or more exactly England – and the nostalgia of when it made the rules, which she says drove Brexit. England wanted to make things happen in a Thatcherite way when she played with her bag in Brussels and got the famed EC rebate, or when she sent a task force to the now totally forgotten and irrelevant Falklands 40 years ago. This approach was epitomized by a younger Boris Johnson (an Oxford Bullingdon Club fellow member of her husband Radek) who, when at the Daily Telegraph, would publish numerous half-lies or tall tales that his ardent Tory readership enjoyed, such as those about the EC or EU that would cancel London "double decker buses" or prawn cocktail-flavored crisps, giving the younger editor a "weird sense of power." The Single Market, that Britain had helped build, was a great Thatcherite achievement for the country and its entrepreneurial class, but also a major source of annoyance and embarrassment in having to lower itself to negotiate with a lesser Brussels – even if the later was always very commercial and flexible in its approach. Britain, on the other hand, was always keener on its "Special Relationship" with the US as the latter was, according to Prime Minister Harold McMillan in his half-disguised exceptionalism "the Romans to us Greeks." Not totally wrongly, Britain would not forget that they were the only European country to have from the start won WW2, which put it in a category of its own among nations, all the more so in Europe. Sadly, restorative nostalgia usually goes hand in hand with mild conspiracy theories and medium-sized lies, which the Tories started to spread gradually about Europe for electoral and existential purposes stressing that the EU had perverted the course of history. The phenomenon was aggravated with the fall of the Berlin wall, which vindicated the often-left wing criticized Tory cold warriors, but created a vacuum after the great fight had been won – this enhanced by post-Thatcher leaders who fitted a calmer new normal. John Major was snubbed by many Tories as a leader without a fight, also due to his lack of charisma and moreover university degree (something top PE firm Carlyle later never minded) together with his pragmatic focus on reuniting Europe, while Tony Blair brought a non-exceptional Britain or an England that would see devolution all in a way that recalled the radical 1960s in Tory eyes. To the Tories, many of whom were slowly shifting toward the more extreme regarding the EU, as it provided a program to sell voters, Brussels had become the embodiment of everything that had gone wrong in British life – leadership, culture, capitalism and national vigor with on top all the Polish plumbers and Spanish data analysts threatening the national identity. In an almost funny list of medium-sized lies perpetrated by the Leave camp were Johnson claiming that Brexit would bring in GBP 350m a week to the National Health Service, that if Britain stayed it would be forced to accept Turkey as a member all with Nigel Farage's UKIP posters showing him with trails of Syrian refugees reaching the English shores. Dominic Cummings, the sadly bright Brexit architect later compared their messages to Soviet propaganda, some of his videos having been seen by at times in excess of 500,000 viewers. The Vote Leave camp also cheated and broke electoral laws to advertise more on Facebook or used data famously stolen by the company Cambridge Analytica, all while benefitting from Russian trolling operations that served the ultimate goal of the Kremlin to weaken both the EU and Britain (to his credit Boris Johnson has led a "good war" against Russia following the invasion of Ukraine). Joe Cox, a Labour MP and Remainer, was murdered during the referendum campaign by an unsettled fake news-radicalized man who thought Brexit meant "liberation" for Britain. Many Leave leaders and opinion makers thought that only a radical change such as Brexit could save Britain, that they perceived as once a leading nation now terminally lost. The Brexiteers became immune to facts and means as long as the victory was reachable, and when it was in sight, the harder the Brexit the better so a healthy shock would wake Britain up, whatever the costs including economic – this leading to what was to be known as a hard Brexit. Chaos was seen as good, including perversely by many in the Labour Party's Corbyn leadership who believed that it would eventually bring voters to the radical left while others on the free market front thought it would bring an end to burdensome regulations. The majority of the country had not voted for this type of disruption but the extremists, going beyond any mandate, had produced it. Applebaum generously stressed that Boris Johnson had not ideologically loved autocracy but was simply about winning, which drove him to use and pursue whatever means and avenues were available – with clear success. There were talks among hard Brexiteers after the December 2019 elections of altering the funding of the BBC, curtailing or limiting the courts or purging civil servants with obedient individuals, as if London had changed to Budapest-on-Thames (with all due respect to Budapest whose mayor is actually a liberal like in Warsaw). It is clear that all is not yet well with Britain today, and that Brexit has not yet been digested – notably with job shortages from the trucking industry to the famed NHS. However, as in Fawlty Towers the official populist line in a rather unnatural mode is "don't mention Brexit" or more aptly, destroy agreements that were in place, like dealing with trade and Northern Ireland.
Hard-line Tories liked undemocratic polities in other countries, especially Poland and Hungary, while they were becoming more authoritarian and attacked their judicial systems, prompting a stark condemnation from the EU. At that time, according to Applebaum, the British government, consumed with how Brexit would unfold, had dropped any pretense of standing for democracy around the world, which admittedly can be viewed rightly by many as too strong a statement. Tory MEPs and Law & Justice MEPs were part of the same caucus in the European Parliament, leading the Tories to defend Law & Justice when under EU attack. Formerly well-known anti-Communist MPs became friends of Law & Justice officials, which the anti-Russia stance may have helped. Tory and UKIP MEPs voted to protect Orban from being censured by the EU, in a way to assert the right of a democratic nation, however in name only and de facto authoritarian, to defy Brussels's "interference". To some of her British friends and former colleagues at The Spectator, Applebaum was now part of a "liberal, judicial, bureaucratic, international elite" opposed to "democratically elected parliaments". One of them now a resident scholar at The Danube Institute founded and funded by Orban supporters, who made the remark about her "elite belonging" would have only dreamed to be part of it in London but simply could not, underlining Appelbaum's point about underachievers usually joining the ranks of less-traditional achievement-demanding populists at home or abroad to access better jobs and roles, whatever the cost to their image and probity.
How the populists operate and why they get an audience. Applebaum makes the point that authoritarian predisposition is not the same thing as closed-mindedness but is closer to simple-mindedness. People are attracted to authoritarian ideas as they are simple and, unlike the democratic debate, not cacophonic. This blog always stressed the damage done by easy and indeed simple solutions to complex issues that populists love, as allowing to sell extremist ideas to voters who feel more at home with a lack of diversity of opinions and experiences and react aggressively against the complexity of drastic changes like the refugee crisis of 2015-2016. Applebaum goes into the role of social media in shaping the minds of voters, and more generally users, as many people in our age like to click on the news they want to hear, even if they may be false stories based on incorrect facts and disseminated by able spin doctors also using algorithms that radicalize their audiences, leading to hyper-partisanship. This hyper-partisan mode results in a rejection of normal politics, establishment politicians, the so-called elite, derided "experts" and mainstream institutions. No neutrality is acceptable in a polarized world as non-partisan or apolitical institutions are not desired. Reddit, Twitter and Facebook have unwittingly become the perfect media for irony, parody and cynical memes, creating a generation of young people who either vote for extreme parties or show a disdain for democracy that does not work for them. While being clear about the role of tech-enabled social media, Applebaum is also acknowledging their good aspects and not advising a return to an analog past when all was indeed not perfect. She just stresses that the new information world provides a new set of tools and tactics that populist leaders can use to reach people who want a simple language, powerful symbols and clear identities as if searching for an elusive unity.
Going into less well-known cases of European populism. Applebaum goes into a less well-known story about European politics that starts with the post-Francoist transition that led to the new Spanish political landscape post-1975. The new Spain eventually showed the center right Popular Party with names like Aznar (time indeed flies) and the center left Socialist Party, in a mirror image of many of its neighboring countries like France with its Socialist and Gaullist parties, the latter under many different names over the years (the two, as a sign of the times, having garnered less than 7% of the votes against 58% for all radical or extremist candidates and their parties in the first round of the presidential election in April 2022). As the 2010s started, the traditional parties got weaker as everywhere in Europe and new movements like populist-nationalist party Vox led by Santiago Abascal took more of a center stage as radical left Podemos and liberal Ciudadanos also appeared. Applebaum tells us about the trail of an ex-Aznar center right politician, Rafael Bardaji, who had disappeared for a decade, was forgotten and engineered a re-emergence away from its center-right roots with a "Make Spain Great Again" that had some Transatlantic Trumpian feel to it. Vox, which represented Francoism's de-hibernation, became stronger in its opposition to the Catalonian referendum of 2017, that unlike the British one failed, and increasingly attracted more younger voters than their more liberal elders. Vox wanted to bring back the feeling of unity of the old "Arriba Espana" with leaders now using YouTube, Twitter, Instagram, Telegram and WhatsApp to channel their easy solutions to complex issues. Vox, not unlike other populist extreme right parties, took ownership of a mixed bag of resentment-filled issues for a large group of Spanish voters: opposition to Catalan and Basque separatism, same sex marriage, feminism, immigration of a Muslim kind (even if very low in Spain unlike historically France), and corruption, while supporting hunting and handgun ownership and showing boredom with mainstream politics that destroyed Spanish unity, all with a talent for mockery and a huge dose of restorative Franco nostalgia. NATO was deemed only useful for Eastern European countries bordering Russia (indeed) though Trump's radical Islam fight was seen as a good one and more generally his governing style a fit for Vox. This foray into Spain was useful as not a country where populism comes immediately to mind, showing the extent of the problem across Europe.
And of course, focusing on Trump, the most successful populist of our times. Appelbaum had to spend some pages on the advent of the Trump presidency that was a high point of the rise of populism globally, and shattered for many the previously immovable image of the American liberal democracy. As Lincoln spoke of America as "the last best hope on earth" and Reagan's 1989 speech of "the shining city on a hill", both wanting to stress American exceptionalism and greatness, many extremists disagreed or wanted to go back to its perceived roots ranging from the radical left in the early 20th century to the Christian right more recently – as well as the great history of the KKK or even the noble rise of domestic terrorists like Oklahoma bomber Timothy McVeigh, who had plotted mass murder in order to rescue a nation. Trump's inaugural address marked a turning point for modern America, as it contained left and right strands of anti-Americanism combining a rejection of the self-serving "Establishment" and the evangelical despair about the moral decay of the country delivered time and time again by someone who was the son of a multi-millionaire, himself a powerful elite businessman and a draft dodger. Trump, who had little or no knowledge of and thus no faith in the American story, added the deep cynicism of a man who ran unsavory business schemes globally (some now under scrutiny even in the US) while appealing to the millenarianism of the far right and the revolutionary nihilism of the hard left. He had no interest in America being a model among nations, indeed crudely rejecting its exceptionalism, and thus its role in the world, leading to a contempt for American international engagement and thus NATO, a well-known admiration for Putin he saw as a true leader and an isolationism characterized by "America First" as the only way to make it great again. American ideals would be false and its institutions fraudulent – the latter as when he described the FBI and its "corrupt and disgraceful leadership" two years into his mandate. As Trump would state it clearly in 2020, two years before the invasion of Ukraine, America would have no vital interest in choosing between warring factions whose animosities go back centuries in eastern Europe. There should be no important distinction between democracy and dictatorship. For the party of Reagan to become that of Trump and abandon American idealism and adopt the rhetoric of despair was a sea change. In a return to 1995 Applebaum recalls a gathering of Republican thinkers and writers which, like in a prelude of her own Polish New Year 2000 party, would see attendants not speaking to each other years later with David Brooks, David Frum or Irving Kristol (and indeed others like Max Boot even if not invited then) going away from the party happy to be taken over by the populist Trump on the altar of winning elections.
In looking back at history, Appelbaum tells in her last chapter about the famous Dreyfus affair in 1894 France, which targeted an innocent Jewish French officer accused of treason, in what was a fight between the ancestors of today's national-populists and the democratic liberals of the day and with hindsight a prelude to the 1930s in Europe. The societal shock of the Dreyfus affair – that almost destroyed the tissue of France – was very reminiscent of Appelbaum's vivid experience of those lost friendships of the new millennium. In a fascinating and rarely-expressed comparison, Appelbaum notes that those who maintained Dreyfus's guilt against all evidence were the American alt-right, or the Polish Law and Justice Party, or the French National Rally of the day, knowingly pushing a conspiracy theory, the means justifying the ends. This fascinating story resonates at a time when Marine Le Pen, supposedly being the voice of the traditional France and the left-outs, in a classical, modern day contest against elitism, was losing for the second time in the final round of the presidential race to technocratic, democratic, liberal and pro-EU Emmanuel Macron. As Trump was born with a golden spoon in his mouth, and went on to be a populist politician and President, we too often forget that Marine Le Pen is also the rich daughter of Jean-Marie Le Pen – making her indeed an aristocrat of sorts both financially and politically – who has nothing in common with the voters she is targeting with her appealing vote-buying messages. As her more clearly extremist and Vichy-flavored father scored 17.8% in 2002 against Jacques Chirac and she scored 33.9% against Macron in 2017, her score of 41.4% in 2022, even if much lower than anticipated (whilst some would also see her potentially win based on first round vote make-up), shows a trend where democracy and liberalism are gradually losing voting ground against populism and its easy answers to complex issues. Will a populist finally take over the Elysée Palace in 2027 and start dismantling the democracy of a G7 country and key historical player? And what about Donald 2.0 in 2024, all the more so,following a likely control of Congress in November by the Republicans who will be focused on revenge, even for some if losing their souls?
As Applebaum says at the end of her book, her title "Twilight of Democracy" was not a prediction but a warning. Anti-democratic forces using and abusing the democratic electoral process have won many followers in the past, especially in the last decade, building on distrust on the back of apparently noble (for some) but fallacious themes, and they actually will in the future too. It was interesting to note in the recent French election that polls showed that well besides and beyond electoral programs, 71% of Macron voters considered themselves "happy" in life while 80% of Le Pen's felt unhappy, thus more prone to resentment and following extreme, if unrealistic and dangerous, political solutions for France. Winning elections will be the key driver for populist leaders for whom messages will be secondary and remain tools of the end game. And if they succeed, democracies will be gradually altered, as already seen in parts of Europe, and elections might eventually vanish as an unnecessary process.
Posted on 2nd May 2022 2nd May 2022 Author Desp(e)rat(e) measuresCategories Book Note
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redpajama_set_name: RedPajamaCommonCrawl


Hi, I have that terrible Winfixer . I clicked on your steps to take and downloaded AdAware. It found some things I need to get rid of but I want to make sure it is ok to get rid of them before I do anything.
Edited by Buckeye_Sam, 09 October 2005 - 06:09 AM.
The scan is running now. I have my Hijack This log but I can't find the vundofix.txt file.
Here is the Hijack This Log. I will post the results of the scan when it finishes.
If you will tell me how to find the vundifix.txt file I will see if I can find it.
No need for the Vundo log. The infection is gone!
In your Hijackthis log the 016 lines represent active-x controls that you have downloaded for virus scans, games, etc... You seem to have a lot of these and while the ones other than the three I indicated aren't necessarily bad, it would be a good idea for you to review these and fix with Hijackthis any that you haven't used in a long time or don't expect to need again. These are purely optional. The active-x control is installed automatically again if you need it.
How are things running now? Any problems?
Do I do a search for this file C:\WINDOWS\system32\pmkhg.dll to delete it or is there a certain place I need to go?
I will also clear out the active x controls.
Once you find it, right click on the file and select Delete.
Ok, I looked there and didn't see it. But when I run the PandaScan again it still shows up. Now What?
It may be hidden. Make sure you can see hidden files.
Select the View tab and make sure that 'Show hidden files and folders' (or 'Show all files') is enabled.
Also make sure that 'Display the contents of system folders' is checked.
For more info on how to show hidden files click here.
Hmmm....let's try it this way.
Download KillBox and unzip it to your desktop.
Open Killbox and select the Delete on reboot option.
Copy and paste the following file to the field labeled "Full path of file to delete"
Press the Delete button (the button that looks like a red circle with a white X in it).
A first dialog box will ask if you want to delete the file on reboot, press the YES button.
A second dialog box will ask you if you want to REBOOT now. Press the YES button.
Your computer will reboot. If you get an error at this point, just reboot manually.
After reboot, post a new hijackthis log and let me know how things are working for you.
Sorry, it took me so long to get back to you. I had to go to a job interview.
O23 - Service: Pml Driver HPZ12 - HP - C:\WINDOWS\System32\HPZipm12.
Disable and Enable System Restore. - If you are using Windows ME or XP then you should disable and reenable system restore to make sure there are no infected files found in a restore point left over from what we have just cleaned.


text:
Posted on June 29, 2018 by Bonald
Once, someone asked me if the state I lived in was a "swing state", then said that people who live in those states are lucky, because only their votes count. The sentiment seems to be common, but as usual my instincts are different. In a non-swing state, most people get the outcome (or, at least, the electoral votes of their state) that they want. In a swing state, nearly half the votes are overridden.
Similarly, I can't understand all the hostility toward retiring Justice Kennedy, all this talk about him being the nation's real ruler just because his vote is not as predictable as the others'. I can understand being angry at the man for what one regards as his bad rulings, but one should be angrier at the justices who consistently and predictably give bad rulings.
the herd of independent minds
Steve Lagerfeld writes
Much of what social critics decry as rampant individualism in contemporary America is really rampant crowd behavior. It is herds of people busily declaring that they are not part of the herd.
The contrarian's great temptation is moral vanity, and what a sweet one it is. I am contrarian by birth and temperament and not a joiner, but when the Satanic Temple made its pariah pitch I knew exactly what they were talking about. For some of us, there is nothing like the joy of being a pariah. There is no better place to be than on the wrong side, scorned, hated, and despised by people about whom you have exactly the same feelings. I'm right and they're wrong. Their scorn is an intoxicating indicator of my own rightness and moral superiority. The sensation is physical, like what I imagine people get from extreme sports. But it's a pleasure I strive mightily to deny myself. Over the years, I've learned that its costs are high, and that I'm not as smart as I think I am. Even when I'm right, my impulses can lead to bad things. I've gone from thinking of my instinctive desire to be a minority of one as a distinguishing trait to thinking of it as something more like Asperger's syndrome—a disability that can in rare circumstances be an advantage.
One of the virtues of traveling a relatively solo path is that you pay the price directly for what you do. Crowds are shielded from the hard lessons of the contrarian way. They combine the frisson of being an outlaw with the comforts of belonging. The more contrarian they are, the more belonging they offer—and the more belonging they offer, the more conformity they demand. Psychologists Matthew Hornsey and Jolanda Jetten write that "there is a perverse tendency for groups that define themselves most aggressively against the mainstream to be characterized by the highest levels of intragroup conformity."3 That doesn't leave a lot of room for introspection.
More non-conformism
Jonathan Ree writes
Back in the 1970s, Raymond Geuss was a young colleague of Richard Rorty in the mighty philosophy department at Princeton. In some ways they were very different: Rorty was a middle-class New Yorker with a talent for reckless generalization, whereas Geuss was a fastidious scholar-poet from working-class Pennsylvania. But they shared a commitment to left-wing politics, and both of them dissented from the mainstream view of philosophy as a unified discipline advancing majestically towards absolute knowledge. For a while, Rorty and Geuss could bond as the bad boys of Princeton.
Out of his twelve philosophers, Geuss seems closest to Lucretius, who despised religion…In the wake of Lucretius, Hobbes, Hegel and Nietzsche, philosophy seems to be essentially a battle against the bewitchment of our intelligence by moralistic sentimentality.
Good thing these Leftists have escaped from the bewitchment of moralistic sentimentality.
I am saddened to hear that the Laura Ingalls Winder award is being renamed. My wife and I read Little House in the Big Woods to our girls a while ago, and it is a wonderful book. I didn't like Little House on the Prairie as much and actually wondered if the author's memories had been influenced in a PC direction. If so, it wasn't enough to save her. Even so, that the vote was unanimous and in one account followed by a standing ovation is just gratuitously insulting. I guess we should be grateful they didn't rename it the Harper Lee award. Ominously, the librarians promise that this is only a first step, and that they're looking for other white authors to purge.
You know what cultural power is? Suppose a cabal of Catholics took over the Miss America board of directors and announced they were abolishing the swimsuit competition because it is immodest. And suppose everyone just accepted this, with no grumbling about theocracy or the Taliban.
Of course, every bit of this scenario is unimaginable. But feminists can do this sort of thing with the snap of a finger, and their decisions are irrevocable. At most, some people will make fun of them, but even that is becoming dangerous.
Whither the humanities?
Humanities professors are always worrying that the public doesn't appreciate them. This article in the Chronicle of Higher Education is a generally sensible argument against the strategy of defending the humanities because of their "usefulness" for inculcating communication skills or even broad-mindedness and empathy. The author, Stanley Fish, rightly rebukes historians taking it upon themselves to tell the public how to vote, and his skepticism to the claim that immersion in literature makes one a better person is refreshing. There is an admirable honesty in his conclusion that the humanities must be defended as valuable in themselves but that he has no idea how to "sell" this to the wider public.
Oddly, Professor Fish doesn't address the usual conservative claim that the humanities are dying because they have become politicized. At the very least, the Leftist orthodoxy in academia keeps it from making the most emotionally powerful defenses of the humanities that it might have made. One of these, I think the most powerful, is the argument from piety. It would be natural, would it not, for a people to invest some resources into the careful preservation and transmission of its higher culture, its collective memory, its myths, its narratives, the wisdom of its most revered sages, the highest expressions of its collective soul? This would be a natural role for a people's literature professors and historians, but it is certainly not one that today's humanities scholars would be willing to assume, or even willing to pretend to assume for the sake of funding. Today, all scholarship, to be considered legitimate, must assume a position of hostility toward its subject (at least, if its subject is a part of Western civilization, and not an oppressed minority). But really, if white, Christian England was wicked and ignorant, why should we invest resources and time into studying English literature? The other argument I could imagine would be unashamed elitism–that there is a known canon of objectively superior (but rather inaccessible) works that must be studied and transmitted. But again, if the whole point is to deconstruct the follies of the past, one wonders what the point is. Why bother about things that we know are wrong?
I'm not convinced that the humanities really are suffering eclipse from the "STEM" subjects, anyway. Measured in terms of external funding, I'm sure the sciences appear stronger, but this is an obviously inappropriate metric. Science needs funds to build and operate experiments; literature and philosophy have no comparable material needs. In terms of number of students taking a course in their departments, I expect the humanities as a whole does well, thanks to general education requirements if nothing else. Probably more students take a course in the English department than in the Physics department except at colleges that cater mainly to engineers.
However, when it comes to influence outside of academia, the dominance of the politicized departments (a continuum within which the humanities exists) over the sciences is obvious. People may say that science is the only source of real knowledge (an idea they got from positivist philosophers, not scientists, by the way), but which of the following random collection has had the biggest effect on the public consciousness: renomalization group theory, Bose-Einstein condensation, cardinal numbers, category theory, or microaggressions? The last is an utterly puerile idea but has affected the thought and interactions of modern men more than any idea in the history of chemistry save perhaps the existence of atoms. Or how about this one: which unobserved object has more greatly affected modern men's idea of their place in the cosmos: the theory of dark matter or the theory of invisible knapsacks? Even science departments are having to adjust their admissions and hiring policies to accommodate these nonsense ideas coming out of the humanities, social science, and "studies" departments.
Well, you may say, that's not a fair comparison, because humanities and social science ideas are "actionable" in a way that STEM isn't. The existence of invisible knapsacks inspires action, but dark matter isn't something we need to do anything about. Indeed, this is an intrinsic structural advantage that the politicized subjects have, but it is an advantage nonetheless. Critical theory, not computer science, is the road to influence, that is, the road to power.
Speaking for myself, I lament the oversized influence of the non-STEM sector of the university.
Speculation on hostile elites and clerical celibacy
It's not true that the Jews are uniquely smart, hostile to Western civilization, and fanatically Leftist; Indian immigrants are just the same. Two priestly peoples, with thousands of years of natural selection for intelligence and ideological zealotry. What's remarkable is how hapless the European races are in comparison, since these outsiders clearly show that our societies are also structured to reward this combination.
There have been "solar" peoples where warriors ruled, where being smart and self-righteous would do little to help one climb in status. But we are a clerical people, a dogmatic people, and that has advantages, because truth matters and such a people is better disposed to develop science. Such peoples are prone to ideological fixations and handsomely reward those at the front of a craze. For us, the pursuit of conspicuous holiness has been deliberately detached from reproductive success. It is amusing to wonder how much different the Western personality might have been if we hadn't had so many monasteries and for good measure forced our priests to be celibate. It worked well for us for a time. The trouble is that if one then allows a foreign priestly people to join the competition for status and power, they will quickly make mincemeat of the locals.
Book review: Scholastic Metaphysics
Posted on June 7, 2018 by Bonald
Scholastic Metaphysics: a Contemporary Introduction
by Edward Feser (2014)
This is a very useful introduction to scholastic metaphysics, especially for those who want to use Thomism for more than just theology. What makes it "contemporary" (besides 2014 being not that long ago) is Professor Feser's effort to relate scholastic positions to discussions in contemporary analytic philosophy on powers, causality, and mereology. In each case, modern philosophers are being pushed back toward scholastic positions as their more ontologically-sparse Humean positions prove unable to make sense of the power of natural science. It is bizarre, in retrospect, that philosophers have tied themselves into such knots denying such obvious things as that objects have powers (active potencies). Yet the failure of the attempt to do away with them has been instructive. Potencies really are funny things–they can't be reduced to present structure–and yet it seems that we need them with all of their weirdness. The resurrection of final causes in modern philosophy also proves instructive. While Feser prefers the old language, I found the phrase "physical intentionality" from modern philosophers very useful in clarifying what it could mean to say that an inanimate object acts teleologically.
The book has a wonderful section on hylemorphism, laying out the full radical holism of the Thomist position. We are all familiar with atomism, the idea that constituent parts ground the existence of their wholes, and that the parts therefore enjoy some sort of ontological priority. To use scholastic language, the atoms (however conceived) are substances, while their wholes are mere accidental assemblages. A more moderate position, what one might call "modularism", is that substances could be composed of substances, with no ontological priority. Thomists do not see this as meaningfully different from atomism; for them, an assemblage of substances cannot be a substance. Instead, only the whole substance exists, and the constituent atoms exist only virtually, as potencies of the substance describing how it will respond to splitting. That is–if I understand correctly–if I probe a substance with something that responds to single atoms–a high-energy photon, say, to take "atom" in its modern meaning–then of course it will register (e.g. scatter off) a single atom, but that doesn't mean that the atom was really there beforehand or that the substance was actually always made up of them.
I am actually open to this sort of revisionism and have considered similar ideas myself but am uncomfortable applying it for parts larger than molecules. Are cells real? Organs? Do citizens of a nation exist virtually? Thomists would certainly say no to the last case. People are substances, and their groups are only accidental. Likewise, Feser insists that human artifacts like computers have merely accidental forms. He may be right, but I think the criterion for identifying real substances must be made more rigorous, because nations and computers clearly do perform actions (government acts, algorithms) distinct to themselves as wholes.
The Thomist alternative would be compelling if atomism and modularism can be shown to be false. The argument from Oderberg against atomism doesn't work. The idea is that water, for instance, cannot be made of hydrogen and oxygen because water lacks the properties that flow essentially from hydrogen and oxygen. But an atomist would not say that water is made of hydrogen and oxygen. He would say that hydrogen and oxygen properties are emergent phenomena in aggregates of hydrogen and oxygen atoms or molecules, that water is made of water molecules, and water molecules are made of hydrogen and oxygen atoms, etc. I would say that atomism is still viable, but readers will probably be surprised to realize that radically different ideas are viable too.
The book's introduction carries the very good news that Dr. Feser is planning a follow-up book on the philosophy of nature. This is a crucial field, since we can't be confident in our grasp of metaphysical concepts unless we're sure we know how to use them, and Dr. Feser is one of the most qualified contemporary scholastics for the job.
Dr. Feser is himself a Thomist and clearly sides with the Angelic Doctor when he relates intra-scholastic disputes. As someone who generally takes the side of Duns Scotus where he disagrees with Aquinas, I appreciated that Feser explains some Scotist and Suarezian positions well enough for readers to know what they are. I address some of these intra-scholastic disputes below. Although Feser often makes good points, my Scotist sympathies remain largely intact, so I urge readers who identify Thomism with Catholic orthodoxy not to read further.


Validation is an important part of being in relationship with Self and others. When we validate someone we are acknowledging that person's unique identity. Our external validation can also affirm positive feelings the person holds about him/herself. Understanding validation, and knowing how to give and receive it, is an essential career competency.
Human beings are social animals. The importance of belonging to a group has been critical for our survival as a species. Having someone else know and understand me contributes to my sense of belonging within the group, allowing me to "fit in." It also contributes to my identity and value as a person.
We need feedback from others in order to learn how to become an accepted member of our social group. The validation process begins within the family system, where ideally parents both protect and sustain the child's physical and emotional well-being.
Through adolescence, young adulthood, and the rest of life's stages, we continue to learn to self-validate, which is to recognize and acknowledge our internal experiences. And we continue to benefit from external validation and feedback.
In addition to the family system, our work environment provides an excellent opportunity for feedback and validation. While I may know when I'm doing a good job and experience a high degree of satisfaction from doing so, hearing the importance it holds for others, can be extremely meaningful.
* Never be threatened by someone else's competency-celebrate it!
I would love to hear about your validation experiences.


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PwC projects strong growth in data consumption in Canada
05 July 2019 Consulting.ca
PwC's Global Entertainment and Media outlook projects staggering growth for data consumption, internet access, over the top (OTT) services, and esports, as well as modest growth for cinema, music, and internet advertising.
The industry is expected to grow at a stable CAGR of 3.7% to 2023, which was the same growth rate seen last year.
Data consumption is the highest growth area identified in the consulting firm's report, with consumption projected to double from 32 trillion MB in 2018 to 77 trillion MB in 2023 – a CAGR of 19.4%. A thriving video-on-demand streaming market will be a driving force in the growth.
Canadians, however, currently consumer consume very little data relative to other developed nations (1.3GB on average), according to research from telecom website Tefficient. This is mostly due to high relative costs for mobile data and plans: analysis from boutique consultancy Rewheel found Canada near the bottom of its global ranking. In 2018, 30 euros purchased a mobile plan with 2GB of 4G data in Canada, compared to 100GB in the UK and unlimited data in Switzerland, Finland, the Netherlands, and other European states.
Canada's telecom trifecta of Bell, Rogers, and Telus attribute higher costs to requisite high costs of infrastructure across a vast country, but Canada's atrocious rates are likely an effect of a toothless industry watchdog (the CRTC) which fails to ensure real competition in the telecom market – and fair rates for its citizens.
The PwC report projects that 5G fixed and mobile internet penetration will increase slightly over the next five years, reaching a CAGR of 7.36%. The next-gen mobile spectrum will enable better streaming of high-quality video for consumers, reducing latency and increasing speed – especially important for live-streamed events and video games.
Over-the-top services (Netflix, Amazon Prime, etc.) will see revenue increase at a 10.7% CAGR in Canada, growing from US$1.6 billion in 2018 to US$2.7 billion in 2023. That growth will put Canada in fourth place, just above the UK at US$2.6 billion.
Canada currently has 25 OTT services, though Netflix dominates the market with a more than 70% share. Canadian broadcasters have adjusted to the new reality, with Bell offering a compelling service (Crave) mostly on the back of the streaming service's partnership with marquee content providers HBO, Showtime, and Starz. CBC, meanwhile, has put out its own free streaming app, Gem. Rogers' OTT service, Shomi, shuttered in 2016, after less than two years in operation.
Canadian video games and esports revenue is projected to grow at a strong CAGR of 5.5%, reaching US$2.8 billion in 2023. Canada has a strong video game development industry due to competitive tax incentives. Ubisoft, maker of popular franchises like Assassin's Creed and FarCry, has a strong presence in Montreal and Toronto. The country is also home to some premier indie developers, including Oakville-based StudioMDHR, which put out the popular Cuphead video game.
Esports is expected to grow from its nascent base of US$19 million to US$37 million 2023. Theatre chain Cineplex recently bought esports platform WorldGaming, and plans to situate a national esports league at its venue. Think of it as somewhat of a modern replacement for the area coin-operated arcade machines used to serve in movie theatres, though many youths watch esports and game streaming with the type of dedication once reserved for MASH or Cheers.
According to the report, the largest and fastest-growing part of esports revenue is media rights, which will more than double to reach US$11 million in 2023, at a CAGR of 29.3%.
Hundreds of local radio and TV stations could shutter in next three years Up to 200 Canadian private local radio stations and 40 private local TV stations could close by 2022, according to a recent report from media consultancy Communications Management that was commission
Calgary taps consultants to help boost attractiveness as video game hub Calgary Economic Development enlisted consultants to build a strategy for making the Alberta city a leading hub for video game and immersive media development.
Deloitte predicts more than 750 million edge AI chips will be sold in 2020 Deloitte predicts more than 750 million edge artificial intelligence computer chips will be sold in 2020 – more than double the number sold in 2017.
More PwC
Pandemic causes majority of businesses to shift their cybersecurity strategy An overwhelming majority of Canadian business (97%) say they will shift their cybersecurity strategy as a result of increased digitalization driven by the Covid-19 pandemic, according to a recent sur
Le Château files for creditor protection, appoints PwC as monitor Le Château, a Montreal-based fashion retailer, has filed for creditor protection.
Alberta hires PwC to examine feasibility of provincial police force The Alberta government earlier this month announced the hiring of consulting firm PwC Canada to examine the feasibility of transitioning from the RCMP to a provincial police force.


One way to know if your website/blog had been penalized by Google is when your blog/site doesn't even land the first line of search results when searching for it. In this case, I searched for "freemindfreelines.com." For over a year or maybe two, this blog had been under penalty. See this post for more info. It's a relief that the penalty is apparently already lifted.
For detailed content, see the article here.


What could be important enough to mention from our very first year in business - 1965. One of the hit songs on the charts that year, "What the World Needs Now Is Love". Who could argue that need for Love is greater than ever!
My very first project which set the stage for years to follow was Master Planning the church campus for the Panthersville Presbyterian Church in Decatur, Georgia.
The head of their building committee, Keller Cobb, has remained a good friend through the years.
"Zac Henderson, has been my architect for over 35 years. Zac designed and assisted in the renovation of an 1890's cottage in Historic Roswell that was to be my law office for 30 years, and the home is now the residence for me and my wife. It is a showplace, thanks to Zac.
But Zac is more than an exceptional architect, he is a leader in the community and I am proud to call him my friend."
Thanks to Tom for always being there for us.
"It would be impossible to give an account of American Home Equities' development history in Atlanta without including the great design work done by you and your firm. Your designs were the basis of award winning townhouse communities and innovative multi-family projects that made history in Atlanta. Your help in countless community zoning meetings, official hearings and obtaining building and zoning development approvals was key to our success. Many thanks to you and your team."
Many thanks, James, for many years of great adventures and successful projects.
"Zac designed a beautiful and sustainable building that blended beautifully with the natural setting of our 40 acre campus. We are forever grateful for his services and we would not have achieved GOLD LEED CERTIFICATION without his energy efficient design."
Thanks, Selena. What a pleasure to have you as my friend.


text:
Q: zookeeper status command in windows I am new to zookeeper and I configured three servers in my local host and I started three servers and they got started. But when I checked the status it returns,
"JMX enabled by default"
"Using config: "C:\..\zoo.cfg"

Unlike linux, it doesn't returns mode as
leader or follower

Can anyone tell me why

A: From zookeeper supported platforms documentation:

Win32 is supported as a development platform only for both server and
  client.

So it makes sense, that leader selection does not work.

redpajama_set_name: RedPajamaStackExchange


Balangir: In what can be called as a stern move, Balangir district Collector issued instruction to hold back a day's salary of district officials who were absent in the monsoon preparatory meeting held here today.
"An order has been issued against the officials for their break-in-service as they were absent without permission," informed Balangir Collector Ashish Thakare.
Leader of Opposition Narasingha Mishra, who was also present, said action should be taken against the officials who remained absent in the meeting without taking prior permission.
"Officials from the PHD, RD and MI were absent in the meeting. As per the direction of the Collector, the officials would be served show-cause notice and a day's salary will be withheld," said a district official.
The district administration also discussed revival of the Deogaon Sugar Mill.


category SPX , IRM , DE:VTM , and 54 more.
category Market News , Bloomberg Markets , KIM , and 5 more.
category Analyst Research/Ratings , WRI , MPW , and 41 more.
category Company Announcements , Retail , General , and 7 more.
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category NI , KIM , Downgrades , and 36 more.
category KIM , Pre/Market Outlook , FULT , and 9 more.
category Craig Schmidt , REIT , Benzinga , and 7 more.
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category DJIA , CL1 , XRAY , and 85 more.
category Baird , KIM , RJ Milligan , and 7 more.
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category ROIC , AMZN , HCP , and 2 more.
category CTL , Gas/Utilities , Aerospace , and 83 more.
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text:
Q: Can not assign iOS Charts valueFormatter to valueFormatter I had to update Charts pod because of an xCode update. Now I'm troubling with this funny issue.
let formatter: AxisValueFormatter = XAxisNameFormater(dates: self.formatedDates)
lineChartView.xAxis.valueFormatter = formatter

      public class XAxisNameFormater: NSObject, AxisValueFormatter {
        var dates:[String] = []

        init(dates: [String]) {
          self.dates = dates
        }

        public func stringForValue(_ value: Double, axis: AxisBase?) -> String {

          if value < 0 {return ""}
          if value == 0.5 {return ""}
          if Int(value) >= self.dates.count {return ""}

          let formatter = DateFormatter()
          formatter.locale = Locale(identifier: "tr")
          formatter.dateFormat = "dd MMM"

          let dateString = formatter.string(from: Date(timeIntervalSince1970: dates[Int(value)].convertToDouble()!))
          return dateString
        }
      }

And the error:

How can this be even possible? Any ideas?


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text:
Tiburon Yacht Club (U.S.)
Keywords: tiburon yacht club | united states yacht club | california |
image by Ivan Sache, 24 May 2000
Tiburon Yacht Club
The page at www.well.com/user/pk/yachtclubs.html gives a list of links towards the homepages of the Yacht Clubs of the Bay of San Francisco, and most of them show their flag on their respective homepage.
Ivan Sache, 24 May 2000
Founded in 1965 as Paradise Yacht Club, incorporated in 17 May 1965 as Paradise Harbour Yacht Club, renamed on 17 May 1980 Tiburon Yacht Club.
Tiburon Yacht Club - www.tyc.org:
"Tiburon Yacht Club is a friendly, informal club ... located on the east side of the Tiburon peninsula at Paradise Cay Marina, ... emphatically a "Yacht" Club rather than a "Social" Club." A picture of an actual burgee can be seen in the "Gear" section; it turns out to use a T in a slightly different font.
Peter Hans van den Muijzenberg, 2 March 2010


text:
Previous Post: MN Driver's Manual Updated Four Years After Traffic Stop Shooting
Next Post: What Does a Revocation of Stay Mean for My MN Probation?
Twin Cities Violent Crime Task Force: MN Now Working With the Feds
Category: Criminal Defense | Federal Crimes | Violent Crimes
In the two and a half months since the death of George Floyd, Minnesota has been spotlighted as the center for protests, change, and civil unrest. The results have varied widely.
City Council members unanimously voted to eliminate the Minneapolis Police Department in June. Over 100 officers have resigned, were fired, or took a leave of absence. The entire community service staff was let go due to budget cuts.
So what effects are the protests and changes having on crime?
The answer depends on the statistics that you see. Total reported crimes went down 31% in June and 4% in July. Police stops dropped by 50%. Yet when you zoom into gunfire incidents, you see a different story.
Gunfire incidents went up 224% in June and 166% in July. Between May 25 and July 8, eight people died and 118 were injured due to violent crimes.
U.S. Attorney in Minnesota Announces Violent Crime Task Force
As a result of these statistics, in early July, United States Attorney Erica H. MacDonald announced that she would put together a task force to specifically address the violent crimes happening within the Minneapolis-St. Paul area.
This could mean that offenders could face federal, rather than state, criminal prosecution. Understanding the difference between these types of crimes is crucial if you want to create a strong defense and maintain your freedom.
What Will This Task Force Look Like?
Do not worry about a slew of federal agents making arrests like those seen in Portland and New York City. MacDonald stated that her goals for the task force are "not to flood our communities with law enforcement, but rather to leverage law enforcement's collective resources to allow for focused and effective enforcement actions."
Instead, the task force will get together to gather intelligence, share information, and make quick arrests so victims of gun violence can see justice. Groups at the state and federal level are involved in this task force, including:
United States Secret Service
United States Marshals Service
Minnesota Bureau of Criminal Apprehension
State and federal prosecutors, along with deputies from surrounding counties, will also submit their input. This collaboration increases the risk that offenders will face federal, rather than state, charges.
State vs. Federal Crimes in Minnesota
The difference between a state and a federal case may be who arrests you and who takes up your case.
Federal prosecutors have the ability to usurp a state's case and charge offenders with federal crimes. When crimes are charged at the federal level, offenders have to attend different courts, face different sentences, and hire different defense attorneys to handle their cases.
If you are arrested by federal officers, even for committing a crime within the state of Minnesota, it's time to reach out to a defense lawyer who is qualified to take on federal crimes.
Penalties may vary for similar crimes, as well. Both Minnesota state and the federal government have specific charges for illegally possessing a firearm while under the influence of drugs.
Even if you have a permit, it is a misdemeanor crime in Minnesota to carry a firearm while intoxicated. Penalties may include up to one year in jail and up to $3,000 in fines.
If this case is taken up by the federal government, you could face a much severe charge. Possessing a firearm while under the influence of drugs, for instance, could get you ten years behind bars.
Christopher Keyser is an AV-Preeminent rated criminal and DWI defense attorney based in Minneapolis who is known for fighting aggressively for his clients and utilizing innovative tactics to get the most positive results. He has been featured in numerous media outlets due to the breadth and depth of his knowledge and named a Certified Specialist in Criminal Law by the Minnesota Bar Association. Mr. Keyers is Lead Counsel rated, and he has received recognition for his criminal law work from Avvo, Expertise, Super Lawyers, The National Trial Lawyers, and more.


I have spent some time today reading some pretty unnerving posts about two Fountains and a Cig TG that went in pretty hard.
I must put myself in the category of an undereducated rookie when it comes to performance boating and am grateful for the water time spent with Randy Hartmann, and upon delivery another round of training. Believe me when I say I have nothing but the utmost respect for the elements and physics of this sport.
We are currently stockpiling goodies for our new boat and would like input on two jackets. While you can't put a price on life I would like to understand the difference.
The first from Lifeline http://www.lifelinejackets.com/catal...rfjackets.html high dollar, high end jacket.
The other is a Stearns 4185 SAR vest. http://www.rocknrescue.com/acatalog/...tearns_75.html The Stearns is rated 100mph impact.
I also looked at many of the vest on the market (LifeLine, SRP, Auto Inflatables) and ended up buying Lifelines for both children, wife, and myself. I couldnt be happier with them. Very comfortable and not in the way while driving as other bulky lifevest were.
The CG requires is that an approved jacket be "on board", they don't say it has to be worn. So all you have to do to be in compliance is put a few cheap-o's somewhere on the boat, and you will comply with CG req's, even when wearing your Lifeline or other race jacket.
I doubt your insurance liability clause is going to protect you when your passenger is hurt or killed while wearing an unapproved life vest that you provided to him or her. If you do I would get it in writing from your insurance company because the last thing you need after a tragedy is a hot shot attorney filing a wrongful death suit against you because your equipment isn't "legal." I in no way doubt the protection provided by a lifeline vest.
If an inflatable vest can be required to be worn to be legal I fail to understand why a more standard vest cant be certified in the same manor..ie why doesn't lifeline approach the USCG for a new classification of vest that is noninflateable but yet must be worn to count as a PFD? I mean if the vest meets all other requirements and offers better protection I can't believe that this can't be done, although I guess we are talking about the government.
Is my solution too simple? BTW I did e-mail UL to get the answer to this question, I wonder if they will respond.
are the lifeline sport jackets uscg approved??
Alright, this is going to sound very "rookie" but I am and here it goes. I understand the reason for not using restraints in a boat that may flip and trap the occupants however, it seems that allot more injuries occur when people get ejected and the boat survives upright. Does anyone have the stats on rollovers vs ejections? Its all a matter of playing the odds I just wonder what the odds really say. Maybe if your going to refuse to wear a vest a restrain is a better gamble than nothing at all. Either way, it should remain a matter of personal choice. The only problem with that is the uninformed passenger that doesn't know the risk.
First of all, I would NEVER trust my life to one of those $10 cheapo "coast guard approved" life vests. Nothing about them is rated or built for the types of speeds we run.
However -- the Lifeline jackets ARE.
Not only are they approved for over 100MPH racing, BUT all of the top racing organizations INSIST that you ONLY use Lifeline or Security race jackets (keep in mind that none of them are USCG approved, and never have been).
Do you think they'd keep insisting on these race jackets if they thought they lose in court over a non-racing USCG label?
If APBA and the UIM can insist that their competitors race ONLY with these types of well-built, race approved, damage resistant, injury limiting non-CG approved jackets, I don't think an average boater would have much hassle in court if someone was wearing one either.
Judges and juries will see right away that the RACE JACKET was by far, the most researched protective flotation device available for any boater, and has been in use in nearly all professional powerboat racing sports for many decades. It wouldn't take much to point out all the benefits of a $400 impact resistant, ballistic material, kidney/rib cage/heart protecting multi-race organization approved high speed racing vest vs. a $25 hunk of vinyl and foam with a USCG label.
Also -- regarding what makes a jacket "Coast Guard Approved", one of the points is "Easy to put on in an emergency". That is because these PFDs are not required to be worn, but must be "readily accessable". The CG knows most people will keep the PFD in a storage area instead of wearing it.
Racing jackets are very stout, and the buckles and zippers are NOT easy to put on in an emergency so they all fail the section of the USCG laws for "reasonable amount of time to put on". To alter them so they met CG standards of ease would be going backwards, IMO. But most people who own these jackets, wear them all the time and wouldn't have to worry about this particular USCG req anyhow.
But your idea about the inflatables being "required to be worn" brings up a very good point about why a racing jacket can't get the same deal. Could be that the costs would inhibitive? I do know that the mfg has to pay for some testing. This is a good question. Glad you brought it up.
Adult I & II 34 lb.
There are a lot of jackets on the market that are "100 MPH vests". Keep in mind this is not a bodily impact rating, it is only the rating for the materials used to make the jacket. (Straps and snaps will withstand 100 MPH without tearing, etc).
This is because many USCG jackets will disentegrate or shred upon hitting the water at higher speeds because the materials are very cheap and built very flimsy.
Hitting water at over 60 is like hitting concrete - be sure your flotation device is built to stay on your body under these high speed conditions. (leg straps are a must).


Higher National qualifications provide practical skills and theoretical knowledge that meet the needs of employers. The HNC in Facilities Management (SCQF level 7) develops knowledge and skills of the modern Facilities Management industry including both 'hard' and 'soft' services. The HND in Facilities Management (SCQF level 8) builds on the knowledge and skills of the HNC and also covers workforce development, risk management and business continuity.
The HNC qualification covers areas such as support services, managing stakeholder delivery, health and safety, sustainability, people management, project management, financial management, and facilities management strategy.
The HND qualification builds upon this with an additional focus on workforce development, risk management, business continuity, management accounting, information management, managing negotiations, managing relationships with suppliers and specialists, managing procurement and contracts and space management.
Learners who achieve an HNC Facilities Management can progress to the HND in Facilities Management (GP05 16).
HNCs and HNDs can provide progression to degree-level study. For example, the HNC in Facilities Management allows direct entry into the second year of most degree programmes, and the HND in Facilities Management allows direct entry to most third year programmes.
HNC Facilities Management at SCQF level 7 consists of 12 mandatory Unit credits (96 SCQF credit points).
HND Facilities Management at SCQF level 8 consists of 25 mandatory Unit credits (200 SCQF credit points) and a number of optional Units (40 SCQF points).


All members please note that there is now a Security Key Box on the main gate for use in an emergency.
If you are alone on site and need to call for an ambulance they can gain access to the site and get to you without you needing to open the gate. They have the code to the box.
All pesticides,weedkillers and other noxious substances must not be kept in unlocked sheds or tool boxes. See by law below.
8.3 The tenant must use and dispose of pesticides, weedkillers and other noxious substances according to the manufacturer's instructions. They should be kept in a secure place or removed from site when not in use.
8.10 Tenants must ensure that any pond on their allotment is located well away from footpaths and roadways, is clearly visible and is protected with a rigid mesh cover.
8.11 Tenants bringing children to site must supervise them at all times to ensure that they are safe and do not cause a nuisance to other plot holders.
7.3 Any asbestos found on site should be notified to The Committee who will arrange for safe removal and disposal.
The hedge that forms the border of the allotments backing on to the footpath along the Coronation Road side is formed mainly of Hawthorn and care should be taken if you are working near or coming through the entrances through the hedge.


text:
EXPLAINED: What Brits with EU partners need to know about returning to live in UK
@thelocalfrance
BrexitDealing with Brexit
Photo: Martin Bureau/AFP
While many of the 1.2 million Brits living in the EU have no immediate plans to return to the UK, circumstances can change. For those who have non-British partners heading home on a long-term basis could be more difficult than they imagined. We explain why.
Since Brexit, the UK has a strict immigration policy in place for EU nationals moving to the country and contrary to popular belief, even if they are married to a British national it does not exempt them from those requirements.
So whether you're planning a move back to the UK with your non-British partner in the near future or whether you just want to keep your options open, here's what you need to know.
Moving before March 2022
If your moving plans are imminent, you should be able to meet the deadline of March 29th 2022, which is an important cut-off point.
Thanks to campaigning groups like British in Europe, the UK government agreed to a grace period for Brits living in the EU to move back and bring their non-British spouses with them.
The March 29th date relates to the UK's original exit date from the EU, and British in Europe is campaigning for an extension to reflect the several delays before the UK actually left.
This means the process is easier – but it's still not simple.
First you must apply to the Home Office in the UK for an EU Settled Status Family Permit. This must be done before the move and the EU partner should not enter the UK until they have the permit.
Processing time for these permits vary, some people have reported it has taken several months, while others have had their application rejected and had to begin the lengthy appeals process.
Once you have the permit you can then make the move, and once in the UK the EU partner needs to apply for EU pre-settled status.
This application must be made before March 29th 2022 in order to benefit from the Settled Status system, which is now closed to all other new arrivals from the EU.
The advantage of this system is that the EU partner does not have to satisfy immigration criteria such as financial thresholds.
Moving after March 2022
If you move back to the UK with a non-British partner after March 2022, or you don't get the application submitted in time, you fall under the new immigration regime.
This means that the EU partner will need a visa to enter the country, and in most cases this needs to be applied for before the move.
Some people think that being married to a Brit means more or less unlimited entry to the UK, but in fact this is not the case and the couple must comply with strict rules including minimum income levels. For people in low-earning professions, or those who are not able to work in the UK, this could effectively bar the non-EU partner from entering the country.
There are essentially two routes – the non-EU partner can apply for a visa in their own right, or the British partner can sponsor their partner for a visa
Own visa
The points-based system that now applies to EU citizens is the same as the system in place for non-EU nationals and essentially requires applications to gain a required level of points by things like earning enough money, having sufficient language skills or having certain skills or qualifications that the UK has a shortage of.
Find our more here.
Sponsored visa
There is also an option for the British partner to sponsor their EU spouse's visa, but this too has a minimum income requirement.
The Citizens Advice Bureau in the UK lays out the following income thresholds British partners must earn in order to sponsor their EU national spouse.
Partner only – minimum of £18,600 a year
Partner and children – minimum of £18,600 a year plus £3,800 for the first child and an extra £2,400 for each child after that. The extra income for children only applies if the children do not hold British citizenship or have residence rights in the UK.
Income can come from savings, pensions, rental income or earnings – but only earnings in the UK are taken into account, so if you have a salary from the EU country where you have been living, this would not be taken into account.
This could also rule out – for example – someone returning to the UK in order to take care of elderly or ill family members, who may not be able to work while taking on caring responsibilities.
If you do not meet the income requirements you can make up the amount through savings, if you have a sufficient amount. This needs to be £16,000 plus an extra £2.50 for every £1 below the income threshold you fall. The savings must have been in your name for six months or more.
If you're British and don't have a foreign partner (or you're willing to dump your partner for the pleasure of living in a country of drizzle and chunky chips) then you can move back at any time without the need for a visa.
Short visits back to the UK to visit friends or family are allowed, although the non-British partner will need to be aware of new travel rules since the end of the Brexit transition period, including the end of using national ID cards for immigration purposes – only passports are now permitted. The same applies to children.
But longer visits should be approached with caution to ensure that the non-Brit does not exceed their maximum allowed number of days in the country. The 90-day rule applies to EU nationals visiting the UK, but the UK rules allow 180 days together, they don't need to be divided into two sets of 90 like in the EU.
There are also reports of EU arrivals being grilled by immigration officials on arrival and some people who said they intended to, for example, help with childcare for their family were treated as unauthorised job-seekers and detained, so be sure you are very clear that you do not intend to work while in the UK.
How roaming charges will hit travellers between the UK and EU in 2022
Brexit: How UK residents of Denmark can document status for Christmas travel without new ID card
Christmas travel between Denmark and the UK: What can I not pack in my suitcase?
How Brexit will affect sending Christmas parcels between Denmark and the UK
Brexit: Danish minister urges Denmark-based Brits to apply for new residency status
Should British-Danish dual citizenship applicants also apply for post-Brexit residency?
Passport stamps: What British residents in the EU need to know when crossing borders
Brexit: How Brits can properly plan their 90 out of 180 days in Denmark and Schengen Area