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An Education Primer on Defamation Law in Florida
Florida Defamation Law, October 2020
By Maurice Arcadier, Esq.
Mr. Arcadier is a board certified attorney and is regarded as an expert in Florida Defamation Law. Below is a complete transcript of a Florida Defamation Lecture. The lecture was sponsored by NACLE which is the national recognized organization which provides continuing education for attorneys. The intent of the lecture was to provide a general understanding and analysis of Florida Defamation Law. The lecture was prepared in October 2020.
Welcome to Florida Defamation Law. My name is Maurice Arcadier. I am the managing partner of Arcadier, Biggie and Wood, PLLC located in central Florida. I am a board-certified litigation attorney and I have been practicing law for 23 years. My areas of practice include defamation, commercial litigation, and employment law, and includes trial and appellate work.
The purpose of this lecture is to assist attorneys identify issues and provide a flavor as to the factual and legal complexities of defamation law. The goal is to help attorneys understand the elements of a defamation claim, the type of defenses, and to give a background as to legal issues that may need to be addressed at the trial level or appellate level as the case may be.
Defamation law has many nuances and it is fact intensive, meaning, a careful review of the facts, including the context of the facts, need to be analyzed and applied to the current laws. This lecture is not intended to substitute sound legal advice from an experienced attorney who can hear the particular fact pattern of the defamation case.
Also, Defamation law is constantly evolving, and as the proliferation of social media continues to evolve, the Courts are slowly addressing the legal applications to current events.
Part of the complexities of defamation occurs because of the interplay between protected first Amendment rights, and the right of privacy of individuals. On the one hand, our jurisprudence demands the protection of speech, whether it is by the media, in writing, in a publication, or verbal utterances. On the other, the Law and the Courts desire to protect harms against individuals or corporations as a result of malice or ill-will which results in defaming innocent individuals or viable companies.
There are two types of defamation: Libel and slander. Libel means defamation which occurs in writing or through a written publication. Slander means defamation from verbal utterances and verbal speech.
In Florida, Defamation cases have a two-year statute of limitation, which means, that a defamation claim must be brought forth within two years from the date of the publication. This is codified under Florida Statute 95.11(4)(g). It used to be the case that publications existed solely in print, which of course means that the date of the publication was easily discernable. Similarly, in the case of slander, the date of the publication was the date in which the last actionable statement was made. A republication can also trigger a new Statute of Limitations date. A republication occurs on the date that the defamation is republished, even if it was simply copied from a previous publication.
However, with the advent of web sites and digital publications, it is not always the case that the publication date is easily known. For instance, if a publication is made on a web site, is it the publication date that the web site was last amended? or is it the date when the article was first published? Although I am unaware of any appellate cases specifically addressing this issue, Florida Trial Courts are tending to use the date in which the article was last amended, even if the amendment or update has nothing to do with the defamatory language. For instance, an article which provides new information below the previously published information, would trigger a new statute of limitations commencement date as it would be considered a republication.
Alright, so what is Defamation
In its simplest form, defamation is a false statement which causes damages.
And, as to the elements of defamation, they are also pretty straight forward:
1. The defendant made a false statement about the plaintiff
2. The false statement was published to a third party, and
3. The falsity of the statement caused injury to the plaintiff.
Lets go deeper into the Elements:
Lets talk about what the first element means, in particular, what does it mean that "the defendant made a false statement about the plaintiff"
For starters, expressions of opinion are privileged and are protected by our Constitution.
For instance, having an opinion such as: John Doe is a bad person, is not going to be defamation. Other examples of statements which Florida Courts have recognized as opinions include: John Doe abuses the elderly, John Doe is profane John Doe is Lazy, or John Doe never does good work.
Also, the truth is generally an affirmative defense to Defamation. But even that, tends to get complicated and convoluted very fast, and that is because Defamation can exist even if something is truthful, but it is somehow juxtaposed in a way that creates a false impression.
Prior to 2008, Florida Law recognized claims under a False Light private cause of action. False light does not necessarily involve false facts, but rather, organizing the facts in such a manner which causes the reader or hearer to form a false impression.
In 2008, the Florida Supreme Court, in a landmark decision, Jews for Jesus v. Rapp, the Supreme Court of Florida abolished the separate cause of action of false light. By the way, Jews for Jesus is definitely a case that is a must read for anyone considering practicing in the area of Florida Defamation Law as it lays out the history of defamation law in Florida. In Jews for Jesus, the Court eliminated the common law claim of False Light. In its place, the Court merged the false light claims into a category known as: Defamation by implication.
The Court said that:
"Defamation by implication arises, not from what is stated, but from what is implied when a defendant either '(1) juxtaposes a series of facts so as to imply a defamatory connection between them, or (2) creates a defamatory implication by omitting facts, [such that] the defendant may be held responsible for the defamatory implication ․
The Court further stated: "A defamatory communication may consist of a statement in the form of an opinion, but a statement of this nature is actionable only if it implies the allegation of undisclosed defamatory facts․")."
Simply put, "if the defendant juxtaposes a series of facts so as to imply a defamatory connection between them, or creates a defamatory implication by omitting facts, Defendant may be held responsible for the defamatory implication, unless it qualifies as an opinion, even though the particular facts are correct."
Courts also tend to be strict in the pleading requirements of Defamation cases. For instance, defamation by implication must be plead, and should be pled as a separate and distinct count. Also, when there are multiple defendants, each of the defendants should be separated into separate counts for each of their types of defamatory statements.
There are dozens of noteworthy Florida Appellate cases which have further explained what Defamation by Implication means:
In Boyles v. Mid-Fla. Television Corp., the 4th District Court of Florida reversed a trial Court dismissal based on statements that implied that plaintiff was a suspect in the death of the child, and was a habitual tormentor of retarded patients. Boyles worked at the group home, but was not working on the date that the child passed away. The Defendant published truthful statements about Plaintiff's evaluations and areas where employer said Boyles needed to improve. These statements about Boyles was made in the story that was published about the child's death, thereby insinuating and implicating, without stating, that Boyles was complicit in the child's death. The Court in Boyles determined that even though the statements about Boyle's employment record were truthful, defamation by implication still existed because giving the truthful details about Boyles as part of the wrongful death article implicated that Boyle's contributed to the wrongful death of the child.
Next, lets talk about the second element:
The second element in a defamation case states that "The defamatory statement must be said to a third party."
Simple enough right? Well, not so fast.
First the defamation is not actionable defamation if the intended recipient of the defamatory statement was the Plaintiff.
So for instance, if Defendant tells Plaintiff "I saw you steal yesterday," and someone overhears it, the defamation was not said to a third party. Who the defamatory statement is intended for is the conclusive determinant factor as to whether the element … to a third party, has been met.
Also, to meet the standard for publication to a third party, a plaintiff must be able to prove, and "the complaint must allege the 'identity of the particular person to whom the remarks were made with a reasonable degree of certainty.
However, In Brown v. Tallahassee Democrat, Inc., the Florida First District Court of Appeals overturned a trial Court's dismissal of the defamation case. In Brown, the Defendant simply published a picture of Plaintiff in a story about a murder, which implied that the countenance of the person in the picture was a murderer. However, the Defendant never disclosed or published the name of Brown. The appellate court reasoned that the published picture is enough to discern who Plaintiff is, and the juxtaposition of the picture with the contents of the article constituted enough to subject Defendant to the claim of defamation by implication.
Also, Florida recognizes the Intra-corporate conspiracy doctrine in many contexts.
In the Florida Defamation context, "The intra-corporate conspiracy doctrine provides that employees of a corporation or governmental entity cannot defame each other because they are treated as one entity."
This means that a company cannot be held liable for defamation if a supervisor defames an employee by stating false information about the supervisor's subordinate. Under the intra-corporate conspiracy doctrine, the supervisor and subordinate of employer are both employees of the company, and as such, the law will treat the statement as a defamatory statement made from the same person meaning, it defamed itself. In other words, employees of the company who defame each other are really just defaming elements of the company itself. Since employees of the same company are not third parties, the defamatory statements perpetuated by one employee against another will not give rise to a claim for defamation because the second element cannot be had.
However, an exception to the doctrine exists when the challenged activity takes place outside the scope of employment and done out of self-interest. For instance, if an employee accuses another employee of stealing outside of work, and the employee makes the accusation to advance his own personal interest, then, that is enough to establish the exception to this doctrine. The way we normally see this play out is when an employee wants to get another employee fired because they do not get along, or one of the employees wants the job of the other.
The third Element of defamation is damages:
This is where the complexity of defamation cases shows its true colors. Showing damages is the most basic of elements in tort related cases. In defamation cases in particular, damages may not be so clear. This is because there are many intangible aspects to defamation such as what is the value of a reputation, how do you show the amount of business one has lost as a result of a fake review, and how do you prove the losses suffered?
The evolution of the case law has created two types of defamation cases. Per Se and Per Quod. Depending on which type of defamation has occurred will determine the types of damages and remedies that are available as well as determine how the damages need to be proved.
In Per se Defamation cases, damages are assumed, meaning, actual damages do not need to be proved. In contrast, In per quod defamation cases, actual damages must be proved.
So, lets talk about Defamation per se:
Under Florida Law, Per Se defamation is a defamatory statement that is defamatory on its face, meaning, no extrinsic or contextual evidence is needed. Meaning, the defamatory act, can be considered alone and without innuendo.
AND must be one of the following:
Making a defamatory statement about Plaintiff having loathsome disease.
For instance, claiming falsely that someone has HIV would be enough, but claiming someone has the flu would not.
(2) Making a defamatory statement which attacks one's profession or business.
This is the most common type of per se defamation. It arises in many contexts, such as online reviews where a customer makes false accusations about the business not being licensed, or when one business is defaming another business to gain a competitive advantage, or someone falsely claiming that a professional has been disbarred or reprimanded by a licensing board.
Making a defamatory statement about a woman being "unchaste" which includes relating to or engaging in sexual activity of an illicit or extramarital nature.
Many of these types of cases are arising from Facebook postings of disgruntled exes who have made defamatory statement about a woman's proclivities or false accusations of adultery. Interesting to note, that under this category, thus far, Florida Courts have only recognized defamatory victims to be limited to women.
4) an infamous crime
Florida has been strict in defining infamous crimes. Florida Courts have drawn the line between felonies and other crimes. So a felony can be considered an infamous crime, but a misdemeanor cannot. Additionally, Courts have categorized certain types of defamatory statements to be Rhetorical hyperbole, and therefore, not actionable.
A statement is considered rhetorical hyperbole when "the language itself negates the impression that the writer was seriously maintaining that the plaintiff committed the particular act forming the basis of the defamation."
For instance, someone stating "he lynches everyone" in the context to mean, he fires someone, is not defamatory. Also, statements such as "he is a fraud" is not per se defamation because it requires additional facts to be able to discern its context. When context is considered and 'extrinsic facts and innuendo are needed to prove the defamatory nature of the words,' the statements are not defamatory per se. So a statement: "he is a fraud" may fall into the category of defamation per quod, but it will not be defamation per se.
And finally #5, which is almost like a catch all or at least where most attorneys try to fit their client's defamation claims into per se defamation
And that is, …allegations that subjected one to hatred, distrust, or ridicule.
However, Florida Courts have consistently ruled that the defamation statement must be severe and extreme.
Publications such as:
Plaintiff took advantage of an old sick man and committed elder abuse is not enough.
Plaintiff is a drunkard, is not enough.
Courts are left with the challenge to determine whether actionable expressions are pure opinion, are per se defamation, are jokes, or are rhetorical hyperbole. Some attorneys have tried to argue that it should be juries that decide the intent of a fact. But, this is where things get fuzzy. Is it a question of law or fact whether a defamatory statement was intended as a rhetorical hyperbole or is it up to the Juries. Up to now, the Courts have consistently ruled that it is a question of law and routinely make these determination at the pleading and summary judgment stage.
If plaintiff is unable to plead and establish defamation per se, then, plaintiff can still plead defamation "per quod" but actual damages must be proved when pursuing a defamation per quod case. Best practice is to plead, in separate counts, Defamation per Quod and Defamation per se, even for the same defamatory statement.
Defamation Per Quod is the most common type of defamation and it literally means Defamation "by reason of which"
Defamation per quod is not apparent on its face, and must be plead with a showing of actual damages.
In Florida, defamation per quod actions require an allegation and proof that the defamation precipitated an actual injury. Precipitated means that the defamation was the but for cause of injury.
Words in a per quod action means that they are not injurious on their face; when such is the case, Florida Law requires plaintiffs to use extrinsic evidence to support the defamatory nature. In cases of innuendo, extrinsic evidence must be supplied that "must be known in order to inflict an injury." Id.
In Defamation per quod cases, Plaintiff must be able to proof some [E]vidence of some actual injury.
The type of injury can be anything, but it needs to be able to be quantifiable. For instance, if the injury involved loss of a job, then the loss of income from the job loss can suffice. If it is loss of reputation, then a showing of business loss is required.
The other type of damage recovery that is available in some case is injunctive relief where you ask the Court to order the defendant to take a statement down or to issue a retraction.
Injunctive relief may be sought at the onset of the case by filing an emergency motion for injunction relief.
To prevail in preliminary injunction, the plaintiff must establish the likelihood of irreparable harm; (2) the unavailability of an adequate remedy at law;(3) substantial likelihood of success on the merits; and (4) consideration of the public interest" As a general rule, a trial court has sound discretion to grant injunctions.
Ultimately, the Plaintiff is required to demonstrate facts that weigh heavily in favor of the issuance of a temporary injunction.
Now lets talk about the affirmative defenses
There are two main affirmative defenses which are unique to defamation:
The most common one is the affirmative defense that the statement is truthful.
What means truthful is a subject of many arguments:
Typically, the courts have defined a truthful statement as a statement which is substantially true if its substance or gist conveys essentially the same meaning that the truth would have conveyed. In making this determination, Courts will consider the context in which the statement is made and disregard any minor inaccuracies that do not affect the substance of the statement."
The legal significance of the "gist" of a publication means that a defendant may be held liable even if defendant has the details right, but the gist wrong. The gist is always more important than having minor inaccuracies or minor facts wrong.
As far as the truth is concerned, if a statement is accurate, then it is not defamatory.
The next common type of affirmative defense is that the Statement was a statement of Opinion
Once again, defamation is a false statement of fact. For this reason, a statement of opinion cannot be defamatory. However, simply because you might phrase a statement as a statement of opinion does not automatically mean that it will be interpreted as a statement of opinion for purposes of defamation law.
Let us look at an example to see why this is so. Let's say that Tom told someone, "I think that John beat up his girlfriend last Saturday," and, as a result, John lost his job and most of his friends. Tom might say he was only giving his opinion because he qualified his statement with the word 'I think'; Tom will argue that he didn't say: "John beat up his girlfriend." Tom qualified his statement." But simply adding "I believe" or "I think" to an otherwise straightforward statement of fact does not necessarily make someone's statement an opinion.
In a defamation lawsuit, the jury will be instructed to look at all of the circumstances surrounding the publication of the defamatory statement. Following our example above, how well Tom knew John knew the person that he made the alleged defamatory statement to, and how precise the allegedly defamatory publication was, are all relevant factors. But, the most important factor is why did John make the statement. For instance, if John and Tom work together and Tom's motivation was to get John fired, then normally, the statement is more likely to be construed as a defamatory statement and not a statement of opinion.
In any event, the jury will be instructed to put all that context together. After combining all the context together, if a jury believes that John was really making a specific statement of fact and hiding it as a supposed statement of opinion, then John will be found liable for defamation.
Defamation cases also have two types of privileges we need to be discuss
First is the Absolute Privilege
Certain types of communications or publications are absolutely privileged. Absolute privilege means that the person making the statement has the absolute right to make that statement at that time, even if it is defamatory. In other words, the person making the defamatory statement is immune from a defamation claim.
In general, absolute privilege exempts persons from liability for potentially defamatory statements made:
during judicial proceedings
by high government officials
by legislators during legislative debates
during political broadcasts or speeches, and
between spouses.
Defamatory statements during judicial proceedings enjoy an absolute privilege. This includes allegations in pleadings, statements in motions, and testimony. Of course, if the testimony is false, then it is perjury, but it is not defamation.
The litigation privilege extends to Judges, attorneys, witnesses, and the parties so long as it directly part of the litigation proceeding. The Florida Supreme Court drew the line in a landmark case known as Delmonico v. Traynor, which is a 2013 Supreme Court opinion where the Court refused to extend the privilege to an attorney who had ex-parte communications with witnesses outside of the Court house.
There is a long history as to how judicial proceedings have enjoyed this privilege and that is because in a judicial proceeding, one has a judge who can strike a statement in a pleading or motion, can seal record, and can sanction accordingly.
High government officials also enjoy an absolute privilege when defaming each other, or when a person defames them. Think of all the potential lawsuits that could exist between Presidential candidates. Because these types of publications are protected by an absolute privilege, it is irrelevant the motivation or if extreme malice exists.
Florida has been liberal in construing what a high government official means. Meaning in extends coverage to most government officials. Although there is much debate as to affording absolute privilege across the board as to government employees, currently, Florida extends the absolute privilege to all government employees so long as they are acting within the course and scope of their government duties.
Legislators on the legislative floor also enjoy absolute immunity as to any defamatory statements uttered during debate of the bill, even if it directly defames an individual and even if it defames an individual with malice.
So it follows, that during a political broadcast, speeches, and political debates, an absolute privilege is enjoyed by the speaker.
Finally, defamatory statements from one spouse to another or about another spouse enjoys an absolute privilege. This privilege has developed as part of defamation due to Florida's recognition of the spousal privilege as recognized under Florida Statute 90.504.
Qualified Privilege
Other types of communications are subject to what is called a qualified privilege, meaning that the person making the allegedly defamatory statement may have had some right to make that statement.
If a qualified privilege applies to a statement, it means that the person suing for defamation must prove that the person who made the defamatory statement acted intentionally, recklessly, or with malice, hatred, spite, ill will or resentment. In a qualified privilege scenario, the motivation of the individual publisher of the defamatory statement is what is most closely analyzed.
Some examples of statements which have a qualified privilege are:
statements made in governmental reports of official proceedings
citizen testimony during legislative proceedings
statements made in self-defense or to warn others about a harm or danger
certain types of statements made by a former employer to a potential employer regarding the employee, and
published book or film reviews that constitute fair criticism.
Important to add as to book publications is how the book or publication is marketed. If it is marketed as a factual biography of a person, then fictional elements to the factual biography could very well be actionable. But, as we often see, words like "based on a true story" with "some elements have been changed for dramatical purposes, are likely to be construed as qualified privileged.
Public figures are also covered by the qualified privilege.
If the plaintiff bringing a defamation claim is a public figure, he or she must also demonstrate with clear and convincing evidence "actual malice" by the person publishing the statement. The landmark case is the U.S. Supreme Court Case, New York Times Co. v. Sullivan, which, for the most part, remains the law of the land.
The General Facts of Sullivan are as follows
During the Civil Rights movement of the 1960s, the New York Times published an ad for contributing donations to defend Martin Luther King, Jr., on perjury charges. The ad contained several minor factual inaccuracies. The city Public Safety Commissioner, L.B. Sullivan, felt that the criticism of his subordinates reflected on him, even though he was not mentioned in the ad. Sullivan sent a written request to the Times to publicly retract the information, as required for a public figure to seek punitive damages in a libel action under Alabama law.
When the Times refused and claimed that they were puzzled by the request, Sullivan filed a libel action against the Times and a group of African American ministers mentioned in the ad. A jury in an Alabama state court awarded him $500,000 in damages. The state supreme court affirmed and the Times appealed.
The Supreme Court posed the following Question:
Did the libel law unconstitutionally infringe on the First Amendment's freedom of speech and freedom of press protections?
The Court concluded: To sustain a claim of defamation or libel, the First Amendment requires that the plaintiff show that the defendant knew that a statement was false or was reckless in deciding to publish the information without investigating whether it was accurate.
In the unanimous opinion, the Supreme Court ruled for the Times. When a statement concerns a public figure, the Court held, it is not enough to show that it is false for the press to be liable for libel. Instead, the target of the statement must show that it was made with knowledge of or reckless disregard for its falsity. Justice Brennan used the term "actual malice" to summarize this standard, although he did not intend the usual meaning of a malicious purpose. In libel law, "malice" had meant knowledge or gross recklessness rather than intent, since courts found it difficult to imagine that someone would knowingly disseminate false information without a bad intent.
A lot of issues and conflicting opinions have arisen since Sullivan as to what constitutes a public figure. The term "public figure" is defined to include those who "have assumed roles of special prominence in the affairs of society," or who occupy "positions of such persuasive power and influence that they are deemed public figures for all purposes. Indeed, anyone that is famous will be deemed a public figure. Whether someone is famous is often highly litigated with different results across courts as the extent of one's prominence in society affairs is a very discretionary concept.
In Florida, Employers also have a qualified privilege:
This is known as the employer review qualified privilege. In order to avoid defamation claims, some employers these days refuse to confirm any details about former employees other than their dates of employment, and job position. This is known as a neutral reference and we don't want a former disgruntled employer to be giving false references about a former employee who is simply trying to work and be productive with a new employer. But from a societal perspective, a truthful reference concerning a legitimate issue concerning the former employer, can be valuable. For instance, if, the employer fired the employee for theft, a statement about that to a potential employer might qualify as a statement made to warn others about a harm or danger (i.e., the danger of hiring someone who might steal from you). Because references can provide a societal value, Florida has specifically codified the qualified privilege under Florida Statute 768.095 The statute states "An employer who discloses information about a former or current employee to a prospective employer of the former or current employee, upon request of the prospective employer or of the former or current employee, then such disclosure is immune from civil liability or its consequences unless it is shown by clear and convincing evidence that the information disclosed by the former or current employer was knowingly false or violated any civil right of the former or current employee protected under Florida Statute chapter 760, which are Florida anti-discrimination laws.
Utilizing the statute, the Courts have interpreted the law to create the following additional requirements:
That the Plaintiff Must prove by clear and convincing evidence that any statement made about Plaintiff by the Defendant to any prospective employer was knowingly false, deliberately misleading, or rendered with a malicious purpose.
When a statement is made by an employer regarding an employee's performance it is conditionally privileged and the burden shifts to the plaintiff to establish that the privilege was lost through express malice or improper purpose.
The way I commonly see defamation cases play out is when a former employee applies for a new job. The potential new employer asks the employee who was his previous employer and asks if he can call the prior employer. Regardless of whether the employee gives permission, as part of the hiring process, the prospective new employer may call the prior employer.
Of course, the employee is normally not privy to the information exchanged. Normally, the only knowledge that the employee receives is whether he was hired for the job. If the employee is not hired, and the interview went well, the employee is left with a feeling that the former employer defamed him.
In defamation cases, as with most tort cases or intentional tort cases, the Plaintiff bears the burden to prove all the elements of the case. In the case of a former employer who may have said something negative or adverse about the employee, the employee bears the burden of proof to show, by a preponderance of the evidence the exact false statement which was communicated to the new employer. Normally, an employer who has not hired an employee does not want to be involved in litigation and it will be unusual for the prospective employer to disclose what the previous employer stated.
Next, lets talk about the rise of defamation claims in the Social Media Context. The number one client consult my firm I is nowadays getting are clients seeking advice as to how to address defamatory statements stated by third parties utilizing online boards, utube, facebook and the like.
We begin our discussion with the Federal Communications Decency Act which was passed by congress in 1996. Particularly relevant to us is Section 230 of the Act.
Section 230 of the Communications Decency Act grants interactive online services of all types, including blogs, forums, and listservs, broad immunity from tort liability so long as the information at issue is provided by a third party. The Act makes web sites such as Facebook, Glassdoor and Linked-In, immune from liability for false information which is provided by users. The Act shields the web site from false information which is posted by users of the site. Of course, the actual author of the publication bears personal liability for the information which he or she published, but the actual medium which is used, such as providing a text box, bulleting board, or publication access to the web site, does not place on the web site any responsibility or duty to ascertain whether the information is truthful, or weigh or address any harm which the publication is causing.
Moreover, because of these protections, the web sites have taken a firm stance on not taking anything down unless it violates their own personal policies, or otherwise, unless a Court specifically orders it.
I have gone down that rabbit hole. Let me tell you how that looks like:
I have been retained by clients to cause the removal of false information from the web site. Honestly, for me, it has been an ordeal. First, you can try sending out a letter asking the web site to take it down. I have done that numerous times, and provided evidence of the falsehood of the publication. Most of the times, I have been ignored. Some clients have nonetheless retained me to pursue the matter further, meaning, Carte Blanche to do whatever it takes.
When the letter did not work, the next step was to send a cease and desist letter to the actual person who published the false information. As is often the case with defamation cases, the publication is made out of anger and the author of the defamatory information may be unreasonable and fearless, meaning, not having much to lose. In my experience, it is seldom the case that a cease and desist letter will result in the defamatory content being taken down. Although a cease and desist letter is only required for media defendant, it is best practice to nonetheless give an opportunity to the publisher of the false information to take down the content. Your cease and desist letter to the publisher may very well be Exhibit number 1 to a Judge or Jury.
So, if the cease and desist letter does not work the next step is to file a lawsuit. The lawsuit can be filed wherever the publication was published and caused damages, or where the defendant resides. {This is unique to defamation cases} In web site publications, the publication and distribution of said publication is virtually world-wide. But, where the damages occurred is typically somewhere close to the Plaintiff's location. Of course, you can always have jurisdiction where the defendant resides.
After the lawsuit is served, the Defendant has 20 days to file a responsive pleading. The best you can hope for is to have an attorney make an appearance. This tends to cause reasonable minds to prevail. In defending defamation, the defendant will incur significant attorney fees which usually results in an agreement to remove or correct the wrong information. Other times, an attorney is not involved, and the defendant, pro se will start filing stuff and does not follow the rules of procedures. These type of pro se defendants are difficult to deal with. Trial Courts tend to give a lot of procedural leeway and many opportunities to fix their discovery mistakes, including missing depositions, failing to provide discovery, and causing needless hearings and delays. A generous Court and a malevolent defendant could drag the case for years and cost your client tens of thousands to get to a judgment or to be successful in achieving injunctive relieve. The third possibility is when defendant ignores the lawsuit, and after a trial on damages, you finally achieve your judgment with a Florida order that says that the information must be taken down.
So, after the Judgment is achieved, the legal battles may just be beginning. Indeed, your hard earned judgment is only against the individual author. The next step is to sue the actual web site to have jurisdiction over the web site. In the case of Facebook, the lawsuit needs to be filed in California, including a count to domesticate your Judgement. If you are a Florida attorney and lack a license to practice law in California, like me, you will have to associate yourself with a California attorney to either handle the California proceedings or have you admitted, under their supervision, as pro hoc vice.
The litigation battles with some web sites will be intense. My experience with these popular web sites is that they stubbornly defend these cases so as not to set precedence that they are willing to entertain being forced to take down the content or open up the flood gates. Challenges will be made that a Florida Judge cannot tell a California company to take something down. Challenges will be made based on California public policy and State first amendment rights, and you could be relitigating certain aspects of defamation law and rearguing some of your facts to California law principals.
Even if you prevail on that, you can expect an adverse order against the web site to be appealed. All the while your client is calling, upset at the extraordinary expense he has incurred, and more importantly, the many years it is taking to achieve a result. Indeed, all these years, the false publication has continued to be published and may even be moot by this time.
The purpose in presenting all this is to give you a flavor of the practical consequences of pursuing defamation claims against individuals. As you can see, in addition to overcoming numerous legal issues, factual nuances, and contradictory evidence that is inherent in defamation cases, there is a practical element that should not be ignored, and, at a minimum, client expectations should be managed, and the practical possibilities should be fully discussed with the client prior to committing to full action.
In addition to the practical consideration we have just discussed, web site immunity cases carry another burden of complexity. This is known as the "mixed content web site cases." Sometimes, web sites manage the content by editing the content, allowing others to edit the content or add to the content, or otherwise shape the content by submission forms or drop downs. An example of this is Wikipedia where they allow users to publish content, and then other users, or Wikipedia themselves, edits or adds content. When such is the case, the Courts, as a matter of law, are left to determine whether Wikipedia or similar web sites have interfered with the author's publication enough to take the Web site outside of the civil protections afforded by the Communication Decency Act. Right now, we are seeing this battle taking place in Congress and in the media. On the one hand, some of the public demands accountability for false information which is disseminated through popular web sites. On the other hand, who is the arbiter of truth? The individual decisions these companies are making vary from company to company, but, if the web site company begins to interfere with the content, then the web site company may be waiving its immunity under the Communication Decency Act. This area of the law is rapidly evolving, but as of the date that this lecture was given, I am unaware of any Florida appellate court rulings which provide further guidance.
There is also a criminal law Florida Statute which makes defamation a crime.
Florida Statute 836.01 state: Any person convicted of the publication of a libel shall be guilty of a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083.
I have not seen a criminal case that has utilized this statute. However, there are many practical uses of the statute in Civil Court including when the time comes to plead punitive damages. With the right set of facts, Florida Statute 836.01 can be used to meet the outrageousness elements when it comes time to move to add punitive damages to a complaint. Other uses include cases which include counts for conspiracy, extortion of the elderly and tortious interference. But if you think that an individual can simply call the police and have the police investigate a defamation case, good luck. Most of the time (if not all of the time), the police will point you to the Civil Court House.
I came close once when I represented a motel. A group of young adults where going up the east coast of Florida, staying at beach motels. After they stayed at the hotel, they would go to the owner or manager of the motels where they would tell manager that their room had roaches and that if they wouldn't get comped, they would write negative reviews. When that happened to my client, my client refused, and in fact, 5 negative reviews went up.
Not willing to undergo the financial feasibility of pursuing a civil defamation per se case against the five individuals, my client opted to report the crime to the police utilizing this statute. Because these individuals were doing this to multiple hotel owners, I thought it had a chance. Unfortunately, police and prosecutor refused to press charges because it would be difficult to prove, beyond reasonable doubt that there were no roach infestations in any of the rooms.
The take away from this is that even though there is a criminal statute for defamation, the application of it is impractical, but it may provide side benefits in civil defamation arguments which may arise as part of the civil process.
Yet another area of Florida Defamation Law is the Media Defendant:
Under Florida's defamation law, a prospective plaintiff is required to give a media defendant notice five days before initiating a civil action. This is codified in Florida Statute 770.01. The notice must specify the alleged false and defamatory statements contained in the article or broadcast. Id. Further, section 770.02, limits the amount of damages a plaintiff may recover where: (1) the statements were published in good faith; (2) the statements were false due to an honest mistake of facts; (3) there were reasonable grounds for believing the statements were true; and (4) a full and fair correction, apology, or retraction was published or broadcast within a specific time period. The Courts have interpreted these conditions to be necessary protections to ensure the delicate balance between preventing tortious injury resulting from defamatory statements and protecting the constitutional right to free speech.
The notice requirement is a condition precedent, meaning, failure to give the notice results in not being able to bring forth the claim. Further, Courts have given it a very strict construction including the fact that it cannot be cured after the lawsuit is filed. Meaning, even if the case is dismissed, and then, a proper notice is given, the case cannot be refiled.
A lot of litigation has also arisen as to what constitutes a media defendant. Of course, Newspaper publications, tv channels, and news commentary applies. Less obvious is what I like to call as quasi-media, such as bloggers, youtube personal channels, Facebook recurring postings, and other forms of internet media. Currently Courts are tending to rule that most people who disseminate information on a regular basis in any kind of structured format, is entitled to the media pre-notice requirement.
If a Court finds that the defendant is a media defendant, then, if Plaintiff failed to provide the notice letter, Defendant wins.
If the Court finds that the notice requirements of F.S. 770 have been met, then we need to see if a fair correction or retraction was published utilizing the same publication medium. For instance, if the defamatory publication was originally published in a newspaper, then the retraction must occur in the publication, in similar format. Taking it one level deeper, if the publication occurred in the Sunday circulation which has a broader audience, the retraction should also be published with the broader Sunday audience.
However, simply because a retraction occurs, it does not eliminate the liability of the Media defendant. The benefit to the defendant is simply the types of damages which would thereafter be recoverable. Punitive damages are eliminated, damages which can't be quantified are eliminated. But, the Plaintiff can still proceed with its defamation claims and will need to prove actual damages in the same manner in which damages in per quod defamation cases need to be proven.
Other things to consider Considerations:
One is that Normally not covered by insurance, since it is an intentional tort. Also, most defamation occurs between individuals, so collecting a Judgment is oftentimes very difficult so your client should be made aware of those issues prior to significantly investing in the claim.
Also, a practice recommendation. When you decide to take a defamation case which will be litigated, look at the standard Jury instructions for defamation cases. Most experienced trial attorneys will be very familiar with the likely jury instructions the case may have. In the lecture materials, I have provided the Florida Standard Jury Instructions for defamation. This gives you a legal roadmap to your case. Of course, prior to trial the jury instructions have to be tailored to the specifics of the case, and, citing applicable case law, modify certain aspects of the standard defamation jury instructions to suit the specifics of the case.
In Conclusion, from this lecture, you should have been able to get a flavor as to the complexities of defamation, and help you identify the main issues that arise in defamation cases. Defamation law and legal interpretations are constantly changing, and this lecture is not intended to substitute sound legal advice based on the particular facts that are presented.
All the topics which I have covered today are also covered in the written materials of this lecture, and the materials reference the landmark cases which should be known to any attorney who chooses to practice in the area of Florida Defamation Law.
Well that concludes this lecture. If anyone taking this lecture has a Florida Defamation question, feel free to reach out to me via email: arcadier@melbournelegalteam.com or by phone: 321-953-5998.


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Danbury Dancer Earns Regional Titles and Qualifies for the World Championships
Written by Ashurst Academy of Irish Dance
The New England Regional Irish Dance Championships, also known as the "Oireachtas," was recently held in Hartford, CT the weekend before Thanksgiving. It is the area's most prestigious event bringing in top dancers from schools in Connecticut, Rhode Island, Massachusetts, New Hampshire, Vermont and Maine and competitions have as many as 100 competitors.
At the event, local dancers, representing the Ashurst Academy of Irish Dance, were proud to earn a World Championship qualifying position, 3 National Championship qualifying positions, as well as numerous additional podium placements and medals including 3 regional champions: Piper Normand of Canton, Evelyn Anderson of Danbury and Evelyn Savage of Brookfield.
The World Irish Dance Championships, which is the Olympics of Irish dance, will be held in Montreal, Canada next April and the academy is proud to have champion Piper Normand of Canton qualified to compete. Normand also qualified at the event for the North American Championships to be held in Nashville this July along with medalists Caroline Morneau of Bethel and Trey Ruffles of Danbury.
Additional medals were earned in solos, traditional sets and teams by Emily Delp of Southbury, Deirdre Smith of Newtown, Natalie Anderson of Danbury, Riley McGrath of Danbury, Katie Ruszczyk of Newtown, Amelia Hogrefe of Southbury, Vivian Eaton of Newtown, Samantha Erdman of Derby, Addison Bertholf of Oxford, Alexa Sandor of Southbury, Kiley Foster of Brookfield, Lily Sandor of Southbury, Scarlett Tichy of Newtown, Olivia Lanza of Oxford, Britta Petersen of Newtown, Sofia McKirdy of Newtown and Kylee Dugan of Washington.
The Ashurst Academy of Irish Dance is directed by former Riverdance and Lord of the Dance stars Craig Ashurst and Christina Dolzall-Ashurst of Newtown. Both were highly successful competitive dancers themselves collectively holding many regional, national and international titles.
The Ashurst Academy of Irish Dance is currently enrolling a new beginner program beginning in January 2023. For information, visit: http://www.ashurstirishdance.com or call (203) 928-0689.

redpajama_set_name: RedPajamaCommonCrawl


The canapés were divine, the room was grand and the table centrepieces were - erm, how can we describe them? - Edwardian busts complete with Carmen Miranda-style fruit hair. It could only be the Fortnum & Mason Food and Drink Awards! Industry writers, publishers and broadcasting superstars breezed along to find out the best movers, shakers and eaters, nibble on chocolate-dipped strawberries and chat about recipes with Tom Parker Bowles and Michel Roux Jr. Then Claudia Winkleman stepped up on stage to announce the winners and - hurrah! - Mary Berry and Paul Hollywood walked away with the TV Personality Award. Well, Paul wasn't in attendance so Mary soaked up all the glory instead. A very good night indeed.


Our selection of exterior shutter hardware gives you further opportunities to customize your shutter design. You can install it for function, decoration, or both! With our wide range of exterior shutter hardware, you have a variety of options to express your style. In addition, you can choose between wrought iron and stainless steel pieces. We also offer historical, European, and whimsical styles, enabling you to find the perfect fit for your home.
Hinges transform your shutters from simply beautiful to functionally beautiful. They are available in several lengths, offsets, and constructions to work with every window of your home.
Traditionally, a pintel is required along with a hinge for proper installation. They are available in a variety of weights and widths to work with the hinge that best fits your window's needs.
Shutter locks and pull rings can enhance your shutters' functionality, their aesthetic, or both. These elegant details pull and keep your shutters closed and add an authentic style to your exterior.
Tiebacks, also called shutter dogs, are available in both historical and whimsical designs. They hold your shutters in place and offer a great way to express your style.
Faux strap hinges, jamb hinges, and tiebacks give your shutters the appearance of authentic, fully functional shutters, even if they are fixed-mounted to your home.
The hardware for our Bermuda (also called Bahama) shutters brings function to the shutters' breezy appearance – giving them the ability to provide shade, air flow control, and privacy.
No detail is too small. Every capping, fastener, anchor, and sill-mounting kit is here to make sure you have what you need to properly install your new Timberlane exterior shutters.
Our European Hardware Collection includes a variety of hardware pieces to give your home added curb appeal. Accent your refined taste by adding these cosmopolitan details to your home exterior.


I use my phone a lot during the day to whiz through my social media channels and to check my email (and occasionally make calls and send texts) and by 3pm it is usually gasping for breath, ready to give up the ghost on battery life. If I'm lucky I can usually plug my phone into a laptop somewhere and give it a bit of a boost but that's not always possible so I am a huge fan of portable battery chargers like the RAVPower Luster.
This is a dual power bank and torch/flashlight with three modes (high beam, low beam and strobe). The fully charged battery pack will enable you to run your phone for approximately six hours and is true plug and play. The power bank will automatically detect when your device is fully charge and put itself in standby mode to avoid over-charging. If you disconnect the power bank from the device it will wait about 5 seconds and (again) automatically switch to standby mode.
Recommendations: I would like a charge indicator on the power bank simply to tell me how much "juice" is left in it and to remind me to recharge it.
The spec says that it is the size of a lipstick but I'd suggest more the size of a mascara or a roll of coins (12cm in length) and it weighs just under 3 ounces. It fits perfectly into your pocket or bag and is available in five colours (as you can see from the picture of the box - blue, pink, black, gold, silver). It has been a handy piece of kit on a few occasions over the past few weeks.
RRP is £39.99 but, at the time of writing, you could purchase it for under £15 on Amazon.
*The Apple 30-pin charging cable is not included however you can use any original 30-pin to USB cable provided by Apple. Also if your mobile devices do not have a Micro USB port then it is recommended that you use the original charging cables that came with your mobile device.


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Getting tulips right
In West Michigan this time of year, especially in the Holland area, it's hard to avoid the hype around the tulip-- and for good reason. These bulbous members of the lily family are an annual reminder that spring has sprung; they thrive in areas with dry summers and cold winters, so West Michigan is a great place to enjoy them.
If you're interested in growing tulips, or even if you've had them in your yard for years, we've got some tips for getting the most from these beautiful perennials.
For planting:
Nature never intended for bulbs to hang out above-ground, so plant them the same year you get them.
Plant tulip bulbs in the fall, six to eight weeks before a hard frost is expected and when soils are below 60 degrees F. In West Michigan, this means October to early November.
Tulips dislike excessive moisture. Ideally, the soil is well-drained, neutral to slightly acidic, fertile, and dry or sandy.
Rainy summers, irrigation systems, and wet soil are death to tulips. Never deliberately water a bulb bed. Wet soil will lead to fungus and disease and rot. Add sand to the soil when you plant to encourage quick drainage.
Space bulbs 4 to 6 inches apart, so choose an appropriate plot size.
To deter mice and moles—if they have been a problem—put holly or any other thorny leaves in the planting holes. Some gardeners use kitty litter or crushed gravel.
If ravenous rodents are a real problem, you may need to take stronger measures, such as planting bulbs in a cage of wire.
Plant bulbs deep—at least 8 inches, measuring from the base of the bulb. But when you're digging your bulb's hole, don't stop at 8 inches-- digging even deeper to loosen the soil and allow for drainage. Remember, the bigger the bulb, the deeper the hole it needs.
Set the bulb in the hole with the pointy end up. Cover with soil and press soil firmly.
Water bulbs right after planting. Bulbs need water to trigger growth. But then, lay off the water.
If you're planning to raise perennial tulips, feed them when you plant them in the fall. Bulbs are their own complete storage system and contain all of the nutrients they need for one year.
Caring for your bulbs and tulips:
Water tulip bulbs only during dry spells in the fall; otherwise, do not water.
Add compost to the bulbs and flowers every year (fall & spring).
Deadhead tulips after flowering.
Allow the foliage to go yellow for about six weeks after flowering before cutting it down.
Replant the largest bulbs; smaller bulbs may be grown in containers in a bulb frame, in mix of equal parts loam, leaf mold, and sharp sand.
Every fall the City of Holland plants over 300,000 tulip bulbs, which in the spring will welcome visitors to Tulip Time. Once the blooms are done, the city invites people to be part of their annual "Tulip Dig." You bring a shovel and buckets and help yourself. Keep an eye open at the City of Holland's website for more info later in the spring.
Tulips don't last long, but they are a welcome flash of color after a cold gray winter. Follow these tips and yours will be the envy of the neighborhood for years to come.
Source: Farmer's Almanac. Read more on raising tulips here.
The benefits of using vermicompost
Vermicompost with red wiggler worms
Vermicompost-- or compost made by worms-- is not only a great alternative to chemical fertilizers, it's also a better alternative to traditional compost. We've been using it in our yard and garden, and selling it to our customers, for years with amazing results.
But what are the actual benefits of vermicompost-- what's the science behind it? We've laid it out for you below:
What is vermicompost? Vermicompost-- or worm compost or worm casting or worm poop-- is what you get after worms consume organic matter and excrete it. As food passes through their digestive tract, worms secrete chemicals that break down organic matter into sustainable nutrition. These chemicals, excreted with their castings, comprise vermicompost, which improves soil texture, structure and aeration. From the Latin "vermi," which means worm, vermicompost offers nutrients that are immediately available to plants. It can be applied as mulch, incorporated as a component in potting mixes or brewed in water as a compost tea liquid fertilizer.
Soil enrichment. University studies have shown vermicompost to actually add nutrients to the soil, which are immediately available for plants. This makes it superior to traditional "hot" composted material, and it makes it a nice organic alternative to chemical fertilizers. Purdue University reports that earthworms leave soil 5 to 11 percent richer in the essential plant nutrients of nitrogen, phosphorus and potassium than when they first ingest it. As an organic fertilizer, vermicompost is a substitute for synthetic fertilizer in soil-enriched vegetable transplant potting mixes. As a soil conditioner, vermicompost is superior to traditional compost for its ability to improve soil structure and increase its water-holding capacity, according to the University of California's Project Compost.
It increases crop yields and plant growth. Gardeners and organic farmers like using non-synthetic amendments and fertilizers for the benefits it provides to the environment. But when these fertilizers also produce faster plant growth and higher crop yields, it's an added bonus, says Clive Edwards of the Ohio State University Extension. Edwards' collaborative field crop experiments on tomatoes, peppers and strawberries showed that plants fertilized with organic vermicompost significantly outperformed the same crops fertilized with inorganic, synthetic chemicals. Edwards' research revealed vermicompost tea fertilizer yielded dramatic plant growth rates and crop yields of up to 50 percent.
(Source: SFGate Home Guides) Read more about the benefits of vermicompost here.
If you'd like to try vermicompost for yourself and see the amazing results in your yard and garden, check out the Good Sweet Earth product page.
March gardening?
How do you know when it's time to start planting? Our weather has been more spring-like here in Michigan than wintery and if you are anything like me you have your seeds ready to go.
Is it too early though? A major deciding factor is what you want to plant. It is by far too early for summer crops like tomatoes, peppers, and eggplants, which shouldn't hit the ground until mid- to late-May. But for the spring crops*...it depends.
For those marvelous spring crops that we all love to plant as soon as the ground thaws and the sun kisses the air? The deciding factor is the soil-- the soil's moisture and the soil's temperature.
First, grab a handful of soil and squeeze it into a ball. If the soil becomes tight and holds its shape too well, then it's too wet to plant. Rototilling soil this wet or even walking on your crop rows at this point will compact things unnecessarily. However, if your handful of soil becomes a light ball that breaks apart easily, your soil's passed the first test of spring.
The next consideration is your soil temperature. Cool weather vegetables need the soil to be at least 35 degrees for your seeds to germinate. An inexpensive addition to your gardening toolbox is a soil thermometer. A good strategy when you are unsure if the temperatures will remain warm enough is to plant only a section of your crops, then wait a week and plant more. This way, if temps drop too far, your entire crop won't be lost. Staggering your sowing also spreads out your harvest a bit-- an added bonus.
Now before you put your seeds in the ground don't forget to prepare your soil. Ready to purchase your Living Worm Compost? Click here. It's never too early or too cold to stock up on compost. Not sure how much you need? Email me at Corey@goodsweetearth.com and I'd be happy to help.
(*For the record, these are really the only things you should be putting in the ground in the early spring: spring cabbage, garlic-cloves, kale, onions, peas, radishes, shallots, spinach and turnips. Those are your spring crops that are able to handle a little extra cold.)
Corey Veldheer is the owner of Good Sweet Earth and has been Master Gardener Certified through Michigan State University.


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APT James
The APT James, the newest addition to the passenger ferry fleet on the inter-island sea-bridge. This new passenger vessel successfully completed its maiden voyage and was officially commissioned on Thursday 21st January 2021. The vessel soon joined the inter-island ferry service and completed its first commercial voyage on Monday 1st February, 2021.
The Cabo Star
On July 24, 2017 the Cabo Star was commissioned into service. The Cabo Star is a conventional Roll-on/Roll-off vessel designated to transport cargo between the islands. The vessel was built in 1988 and is approximately 158m in length with a draft of 7.3m. The voyage takes approximately 6-7 hours with the vessel departing Port of Spain, Mondays to Fridays at 2:00pm and Scarborough at 11:00pm. On Sundays, the vessel departs Port of Spain at 12:30pm and Scarborough at 11:00pm. There are no scheduled sailings on Saturdays and public holidays. The Cabo Star can accommodate 130 passengers (crew included) and 300 vehicles.
The T&T Spirit
On 2007 July 20, the T&T Spirit was commissioned into service. The Incat 060 vessel was converted from a military-type configuration to a passenger-type design to service the inter-island bridge. The vessel is 97.22 metres in length with speed of 30-40 knots. It can accommodate 865 passengers and 180 cars. On board facilities include a cafeteria, a bar and a VIP Lounge.
The Galleons Passage
On 2018 October 08, the Galleons Passage was commissioned into service. The Galleons Passage is a Catamaran RoRo passenger ferry, built according to Lloyd's Register Rules and Regulations for Classification of Special Service Craft. The vessel can accommodate 400 passengers and 60 cars. On board facilities include a cafeteria, a bar and a VIP Lounge.


I downloaded a copy of Audacity audio processing program. It appears that I have also downloaded unwanted Adware.
Whenever I run IE I get a warning from Kaspersky.
I choose the "delete" option for each of the three files, but the warning returns next time I start IE. How do I clean out the Adware altogether?
Adware.JS.Znooser is an adware infection that will sneaks into your computer without your knowledge and permission via infected software, spam emails, torrent files, or corrupt websites. This adware has ability to affect Windows 10, Windows 8.1, Windows 7, and Windows Vista. Once inside, it will generate a variety of deceptive and nasty advertisements to your computer.
Some antivirus programs also recognize it as a Trojan infection that may bring more damages to your system and lead to a serious of troubles. Here are some examples.
It can download more threats to your computer and slow your computer.


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The series is scheduled to start in 2009. Probably February.
How We Made Our Face Recognizer 25x Faster
"This is a war story from my real day job. I work at a start-up company
in Pittsburgh that does face detection, tracking, and recognition
software. This particular problem involved optimization of the face
recognizer."
Good reading for concurrent programmers and this was, surprisingly, on Digg front page.
Dustin Kirkland on Encrypted Private Directories in Ubuntu 8.10
Interview with Dustin Kirkland | The Fridge
"Ideally (at least in my mind), each user's entire home directory would be encrypted using a key that's unique to them. It would be mounted when the user logs in, and unmounted when the user logs out. That was my original proposal for Intrepid, but this was deemed a bit too ambitious to accomplish within a single release. The compromise was to provide a single encrypted location inside of each user's home directory, ~/Private."
"Encrypted ~/Private directories in Ubuntu use eCryptfs as the
cryptographic filesystem scheme. eCryptfs first appeared as a
filesystem module in the Linux kernel in November of 2006, in the
2.6.19 release. eCryptfs uses the vetted cryptographic algorithms in
the Linux kernel (AES, by default in Ubuntu), as well as the kernel
keyring for per-user key management. Thus, I would argue that eCryptfs
is built on top of established technologies."
Interesting read. I can't wait to try this one out. I hate havi…
WSO2 Mashup Server Screencast #3: Service Composition
Jonathan looks at service composition in this 3rd installment of a planned series of screencasts.
Facebook Game Developer Playfish Closes $17M Series B Round
"Playfish, the Facebook game developer that has four apps in the top 10 gaming apps on the site, closed a $17 million Series B round led by Accel Partners and Index Ventures."Although Vasanth Sridharan thinks this is a bit bubble like, I see an interesting revenue model here. First of all how do they, the game developers make money and make sure it keeps coming?
They have virtual goods to be bought by players (same approach seen in other games like Mob Wars)In case Facebook decides to pull a quick one, like re-designing the site giving less prominence to apps, they have partnered with Google's Adsense for Games. Pretty good move, that ensures they get more eyeballs no matter whatNow.. How can Facebook have a piece of this action?
Remember the 'Hello World' screen-cast I posted a few days back? Well, now it's time to move on and get some real work done from the Mashup Server. I'm sure most of you are familiar with a little technique called screen scraping.Do I have your attention now? Good. In this screen-cast, Jonathan explains how to scrape data from all those awesome sites.
You see most sites today are late to the party when it comes to developer APIs. But they do have great content nevertheless. Wouldn't it be great if we can somehow harvest this data and use it in our mashups? The Mashup Server has a nice little scraping function, which allows you to;
Harvest data off web pages
Fill and submit forms in sites and click links, which in turn allows you to
perform navigation through pages to get to the 'really' interesting areas
So have a look and start scraping. As a pre-requisite, I would recommend you install Firebug, a great Firefox extension that will, among many other things, allow…
Whitepaper: Estimating the Total Development Cost of a Linux Distribution · October 2008
"we estimate that it would take approximately $10.8 billion to build the Fedora 9 distribution in today's dollars, with today's software development costs. Additionally, it would take $1.4 billion to develop the Linux kernel alone. This paper outlines our technique and highlights the latest costs of developing Linux." According to this paper, the Linux ecosystem is worth $25 billion. As far as I know, Linux market share, both Desktop and Server, amounts to around 1.77%. But adoption is showing and upward trend with some optimistic reports predicting it to be 20% by the end of 2008. Therefore, even though the paper is sponsored by the Linux Foundation, the value does sound right. Note that they are also talking about the complete distribution (the kernel alone is worth $1.4 billion), which often includes the Openoffice productivity suite, an E-Mail Client and the Firefox browser.
Map of Social Networks Popularity Around The World | the Oxyweb Blog
According to this,
Sri Lankans love facebook in contrast to rest of the sub continent, who seem to be hooked on... Orkut?No one outside USA seems to know MySpace
Russians love v kontakte (I always wondered about the lack of Russians on FB)Good data for marketers using Social Networks as a channel. Use the ideal network for your target audience.
Basic concepts of REST architectureConsuming public REST-style services from your PHP applicationsConsuming RESTful web services, such as those from leading APIs such as Flickr, and Yahoo Web SearchMaking your own PHP applications accessible to other applications through a RESTful APIREST support in the popular Zend frameworkDebugging RESTful services and clientsA case study of designing a RESTful PHP service from the ground up, and designing clients to consume the service"This book targets PHP developers who want to build or make use of
Samisa is the chief architect behind Apache Axis2/C Web Services engine and used to lead WSO2's web services framework for PHP before taking up his new role as our Dire…
Channa's Blog: How to write Mashups
"The Quick Start Guide assumes that the reader just knows he or she wants to create a Mashup and maybe something about JavaScript; nothing much else."That pretty much sums it up. But I would like to add some more. Channa introduces you to some of the cool tools we've been working on.
The Mashup Editor with a skeleton code generator, gives you a running 'Hello World' mashup in just seconds, with a UI AND a Google GadgetThe Javascript Stub Generator allows you to create a stub (or wrapper) to any external SOAP Web Service, which you can 'include' in your mashup and useThe Scraping Assistant will help you generate XML instructions to scrape web pagesTake these tools for a spin and suggest improvements you would like to see in them. If you run into problems get help form the developers and users who already use these tools.
How Key is Governance to SOA? Larry Fulton Explains
How Key is Governance to SOA? Larry Fulton Explains - ebizQ's Business Agility Watch - ebizQ
"Back when people talked about distributed objects, and components and things, the one thing that was missing was a really well reasoned discussion across the industry of well, how do we manage these things? And how do we ensure that we're not just building bits and pieces but these pieces are doing what they need to do and that they are serving the business?"Intersting podcast. The transcript is available as well.
Nah.. it's not the javascript library it's the local metal band. Suran (also their vocalist) posted some clips from the gig.
1.21 GIGAWATTS!!!: Prototype at Bring Your Own Nuns
Enjooy!!
I'm sure you have all seen how people on the internet (mostly American) make fun of Sarah Palin for pronouncing Nuclear wrong. But I have seen others do the same mistake too.
Forget George Bush, I've heard Lawrence Lessig do it and he's an Academic. I listened to him when he visited Sri Lanka in 2006 and gave a speech at FOSS-ed for hackers one of the local Open Source events. Not that this takes away the respect I have for the good professor, who came up with Creative Commons, but it does get a tad irritating at times.
I thought it was one of those American English things, you know like using learned instead of learnt, Math instead of Maths, spelling centre as center, color instead of colour etc etc. Typical American vs British English stuff. But it looks like I was wrong. I guess they agree that Aluminium isn't pronounced as aluminum either?
Both weeks were dominated by Business Communication lectures. This was due to Statistics and Accounting lecturers being out of country. I enjoy BC lectures mostly thanks to the interactivity and interesting discussions that come up during group presentation etc.
The Johari Window is something we discussed out of syllabus, yet can come handy when understanding your team members and yourself. Something I always found useful before learning this is Maslow's hierarchy of needs, which I learnt as an undergraduate. The Johari Window is a bit complex comparatively and usually requires information from many people to complete, whereas Maslow's Hierachy is pretty simple.
When reading up on this, I found that while a Johari Wondow concentrated on positive personality traits, a A Nohari window is the inversion of the Johari window, and is a collection of negative personality traits instead of positive.
I also cam across this cool online tool that helps one to create a Johari Window for him…
BBC SPORT | Motorsport | Formula One | FIA wants French GP clarification
The 2009 French GP was cancelled after the French Motorsports Federation (FFSA) withdrew its financing.
Bad news for all F1 fans. The good news is that Disneyland, Paris is being considered as an option instead of the rural Magny-Cours for future events.
Jonathan has done an excellent introduction to the WSO2 Mashup Server. If you are a 'Level 0' Mashupper yearning to start writing your own Mashups, this screen cast is a must view.BTW, you ain't seen nothing yet. I had a sneak-peak at some of his other screen casts and those were pretty awesome!!
"This is how this works. You write a few e-mails, and choose the recipients. These emails are encrypted with military-grade algorithms, so you can be sure that no-one except the intended recipient will ever read them. Your switch will email you every so often, asking you to show that you are fine by clicking a link. If something were to... happen... to you, your switch would then send the emails you wrote to the recipients you specified. Sort of an "electronic will", one could say."
So there. If you are an average guy with a will to be published or a message to be sent to your loved ones when the final curtain comes down or if you are one of those spy/whistle-blower types going to a meeting with your rival from which you might never return; Let Dead Man's Switch be your insurance.
'Free lunch' and open-source support | The Open Road - The Business and Politics of Open Source by Matt Asay - CNET News
"I recently discovered this when a large, global system integrator (SI) deployed Alfresco Labs, our free and unsupported product, for a large client in Europe. The SI wasn't a partner of ours, and as the client soon learned when its deployment stumbled, the SI wasn't capable of providing enterprise-class support on the product. Yes, it knew the product well enough to deploy it and get paid over $50 million for its trouble, but when the deployment hit a glitch, guess to whom the SI came crawling for help?"
Matt Asay (Alfresco) raises some valid points in this post for Enterprises deploying Open Source software via a System Integrator (SI). Having previously worked for a global SI and now working for an Open Source Middleware company, I have to agree.
In his scenario, Asay describes how an SI failed to buy support spending just $50,000 (as part …
AJAX in the Cloud: Save Your Company a Bundle with Your RIA Strategy!
"AJAX apps need to talk to an intermediate server that acts as a proxy between the web client and the database. This means that the AJAX developer has to develop lots of server-side code that coordinates between the proxy and the database. In addition to requiring precious development cycles, the proxy is a performance bottleneck."
I have to respectfully disagree. If you use a solution such as WSO2 Data Services (Apache 2.0 licensed, Free and Open Source software), you would save a lot of trouble. It's just a matter of writing the correct SQL or Stored Procedure and the Data Services solution will expose your result set as a service. In addition, you can configure security and other QoS parameters for your data service.
Bottom line? No server side code, absolute minimum number of development cycles and reduced worry on performance issues (since the solution is tuned by its developers).
Enterprise Mashups among the Top 10 Strategic Technologies for 2009
Gartner Identifies the Top 10 Strategic Technologies for 2009 - MarketWatch
Enterprise Mashups is among Virtualization, Cloud Computing and Web Oriented Architecture in Gartner's list of strategic technologies for 2009. For the past few months, I have been developing a bunch Mashups for our marketing team using the WSO2 Mashup Server. In summary, these Mashups bring together statistics harvested from various sources and present a unified view, which helps them in their decision making.
The most important aspect is the the implementation time, which is in weeks rather than months. The amount of flexibility when you want to mix data up is amazing. In my point of view, Enterprise adoption will involve at least 2 stages. The first stage would be exposing data you want people to work with as services (in the WSO2 Mashup Server I do it mainly via Data Services). This might take a bit of time and expertise. Once you have these services up and running, any user familiar with a bit of javasc…
Top 10 Best Guitar Players of All Time | Top 10 Video Lists
People were complaining about the lack of wikipedia links on that post. So here goes..
Jimi HendrixDuane AllmanB. B. KingEric ClaptonRobert JohnsonChuck BerryStevie Ray VaughanRy CooderJimmy PageKeith Richards
Here's something promising for the Javascript RIA developer, who works constantly with SOAP/REST Web Services as back-ends and is also in touch with his inner GWT :)
SOAFaces allows GWT developers to bring SOA and RIA together. It also gets rid of the RPC involvement, which is a negative when ocnsidering GWT for realworld applications.
"Specifically, the goals of the SOAFaces project include the following: No need to write GWT RPC code anymore. Use the UniversalClient
API to talk with POJO services that are packaged in your application
server and/or talk with Mule accessible services/endpoints all across
your enterprise and internet. Your GWT application will have convenient
access to messaging services (SOAP, JMS, ESB ...etc) that can return
JavaBeans or JSON objects back to the GWT client. All marshaling is
handled by the framework. A framework for building SOA GUI
applications using modular components. Build anything from a simple
AJAX type applet all the way to a full blown web app…
An interesting presentation I came across today with some really good tips to consider when putting together slides.
Death by PowerPoint View SlideShare presentation or Upload your own. (tags: tipspowerpoint)
How to run a Southwest Airlines Auto Checkin Mashup from your computer
If you are a regular reader, you would know about the Southwest auto check-in mashup and how Southwest decided to use a 'cease and desist' type threat to get it out of circulation. The threat worked, mainly because WSO2 is a reputed company and they were running the mashup as a 'demo'. Not to make money from it.
But I say they can't prevent people running it from their personal computers. Here's a little how-to.
Download the Free and Open Source WSO2 Mashup Server (A Windows installer and a .zip file are available. It's a Java program so you need a Java version 1.5 or higher installed too)
Install it and run the server as described in the user guideGotohttps://localhost:7443/ and give a username for the admin user
Download the Southwest Auto Check-in Mashup and extract the zipYou will have 2 .js files (alertme.js and southwestAutoCheckin.js) and a folder named southwestAutoCheckin.resourcesCopy those files and folder to [your-mashup-server-installation-director…
Southwest airlines called. They want our Mashup offline ...
Apparently Jonathan's recent Mashup on auto reserving a good seat at Southwest airlines has raised a few alarms there. Then again, this is the downside of Scraping web content. Scraping may violate the Terms of Use of a site. I guess it's a learning experience and we have deleted the Mashup from our mooshup.com community site.
Neel Kashkari has been selected as the head of US Treasury's new Office of Financial Stability making headlines there and in the old country. He'll be managing the $700bn bailout plan in the coming months. At 35, he has already been an Engineer at NASA then a VP at Goldman, Sachs.
... and I hear his parents are still unhappy and think he can do better ;)
Narcissistic people most likely to emerge as leaders according to a recent research.
"The researchers found similar results in two separate studies
involving college students, and one involving business managers in an
MBA program."
Interesting read ...
In a recent blog post, Jonathan explains how to put together an iGoogle compatible gadget for your Mashup. I like his concise explanation of what a gadget is ...
"A widget or gadget is a little program, usually with a cute and compact UI, that runs inside a widget engine. The widget engine generally has the characteristic that a number of widgets can be viewed at once, allowing a user to construct their own digital dashboard of relevant information sources. There are a number of widget technologies under various names – gadgets, widgets, portlets. Some examples of widget engine include the Google Desktop, iGoogle, Windows Vista Sidebar, Windows Live widgets, Yahoo! Widgets, Apple's Macintosh Dashboard, and lots more."
Then, he follows the previous post with his latest (and apparently very successful) experiment on making an early, automated reservation at Soutwest Airlines using a Mashup.
"This time I successfully checked in online within 5 minutes of the opening of on…
Warren Buffet on the Crisis, Bailout and Related Issues
He makes quite a few analogies. I loved the one on using resuscitation. Basically what he says is that, this isn't the time to blame the patient for not exercising or not coming to regular checkups or being greedy. This isn't the time to argue on where to place the resuscitation device, whether it should be more to the left or to the right. We just need to resuscitate the patient and try to save his life.
He also talks about accounting standards and practices towards the end too. A lot to learn from the "Oracle of Omaha" . The best 55 minutes of this week so far.
It was 17 years ago on the 5th of October that someone named Linus Benedict Torvalds posted this to comp.os.minix board. The rest is history.
European leaders agree to £12bn financial crisis rescue package - Telegraph
"The plan to set up a small businesses fund across Europe was supported by French president Nicolas Sarkozy, German chancellor Angela Merkel and Italian prime minister Silvio Berlusconi at an emergency European Union summit in Paris"
Also from the article, these quotes from British Prime Minister Mr. Gordon Brown ...
"I want the message to go out from this meeting today that no sound, solvent bank should be allowed to fail through lack of liquidity. That is why we have taken action in Britain yesterday to extend the liquidity that is available to the banking system. That is why the European Central Bank has done likewise.
"That is why also we must take the action necessary to sort out whatever failings exist in the system. Every country represented here today wants to do whatever is necessary to ensure the stability of the system and to ensure the safety of hard-working families and businesses."
Amen to …
Things to ponder ...
Where?: Lecture; Business Communication
What?: "During oral communication approximately 30% of information is lot in each transmission" and "Studies show that employees are able to retain approximately 50% of what they are told and supervisors can retain around 60% of information they receive."
Why?: This isn't something new. Most of us have played Chinese Whispers (or a variant of it) and seen how distorted a simple message can get when it's passed around.
Where?: Lecture; Statistics for Management
What?: The role of Statistical Analysis in Lean Manufacturing / Toyota Production System (TPS) / The Toyota Way
Why?: "Base your management decisions on a long-term philosophy, even at the expense of short-term financial goals."
"The general who wins the battle makes many calculations in his temple before the battle is fought.
The general who loses makes but few calculations beforehand." - Sun Tzu (The Art of War)
Why a bailout IMHO is better than doing nothing :: An Asian perspective
First of all I'm not a US citizen. But we live in a global economy and mistakes made by those thousands of kilometers away will eventually have an effect on me. Therefore it pays (both literally and figuratively) to pay attention.
Over the past weeks we've seen viral fear-mongering over the internet on how America should now be named USSA and her decisions are from the rich for the rich etc. etc (drama drama drama). Well that's all good. Freedom of speech and what not. But take it from someone 'actually' living in a country with a socialist agenda and a civil war; The roots of socialism often lies in the envy and hatred towards the rich. Enough about that. What I find funny is that none of those fear-mongers had a plan either. Their plan was just "no bailout", which eventually translates to "do nothing". Let them pay for their mistakes. But it's not that simple is it?
Let's imagine for a moment that the US government indeed opted to do not…
Google posted this video of their Android search application today.
There are also reports on device vendors such as Motorola ramping up and expanding their Android forces from 50 to 359 people apparently with Nokia right behind. It seems like most device vendors in the Open Handset Alliance will follow the lead of Motorola and Nokia, which means cheaper handsets as the competition increases.
In the apps market space, companies such as Handaho are already on-board while there are and will be an awesome set of free Android apps for the taking. Interesting times.
Which technologies stand to benefit from the Wall Street collapse?
According to a recent survey of 1,000 CIOs done by the WSJ,
61% of CIOs are currently re-evaluating their 2009 budgets, while putting non-essential projects on hold.
49% have cut the amount they spend on consultants while restricting travel. Nearly 25% have put a hiring freeze in placeAlthough this may seem like an expected reaction, which renders the tech spending forecasts just two weeks old obsolete, the fact remains that a business must carry on and IT must keep up with the operational demands. Your company will depend on you to scale its systems and remedy the failing ones just as before. So what can one do, given the restricted budgets and a freeze on human resources and consultancy?
In the coming quarters, we might see an increasing demand for Cloud Computing Services (despite RMSs valid but mostly paranoid concerns). Utility computing services such as Amazon EC2 and S3 will see increased adoption mainly due to lower costs up-front, lesser number of human resources required to mai…
In celebration of their 10th anniversary, Google has put up a search index from 2001. So go ahead and see the world before the iPod, YouTube and Facebook.
What is WOA?
"Web Oriented Architecture (WOA) is a style of software architecture that extends Service-oriented architecture to web based applications. WOA is also aimed at maximizing the browser and server interactions by use of technologies such as REST and POX." - Wikipedia
Then why the debate of SOA vs WOA? That's a question I've had for a while. The way I see it, WOA is SOA for the web isn't it? ...ok with added REST goodness.
In a recent interview, Gartner Vice President Nick Gall, who is credited with first describing Web-oriented architecture (WOA), was asked to give us, the less enlightened, the bottom line about the WOA versus SOA debate.
Interesting read.


According to the Employment Situation Report released by the BLS this morning, unemployment for the month of October was at 4.1%, the lowest since December 2000.
The good news was accompanied by revisions in the number of payroll employees for the past two months which means that the US has had positive job gains for every month since October 2010.
On a less positive note, 765,000 people left the labor force this month which caused the labor force participation rate to dip 0.4 percentage points to 62.7%. We will continue to monitor this measure.


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text:
Carrozzeria Scaglietti () was an Italian automobile design and coachbuilding company active in the 1950s.  It was founded by Sergio Scaglietti in 1951 as an automobile repair concern, but was located across the road from Ferrari in Maranello outside Modena, Italy.

Scaglietti gained Enzo Ferrari's trust and respect both through his bodywork and design skills and for providing a retreat for young Dino Ferrari. Their professional relationship began when Ferrari asked Scaglietti to repair and modify race car bodywork in the late 1940s, which was soon followed by orders for full car bodies in the early 1950s. Scaglietti and Dino Ferrari designed a 166 MM, s/n  0050M, the first Ferrari to have a "headrest" bump. This feature was subsequently used on most racing Ferraris of the 1950s and 1960s. The idea was initially despised by Enzo but championed by Dino, and 0050M's design became an overall success. The car became a prototype for the Monza range.

In the mid-1950s, Scaglietti became the Carrozzeria of choice for Ferrari's racing efforts. Many sports racing prototypes were designed and manufactured at their facility. All those exclusively designed by Scaglietti carried the Scaglietti & C. badge while cars built to outside designs did not. The company's 1958 250 Testa Rossa, with its Formula One-inspired pontoon fenders, is one of the most famous Scaglietti designs. Several of Ferrari's most coveted models such as the 250 California Spyder, 250 GTO and 250 Tour de France were built by Scaglietti to a Pinin Farina design.

Today, the former Scaglietti works is owned by Ferrari and used to produce Ferrari's current line of aluminium bodied cars, including the 488 and F12, using both modern and traditional techniques. In 2002, a special edition of the 456, the 456M GT Scaglietti was named in honor of Scaglietti.  This was followed by the 2004 introduction of the 612 Scaglietti, a 2+2 GT car produced until 2010. Despite names honoring Scaglietti, both the 456 and 612 were designed by Pininfarina.

Sergio Scaglietti died at his Modena home on 20 November 2011 at the age of 91.

Designs

Original Scaglietti designs include:
 1950-built Ferrari 340 America Barchetta (converted from 275 S and rebodied after 1952)
 1953 Ferrari 166 MM/53 (rebodied as Scaglietti Spyder to an Alfredo Ferrari design and restamped as s/n 0050M)
 1953 Ferrari 735 S, rebodied by Scaglietti from "Autodromo" design.
 1953 Ferrari 166 MM/53, s/n 0262M, rebodied from an Abarth spider design in 1954.
 1953 Ferrari 500 Mondial, rebodied from a burnt 625 TF berlinetta before 12 Hours of Casablanca in December 1953.
 1954 Ferrari 750 Monza
 1954 Ferrari 250 Monza (one original and one further rebodied in 1957 in 'pontoon fender' spyder form)
 1954–5 Ermini 357 Sport
 1955 Ferrari 410 S (Spyders and Berlinetta Speciale)
 1955 Ferrari 857 S
 1955 Ferrari 376 S
 1955 Ferrari 735 LM
 1956 Ferrari 500 TR
 1956 Ferrari 860 Monza
 1956 Ferrari 290 MM
 1957 Alfa Romeo Giulietta Sprint Veloce Scaglietti
 1954 Ferrari 375 MM Berlinetta (s/n 0402AM)
 1957 Ferrari 410 Superamerica Coupé (s/n 0671SA)
 1957 Ferrari 290 S, 315 S and 335 S
 1958 Ferrari 250 Testa Rossa
 1958 Ferrari 312S/412 S
 1958–9 Chevrolet Corvette Scaglietti Coupe
 1967 Ferrari 275 GTS/4 NART Spyder

Bodies executed to a third party design:
 1956 Ferrari 250 GT Berlinetta
 1957 Ferrari 250 GT California Spyder
 1962 Ferrari 250 GTO
 1963 Ferrari 250 GT Berlinetta Lusso
 1963 Ferrari 250 LM
 1964 Ferrari 275 GTB
 1968–74 Dino 206 & 246
 1968 Ferrari 365 GTB/4 'Daytona'

Gallery

References

Bibliography

External links

 Coachbuild.com Encyclopedia: Scaglietti

Scaglietti
Ferrari

redpajama_set_name: RedPajamaWikipedia


Canon PIXMA G4500 Driver Download - tag : Download Driver Canon G4500 , Canon G4500 Driver For Windows 10/8.1/8/XP/Vista/2000/Windows me/Windows server, Canon G4500 Driver For Mac /mac os/mac x, Canon G4500 Driver For Linux Operating System | Presenting the model Canon PIXMA G4500, which prints, check, duplicate and also Fax. Multifunctional see canon made use of in tiny offices. The test for that reason analyzes exactly how beat in the work environment.
Canon PIXMA G4500 Driver - If we focus on the pricing page, Canon has done well with Pixma multifunction container system thanks to the Canon PIXMA G4500 job super cheap. It holds true that such a gadget would certainly be excellent to be assigned in a tiny workplace. Nevertheless, the slow work rate. Additionally, important features such as duplex systems lost-at the very least for printing, and also benefits scanning. Canon refillable system not sure for sure at the moment, since if the company does not want to focus specifically by itself online shop. The requested cost of 329 Euro juicy, however a two-year service warranty is commendable.
printerdriverseries.net provides a download link for the Canon PIXMA G4500 Publishing directly from Canon Official Website you can download easily, to get the download link can be found below!


I am based in Canda. How do I claim custody of my child who is in Goa.
Does my inheritance right change if I convert to Islam?
Can a foreign decree be executed in India?
What is the procedure to divorce a foreign national?


Albin, Gennifer. Crewel. Macmillan/Farrar Straus Giroux. 2012.
Banks, Anna. Of Poseidon. Macmillan/Feiwel & Friends. 2012.
Cabot, Meg. Underworld. Scholastic/Point. 2012.
Cashore, Kristin. Bitterblue. Penguin Group/Dial. 2012.
Cole, Kresley. Poison Princess. Simon & Schuster. 2012.
Cooner, Donna. Skinny. Scholastic/Point. 2012.
Cross, Sarah. Kill Me Softly. Egmont. 2012.
Damico, Gina. Croak. Houghton Mifflin Harcourt/Graphia. 2012.
Fukuda, Andrew. The Hunt. Macmillan/St. Martin's Griffin. 2012.
Harstad, Johan. 172 Hours on the Moon. Little, Brown & Company. 2012.
Hartman, Rachel. Seraphina. Random House. 2012.
Hocking, Amanda. Wake. Macmillan/St. Martin's Griffin.
Hopkins, Ellen. Tilt. Simon & Schuster/Margaret K. McElderry Books. 2012.
Kontis, Alethea. Enchanted. Houghton Mifflin Harcourt. 2012.
LaFevers, Robin. Grave Mercy. Houghton Mifflin Harcourt. 2012.
Lange, Erin Jade. Butter. Bloomsbury. 2012.
Laybourne, Emmy. Monument 14. Macmillan/Feiwel & Friends.
Levithan, David. Every Day. Random House/Alfred A. Knopf.
Lowry, Lois. Son. Houghton Mifflin Harcourt. 2012.
Lyga, Barry. I Hunt Killers. Little, Brown & Company. 2012.
McGarry, Katie. Pushing the Limits. Harlequin Teen. 2012.
Nielsen, Jennifer. The False Prince. Scholastic/Scholastic Press. 2012.
Picoult, Jodi. Between the Lines. Simon & Schuster/Simon Pulse. 2012.
Rhodes, Morgan. Falling Kingdoms. Penguin Group/Razorbill. 2012.
Roth, Veronica. Insurgent. Harper Collins/Katherine Tegen Books. 2012.
Speer, Scott. Immortal City. Penguin Group/Razorbill. 2012.
Stiefvater, Maggie. The Raven Boys. Scholastic/Scholastic Press. 2012.
Wein, Elizabeth. Code Name Verity. Disney/Hyperion. 2012.


If you are a professional cleaning contractor, it makes sense to have a set of lances available for every situation you might encounter.
This spigot fits on to the end of any lance with a 1/4" male end, and enables it to fit into the bayonet fitting CW321.
Hence, in your van you can have lots of different lances.... 400mm fan jet , 900mm fan jet , turbonozzle , sandblast , underbody , extension, gutter, twin wash, etc... and just one washgun !


Specifications: 12 Volt DC, 10 ft. power cord, 15 amp twist-lock molded-on marine plug, and Push Button Switch.
The Turn-A-Mate Drive is designed to help you reel in empty lines while fishing, checking bait, or clearing lines while tournament fishing. Also handy for winding new line on your reels and for retrieving lines at the end of the day when you make the final pull. Components of the system include the Turn-A-Mate Drive and a drive stud for each reel (sold separately).
For Single Speed Reels Only.
412-T + 412HSBP Battery Pack: 412-T Turn a mate drive and Model 412HSBP battery pack and a 6 ft coiled power cord with molded-on cigarette lighter plug.
Choose Battery Pack Combo for Cord below.