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Monthly Archive for February, 2020
BROKER AND POLICYHOLDER FACE POTENTIAL LIABILITY UNDER NEW JERSEY'S INSURANCE FRAUD PREVENTION ACT (New Jersey Federal)
Published on February 28, 2020 in NJ - Reverse Bad Faith. Closed
The insurer sued to void two life insurance policies on the basis they were obtained through fraudulent statements and omissions. It also sought relief under New Jersey's Insurance Fraud Prevention Act (IFPA).
A Trust was both the policyholder and beneficiary. In its initial complaint, the carrier alleged the insured decedent made false statements and material omissions concerning serious medical conditions concealed from the insurer, including Hodgkin's Lymphoma.
The carrier wanted to amend its complaint by adding claims against the Trustee and its insurance broker for their alleged knowing involvement in this fraudulent conduct. The Trustee and broker opposed the motion to amend. The court granted the motion.
The court rejected the argument that the IFPA only applied to misconduct during the course of an insurance claim. The court recognized the IFPA also applies to conduct in the application process.
In granting the motion, the court relied upon allegations that the broker "was untruthful when he filled out the agent's statement…." The court found this could violate N.J. Stat. Ann. § 17:33A-4(a)(3), which addresses concealing or knowingly failing "to disclose the occurrence of an event which affects any person's initial or continued right or entitlement to (a) any insurance benefit or payment or (b) the amount of any benefit or payment to which the person is entitled."
The court also looked to the allegation that both the broker and Trustee "knew of and conspired to conceal" the decedent's medical visit to a longevity center and the results of that visit which referenced prior medical history. The court added that if the broker and Trustee "knew the Decedent was untruthful on the applications and failed to disclose that…, or actively participated in the Decedent's alleged misconduct, it could demonstrate a violation of N.J. Stat. Ann. § 17:33A-4(a)(4) or (b)."
Section 17:33A-4(a)(4) addresses a person who "[p]repares or makes any written or oral statement, intended to be presented to any insurance company or producer for the purpose of obtaining: … (b) an insurance policy, knowing that the statement contains any false or misleading information concerning any fact or thing material to an insurance application or contract…."
Section 17:33A(4)(b) encompasses a person who "knowingly assists, conspires with, or urges any person or practitioner to violate any of the provisions of this act."
Symetra Life Ins. Co. v. Jjk 2016 Ins. Trust, U. S. District Court District of New Jersey Civil Action No. 18-12350 (MAS) (ZNQ), 2020 U.S. Dist. LEXIS 29291 (D.N.J. Feb. 18, 2020) (Quraishi, J.)
UIM JURY VERDICT NOT RELEVANT TO BAD FAITH CASE BECAUSE IT OCCURRED AFTER THE INSURER HAD COMPLETED ITS CLAIM EVALUATION (Philadelphia Federal)
Published on February 27, 2020 in PA - Claims Handling (general), PA - Coverage Issues, PA - Discovery and Evidence, PA - Insurer wrong, but reasonable, PA - MVFRL and PA - UIM/UM Cases. Closed
In this UIM bad faith case, the insureds demanded UIM policy limits which the insurer did not pay. The insureds took their case to trial, and the jury verdict far exceeded policy limits. The insureds pursued a claim for bad faith, arguing among other things that the jury verdict could be used as evidence of bad faith.
The court disagreed. Bad faith can only be determined based on the insurer's conduct in evaluating the claim when it was submitted and on "the information available to the insurer during the claims processing". The jury verdict was rendered after the insurer had done its claim evaluation. Thus, the jury verdict was not relevant to bad faith.
The central legal issue in the case was whether the insureds had executed some version of an enforceable UIM policy limit sign down, below their liability coverage. The court's detailed analysis revealed that the insured's application, which would otherwise have effected an enforceable sign down, was ineffective because it made that decision contingent on another required form that was only signed over one month later. The accident at issue occurred during the interim. The court found that there was no effective sign down, and the UIM limits defaulted to the liability limits, a difference between $300,000 and $750,000.
The insureds claimed that asking them to sign the second document constituted bad faith. The insurer consistently took the position that the second document was not necessary to succeed on the sign down argument; rather, the application controlled and the second document was basically redundant.
Magistrate Judge Rice disagreed with the carrier's position on the application as stated above, but still found no bad faith:
"Nor does the failure to have [the insured] sign the UIM coverage selection form until [one month after the application] constitute bad faith. [The insurer] consistently maintained that the … application established the UIM policy limit, and the [insureds] had access to all relevant documents at all times. My post-trial disagreement with that determination fails to establish … bad faith."
Gibson v. State Farm Fire & Cas. Co., U.S. District Court Eastern District of Pennsylvania CIVIL ACTION No. 18-4919, 2020 U.S. Dist. LEXIS 27531 (E.D. Pa. Feb. 18, 2020) (Rice, M.J.)
INSURER'S RELIANCE ON ADVICE OF COUNSEL, AMONG MANY OTHER FACTORS FAVORING THE INSURER, DEFEATS BAD FAITH CLAIM (Philadelphia Federal)
Published on February 25, 2020 in PA - Attorney Client Privilege, PA - Claims Handling (reasonable), PA - Coverage Issues, PA - Discovery and Evidence, PA - Experts, PA - Red flags during investigation, PA - Reverse Bad Faith, PA - Sworn Statement/EUO and PA - Work Product. Closed
This case involves a head-spinning array of factual discrepancies between the insured's claims to the carrier and the results of the insurer's investigation. These range from whether the insured actually owned the property to whether the structure at issue collapsed from a sudden event or collapsed because of (uncovered) faulty construction. We leave you to the court's lengthy and detailed narrative concerning these discrepancies, and the various coverage issues invoked by their presence. Of particular interest here is that in addition to involving an adjuster, SIU adjuster, supervisor and engineering expert, the insurer also puts its outside counsel's coverage opinion on the record.
The insured brought a bad faith claim, and the insurer moved for summary judgment after making a detailed record. The insurer asserted various bases for why it was entitled to summary judgment. In granting summary judgment, the court stated that, at a minimum, there was a reasonable basis to deny coverage:
"The record indicates that [the insurer] conducted a thorough investigation of the claim and ultimately decided that coverage should be denied. Indeed, [a] property adjuster and an SIU adjuster inspected Plaintiff's loss; the claim was reviewed by [a] supervisor; [the insurer] took the recorded statement of Plaintiff and reviewed relevant property documentation from the City of Philadelphia; [the insurer] obtained the services of a structural engineer; and [the insurer] then sent the structural engineer's report, which opined on the cause of the loss, to independent legal counsel for an opinion on the coverage. Finally, relying upon independent legal counsel's conclusion that coverage did not exist for Plaintiff's loss, [the insurer] denied Plaintiff's insurance claim. It cannot be said that [the insurer]'s investigation and decision-making process was 'frivolous or unfounded,' as required under Pennsylvania law to succeed on a bad faith claim."
The court added, "the factual record is devoid of any 'clear, direct, weighty and convincing' evidence that would allow a factfinder to find 'without hesitation' that [the insurer] acted in bad faith in investigating and ultimately denying Plaintiff's insurance claim."
Moreover, even if the insured could make a case for unreasonableness, "the record is devoid of any evidence that [the insurer] either knew it had an unreasonable basis for denying coverage or recklessly disregarded its lack of a reasonable basis in denying Plaintiff's claim or in the manner in which it investigated Plaintiff's claimed loss." The record shows the contrary. The insurer not only engaged a structural engineer, but also independent legal counsel to analyze coverage. It then "relied on the independent findings of both the expert and legal counsel in its ultimate decision to deny" the claim.
Nguyen v. Allstate Insurance Co., U.S. District Court Eastern District of Pennsylvania CIVIL ACTION No. 18-5019, 2020 U.S. Dist. LEXIS 25789 (E.D. Pa. Feb. 14, 2020) (Kenney, J.)
STATUTORY BAD FAITH CLAIM BARRED BY TWO-YEAR STATUTE OF LIMITATIONS; PUTATIVE COMMON LAW BAD FAITH BARRED BY TWO-YEAR CONTRACTUAL LIMITATION; NO COMMON LAW BAD FAITH IN FIRST PARTY CASES (Middle District)
Published on February 24, 2020 in PA - Common Law Bad Faith (contractual or fiduciary basis) and PA - Limitations Period. Closed
The insurer denied coverage on November 3, 2015. The insured sued for breach of contract and bad faith on September 20, 2019. The insurer moved to dismiss the contract claim based on a contractual two-year limitation period, and the bad faith claim under the controlling two-year statute of limitations. The relevant facts were evident on the face of the complaint. Therefore, the court could decide the issues on a motion to dismiss.
As to the contract claim, because the "policy had a 2-year suit limitation, there is no merit to plaintiff's contention that Pennsylvania's 4-year statute of limitations for contract claims under 42 Pa.C.S.A. §5501 should control in this case." The insured nowhere alleged the insurer "led her to believe the two-year limitations period would not be enforced or that [the insurer] committed any actions that induced her to file her complaint after the two year deadline." The contract claim was dismissed with prejudice.
As to the bad faith claim, "since 'Plaintiff's claim of bad faith is … based on Defendant's denial of benefits to Plaintiff under the Policy, [the] Court can therefore consider the [November 3, 2015 denial of coverage letter] attached by Defendant to its Motion to Dismiss." The court would not let the plaintiff escape the timing issue by simply leaving out the denial date and not attaching a document on which it relied in its complaint in pleading its case, where the defendant then attaches to its motion.
Further, the court found "[no] doubt that the two year statute of limitations for a bad faith suit begins to run when insured first learned that the insurance company was denying coverage." Thus, the statutory bad faith claim was time barred.
[Note on statute of limitations triggers and the scope of the bad faith statute. The court observes that the two year bad faith statute of limitations begins to run at the time coverage is denied, and cites case law for this proposition, also phrased as when claims for benefits are denied. As noted previously on this blog, there are cases holding that the bad faith statute applies not only to coverage denial, but distinctly to various claims handling misconduct. Under this theory, the statute of limitations cannot begin to run at the time coverage is denied, because, e.g., no coverage may be due and bad faith is based solely on egregious claims handling failures. Does this mean that the statute of limitations case law makes clear that statutory bad faith must be based on a benefit denial, see one example here, and these bad faith claims handling cases are wrongly decided; or that there are other triggers for the two-year statute beginning to run wholly independent of a coverage denial?
The governing case on the statutory bad faith statute of limitations is the Pennsylvania Supreme Court's decision in Ash v. Continental Ins. Co., 932 A.2d 877 (Pa. 2007). In Ash, a clear majority of Pennsylvania's Supreme Court followed Chief Justice Cappy's Toy v. Metropolitan Life Ins. Co. opinion. The Ash majority states: "The bad faith insurance statute, on the other hand, is concerned with "the duty of good faith and fair dealing in the parties' contract and the manner by which an insurer discharge[s] its obligation of defense and indemnification in the third party claim context or its obligation to pay for a loss in the first party claim context." See Toy v. Metropolitan Life Ins. Co., 928 A.2d 186, 199 (Pa. 2007). It applies only in limited circumstances–i.e., where the insured first has filed 'an action arising under an insurance policy' against his insurer, see 42 Pa.C.S. § 8371–and it only permits a narrow class of plaintiffs to pursue the bad faith claim against a narrow class of defendants." An article discussing Toy and Ash can be found here.]
The insured attempted to claim there was somehow a common law bad faith claim, subject to the four-year contract statute of limitations. Aside from the fact that the complaint alleged statutory bad faith, common law bad faith is solely contract based in Pennsylvania, and merges with the breach of contract claim. Thus, it would be subject to the same two-year contractual limitations period.
Finally, the court stated that in any event, common law bad faith did not apply to first party property damage claims, as were at issue in this case. The court relied on Judge Munley's 2009 Bukofski decision on this point.
Mazzoni v. Travelers Home & Mutual Insurance Co., U.S. District Court Middle District of Pennsylvania CIVIL ACTION NO. 3:19-2169, 2020 U.S. Dist. LEXIS 25513 (M.D. Pa. Feb. 13, 2020) (Mannion, J.)
FAILURES TO COMMUNICATE WITH THE INSURED UNDERMINE INSURER'S SUMMARY JUDGMENT EFFORTS; INSURER MUST SHOW ACTUAL DISAGREEMENT OVER VALUE OCCURRED (Western District)
Published on February 19, 2020 in PA - Claims Handling (unreasonable), PA - Communication with insured, PA - Cooperation with insurer, PA - Delay (Investigation/Claims handling), PA - Estimates, Valuation or Appraisal, PA - Experts, PA - Litigation Conduct Claims and PA - UIM/UM Cases. Closed
The court denied the insurer's motion for summary judgment on plaintiff's UIM bad faith. Key issues were the insurer's having failed to adduce evidence explaining the basis for its denial, and not sufficiently adducing facts contrary to the claims handling allegations in the insured's complaint. The carrier focused on the fact that the insured did not take discovery, but this was not as detrimental to plaintiff's case as the insurer believed.
The insured received $50,000 from the tortfeasor's carrier, and had $250,000 in UIM coverage under his own policy. The complaint alleged detailed facts supporting the position that the insured was highly cooperative in producing information, both independently and upon the insurer's request. Moreover, the insured submitted to an examination under oath and an independent medical examination, and follow up requests after both.
The claim/investigation process went on for eight months, with the insured's counsel repeatedly making policy limits demands, with no counteroffer. Ultimately, the insurer offered no payment of any kind to the insured.
During the claim/investigation process, the insured filed a writ of summons. The insurer ultimately responded with a rule to file a complaint, and after the complaint was filed it removed the action to federal court. [Note: Among the various legal principles governing bad faith claims the court recites, is "[t]he Third Circuit has also recognized that 'using litigation in a bad faith effort to evade a duty owed under a policy [is] actionable under [Pennsylvania's bad faith statute].'" The court did not amplify on that principle in this case.]
The court observed the carrier did not develop a factual record refuting the detailed claims handling history in the complaint. Thus, "[w]hether the undisputed facts in the Complaint are sufficient for Plaintiff to prove by clear and convincing evidence that [the insurer] acted in bad faith is for the jury to determine." Further, there was no evidence in the record as to how, or if, the insurer provided the basis for its claim denial to the insured. At most, the rule to file a complaint functioned as the notice of denial; but even then, the insurer never gave the insured "any information about the basis for its decision."
The insurer did include a copy of its medical expert's reports in moving for summary judgment. These reports concluded that the insured "required no further care, treatment or limitations as a result of his motor vehicle accident." On the other hand, the court found that the insured had apparently produced his own medical expert report during the litigation, opining that significant medical issues resulted in a "no work" restriction.
The court stated: "It may well be that [the insurer] relied upon the results of the independent medical examination or other valid grounds, but the record does not reflect that [this] report was supplied to Plaintiff or that [the insurer] relied on this report in denying Plaintiff's claim."
Generally, the court accepted that there might a been a reasonable basis for evaluating the claim for eight months and then denying it, but that reasoning was not disclosed in the record. The insurer attempted to frame the issue as merely a disagreement over value (apparently $250,000+ on the insured's end and $0 on the insurer's end).
However, "to prevail on its motion on the ground that the parties had a legitimate value disagreement, it is [the insurer's] burden, [1] initially, to point to evidence illustrating not only that there was indeed a disagreement over the value of Plaintiff's claim (as opposed to an outright denial), but [2] also that [the insurer] communicated that disagreement to Plaintiff, for example, by making a counter-offer. [The insurer] has not done so."
In sum, "[b]ecause there are genuine issues of material fact regarding Plaintiff's bad faith claim based upon the current state of the record, [the insurer] is not entitled to judgment as matter of law."
Baldridge v. Geico Insurance Co., U.S. District Court Western District of Pennsylvania, Civil Action No. 18-1407, 2020 U.S. Dist. LEXIS 22311 (W.D. Pa. Feb. 10, 2020) (Dodge, M.J.)
On April 1, 2020, Magistrate Judge Dodge denied the insurer's motion for reconsideration. A copy of her opinion can be found here.
NO BAD FAITH WHERE COVERAGE ISSUES FAIRLY DEBATABLE; NO PUNITIVE DAMAGES WHERE NO BAD FAITH; NO RIGHT TO ATTORNEY'S FEES IN DIRECT ACTION (New Jersey Federal)
Published on February 18, 2020 in NJ - Attorney's Fees, NJ - Coverage Issues, NJ - Discovery and Evidence, NJ - No coverage due, no bad faith and NJ - Punitive Damages. Closed
The insurer filed a declaratory judgment action concerning first party property damage to a commercial building. The insureds counterclaimed for breach of contract and bad faith, and the insurer moved to dismiss the bad faith counterclaim.
Under New Jersey law, "to establish a claim for bad faith in the insurance context, a [claimant] must show two elements: (1) the insurer lacked a 'fairly debatable' reason for its failure to pay a claim, and (2) the insurer knew or recklessly disregarded the lack of a reasonable basis for denying the claim."
"To meet the 'fairly debatable' standard, a claimant must be able to establish, as a matter of law, a right to summary judgment on the substantive claim; if [claimant] cannot establish a right to summary judgment, the bad faith claim fails. In other words, if there are material issues of disputed fact which would preclude summary judgment as a matter of law, an insured cannot maintain a cause of action for bad faith." "Thus, dismissal of the bad faith claim is proper when the insured cannot prevail on summary judgment for the underlying insurance claim."
"[A] bad faith claim against the insurance company fails at the motion to dismiss stage if the claimant cannot establish a right to summary judgment on the substantive claim."
The case involved an alleged partial building collapse. There were issues of fact as to what caused the collapse, the resolution of which were necessary to determine coverage under the policy. There were also issues concerning policy interpretation. The insureds took the position that the insurer's policy interpretation position was irrelevant to bad faith, rather than arguing the insurer's position was incorrect and taken in bad faith. The court found this argument fatal to the insured's bad faith claim.
Moreover, the court concluded the insurer's reading of the insurance policy provided a reasonable basis to deny the claims. It stated that denying benefits on the basis there was no coverage "is the 'easiest to understand' why the denial of insurance claims is 'fairly debatable.'" Thus, the insureds failed to show the insurer lacked a fairly debatable reason to deny the claim. Further, "[b]ecause this deficiency cannot be cured by further amendment or through discovery, the Court dismisses Defendants' claim for bad faith with prejudice." (Emphasis in original)
The court also dismissed the insured's punitive damages claim, with prejudice, stating "an insured who cannot state a claim for bad faith damages is necessarily unable to prevail on a claim for punitive damages under the higher standard of egregious circumstances."
Finally, the court dismissed the claims for attorney's fees and legal costs with prejudice, under either the contract or bad faith claims. "New Jersey law does not allow awards of attorney's fees and costs 'to an insured who brings direct suit against his insurer to enforce casualty or other direct coverage.'"
Merchants Mutual Insurance Co. v. 215 14th St., LLC, U.S. District Court District of New Jersey Civil Action No. 19-9206 (ES) (SCM), 2020 U.S. Dist. LEXIS 23664 (D.N.J. Feb. 10, 2020) (Salus, J.)
COURT REFUSES TO STRIKE INSURER'S FRAUD IN THE APPLICATION DEFENSE; BUT DENIES MOTION TO SEVER AND STAY INSURED'S BAD FAITH CLAIM (Western District)
Published on February 12, 2020 in PA - Bifurcate/Sever & Stays and PA - Reverse Bad Faith. Closed
This case involves a homeowners' fire loss claim. The carrier refused to pay on the basis that the insureds made material misrepresentations in applying for their policy. The insurer asserted affirmative defenses that the homeowners falsely stated that they did not have knob and tube wiring and that no insurer had ever cancelled the homeowners' coverage, when in fact, they did have knob and tube wiring and a prior policy was cancelled.
The matters before the court were the insureds' motion to strike the affirmative defenses as inadequately pleaded, and the insurer's motion to sever and stay the insureds' bad faith claim.
The Insurer Adequately Pleaded Fraud as an Affirmative Defense
The court denied the motion to strike. It found that affirmative defenses are measured by Rule 8(c) and do not have to be rigorously articulated. That being said, because fraud is pleaded, there are additional pleading requirements under Rule 9(b) to plead with particularity (other than intent).
Still, measured by these standards, the affirmative defenses are adequate. The insurer pleads that the insureds made written misrepresentations on the application, and that it would never have issued the policy if the insureds stated the true facts in their application. This was sufficiently specific to put the insureds on notice of the grounds for the affirmative defenses.
The Court Refuses to Sever and Stay the Bad Faith Claims
The insurer sought to sever the insureds' bad faith claims from their breach of contract claim. The court found this unwarranted for the following reasons:
The underlying issues in the two claims overlapped. The court recognized the ultimate issues were distinct on breach of contract and bad faith, but found "they are subject to the same sources of proof and concern the same underlying issues."
Trying the claims together would not unduly prejudice the insurer. The insurer "failed to show exactly how it would be prejudiced if [the insureds'] claims are tried together." Further, if discovery disputes arise, the court could properly resolve them at that future time.
Trying the claims together would promote judicial economy. The court stated that "judicial economy strongly disfavors severance in this case." Turning one case into two cases "would require the Court to schedule deadlines separately for each case and hold two separate trials on claims stemming from the same dispute." Moreover, the insurer did not provide any valid reason for severance.
Date of Decision: February 6, 2020
Walls v. American Modern Select Insurance Co., U.S. District Court Western District of Pennsylvania Case No. 3:19-cv-80, 2020 U.S. Dist. LEXIS 20088 (W.D. Pa. Feb. 6, 2020) (Gibson, J.)
EVEN THOUGH COVERAGE MIGHT BE DUE, INSURED COULD NOT ESTABLISH DENIAL WAS UNREASONABLE (Philadelphia Federal)
Published on February 11, 2020 in PA - Claims Handling (reasonable), PA - Coverage Issues, PA - Experts and PA - Insurer wrong, but reasonable. Closed
This case involved a wall collapse. The insured and carrier provided each other with expert reports on causation. The carrier's expert analysis would result in a finding of no coverage under the policy, but the insured's expert analysis would result in coverage. The insurer denied coverage, and the insured sued for breach of contract and bad faith.
After discovery, the insured moved for summary judgment on both counts. The court denied summary judgment on the contract claim, because issues of fact remained on causation that might allow for coverage, but granted summary judgment on the bad faith claim after finding that the insured could not meet her burden to show the insurer lacked a reasonable basis in denying coverage.
In addressing bad faith, the court observed that an insurer can defeat bad faith by showing there was a reasonable basis for its action. The court further made clear that at the summary judgment stage, the plaintiff's obligation to prove its case at trial by clear and convincing evidence of bad faith was a necessary consideration. In this case, even taking the facts in the insured's favor, the insurer had a reasonable basis to deny the claim.
The insurer's denial was based on a reputable forensic engineer's report that determined two causes of the collapse; both of which were excluded under the policy. The insured argued that the carrier should have rejected this report, and instead followed the analysis in the report provided by the insured's expert. The court found this was not enough to make out a claim of bad faith because "the mere fact that the parties disagree about coverage is not enough to show bad faith." The court cited Post v. St. Paul Travelers Ins. Co., for the proposition that there is no bad faith "when the plaintiff could only show the parties disagreed about coverage…."
The insured also argued bad faith because the insurer allegedly "ignored the possibility that [the insured's] house would be demolished." The court found this irrelevant to the bad faith claim.
"If the collapse was not covered under the insurance policy, [the insurer] would not have been obligated to pay [the insured] regardless of whether her house was later demolished. In other words, whether the house was demolished would have no impact on [the] coverage decision." Thus, this argument did not go to the reasonableness of the coverage decision itself.
In sum, the insured did not adduce evidence that the insurer lacked a reasonable basis for its coverage decision, and summary judgment was granted on the bad faith count.
Date of Decision: January 31, 2020
Hentz v. Allstate Property & Casualty Insurance Co., U.S. District Court Eastern District of Pennsylvania CIVIL ACTION No. 19-2007, 2020 U.S. Dist. LEXIS 17379 (E.D. Pa. Jan. 31, 2020) (Sanchez, J.)
LACK OF COVERAGE CONSTITUTES UNDISPUTED EVIDENCE OF REASONABLE BASIS TO DENY CLAIM, AND WARRANTS REJECTION OF BAD FAITH CAUSE OF ACTION (Philadelphia Federal)
Published on February 10, 2020 in PA - Coverage Issues and PA - No coverage duty, no bad faith. Closed
The loss at issue was the result of intentional conduct by the named insured's son, in this tragic matter. The son was also an insured under the policy.
The court found the named insured (actually his estate) could not make out a prima facie case for coverage because the loss was not accidental, and the intentional conduct was the act of an insured. Alternatively, the court found the intentional loss exclusion applied. For these reasons, the court granted summary judgment on the breach of contract claim.
As to bad faith count, the court first reiterates that the insurance coverage claims are barred under the policy. Next, "[t]he Court therefore concludes that undisputed evidence demonstrates that defendant had a reasonable basis for denying plaintiff's claim. The bad faith claim is therefore rejected."
Thus, summary judgment was granted on all counts.
Tartour v. Safeco Insurance Co., U.S. District Court Eastern District of Pennsylvania CIVIL ACTION NO. 17-1896, 2020 U.S. Dist. LEXIS 16271, 2020 WL 489467 (E.D. Pa. Jan. 30, 2020) (DuBois, J.)
BAD FAITH EXPERT PERMITTED TO TESTIFY, WITHIN CERTAIN LIMITATIONS (Western District)
Published on February 7, 2020 in PA - Experts. Closed
The court permitted plaintiff's insurance bad faith expert to testify, within certain limitations as to what may be discussed or disclosed.
The case involved a first party property loss, arising out of fire damage to a commercial greenhouse sterilization system (the "ozone system"). The insured alleged the carrier (1) "wrongly denied coverage to replace the entire ozone system; (2) … wrongly denied coverage for crops that were damaged by ozone exposure caused by a mechanical breakdown of the ozone system; and (3) [the insured] was forced out of business as a result of the Defendant's conduct." The insured sued for breach of contract and bad faith.
The insured sought to use three experts, including a bad faith expert. The bad faith expert was an attorney and had over 20 years of experience as a claim adjuster. He was proffered "as a bad faith expert to offer opinions regarding: (1) insurance industry standards and practices; (2) Defendant's handling of the insurance claim at issue; (3) Defendant's compliance with insurance statutes and regulations; and (4) the interpretation of Defendant's policy issued to Plaintiff."
The insurer brought a Daubert motion to preclude the bad faith expert's proposed testimony. The carrier argued that the expert attorney's legal conclusions would not help a jury, and that at a minimum the expert "be precluded from testifying as to: (1) whether or not the Defendant violated statutes or regulations; and (2) the interpretation of Plaintiff's insurance policy."
The court observed "that the admissibility of expert testimony hinges on a 'trilogy of restrictions': qualification, reliability, and fit." The testimony here hinged on fit. Federal Rule 702 the "expert testimony must 'help the trier of fact to understand the evidence or to determine a fact in issue.'" "The standard for fit is 'not that high,' although it is 'higher than bare relevance.'" The insurer argued that the bad faith expert's "testimony does not 'fit' the claim at issue: bad faith is a legal concept of general application, which does not require scientific, technical, or specialized knowledge to be presented to assist the jury."
The Court thought otherwise. It found, with certain limitations, that the bad faith expert's testimony would "assist the jury in determining what constitutes reasonable conduct when handling an insurance claim. In the Court's estimation, [the expert's] twenty-six (26) years of experience as a claims adjuster will be quintessentially helpful in providing the jury with guideposts as to what constitutes reasonable adjusting and claims handling conduct and will be substantially more useful than asking the jury to in essence 'wing it' as to reasonableness in this out-of-the-ordinary situation."
This expert was "permitted to testify as to best practices in handling insurance claims of the type involved here. [He] may not discuss his legal training or experience. And he is not permitted to testify as to whether or not the Defendant violated statutes or regulations (but he is not barred from testifying as to what constitutes best practices regarding the handling of insurance claims, even if the genesis of such practices are statutes or regulations, which he cannot talk about)."
Three Rivers Hydroponics, LLC v. Florists' Mutual Insurance Co., U. S. District Court Western District of Pennsylvania No. 2:15-cv-809, 2020 U.S. Dist. LEXIS 12644 (W.D. Pa. Jan. 27, 2020) (Hornak, J.)


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Q: How to add search bar inside responsive nav bar when it shrinks to mobile screen I am working on a navigation bar that is not made with bootstrap. I want the search bar and some dropdown menus on the navbar, but my search bar is not working correctly. It is not going inside navbar and making the screen size bigger to smaller like from desktop to mobile
Every menu is going into responsive menu when the screen size changes, but the search bar is not doing what I want when the size changes. The search bar should also go into that menu where others are going

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  text-align: left;
}

.dropdown-content a:hover {
  background-color: #ddd;
}

.show {
  display: block;
}
/* Style the input container */
.topnav .search-container {
  float: right;
}

/* Style the input field inside the navbar */
.topnav input[type=text] {
  padding: 6px;
  margin-top: 8px;
  font-size: 17px;
  border: none;
}
.search-container button {
  float: right;
  padding: 6px;
  margin-top: 8px;
  margin-right: 16px;
  background: #ddd;
  font-size: 17px;
  border: none;
  cursor: pointer;
}

@media screen and (max-width: 600px) {
  .topnav a:not(:first-child), .dropdown .dropbtn {
    display: none;
  }
  .topnav a.icon {
    float: right;
    display: block;
  }
}

@media screen and (max-width: 600px) {
  .topnav.responsive {position: relative;}
  .topnav.responsive .icon {
    position: absolute;
    right: 0;
    top: 0;
  }
  .topnav.responsive a {
    float: none;
    display: block;
    text-align: left;
  }
  .topnav.responsive .dropdown {float: none;}
  .topnav.responsive .dropdown-content {position: relative;}
  .topnav.responsive .dropdown .dropbtn {
    display: block;
    width: 100%;
    text-align: left;
  }
}

  Home
  News
  Contact

    <button class="dropbtn" onclick="mydropdown(this)">Dropdown

  </button>

    Link 1
    Link 2
    Link 3

    <button class="dropbtn" onclick="mydropdown(this)">Dropdown 2

  </button>

    jdjd
    Link 2
    Link 3

  About

    <form action="/action_page.php">
      <input type="text" placeholder="Search.." name="search">
      <button type="submit">Submit</button>
    </form>

  ☰

A: The styles are working only on
.topnav a:not(:first-child), .dropdown .dropbtn
you should add the search-container class in both responsive media-queries, after that modify the search button style so it fits

redpajama_set_name: RedPajamaStackExchange


Sometimes I wonder how it feels living as a Moslem in somewhere else outside Indonesia or what if I were born as Palestinians, perhaps, I would not be what I am today. Moslems in Palestina meet different situations than moslems in Indonesia. You know what I'm talking about. People basically have different kind of problems to pass in life, some of them are insecure to have peaceful lives (for example those who live under the war), they have no choice but struggling (that makes me feel so thankful living in Indonesia). In Indonesia where we have so much ease to do anything we want, we can worship whenever we want without fear, Moslemah can wear hijab freely, our problems as Moslems might be 'world temptations' : food, fun, fashion.
I was told that if we pray for someone/people then they will know and feel close with us eventhough they never know about our prayers. One of my friend proved that. She often prays for Moslems in other countries, Moslems who live under the pressure of the government (she said Moslems from Uygur, Moro, Iraq, etc) before going pilgrimage. When she was in Baitullah, Moslemahs from all the countries that she has ever mentioned in her prayer came to her, one by one in unexpected ways of coming. A moslemah from Uygur suddenly came to her camp to take ablution because she ran out of water in her camp. How come, said my friend.
Sometimes.. i think our muslims brothers n sisters who live under the pressure are luckier than us who live in "peaceful" place..
they have their big chance to proof their eeman with the real danger to their own live..
We'll this comment for sure not to curse to what Allah Willed on us here not there.. ;) We all know Allah is the Most Merciful and The Omniscient.
We, as Moslems in Indonesia, face hidden enemies.. Bid'ah, fun, and any temptation which we may not realize and i think hidden enemies are much more dangerous..
ya Alloh mbak. I almost cry reading this "When she was in Baitullah, Moslemahs from all the countries that she has ever mentioned in her prayer came to her, one by one in unexpected ways of coming".


Valentine's Day got you hungry? Is your mind on food more than love?
If so, this post is for you. Keep reading or click here to learn how to get some FREE food on the big Valentine's Day.
Qdoba: Fun V-day tradition that if you kiss someone while ordering your meal you get a FREE burrito with your meal.
Hooters: Fun V-day tradition where you shred and forget your ex's photo and get 10 FREE wings.


text:
import angular from 'angular';
import angularMeteor from 'angular-meteor';
import {
  Tasks
}
from '../../api/tasks.js';
import template from './todosList.html';

class TodosListCtrl {
  constructor($scope) {
    $scope.viewModel(this);

    this.subscribe('tasks');

    this.hideCompleted = false;

    this.helpers({
      tasks() {
          const selector = {};

          // If hide completed is checked, filter tasks
          if (this.getReactively('hideCompleted')) {
            selector.checked = {
              $ne: true
            };
          }

          return Tasks.find(
            selector, {
              sort: {
                createdAt: -1
              }
            });
        },
        incompleteCount() {
          return Tasks.find({
            checked: {
              $ne: true
            }
          }).count();
        },
        currentUser() {
          return Meteor.user();
        }
    })
  }

  addTask(newTask) {
    // Insert a task into the collection
    Meteor.call('tasks.insert', newTask);
    // Clear form
    this.newTask = '';
  }

  setChecked(task) {
    // Set the checked property to the opposite of its current value
    Meteor.call('tasks.setChecked', task._id, !task.checked);
  }

  removeTask(task) {
    Meteor.call('tasks.remove', task._id);
  }

  setPrivate(task) {
    Meteor.call('tasks.setPrivate', task._id, !task.private);
  }
}

export default angular.module('todosList', [
    angularMeteor
  ])
  .component('todosList', {
    templateUrl: 'imports/components/todosList/todosList.html',
    controller: ['$scope', TodosListCtrl]
  });

redpajama_set_name: RedPajamaGithub


text:
Le Film d'art (z fr. film artystyczny) – francuska wytwórnia filmowa powstała w 1908 roku przez Paula Laffitte, dała początek tzw. "filmowi artystycznemu", który to ruch postulował oparcie filmu na literaturze ambitnej, tworzenie adaptacji scenicznych i powieściowych. Był to pierwszy przypadek wykorzystania literatury w nowym medium jakim był film. Po krótkim okresie popularności wytwórnia straciła zainteresowanie publiczności.

Historia
W 1908 roku, na prośbę członków Comédie-Française, bracia Lafitte założyli spółkę Le Film d'art. Spółka miała zajmować się produkcją filmową dotyczącą scen historycznych, mitologicznych i teatralnych. Filmy miały opierać się na adaptacjach prawdziwych i uznanych przedstawień teatralnych. Głównym celem powołania tej spółki było poszerzenie szeregów publiczności kinowej (dotąd dość ludowej) o warstwy bardziej wykształcone. Kino padło ofiarą opinii sztuki jarmarcznej, od której odżegnywała się publiczność teatrów i oper. Dla przyciągnięcia tej publiczności Le Film d'art odwoływała się do aktorów i reżyserów teatralnych.

Popularne produkcje
Najsłynniejszymi filmami były rekonstrukcje historyczne, takie jak Zabójstwo księcia Gwizjusza (L'Assassinat du duc de Guise; scen. Henri Lavedan; 1908), Le Baiser de Judas (reż. Armand Bour, André Calmettes; 1908) i Le Retour d'Ulysse (reż. André Calmettes, Charles Le Bargy; 1909).

Bibliografia
 Na podstawie Toeplitz Jerzy, Studium adaptacji filmowej w: "Powieść na ekranie", Filmowa Agencja Wydawnicza, Warszawa, 1952.

Francuskie wytwórnie filmowe

redpajama_set_name: RedPajamaWikipedia


Most werewolves are warriors, since the only way in skyrim to contract lycanthropy is through the Companions questline. However, as long as you slap Vilkas around with a sword a bit in your initiation, you can get into the companions as a pure mage, and never use weapons again. This character does so, rushing to the ability to transform into a werewolf, and eventually heading to Falkreath to do the Ill Met By Moonlight quest, gotten from talking to the grieving couple in Falkreath's graveyard. Help Sinding, and get the Ring of Hircine as your reward, allowing for unlimited werewolf transformations by reusing the ring's power. Doing the companions questline in its entirety is still worthwhile, as after its completion you can get the Totems of Hircine by doing quests for Aela the Huntress. Another useful quest is clearing out Frostfell Lighthouse and getting the Sailor's Repose perk.
The druid is a spellcaster focused on channeling the power of nature. She calls upon fire, ice, and lightning to ravage her foes. With alteration spells and mage armor perks, the druid is tankier than a normal mage. This is compounded by leveling health. The wildshape druid levels magicka and health about evenly. Focus on leveling magicka first, until you have a respectable amount, and then start adding to health so the werewolf form can keep up with stronger foes. Once you are comfortable with your level of health, go back to magicka. While you will have less magicka then a pure mage who leveled that exclusively, the wildshape druid can become a powerful melee character once drained of magicka, cleaning up anything that remains.
The wildshape druid is a high elf, because this build cares so much about both magicka and health, the 50 extra points in magicka are irreplaceable. Highborn is also a very strong racial power when combined with destruction dual casting and impact. Use the mage stone until you reach 100 alteration, at which point you can take the atronach perk and switch to the atronach stone. The spell absorption from these both apply while you're in werewolf form, making it even more resilient.
I found werewolf form especially useful against mages, who are annoying to fight as another mage, since they will block your spells with wards and drain your magicka with lightning spells. Werewolf form is also incredibly useful for traveling, having incredible stamina and unrivaled speed bounding through the wilderness. Alteration is the most useful skill for a werewolf, as any flesh spells you have cast carry over when you transform, making the werewolf have great defenses. The restoration perk Avoid Death is also useful as a way of healing for a werewolf. Lastly, if your magicka allows it, you can cast a destruction cloak before transforming, giving your werewolf an elemental aura of damage. This just looks cool more than anything.
The wildshape druid is a fun character for having access to two totally different playstyles at the same time, and each one complimenting the other. The humanoid side of the druid is a powerful pure mage who has mastered the natural elements, and can ravage enemies from afar and stagger with dualcasting destruction spells or incapacitate with paralysis spells. The bestial side of the druid gets a huge boost to health, can keep up high defense from alteration magic, and suddenly becomes fast and physically powerful, tearing through enemies in melee combat with savagery. With access to both, the wildshape druid is a force of nature that can take on the deadliest challenges in skyrim, adapting to each situation through the two forms.


text:
The Royal Shakespeare Company productions of the eight history plays from "Richard II" through "Richard III" has concluded, after being cheered by audiences in Stratford-upon-Avon, London, and Michigan. Staged for the Millennium, the plays were presented in historical chronological order. After the first four appeared at Stratford-upon-Avon, the final four, the "Henry VI" trilogy and "Richard III," were produced in partnership with the University of Michigan at Ann Arbor. Its visit to the university included not only the productions, but educational sessions, master classes, and outreach work throughout the State. Finally, all eight plays were seen in both Stratford and London.
Witnessing the final four plays in two days at the Young Vic Theatre in London was an unforgettable experience, for not only were these early works made vivid by expert acting and direction, but history itself was clarified as one after another of Shakespeare's dramatic scenes were brought to life. Credit the Bard himself with selecting the best from the historical accounts he found in Raphael Holinshead's Chronicles, versions not always strictly accurate, and at times biased, especially More's account of Richard III, which he wrote under the patronage of the Tudors and painted Richard as the villain who inspired Shakespeare's version. Holinshead's dull pages become dramatic scenes: Joan of Arc inspiring the French and crowning a cowardly Dauphin; Queen Margaret and Suffolk having a passionate extra-marital affair, suggested by a phrase in the history book; Richard III, whose deeds are in the Chronicles but whose character as a villain combining wit and Machiavellian scheming Shakespeare found in Marlowe, and improved upon.
Directed by Michael Boyd and designed by Tom Piper, the four productions were notable for their imagination, variety, and fast pace; the fighting was exciting, with ladders, scaling ropes, and hand-to-hand clashes, while the rhetoric of the speeches never overtook their clarity. The many characters were clearly defined in their first appearances, and the fact that the same actors continued in the same roles (unless stabbed, beheaded, drowned, or otherwise done away with) throughout the plays. You knew the Bishop of Winchester (Christopher Ettridge) was a bad lot who would make trouble later because in the series' opening scene of Henry V's funeral, he spits into the grave after the mourners leave. Trapdoors hark back to the Elizabethan stage, and these were imaginatively used, representing Henry's grave here, but also the exit for those killed in battle or otherwise. Conveniently, the dead returned through the trapdoor as ghosts Properties descended from above, like scaling ropes in the battle scenes or the white and red roses as York and Lancaster choose up sides in the Temple Garden.
Joan of Arc, being the enemy of England, is treated by Shakespeare as a spirit-attended witch, and here three spirits accompany her in additional scenes (though even Shakespeare could not resist the prediction that she would one day be revered as a saint). The small size of the Young Vic with its open stage meant that the actors were in close proximity to the audience, and this enhanced the clarity of their speeches. The Royal Shakespeare Company earns kudos for not making trendy cuts in the text, as with two currently abbreviated "Hamlet"s, Peter Brook's version, and the Royal National's.
"Richard III" was Shakespeare's most popular play, to judge by the number of quarto (single-volume) editions printed in the author's lifetime. Beginning with his soliloquy at the end of Part III, Richard dominates the play that bears his name, and if Aidan McArdle seemed somewhat less dangerous than was Simon Russell Beale in an earlier RSC production, he was wittier, taking genuine delight in his evildoing. A good director's touch was to bring in at Richard's coronation, mingling with the attendant crowd, the ghosts of those he had murdered and presaging their return before the battle.
Both the acting and the direction were excellent, and the venture is to be commended. It is to be hoped that somewhere there exists a film of it, a record of this achievement that will long be remembered as the definitive version of Shakespeare's history cycle.

redpajama_set_name: RedPajamaCommonCrawl


"I've been taking piano lessons for over five years, and it's awesome! It's cool to sit down and play a really fast piece that sounds impressive. That's my favorite kind."
Lessons that Inspire, Create, and Motivate!
One-on-one piano lessons allow students to learn in a style that is interesting to them, at a pace that is comfortable. Each student receives a thorough and well-managed education on all aspects of musical performance, sight-reading, improvisation, composition, proper technique, and music theory.
Students are exposed to a variety of musical styles from Bach and Beethoven to Jazzy Duets to Movie Soundtracks to Contemporary music. Recital pieces are fun and challenging. This helps to broaden and develop musical tastes and technique!
Our studio offers regular opportunities for performance. From Coffee Concerts to Winter/Spring Formal Recitals to festivals and exams within the greater Twin Cities, students have plenty of chances to get involved in performance!
In a typical piano lesson, a student will not only read notation and polish performance pieces, they improvise "thunderstorm songs," compose and record their own pieces, solve "ear song" puzzles, collect Music Money for at-home practice, and try very hard to beat their teacher in Flashcard Battle. This provides a well-rounded, fun experience that hits different learning styles and keeps each minute full of learning!
We strongly focus on providing resources for parents and families that will give you the best opportunity to make your investment in piano lessons a success. From newsletters to recent articles on music-brain research to a library of books you can check out on how to practice to an annual "Parents Night Out", this is the place to get information! Even within each lesson, your teacher is discussing at-home practice strategies and putting together a weekly assignment sheet that will help make practicing easier and more effective. At-home practice is a key component in successful piano study and we are here to for guidance and encouragement. Parents are always welcome to email/call with questions or for advice during the week!
Ability to "Sit down and Play"
I will teach you or your child the language of music. I agree to provide each student at every level with the cognitive and physical ability to play with beauty and expression. Each student will receive instruction that is well prepared and highly tailored to their individual learning style, musical motivators, and lifestyle pace. My studio is full of joy, critical thinking, and focused study. I will have an assortment of great music, interesting props, fun games, and studio incentives to keep lessons fun and interesting. My responsibilities to you as the parent also include prompt and honest communication in and out of the studio, adherence to a yearly event calendar, and respect of your time and needs during weekly lessons. I also am responsible to hold myself to a high standard of teaching through my own ever developing education as a pianist and instructor.
Students agree to come to each lesson punctually, well practiced, with their assignment books and music in hand. Students understand that the real development happens through consistent practice at home in between weekly piano lessons. Students and parents are encouraged and guided each week to develop a habit of daily efficient piano practice and guided toward incorporating music into life Beyond the study of piano, I would encourage parents and students to try and make your life as musical as possible. Attend live concerts, listen to classical music at home, and play for others!
Parents, please keep an open communication with me! If something is happening in your child's life - either a joy or concern - I want to know! Did Sarah get a part in the school play? Is Jake struggling with a loss and needs encouragement? Are you feeling frustrated with a resistant practicer? Even a quick text on the way to the lesson can help make that lesson a positive experience.
Students are encouraged to have an acoustic, tuned piano at home. Keyboards will not provide the means to forming a proper hand shape or musical tone.
Students come for lessons once a week at a fixed time slot (for example 4:30-5:00pm on Tuesdays). The time slot can be 30, 45, or 60 minutes in length depending on experience level. There are 28 private lessons and 4 weeks of group lessons per year. Registration begins in early August and time spots will be assigned by mid-August for the entire school year. Returning students are guaranteed lessons the following year. If all spots fill, a wait-list will be established on a first-come first-serve basis to accept new students as spots open up. The calendar year is calculated based on the Minnetonka public school calendar, so breaks will coordinate.
A swap list will be emailed at the beginning of the school year, and parents are encouraged to use this to swap with other families in times of scheduling conflict. I realize that seasonal sports or other activities might interfere with a chunk of lessons, and if you have a temporary scheduling conflict for 2+ weeks, I will try to find another family that might switch lesson times with you!
Summer lessons operate in a very flexible "a la carte" system. To accommodate busy and varied weekly schedules during summer time, students choose which weeks and times they are able to come for lessons. Unlike the school year where lessons are set at the same time every week, during the summer students are encouraged to take anywhere from 2-8 lessons depending on their schedule. Arrangements are made directly with Emily. Students are not required to take summer lessons to be guaranteed a spot in the fall.
When a student registers for lessons, they have reserved their lesson spot (for example 4:30-5:00pm on Tuesdays) for the entire school year. Prompt attendance and quiet dismissal help guarantee that every student gets their fair share of lesson time! A swap list will be available and it is the parent responsibility to switch lesson times with another family for a week or two if needed. If you encounter a longer term (more than 2 weeks) scheduling conflict, please speak with me to try and find an alternative lesson time. Please be understanding and courteous of my set teaching hours as it affects my own time as a parent! If you find that you are missing or rescheduling more than one lesson a month, this could lead to an early dismissal.
If you are considering an early termination of this contract, you are financially responsible for 4 weeks of lessons after a written notice or email.
To enter/exit the studio, please walk around the garage to the back sliding glass door. Please respect the objects, pets, and other people in my house by using gentle hands and respectful language. If parents would like to leave their child unattended during the lesson, please discuss this with me beforehand.
I schedule two formal studio recitals each year in January and May which I expect all students to participate in. I also schedule two fun concerts each year as well. It is encouraged for students to memorize at least a portion of their recital repertoire. Please ask about other performance opportunities to participate in piano exams, contests, festivals, and other local recitals. There is a wealth of performing opportunities in this area if you are interested!
I maintain a private Facebook page, Youtube channel, and blog for my piano studio. I do post pictures and short video clips of students performances, always in the best possible light. I find that it's motivating and fun to share our piano accomplishments with friends and family. Please let me know if you would not like me to use your child's photo or video in a public space online.


Whether medium-sized family business or globally-active company – the possibilities for an effective internal communication are manifold. One thing is certain: With the right strategy and target group-oriented design of the individual channels you can ensure a smooth flow of information and communication within the company. This in turn fosters motivation, commitment and satisfaction of employees and creates a positive working environment.
This is a question that has been preoccupying the internal communications departments of global groups, as well as internationally operating SMEs, for the last few years.
of a company and are driven in the course of internal communication. This is best achieved with clear and understandable messages"


The Brown University Society for Women Engineers (SWE) will be sponsoring its 12th annual "Extreme Gingerbread House Competition" on Friday, December 7, from 4-6:30 p.m. in the Hazeltine Commons of the new Engineering Research Center.
Twenty teams of 3-5 students and professors will be allowed to pre-register for the competition. Registration for the event is available at goo.gl/ihWXvD. Team leaders are asked to register with the names of team members (3-5 students/faculty) and a team name. Cost of pre-registration is $5 per team, $10 per team to register at the event Friday evening (as space and supplies allow). The Gingerbread House Competition is open to non-engineers.
Each team will be supplied with two boxes of graham crackers, two Ziploc bags of royal icing, and a tray on which to construct their house. Additionally, all teams will be provided with an empty sandwich size Ziploc bag for taking the communal supplies. Foods such as candy canes, M&Ms, teddy grahams, gummy bears, etc., will be kept on a central table. At the start of the one hour time slot of building, one member of each team will be allowed to take the empty Ziploc bag to the communal table and fill the bag with whatever supplies they feel are most valuable for their team's house. All food items will be provided by SWE at the event; teams are NOT allowed to bring any of their own food.
Teams are allowed to bring any tools that they think will be helpful such as knives, drills, etc. Teams are responsible for bringing the necessary power connections/extension cords. If you plan on using tools, please ensure you know how to use them safely and plan to bring the necessary personal protective equipment, such as safety glasses. No chemicals can be used during the manufacturing of the house; the house and all its contents must remain edible at all times.
After exactly one hour, the teams will be forced to stop construction on their houses. The houses will initially be judged before a panel of three faculty judges on (1) Attractiveness of the house [1-10 points] (2) Novel use of building materials [1-5 points] (3) Use of available space (i.e. decorations other than the house) [1-5 points]. Additionally, judges will have the option to select one "wildcard" house after viewing all the completed houses. Judges will award a bonus of three points to the house if they feel that one house was exceptional in a way that was not represented in the other scores; this is optional and at the judges' discretion. The sum of these components will be used as the team's aesthetic score.
The second portion of judging will be on the ability of the house to withstand a simulated earthquake. The tray will be attached to a shake table and cycled through a regimen moving from a low frequency to a high frequency. After every 15 seconds, the frequency will increase. Time will start when the shake table is turned on, and will be stopped when part of the house falls off the main structure; this includes decorations attached to the house, but not "environmental decorations" that are simply on the tray. The final call on whether a house has "failed" will be at the judges' discretion. Houses will not be judged until tables and floors are clean.
Total group scores will be calculated by combining the aesthetic score (out of 25 points) and the stability score (out of 50 points) for a total score out of 75 points. The team with the most points will be considered the winner. The team with the second highest number of points will be given second place and so forth. The top three teams will be awarded a prize.


text:
Ladder of Jacob
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Library of Ancient Texts
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Now it happened on the second Sabbath after the first, that he was going through the grain fields. His disciples plucked the heads of grain, and ate, rubbing them in their hands.
But some of the Pharisees said to them, Why do you do that which is not lawful to do on the Sabbath day?
Yeshua, answering them, said, Haven't you read what David did when he was hungry, he, and those who were with him;
how he entered into the house of God, and took and ate the show bread, and gave also to those who were with him, which is not lawful to eat except for the priests alone?
He said to them, The Son of Man is lord of the Sabbath.
It also happened on another Sabbath that he entered into the synagogue and taught. There was a man there, and his right hand was withered.
The scribes and the Pharisees watched him, to see whether he would heal on the Sabbath, that they might find an accusation against him.
But he knew their thoughts; and he said to the man who had the withered hand, Rise up, and stand in the middle. He arose and stood.
Then Yeshua said to them, I will ask you something: Is it lawful on the Sabbath to do good, or to do harm? To save a life, or to kill?
He looked around at them all, and said to the man, Stretch out your hand. He did, and his hand was restored as sound as the other.
But they were filled with rage, and talked with one another about what they might do to Yeshua.
It happened in these days, that he went out to the mountain to pray, and he continued all night in prayer to God.
When it was day, he called his disciples, and from them he chose twelve, whom he also named emissaries:
Simon, whom he also named Peter; Andrew, his brother; Jacob; Yochanan; Philip; Bar-Talmai;
Matthew; Thomas; Jacob, the son of Halfai; Simon, who was called the Zealot;
Judah the son of Jacob; and Judah Iscariot, who also became a traitor.
He came down with them, and stood on a level place, with a crowd of his disciples, and a great number of the people from all Judea and Jerusalem, and the sea coast of Tyre and Sidon, who came to hear him and to be healed of their diseases;
as well as those who were troubled by unclean spirits, and they were being healed.
All the multitude sought to touch him, for power came out from him and healed them all.
He lifted up his eyes to his disciples, and said, Blessed are you who are poor, for yours is the Kingdom of God.
Blessed are you who hunger now, for you will be filled. Blessed are you who weep now, for you will laugh.
Blessed are you when men shall hate you, and when they shall exclude and mock you, and throw out your name as evil, for the Son of Man's sake.
Rejoice in that day, and leap for joy, for behold, your reward is great in heaven, for their fathers did the same thing to the prophets.
But woe to you who are rich! For you have received your consolation.
Woe to you, you who are full now, for you will be hungry. Woe to you who laugh now, for you will mourn and weep.
Woe, when men speak well of you, for their fathers did the same thing to the false prophets.
But I tell you who hear: love your enemies, do good to those who hate you,
bless those who curse you, and pray for those who mistreat you.
To him who strikes you on the cheek, offer also the other; and from him who takes away your cloak, don't withhold your coat also.
Give to everyone who asks you, and dont ask him who takes away your goods to give them back again.
As you would like people to do to you, do exactly so to them.
If you love those who love you, what credit is that to you? For even sinners love those who love them.
If you do good to those who do good to you, what credit is that to you? For even sinners do the same.
If you lend to those from whom you hope to receive, what credit is that to you? Even sinners lend to sinners, to receive back as much.
But love your enemies, and do good, and lend, expecting nothing back; and your reward will be great, and you will be children of the Most High; for he is kind toward the unthankful and evil.
Therefore be merciful, even as your Father is also merciful.
Don't judge, and you wont be judged. Don't condemn, and you wont be condemned. Set free, and you will be set free.
Give, and it will be given to you: good measure, pressed down, shaken together, and running over, will be given to you. For with the same measure you measure it will be measured back to you.
He spoke a parable to them. Can the blind guide the blind? Wont they both fall into a pit?
A disciple is not above his rabbi, but everyone when he is fully trained will be like his rabbi.
Why do you see the speck of chaff that is in your brothers eye, but don't consider the beam that is in your own eye?
Or how can you tell your brother, Brother, let me remove the speck of chaff that is in your eye, when you yourself don't see the beam that is in your own eye? You hypocrite! First remove the beam from your own eye, and then you can see clearly to remove the speck of chaff that is in your brothers eye.
For there is no good tree that brings forth rotten fruit; nor again a rotten tree that brings forth good fruit.
For each tree is known by its own fruit. For people don't gather figs from thorns, nor do they gather grapes from a bramble bush.
The good man out of the good treasure of his heart brings out that which is good, and the evil man out of the evil treasure of his heart brings out that which is evil, for out of the abundance of the heart, his mouth speaks.
Why do you call me, Lord, Lord, and don't do the things which I say?
Everyone who comes to me, and hears my words, and does them, I will show you who he is like.
He is like a man building a house, who dug and went deep, and laid a foundation on the rock. When a flood arose, the stream broke against that house, and could not shake it, because it was founded on the rock.
But he who hears, and doesn't do, is like a man who built a house on the earth without a foundation, against which the stream broke, and immediately it fell, and the ruin of that house was great.


text:
Nevada burglary suspect shot by police, in stable condition
HENDERSON (AP) — A burglary suspect was shot by police during a foot pursuit in Henderson and is now in stable condition, authorities said.
Henderson Police Capt. Kirk Moore told reporters after the shooting that detectives were conducting surveillance on a man wanted for multiple burglaries. The man was not identified.
Police said officers attempted to stop him around 9 p.m. but the suspect fled authorities on foot. During the pursuit, the suspect allegedly pulled out a firearm, authorities said.
Moore said he believes only one officer fired at the suspect. Police say the suspect did not shoot.
"It is believed that he was hit only one time," Moore said, adding that the man was taken to a hospital and had non-life threatening injuries.
Moore said another officer was injured during the chase, but it was not a gunshot wound. No further information was provided about the injury.
Kirk Moore
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text:
Photo-Op
Transcendent Portraits of Trangender Christopher Street
By Mark Seliger • 10/04/16 7:18am
"My first realization that I was in the wrong body was when my mother told me I was using the restroom incorrectly."— ShaGasyia Diamond Mark Seliger
I've always been intrigued by the life and theater of Christopher Street. I've noticed the photographic possibility out of the corner of my eye for the past couple of decades—an Ellis Island for freedom of expression and gender identity. More recently, I've noticed it vanishing. My interest in photo documentary led to compiling a series of portraits, which have been collected in On Christopher Street: Transgender Stories (Rizzoli New York, 2016).
'She's a trans woman and I'm a trans man, so it actually makes us completely normal. I'm a man and she's a woman, and that's just as simple as it is.'—Jamel Young Mark Seliger
"In a world that is very much heterosexist, patriarchal and misogynistic, I firmly believe that being trans is resistance." —Lucky S. Michaels Mark Seliger
"I did a movie called The Dictator, with Sacha Baron Cohen and Ben Kingsley and Megan Fox, and I wasn't out. And the New York Post outed me as a transsexual actress, which devastated me. I felt very discriminated against."— Victoria Beltran Mark Seliger
"I always wanted to be a boy—always. I don't remember ever not wanting that."—LES LARUE Mark Seliger
All photos © On Christopher Street: Transgender Stories Photographs by Mark Seliger, Rizzoli New York, 2016
Filed Under: Entertainment, Arts, photography, Transgender, Photo Essay, Mark Seliger, Christopher Street, Human Sexuality
SEE ALSO: Thierry Mugler, Fashion's King of Alien Couture, Is Dead at 73


text:
Polling frequency has certainly shot up since Obama claimed enough delegates to secure the Democratic nomination. Things had gotten slow toward the end of the Democratic battle with the uncertainty of Clinton continuing her candidacy increasing, but they have risen again to a level of about 30 polls a week. Following Wednesday morning's release of the Quinnipiac swing state polls in Florida, Ohio and Pennsylvania, there have been 15 new polls in 13 states:
New Polls (June 18-21)
Alaska Rasmussen +4
California Survey USA +12
Colorado Rasmussen +2
Florida ARG +5
Florida Rasmussen +8
Georgia Poll Position +1
Iowa Survey USA +4
Maine Rasmussen +22
Nevada Rasmussen +2
New Hampshire ARG +12
New Hampshire Rasmussen +11
Ohio Rasmussen +1
Virginia Public Policy
Washington Survey USA +15
Wisconsin Survey USA +9
Alaska surprisingly (or not) remains within Obama's reach following a new Rasmussen poll there. The two new polls out of New Hampshire also paint the race in the Granite state as less competitive than it has appeared recently. Two double digit poll margins will typically help. Both have pulled New Hampshire off the Watch List (below) and though the state is still rated as a toss up favoring Obama, it is trending toward a stronger Obama lean. Among the other states polled, not much is different than before: Virginia is still close, but trending toward Obama, California is still favoring the Democrat and well, not many McCain strongholds were polled this week. In the previous electoral college breakdown, new polling had moved Ohio into the Toss Up Obama category, but evidence of how tenuous that lead was came when the new Rasmussen poll favoring McCain brought the weighted average down to zero. But that shift was the only one other than the shocking poll out of Georgia that showed McCain with only a one point lead in the Peach state. That poll is an outlier, given that most of the polling there had hovered around 10 points. However, with Bob Barr's inclusion in the poll, the margin between McCain and Obama was lower and brought the average just under the 10% line dividing strong McCain states from McCain lean states.
Changes (June 18-21)
Georgia Strong McCain Lean McCain
Ohio Toss Up Obama Tied
With those changes the map shifts very little, but Ohio's 20 electoral votes are now withheld from either candidate due to the tie in the Buckeye state. Even then, Obama holds a 38 electoral vote advantage and could withstand the loss of Ohio and still take an electoral college victory.
[Click Map to Enlarge]
On the whole, the momentum remains behind the senator from Illinois. Last week, Michigan and New Hampshire switched from toss ups favoring McCain to toss ups trending toward Obama. And with Ohio's shift earlier this week, Obama took a commanding lead in the electoral college projection. McCain maintains a hold on 202 electoral votes combined in the strong and leaning categories, but with Georgia's switch, that leaning category is growing. Meanwhile, the states on the Obama side are becoming more secure. The strong category grew with the addition of Washington and the toss up category has been augmented by the addition of states that had formerly been toss ups toward McCain.
The Watch List*
Georgia from McCain lean to Strong McCain
Massachusetts from Obama lean to Strong Obama
Michigan from Toss Up Obama to Toss Up McCain
Mississippi from Strong McCain to McCain lean
Nevada from Toss Up Obama to Toss Up McCain
North Carolina from McCain lean to Toss Up McCain
Ohio from Tied to Toss Up Dem. or GOP
Texas from Strong McCain to McCain lean
Wisconsin from Toss Up Obama to Obama lean
*Weighted Average within a fraction of a point of changing categories.
That trend is echoed by the potential movement of states on the lines between categories (The Watch List). Of those nine states, five of them are close to moving into categories closer to Obama. Three others (Michigan, Nevada and Ohio) are so close to the tipping point between candidates that patterns are difficult to determine, though they likely hinge on any new polling that emerges from those states. Georgia is the only state that is on a line that could favor McCain with a move.
The one piece of the puzzle that we don't have a sufficient answer to at this point (following Obama's crossing the Democratic delegate barrier) is how things look in some of the strongly partisan states. It is a more interesting question when posed in relation to those solid McCain states. Is the supposed "Obama bounce" being felt in those states as well? Increased polling will help to answer that question.
FHQ has obviously rolled out a new look for this post in an effort to deliver a clearer picture of what we project to be happening in the chase for electoral college votes. Love it? Hate it? The comments section awaits.
Labels: 2008 presidential election, electoral college projections, June updates, state polls
The real issue is not how well Obama or McCain might do in the closely divided battleground states, but that we shouldn't have battleground states and spectator states in the first place. Every vote in every state should be politically relevant in a presidential election. And, every vote should be equal. We should have a national popular vote for President in which the White House goes to the candidate who gets the most popular votes in all 50 states.
The National Popular Vote bill would guarantee the Presidency to the candidate who receives the most popular votes in all 50 states (and DC). The bill would take effect only when enacted, in identical form, by states possessing a majority of the electoral vote -- that is, enough electoral votes to elect a President (270 of 538). When the bill comes into effect, all the electoral votes from those states would be awarded to the presidential candidate who receives the most popular votes in all 50 states (and DC).
The major shortcoming of the current system of electing the President is that presidential candidates have no reason to poll, visit, advertise, organize, campaign, or worry about the voter concerns in states where they are safely ahead or hopelessly behind. The reason for this is the winner-take-all rule which awards all of a state's electoral votes to the candidate who gets the most votes in each separate state. Because of this rule, candidates concentrate their attention on a handful of closely divided "battleground" states. Two-thirds of the visits and money are focused in just six states; 88% on 9 states, and 99% of the money goes to just 16 states. Two-thirds of the states and people are merely spectators to the presidential election.
Another shortcoming of the current system is that a candidate can win the Presidency without winning the most popular votes nationwide.
The National Popular Vote bill has been approved by 19 legislative chambers (one house in Colorado, Arkansas, Maine, North Carolina, and Washington, and two houses in Maryland, Illinois, Hawaii, California, Rhode Island, and Vermont). It has been enacted into law in Hawaii, Illinois, New Jersey, and Maryland. These states have 50 (19%) of the 270 electoral votes needed to bring this legislation into effect.
See http://www.NationalPopularVote.com
I love the new look!
I figure since Susan brought it up, I'll note my opposition to a national popular vote. She's right that the current system causes candidates to disregard states which aren't competitive. But a national vote would cause retail politics to disappear altogether. The campaign visits she values wouldn't be spread over 50 states, they'd be replaced by fundraisers--largely in places like New York and California. The money she notes would go largely to national media--again in New York and California. I have nothing against those two states; in fact, I grew up in California and have lived in New York for twenty years. But I'd like "flyover" states to have a role other than casting a vote based on candidates who have run only a national campaign.
The past few cycles have had an unusually small number of battleground states. This cycle promises to be different, with Obama threatening to push the campaign into parts of the deep South and mountain West and McCain looking to parts of the "blue" Midwest. Not the full coverage Susan wants, but a reminder that it's tricky to propose a constitutional amendment based on conditions over a short period.
Finally, I'm very uncomfortable with the idea of a candidate piling up votes in big cities and winning that way (and, incidentally, I'm an Obama supporter, so I'm not speaking out of partisan interest). There's a reason we allocate one house of Congress proportionally by population, and the other by states. The Electoral College is a hybrid of the two, and seems a sensible compromise.
Thanks for the vote of confidence, Scott. Organizing these posts this way, I think, will help to deliver a clearer message.
Since Anonymous/Susan continues to post this same comment (word for word, mind you), I think I'll address that issue in its own post. It'd be a good discussion to have more broadly, instead of hidden away in bits and pieces across several electoral college projection posts.
Josh--I look forward to a centralized discussion of the national popular vote idea. Susan did get me to look at the specific proposal under consideration, and I now have further comments. But I'll wait until you provide a place to air them...


text:
require 'rails_helper'
require 'controllers/concerns/tombstoneable'

RSpec.describe CurationConcerns::FileSetsController, type: :controller do
  describe "modules" do
    it { is_expected.to include_module(CurationConcerns::FileSetsControllerBehavior) }
    it { is_expected.to include_module(Sufia::Controller) }
    it { is_expected.to include_module(Sufia::FileSetsControllerBehavior) }
  end

  it_behaves_like "tombstoneable" do
    let(:factory) { :file_set }
  end
end


text:
/pubs/2018handbooks/aos/korean-studies/ug-arts-korean-studies.html
Friday, 01-Jun-2018 11:14:25 AEST 20 January 2020
Korean studies - 2018
Minor / Major / Extended major
School of Languages, Literatures, Cultures and Linguistics
Dr Andy Jackson
Korean studiesKorean studies (http://future.arts.monash.edu/ug-korean-studies/)
The Korean studies program is designed for students who wish to acquire Korean language skills and understand Korean culture and society. The units offered will be useful to students who aspire to a professional career in business, government, communication, and education, among other fields. Korean language teaching incorporates interactive and multimedia resources to enhance learning and bring Korean culture to the classroom. Introducing Hangul, a phonetic writing system, enables students to type in Korean from the introductory level.
The focus is on enabling you to communicate in Korean in a broad range of situations, and the use of Korean in various genre areas such as business, journalism, science, law and tourism. Sociocultural aspects in these areas are also explored. You may complete a major sequence and honours in Korean studies. Combined honours may be taken in the School of Languages, Cultures and Linguistics and another area of study.
Korean language study caters for students from introductory to intermediate levels. To ensure that students are placed in the most appropriate level according to their individual profile and the best outcome they can expect to achieve, all students, except beginners, are required to undertake placement testing prior to the start of their first semester of language study.
Right of school to determine entry level and approve accelerated enrolment
The Korean studies program convenor retains the right to determine the proper proficiency level for any particular student. Students are not permitted to accelerate their enrolment without first consulting the program convenor. Students wishing to enrol in a language unit higher than introductory need to complete a Language entry level testLanguage entry level test (http://artsonline.monash.edu.au/llcl/language-entry-level/) to determine the language level they should be enrolled in.
Overseas study
Students can replace language units with equivalent language study overseas. The Korean studies program has exchange agreements with three prominent universities: Korea University, Seoul National University and Yonsei University. While each exchange has its own features, collectively they provide a wide range of opportunities for students to study in Korea. For detailed information contact the Korean studies program. Credit arrangements vary and need to be clearly verified with the coordinator before a student can be assured of receiving credit. Grants for study may be available through Monash Abroad, to whom applications should be addressed. Third and fourth-year students may also apply for a Korean Government scholarship.
Korean studies is listed in A2000 Bachelor of Arts and at Clayton as a minor, major or extended major, A2001 Bachelor of Global Studies at Clayton as a major and A0501 Diploma of Languages at Clayton as a major.
In addition to achieving the broad outcomes of their course, students successfully completing this major will be able to:
communicate on topics that are familiar, of personal interest, or pertinent to everyday life (e.g. family, hobbies, work, travel and current events)
demonstrate an understanding of the relationship between language and culture, thereby appreciating the validity of other ways of perceiving experiences as well as your own culture, identity and values
demonstrate advanced learning skills which will support your Korean study to pursue other further studies, e.g. Translation studies, Asian studies or Linguistics
draw upon discipline-specific language and appropriate genres to demonstrate understanding within a field from a scholarly perspective and for a specified audience.
Major requirements (48 points)
No more than 12 points at level 1 may be credited to the majormajor (http://www.monash.edu.au/pubs/2018handbooks/undergrad/arts-07.html) and at least 18 points must be at level 3. Six language units (36 points) must be completed.
Note: With permission, students can take language study overseas units in place of some level 2 and 3 language and elective units.
Students complete:
Entry point 1 - Introductory
For students with little or no knowledge of Korean.
Two level 1 gateway unitsgateway units (http://www.monash.edu.au/pubs/2018handbooks/undergrad/arts-08.html) (12 points):
ATS1171 Korean introductory 1
Two level 2 cornerstone unitscornerstone units (http://www.monash.edu.au/pubs/2018handbooks/undergrad/arts-08.html) (12 points):
ATS2173 Korean intermediate 1
One level 3 capstone unitcapstone unit (http://www.monash.edu.au/pubs/2018handbooks/undergrad/arts-08.html) (6 points) chosen from:
ATS3083 Translating across cultures
ATS3089 Social institutions and power in Asia
ATS3816 The social context of language learning
Two language units (12 points):
ATS3175 Korean proficient 1
One unit (6 points) chosen from the remaining capstone units or the elective list below.
Entry point 2 - Intermediate
For students who have a basic Korean proficiency equivalent to Korean introductory 2.
ATS1319 Global Asia
ATS1339 Putting words together
Minor requirements (24 points)
No more than 12 points at level 1 may be credited towards the minorminor (http://www.monash.edu.au/pubs/2018handbooks/undergrad/arts-07.html).
For students in the Introductory stream the first two units (12 points) from the Korean language sequence.
For students in the Intermediate stream, the following two gateway unitsgateway units (http://www.monash.edu.au/pubs/2018handbooks/undergrad/arts-08.html) (12 points):
For students in both streams, two level 2 or level 3 units (12 points) chosen from the Korean language sequence taken in order, or cornerstone or capstone units, or the elective list
Extended major requirements (72 points)
No more than 24 points at level 1 may be credited to the extended major and at least 24 points must be at level 3.
Students are required to undertake a period of overseas study in order to complete an extended major.
The requirements of the major in Korean studies (48 points)
Any combination of the following to a total of 24 points:
ATS3139 Extended major research unit
study overseas units
one 6-point elective unit
Elective list
Units are 6 points unless otherwise stated.
ATS2671/ATS3671 Managing intercultural communication
ATS2681 Structure of English
ATS2941 Asia's underside: Violence, crime and protest
ATS3064Not offered in 2018 Cultural intelligence: Building competencies for global leadership
ATS3156 Popular culture in North and South Korea, Hallyu and East Asian cultural flows
ATS3627 Global Cultures, media flows: creating and consuming (popular) culture
ATS3935 Professional practice
Note: Electives from other areas of study with substantial Korean studies content may be approved by the Korean program convenor.
Intending honours students
Students intending to enter honours in this area of study must have completed a major in the discipline, with a minimum of 24 points of study at level 3 to be eligible.
Related areas of study
Communications and media studies
English as an international language
Film and screen studies
Global cultural literacies
A0501 Diploma of Languages
Successful completion of the minor or major can be counted towards meeting the requirements for the following single degrees:*
A2000 Bachelor of Arts
A2001 Bachelor of Global Studies
Students in other single bachelor's degrees may be eligible to complete the minor or major by using 24 or 48 points of their free electives.
Successful completion of the minor or major can be counted towards meeting the requirements for the Bachelor of Arts component in the following double degrees:*
A2005 Bachelor of Arts and Bachelor of Fine Art
A2004 Bachelor of Arts and Bachelor of Music
B2019 Bachelor of Business and Bachelor of Arts
B2012 Bachelor of Business Specialist and Bachelor of Arts
B2020 Bachelor of Commerce and Bachelor of Arts
B2006 Bachelor of Commerce and Bachelor of Global Studies
B2024 Bachelor of Commerce Specialist and Bachelor of Arts
D3002 Bachelor of Education (Honours) and Bachelor of Arts
E3002 Bachelor of Engineering (Honours) and Bachelor of Arts
C2002 Bachelor of Information Technology and Bachelor of Arts
L3003 Bachelor of Laws (Honours) and Bachelor of Arts
L3009 Bachelor of Laws (Honours) and Bachelor of Global Studies
S2006 Bachelor of Science and Bachelor of Arts
S2003 Bachelor of Science and Bachelor of Global Studies
* Students cannot complete both the minor and major in the same area of study.
Authorised by: Student and Education Business Services. Maintained by: eSolutions Service Desk. Last updated: 01 June 2018


text:
Volvo EV General Discussion Forum
Volvo On Demand is Volvo's New Shared Mobility Platform
M, the shared mobility brand launched by Volvo is now becoming Volvo on Demand.
https://www.media.volvocars.com/global/en-gb/media/pressreleases/303466/volvo-on-demand-to-continue-reshaping-how-people-think-about-mobility-and-car-ownership
After a successful expansion with 250,000 registered customers and nearly a million completed journeys in Sweden, M, the shared mobility brand launched by Volvo Cars, is becoming Volvo On Demand. Developed and operated by the subsidiary, Volvo Car Mobility, Volvo On Demand continues to expand to rethink car ownership and urban mobility.
A unique mobility platform, to extend the ways customers can access Volvo cars. It is part of a long-term strategic investment to increase the significance of shared mobility in Volvo Cars, to deliver on our aim to provide personal, sustainable and safe mobility and our ambition to become a circular business by 2040. Volvo On Demand is planned to be expanded beyond Sweden's borders with an extended service range.
External analysis shows that one shared car from Volvo Car Mobility currently replaces the need for up to nine privately owned cars in Swedish cities, today corresponding to an annual reduction of over 16 thousand tons of CO2 emissions. The shared mobility service is freeing up space in cities, helping customers to a more sustainable lifestyle while saving time and money.
Volvo On Demand will continue to be powered by Volvo Cars' proprietary AI-driven mobility platform. At the core of the platform is Volvo Car Mobility's dynamic intent model, a market-leading architecture that allows for advanced demand prediction and supply optimisation, backed by AI-supported technologies.
"At Volvo Cars, we want to provide complete freedom to move in a personal, sustainable, and safe way," says Magnus Fredin, Senior Vice President Global Online Business at Volvo Cars. "Volvo Car Mobility's future-forward strategy is helping us to deliver on that promise. Volvo On Demand will make new inroads into the evolution of flexible car access. We're thrilled to be on this journey together. Volvo On Demand is able to reach target groups that don't necessarily want to own a car but need occasional access to one."
"We look forward to accelerating growth based on our mobility platform and becoming a part of Volvo Cars' core offer", says Erik Jivmark, CEO of Volvo Car Mobility. "We expect new product offers and an international expansion to vastly expand the customer base and put us on an entirely new growth trajectory."
Current users of the M service, launched in 2019, will discover the new user interface and a refreshed look and feel already in September 2022. The service will function as usual during this transition.
EVolvo 5 mo ago