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IASB Board Meeting 19-23 January 2009
Derecognition
Technical Plan
IFRIC Interpretation 16
Proposed IFRIC Interpretation: Transfers of Assets from Customers
Annual Improvements 2009
Conceptual Framework Phase C — Measurement
Conceptual Framework Phase D — Reporting Entity
Conceptual Framework Phase A — Objective and Qualitative Characteristics
IFRS for Private Entities
Fair Value Measurement
Financial Instruments with Characteristics of Equity
Financial Instruments Disclosures
IFRS 7 Amendment - Investments in Debt Instruments ED
Fair Value Meausrement and IAS 39
Post-employment benefits
Start date: 19 Jan 2009
End date: 23 Jan 2009
IASB Board Meeting Agenda
Monday 19 January 2009 (afternoon only)
Conceptual Framework Phase A - Objective and Qualitative Characteristics
Conceptual Framework Phase C - Measurement
Conceptual Framework Phase D - Reporting Entity
IFRIC:
Proposed IFRIC Interpretation: Transfers of Assets from Customers - Board vote to ratify
IFRIC Interpretation 16 Hedges of a Net Investment in a Foreign Operation - Amendment to the restriction on the entity that can hold hedging instruments
Annual Improvements 2008: - Analysis of comments on the August 2008 Exposure Draft
Fair Value Measurement (continued)
IFRS 7 Amendment - Improving Disclosures about Financial Instruments - Analysis of comments on the October 2008 Exposure Draft
Derecognition (continued from Monday)
Leases (continued from Monday)
IFRS 7 Amendment - Investments in Debt Instruments ED - Analysis of comments on the December 2008 Exposure Draft
Friday 23 January 2009 (morning only)
Sweep Issues (if needed)
Meeting series
IASB meetings (2009)
The Board discussed several aspects the FASB decisions and the possible impact on the IASB's project, particularly on the timing and possible delays.
The staff informed the Board that the FASB has made the decision that lessor accounting (including subleases) should be further analysed and included as a high level discussion in the upcoming discussion paper (DP) with specific questions, but without changing the scope of the DP.
The staff noted that the FASB has also discussed whether in-substance purchases should be within the scope of the project, but decided no change in scope.
Furthermore, FASB discussed how a right-of-use model as proposed for lessees in the DP could be applied to lessor and decided that its DP should have a high-level discussion of lessor accounting.
The staff asked the Board whether it was willing to defer publication of the DP to include the outcome of the FASB staff analysis.
The Board discussed several aspects of these outcomes of the FASB discussion and the possible impact on the IASB's project, particularly on the timing and possible delays. Staff was asked how long the additional analysis by the FASB on lessor accounting would take. Staff responded that could be a matter of weeks, but possibly a month.
The chairman noted that this would cast doubt over the 2011 completion goal and expressed concerns over the massive changes of the Board membership at that point. He proposed that the IASB should go ahead with the DP as it stands and publish any output from the FASB as a supplementary DP. The IASB DP, to be issued shortly, should highlight that there is more to come.
The Board agreed.
The Board discussed deliberations on its upcoming exposure draft on derecognition of financial assets and financial liabilities.
The Board continued its deliberations on the upcoming ED on derecognition of financial instruments. The staff gave the Board a brief update on where it was at the moment and what issues would be discussed at the January meeting. At this meeting the following issues were presented:
Transfers involving derivatives, hybrid instruments and equity instruments
Transfer of a component of an asset = different asset after transfer?
Similar criterion for transfers of groups involving financial assets
Linked presentation (will be discussed at Thursday's session)
Transfers involving derivatives, hybrid instruments and equity instruments (D/HI/EI)
The staff informed Board members that the Board would have to decide whether components as defined in flowchart 2 of the staff proposals should specifically exclude transferred portions of derivatives, hybrid instruments with separable embedded derivatives, and equity instruments. The staff proposed four alternatives (table below taken from the observer notes):
Portions of D/HI/EI* that involve specified and/or proportionate cash flows
Portions of D/HI/EI that involve specified and/or proportionate cash flows (including those instruments that could be assets or liabilities)
Portions of D/HI/EI* that involve specified and/or proportionate cash flows or other future economic benefits (incl those instruments that could be assets or liabilities)
*D/HI/EI = Derivatives, hybrid instruments with embedded derivatives that require bifurcation or equity instruments.
The Board discussed, as an example, an interest rate swap. It was highlighted that it could be seen as one net stream or two streams (one inflow, one outflow). Board members seemed to come from different opinions on what the asset was and, hence, had different opinions on which alternative was appropriate.
The staff proposed alternative 4, which was a broad definition. However, the Board agreed on alternative 2, which would keep the component definition in IAS 39.16. The Board also agreed that the derecognition tests in flowchart 1 refer to 'cash flows or other future benefits'.
This issue was a follow-on issue resulting from the discussion at the December Board meeting on non-recourse secured borrowings: Does the transfer of a component lead to the original financial asset ceasing to exist. As a consequence, any gain/loss resulting would have to be recognised when the transaction was entered into. It was highlighted that under a full fair value model this would not render any different outcome.
The staff recommended that the components a transferor retains are accounted for as new assets. After brief discussion, the Board agreed.
The staff sought the Board's input on whether a similar criterion is necessary for transfers of components of groups of whole financial assets and for transfers of a group of whole financial assets.
The Board agreed with the staff recommendation that, for transfers of groups of whole financial assets, the similar criterion in IAS 39.16 could be deleted. The staff noted that, as a consequence, the 'continuing involvement' step and the 'practical ability to tansfer' test in flowchart 2 would be applied to the group as a whole.
On the issue of components of groups, the staff noted that any decision must be consistent with the Board decision on transfers involving derivatives, hybrid instruments, and equity instruments. The Board was interested in the consequences for certain scenarios and said that the guidance should not lead to confusion amongst constituents what it was aiming at.
The Board, after a short discussion, agreed to strike out 'similar' from the component definition of IAS 39.16 for components of groups, but that the guidance was to make clear that:
None of those assets can be assets that can, during their life, be an asset or a liability
None of those assets can be equity instruments that involve future economic benefits other than cash flows (for example, shares)
Finally, the staff gave the Board a brief update on the comment letters received by the FASB on its proposed changes to the US consolidation standards.
The IASB staff directors presented the latest version of the IASB's Technical Plan. The staff noted that since the last version of the plan had been discussed, a number of short-term projects had been added to the Board's agenda-primarily in response to the G20's Action Plan to Implement Principles for Reform.
Derecognition had been accelerated, and an ED is expected either late in 1Q2009 or early 2Q2009. An ED of fair value measurement guidance should be issued as planned leter in 1Q2009. Roundtable discussions of both of those projects are likely to be held in late April or May 2009. The locations of these roundtables will be London and other locations to be determined. Meetings outside London especially are likely to be held over two days, to make the best use of Board and participant time.
Certain projects were noted to be 'at risk' (subject to very tight time constraints with little room for slippage). These were revenue recognition and financial statement presentation (already in this category), each with an IFRS expected in June 2011. Added to this category was Leases, for which the Discussion Paper has been delayed by late issues that need to be addressed in January. The staff is concerned that if the DP is not issued by March 2009, an IFRS by June 2011 would be a challenge.
The staff expects some delay in the Phase B of the Framework (elements and recognition). A Discussion Paper for this phase is now scheduled in the middle of 2010 rather than 4Q2009. Other phases of the Framework remain 'on track'.
The IFRS resulting from ED 9 Joint Arrangements is expected late in 2Q2009. The staff wishes to coordinate the release of the consolidation standard arising from ED 10 and that for joint arrangements. Issuing consequential amendments to a standard just issued was thought likely to be more annoying to constituents than delaying the IFRS a month or two.
A revised project plan will be released on the IASB's Website in the very near future.
The Board discussed an issue that had been submitted by a constituent subsequent to the publication of IFRIC 16. The staff had satisfied itself (in consultation with Board members and an IFRIC member) that the constituent's issue was valid and had not been contemplated by the IFRIC when IFRIC 16 was being developed. The concern raised was that in some circumstances, while the total amounts of foreign exchange differences are indeed the same with and without hedge accounting, the split between the amounts included in profit or loss and foreign currency translation reserve would be different. Without hedge accounting, the foreign exchange difference arising from the hedging instrument would be included in profit or loss while the difference arising from the net investment would be included in the foreign currency translation reserve.
The Board agreed to amend IFRIC 16 paragraph 14 by deleting a parenthetical comment: '(except the foreign operation that itself is being hedged)'.
So this amendment can be in place in time to be used for 30 June 2009 interim financial reporting, the Board agreed that it should issue an exposure draft of the proposals for a 30-day comment period (the minimum permitted by the IASB's Due Process Handbook). It was acknowledged that it was unlikely that any amendment could be finalised in time to accommodate first quarter 2009 interim reporting.
The Board approved, subject to written ballot, IFRIC [18] Transfers of Assets from Customers (see IAS Plus Report of the December 2008 IFRIC Meeting for details).
The Board analyzed various comments and discussed IAS 7, IFRS 3 and IFRIC 9.
The Board received but did not discuss the Staff's 'Summary of preliminary comment letter analysis, deliberation objective and provisional project plan'. Under the project plan, the staff expects to complete all redeliberations, including any sweep issues, by the March 2009 IASB meeting, allowing the Improvements IFRS to be issued in April 2009.
Comment analysis - Minor issues
The Board agreed the staff's proposed disposition of the following proposals. A majority of respondents concurred with the Board's proposals:
Scope of IFRS 2 and revised IFRS 3 (IFRS 2)
Disclosures of non-current assets (or disposal groups) classified as held for sale or discontinued operations (IFRS 5)
Unit of accounting for goodwill impairment (IAS 36)
Additional consequential amendments arising from revised IFRS 3 (IAS 38)
Measuring the fair value of an intangible asset acquired in a business combination (IAS 38)
A Board member objected to the staff's proposed amendments to the implementation guidance in IAS 18 with respect to determining whether an entity is acting as a principal or as an agent. The Board member was concerned that the IASB would introduce jurisdictional bias in to its guidance that was neither necessary nor desirable at the level of (non-mandatory) implementation guidance. The Board member would not amend the IG at all. It was unclear whether the Board as a whole concurred with this view.
IAS 7 - Classification of expenditures on unrecognised assets
The Board agreed to modify the amendment to IAS 7 paragraph 16, such that it would state:
16 The separate disclosure of cash flows arising from investing activities is important because the cash flows represent the extent to which expenditures have been made for resources that are recognised as long-term assets and other investments not included in cash equivalents in the statement of financial position. Examples of cash flows arising from investing activities are: (a) ...
A proposal to amend IAS 7 paragraph 32 (not included in the ED) was not approved.
Scope of IFRIC 9 and Revised IFRS 3 (new issue)
The Board agreed that an amendment to paragraph 5 of IFRIC 9 Reassessment of Embedded Derivatives was necessary to clarify that the scope of IFRIC 9 excludes contracts with embedded derivatives acquired in a combination between entities under common control or in the formation of a joint venture. With the revised definition of a 'business' in IFRS 3 (2008), the formation of a joint venture was brought within the scope of IFRIC 9, something that the Board had not addressed specifically as it developed IFRS 3 (2008).
The Board agreed that the scope of IFRIC 9 should be amended to read as follows:
5 This interpretation does not apply to the acquisition of contracts with embedded derivatives in:
a. a business combination;
b. a combination of entities or businesses under common control as described in paragraphs B1-B4 of IFRS 3 Business Combinations (as revised in 2008); or
c. the formation of a joint venture as defined in IAS 31 Interests in Joint Ventures
nor their possible reassessment at the date of acquisition.
So this amendment can be in place in time for the effective date of IFRS 3 (2008) - 1 July 2009 - the Board agreed that it should issue an exposure draft of the proposals for a 30-day comment period (the minimum permitted by the IASB's Due Process Handbook).
The Board continued its discussions of the chapter of the Framework devoted to measurement. No formal decisions were made, although the Board did give a very strong indication of its views at several points.
Careful communication of what the Board was trying to achieve in the Framework was also a theme in this discussion, particularly as many Board members had misunderstood what the staff had proposed in the agenda paper.
Reducing the number of potential measurement bases
The Board discussed a proposal that some measurement bases previously considered candidates for consideration be eliminated. The staff suggested that reducing the number of measurement bases in the Framework (assuming a mixed-basis measurement model) would simplify and thus improve the Framework. The staff proposed to eliminate the following:
Actual or estimated past entry prices, and past estimated exit prices;
Forecast future prices, and forecast future exit prices; and
Value in use.
Many Board members thought that by eliminating 'past prices', the staff was suggesting eliminating historical cost accounting. The staff explained that this was not their intention. An asset or liability would be recognised initially at a current price. That initial amount might or might not be remeasured. However, trying to determine past prices or future prices was an unnecessary theoretical exercise. With this explanation and clarification, the Board agreed with the staff recommendation.
With respect to value in use, the Board agreed with a suggestion made by the US Financial Accounting Standards Board in an educational session earlier in January, that value in use be considered a present value technique and be subsumed in the other 'non-price based' measurement methods.
The Board agreed that, for the moment, the various candidates could be grouped into two broad categories: 'Actual prices' and 'Non-price amounts'. Actual prices would include actual or estimated current market entry prices and estimated current market exit prices. Non-price amounts would include 'market participant view amounts', such as fair value-based amounts (for example, those used in FAS 123R), and 'entity-specific amounts', such as value in use.
The Board discussed various issues raised by respondents to the Board's Discussion Paper Preliminary Views on an Improved Conceptual Framework for Financial Reporting: The Reporting Entity. The decisions made in this session will be accommodated in the next phase of this project, which is an exposure draft due later in 2009.
Definition of the reporting entity
The Board agreed that the reporting entity should be described and defined in the Framework as:
The Board agreed that a reporting entity would usually have 'observable boundaries' that would have legal or contractual rights attached to them. This would permit (not preclude) a branch or segment of a legal entity being a reporting entity.
The Board agreed to clarify that a reporting entity should be determined based on the economic activities the entity is capable of or authorised to conduct and agreed that changes in Phase A (Objectives and Qualitative Characteristics) regarding the primary users of financial reports should be carried over to the definition of a reporting entity.
Implications of the definition
With almost no discussion, the Board agreed the following implications of the definition of the reporting entity:
A reporting entity need not be a legal entity
That the ED should clarify that a legal entity likely would (but not necessarily) meet the definition of a reporting entity
A branch or segment of a legal entity could meet the description of a reporting entity
Group reporting entity
With respect to the group reporting entity, the Board agreed that:
The ED should acknowledge both the controlling entity model and the common control model, and should include a discussion of when the common control model might be appropriate. (The FASB in an educational session earlier in January 2009 had suggested that the controlling entity model should be used in most cases. The IASB thought this was too prescriptive for a concepts-level document.)
The ED should not discuss the risks and rewards model as a standalone model but discuss it in the context of complementing the controlling entity model (if appropriate)
The ED should not discuss models other than the controlling entity model and the common control model.
Consolidated and parent-only financial statements
While agreeing with what the staff were proposing, the Board disagreed with how they had expressed their proposals in the agenda paper, especially a proposal that the 'financial statements of an entity that does not have a subsidiary, affiliate, or venturer's interest in a jointly controlled entity should be considered consolidated financial statements', which they thought was particularly unhelpful.
The Board seemed to agree with a suggestion that emerged during the discussion that the focus should be that the financial statements should present the consolidated results of the controlling entity (that is, the parent) and all subsidiaries (if any). If the parent had no subsidiaries, these 'top level' financial statements would still be IFRS general purpose financial reports and should be within the scope of (for example) the EU IAS Regulation. The Board also agreed that parent-only financial statements, provided they were presented with the consolidated financial statements, could be described as 'general purpose financial statements.' A majority of the Board seemed to be of the view that, if presented alone, parent-only financial statements were 'special purpose' because (while useful) they were incomplete.
The Board agreed that the ED should not discuss whether or how parent-only financial statements should be presented (this is either a jurisdictional or standards-level issue).
The Board commenced its redeliberations of Chapter 2 of the Exposure Draft of Phase A of the Conceptual Framework project: Qualitative Characteristics and Constraints of Financial Reporting.
The Board commenced its redeliberations of Chapter 2 of the Exposure Draft of Phase A of the Conceptual Framework project: Qualitative Characteristics and Constraints of Financial Reporting. In particular, the Board discussed:
whether the revised Framework should classify or somehow distinguish the qualitative characteristics, and if so, whether the classifications in the ED continue to be appropriate; and
whether the term 'reliability' should be replaced by 'faithful representation' as proposed in the ED.
Classifying the qualitative characteristics
Board members agreed that a distinction needed to be made and that the proposal in the ED between 'fundamental' and 'enhancing' was appropriate.
However, the fact that a qualitative characteristic was not labelled as 'fundamental' should not be taken to mean that it was 'not important'. This would need more careful explanation. In addition, the Board agreed that there was no hierarchy implied in the enhancing characteristics. Board members found the proposals a significant improvement over the existing guidance and something that helped to structure their thinking. Several agreed that, for any given issue, the relative importance of the various enhancing characteristics would differ, but that they were all necessary components of relevance and faithful representation in financial reporting.
Reliability vs. Faithful Representation
The Board reaffirmed its desire to use 'faithful representation' in preference to 'reliability' as a qualitative characteristic.
Although some Board members were cautious about losing the term 'reliable' from the general IFRS lexicon, other Board members and IASB senior staff noted that 'reliable' was one of the most problematic terms in that lexicon. Some used it to imply precision; others used it as an excuse to avoid recognising liabilities; others to imply verifiability. The Board concluded that the only way to avoid this misuse and the consequent mis-communication was to focus on what the Framework was trying to communicate was to use a different term. 'Faithful representation' was perhaps not the ideal term, but it was the best they had.
Title of the Standard
The Board agreed that the title should be 'International Financial Reporting Standard for Non-publicly Accountable Entities' (IFRS for NPAEs).
Rewrite of Section 11A Basic Financial Instruments
Initial Measurement
The Board agreed with the restatement of the initial measurement principle for basic financial instruments as follows:
When a financial asset or financial liability is recognised initially, an entity shall measure it at the transaction price. If payment for the asset is deferred or is financed at a rate of interest that is not a market rate, the entity shall measure the asset or liability at the present value of future payments discounted at a market rate of interest.
However it was agreed that some of statements about discounting were problematic and a review by the staff was required in order to ensure that the wording throughout was consistent with that in Example 3 of 11A.11 of the draft Standard.
Derecognition and Factoring
The Board agreed that the guidance on factoring should be consistent with the general principles on derecognition. It was therefore agreed that the proposed paragraphs of special guidance on factoring should be deleted and replaced with two examples of factoring - one that resulted in derecognition and one that did not - based on general derecognition principles.
The Board also decided that the guidance on loan commitments, as outlined in 11A.12(b) should be moved to Section 11B Additional Financial Instruments Issues.
First Draft of Section 11B Additional Financial Instruments Issues
The Board requested that the wording of 11B.4 be clarified. No other issues raised.
Redeliberation of Issues Relating to Other Sections
The Board redeliberated six issues as follows:
Accounting policy options
The staff had recommended that a number of complex options should not be available to private entities. The Board decided that each option needed to be considered on its own merits rather than an 'all or nothing' approach to allowing options within the IFRS for NPAEs. While no final decisions were reached at the meeting, the board tentatively held the following views in respect of each option:
Investment property. Measurement should be circumstance-driven rather than allowing NPAEs an accounting policy choice between the cost and fair value methods. The Board decided if the fair value of an item of investment property can be measured reliably without undue cost or effort, the fair value through profit or loss method must be used. Otherwise, the cost-depreciation-impairment method must be used.
Property, plant and equipment. The revaluation model should not be an option.
Intangible assets. The revaluation model should not be an option.
Borrowing costs. All borrowing costs should be charged to expense. The capitalisation model should not be an option.
Presenting operating cash flows. NPAEs should be permitted to use either the indirect method or the direct method to present operating cash flows in the cash flow statement.
Development costs. All research and development costs should be charged to expense Capitalisation of development costs should not be an option.
Financial instruments. An NPAE will have a choice of applying Section 11 of the IFRS for NPAEs or all of the provisions of full IFRSs - the three financial instrument standards (IAS 32 Financial Instruments: Presentation, IAS 39 Financial Instruments: Recognition and Measurement, IFRS 7 Financial Instruments: Disclosures), and related interpretations. Due to the size of the additional material that would need to be incorporated into the IFRS for NPAEs, the option to use full IFRSs will be available by cross-reference. This would be the only cross-reference to full IFRSs.
Associates. The options proposed in the ED (cost method, equity method, and fair value through profit or loss) should all be allowed.
Jointly controlled entities. The options in the ED should all be allowed with the exception of proportionate consolidation. Therefore NPAEs could choose the cost method, equity method, or fair value through profit or loss.
Consolidated and Separate Financial Statements
The staff recommended that consolidated financial statements be required only when certain conditions are met. The Board disagreed and concluded that consolidated financial statements should be required for all private entities that are parent entities.
Special Purpose Entities (SIC 12)
The Board agreed with the staff recommendation that the guidance in SIC 12 Special Purpose Entities is appropriate for private entities and agreed with the addition of 3 paragraphs to Section 9 of the draft Standard.
Remove distinction between distributions from pre-acquisition and post-acquisition profits under the cost method in the sections on consolidation, associates, and joint ventures
The Board agreed with the staff recommendation to update the relevant sections of the draft Standard to reflect the May 2008 amendments to IFRS 1 and IAS 27 in respect of cost of an investment in a subsidiary, jointly-controlled entity, and associate. This removes the requirement to separate the retained earnings of the investee into pre-acquisition and post-acquisition components as a method for assessing whether a dividend is a recovery of its associated investment.
Amortisation of goodwill and intangibles
The Board agreed with the staff recommendation that indefinite life intangibles including goodwill should be amortised over their useful life subject to a maximum period of 10 years. As proposed in the ED, there would be a requirement to assess at each reporting date whether there are indicators of impairment. The Board agreed that the Basis of Conclusions should explain that this treatment had been allowed on the basis of a cost-benefit analysis rather than being justified on a conceptual basis.
The Board continued redeliberation of issues arising from the Discussion Paper Fair Value Measurements to be included in the forthcoming exposure draft.
FASB staff were present for this session via telephone.
Scope assessment
The Board discussed two issues related to the proposed scope of the ED on fair value measurement guidance:
whether to exclude from the scope of a fair value measurement standard any uses of 'fair value' in IFRSs that have a measurement objective that is inconsistent with the Board's proposed definition of fair value as a current exit price (and the related guidance); and
whether to place constraints on the use of 'fair value' in particular standards.
The staff noted that the 2006 discussion paper stated that the Board would complete a standard-by-standard review of fair value measurements required in IFRSs to assess whether the IASB or its predecessor intended each fair value measurement basis to be a current exit price. That review was completed and the results presented to the IASB in July 2008.
Entry equals exit price on initial recognition
The staff noted that there was a need to explain carefully what the Board means by 'entry equals exit'. In particular the staff noted that the fair value measurement approach developed by the Board considers two separate transactions (that is, the actual transaction to buy the asset and the hypothetical transaction to sell the asset). For both of those transactions, the focus is the reporting entity's perspective. The Board had a long and disjointed debate about this issue, which served to highlight that the use of a measure called an 'exit price' remains a stumbling block with a couple of Board members.
Applying fair value as an exit price to an entity's own equity instruments
The staff noted that unlike assets and liabilities, an entity cannot 'exit' its rights and obligations associated with its own ownership interests unless those interests cease to exist (for example, if the entity is acquired by another entity). This is because equity instruments represent a residual interest in the entity, irrespective of who holds them. The Board debated how best to address this conundrum, deciding that a practical solution would be to deem the exit price of an equity instrument for the issuer to be the same as the exit price for a holder.
Scope assessment and recommendations
The Board discussed the staff's scope assessment briefly and agreed that the ED should propose that the following be excluded from the scope of the fair value measurement guidance:
share-based payment transactions;
reacquired rights in a business combination; and
financial liabilities with a demand feature (at least one Board member objected to this conclusion).
The staff undertook to revisit whether financial instruments subsequently measured at amortised cost should be within the scope of the proposed IFRS.
The presumption that fair value should be defined as an exit price was confirmed.
The staff confirmed that, in the proposed conforming amendments to other IFRS, the ED would propose removing 'how to' guidance on fair value that was inconsistent with the proposed approach (e.g. that in IAS 40).
A review of older Interpretations would be undertaken to ensure that the use and application of fair value was consistent with the ED. The staff was confident (having worked with the IFRIC staff) that the more recent IFRIC Interpretations that used the term were consistent with the ED.
Day One gains-Service contracts
The staff noted that the Board had consistently taken the view that the transaction price is generally the best evidence of the fair value of an asset or liability at initial recognition (with some exceptions, such as related party transactions, distressed transactions, different markets or different units of account). The staff discussed that presumption in the context of a contract to provide services (such as a investment fund management contract, or an insurance contract).
Board members noted that many of the issues that the staff was raising were exactly the same as those addressed in the revenue recognition project, for which a Discussion Paper is currently open for comment. The staff agreed and noted that the staff recommendations were consistent with the Board's Preliminary Views in the DP.
The Board confirmed that for a contract to provide services:
the only true exit market for the provider is the secondary (wholesale) market with other providers, not the primary (retail) market with customers.
the exit price for the provider reflects the perspective of the provider, not the perspective of the customer.
at initial recognition, the exit price for the provider is likely to differ from the transaction price because the provider will typically price the transaction to recover its direct and indirect origination costs and to provide a reasonable return on the origination activity. In contrast, a transferee would not require payment for the origination activity performed by the original provider.
The Board discussed a summary that presented and compared the current disclosure requirements of IFRS 7, the October 2008 ED of proposed improvements to IFRS 7 and FAS 157, with disclosures likely to be proposed in the FVM ED. In addition, the staff had highlighted certain differences between the IASB's proposed disclosures and those required by FAS 157. The Board agreed with the proposed disclosures.
In addition, the Board agreed:
to require entities to disclose fair value measurement information by class of asset or liability rather than by major category;
not to differentiate between recurring and non-recurring fair value measurements;
to require disclosure of purchases, sales, issues and settlements separately for Level 3 assets and liabilities;
to remove the reference to realised and unrealised gains or losses;
to amend IAS 34 to require entities to provide updated interim fair value disclosures if, for example, there is a significant change in the business or economic circumstances; and
to provide the disclosure examples in (non-mandatory) implementation guidance rather than in (mandatory) application guidance.
The disclosures required under the proposed IFRS would replace (and not supplement) those in IFRS 7.
Transition requirements
The Board agreed that the ED should propose that the fair value measurement requirements should be applied prospectively as of the beginning of the annual period in which the IFRS is initially applied, except for financial instruments measured at fair value at initial recognition using the transaction price in accordance with paragraphs AG76 and AG76A of IAS 39. Early adoption would be permitted under the usual rules. The Board agreed that the difference between the carrying amount and the fair value of a financial instrument that was measured at initial recognition using the transaction price prior to the initial application of the proposed IFRS should be applied retrospectively as an adjustment to retained earnings as of the beginning of the annual period in which the proposed IFRS is initially applied, presented separately. This would take into consideration the practical limitations involved in applying the change in accounting policy in all prior periods. In addition, the Board agreed not to require the disclosure requirements for a change in accounting policy under IAS 8.
In order to achieve comparability in future periods, the Board agreed that all of the disclosures required by the proposed IFRS would be required from the date of first applying the proposed IFRS, and that those disclosures need not be presented in periods prior to the initial application of the proposed IFRS.
Comment period
The Board agreed that the ED should be exposed for comment for 120 days, the normal comment period for a standards-level consultation document.
Sweep Issue
The staff raised an issue that emerged during the deliberations on fair value measurement. Under IAS 39 Financial Instruments: Recognition and Measurement, the amount initially recognised for items that are not remeasured at fair value is not fair value as it would be defined in the fair value measurement project. The staff proposed words that could address this issue. The Board agreed to the staff approach, but asked the staff to develop words with a positive and not a negative notion.
The Board discussed the developments of the proposals for an Exposure Draft on financial instruments with the characteristics of equity.
The Board continued its discussions on developing the proposals for an Exposure Draft on financial instruments with the characteristics of equity. At this meeting the staff sought for the Board's input on classification of puttable and mandatorily redeemable instruments (thereafter 'redeemable instruments') with the characteristics of equity. The staff identified four possible alternatives for the accounting treatment of such instruments:
All perpetual and some redeemable instruments are classified as equity
Separate redeemable instruments into equity and non-equity components
Develop rules on which instruments are to be classified as equity
Classify all redeemable instruments as liabilities.
Before the actual staff proposals were discussed, one staff member presented an alternative approach to addressing redeemable instruments. It was noted that this approach involves two steps: firstly, identifying what is to be recognised and, as a second step, deciding how the 'things' that qualify for recognition are to be classified.
The staff member noted that the following 'things' would potentially be eligible for recognition in financial statements:
Rights of other parties to compel an entity to take actions it would otherwise not take for no (additional) compensation
Ownership or property rights in the entity held by other parties
Any amounts of assets in excess of what would be required to satisfy the items in the previous two points (this could occur in co-operative, mutual entities, etc.)
On the issue of classification criteria it was noted that the staff member's approach was based only on one factor: subordination. The staff member highlighted that two issues were already identified where this criterion would have to be further developed: consolidation and anti-abuse provisions).
The Board had a lively debate on the approach. One Board member asked whether the staff member would see a puttable instrument as more or less subordinated as a perpetual instrument. It emerged that much of this discussion was depending on the definition of subordination. The Board continued to debate whether a further distinction between what triggers redemption was helpful (that is, does redemption occur during specified period/at a specified date or on occurrence of a specific event). It was noted that puttable instruments (at fair value, a formula or book value) must also be considered in the analysis. One Board member remarked that splitting out the put option might be the only way to come to a satisfying answer.
The Board did not conclude on the approach, but staff was directed to continue developing the approach addressing the issues discussed at this meeting.
The staff then continued to address its main proposals. After short debate the Board decided to defer discussion on the staff proposals until the alternative approach was deliberated as it concluded that further discussions would not make sense at this point.
The staff introduced this session by reminding the Board members of the two main areas in ED Improving Disclosures about Financial Instruments (proposed amendments to IFRS 7):
Clarifying disclosures about financial instruments
Liquidity risk of financial instruments
The staff turned to the proposal of a tabular disclosure of fair values in accordance with a three level hierarchy (similar to the US requirements). It was noted that respondents linked this hierarchy to the measurement guidance in IAS 39 and were confused if they had interpreted the guidance in IAS 39 as containing a 2, 3, or 5 level hierarchy. Constituents were worried about how to map the IAS 39 fair value levels to the definition of levels under the proposals.
The staff therefore proposed not to go forward with the three level disclosure of fair value, but instead to provide additional information on level 3 disclosures, where some of the inputs in modelling fair value were unobservable. One staff member presented an alternative proposal. This staff member disagreed with the staff proposal and proposed to adopt the approach in the ED and make clear the definitions of the levels are exactly the same as under US GAAP. Also the final amendment was to make clear that there is no link between the IAS 39 measurement hierarchy and the fair value disclosure hierarchy under the proposed amendments.
While a majority of the Board members expressed sympathy for the alternative staff view, some were concerned that the timing for requiring such a fair value hierarchy disclosure would not be acceptable given that this issue would be addressed in a broader context in the fair value measurement project. One Board member noted that this amendment would not only affect financial institutions, but also corporates.
The Board voted in favour of the alternative staff proposal and against the staff recommendation.
The Board also agreed to:
Replace the notion of 'total unrealised gains or losses' with 'total gains or losses'
Require disclosure of the effect of changing one or more of the significant unobservable inputs used in the fair value measurement of level 3 financial instruments to another reasonably possible assumption
Eliminate the requirement to stratify fair value in proposed paragraph 27C
The staff then turned to the proposed amendments to the liquidity disclosures. Staff noted that most respondents welcomed the proposed amendments to the liquidity risk disclosures under IFRS 7. In light of comment received, the staff proposed the following changes to the original proposals:
Require disclosure of separate maturity analyses for derivative and non-derivative financial liabilities based on contractual maturities, but provide relief from disclosing in the maturity analysis contractual maturities for a subset of derivative financial liabilities
Emphasise the existing requirement to provide summary data about each type of risk arising from financial instruments based on information provided internally to key management personnel of the entity, as required in IFRS 7.34(a). This also clarifies that derivative financial liabilities not included in the maturity analysis based on contractual maturities (under the proposed relief above) should be disclosed in a maturity analysis on the basis of the information provided internally to key management personnel.
Clarify the following issues:
the scope of the liquidity risk disclosures regarding derivatives that during their life can change between being financial assets or financial liabilities;
how amounts are determined when the amount payable is not fixed; and
how to consider master netting agreements.
Retain the proposed treatments of
hybrid contracts; and
non-derivative trading liabilities.
Clarify paragraph B11C so that it includes:
derivative financial liabilities that are recognised in the statement of financial position;
loan commitments that meet the definition of a derivative irrespective of whether they are recognised in the statement of financial position; and
issued financial guarantee contracts.
Strengthen the wording in paragraph B11E to ensure disclosure of a maturity analysis for financial assets used in managing liquidity risk, if that is important to users of financial statements in understanding the liquidity risk of the entity.
Other drafting clarifications.
While Board members had some questions on the details of the proposed changes to the liquidity risk analysis, they agreed to all changes as proposed by the staff.
The staff proposed to bring forward the effective date of the amendments to annual periods beginning on or after 1 January 2009, but not to require comparatives. Some Board members were concerned over the backdating in the light of the requirements of IAS 34 for interim reports. Staff informed the Board that this is a broader issue and they plan to bring back a paper on it at the February Board meeting.
The Board agreed with the staff proposals.
The staff presented its comment letter analysis on the Exposure Draft Investments in Debt Instruments that would require additional disclosures for certain debt instruments. Staff said that the vast majority of respondents disagreed with the proposals, mainly for reasons of failed due process, doubts over usefulness of information, weakening the measurement bases chosen in the primary financial statements, and practical concerns.
Many Board members noted that such disclosures were requested by constituents and wondered why they now rejected them. The staff noted that the US FASB, which has exposed similar proposals, will be presented with a staff recommendation to drop the proposals (with the possible exception of requiring SFAS 157 disclosures for interims).
The Board agreed to abandon the proposals for the time being and to add the issues the ED aimed to address to the project on a comprehensive review of financial instruments accounting.
The Board agreed to defer issuing the leases discussion paper if the FASB could complete the lessor section within the timeframe indicated.
The staff informed the Board that FASB staff saw itself in a position to provide a high-level discussion and issues on lessor accounting. The staff indicated that this analysis would not contain preliminary views. The Board agreed to defer issuing the leases discussion paper if the lessor section could be done within the timeframe indicated. The FASB also committed resources to further develop lessor accounting proposals.
The Board continued its deliberations on the upcoming ED on derecognition of financial instruments.
The staff presented its proposals on linked presentation for inclusion in the upcoming ED. The session was structured as follows:
Description of linked presentation and appropriateness
Scope of linked presentation
Display of linked transactions
Measurement in case of presenting items linked in the statement of financial position
The staff explained the merits of linked presentation as it would 'ameliorate' the grossing up of the linked items in the statement of financial presentation. The Board was split about the issue and had a lengthy discussion about pros and cons of linked presentation. Many Board members objected to linked presentation in the statement of financial position, but would accept note disclosure of linked items with appropriate narratives. The Board agreed to go forward with linked presentation.
Staff continued to address the transactions that would be scoped into a linked presentation. The staff proposed to allow only a subset of transactions under flowchart 2. It further proposed to include only transactions where the transferor's exposure is explicitly limited to a fixed and prefunded monetary amount. Board members were concerned over the implications of the proposal and where this could end up. It was decided to discuss the display (that is, face or footnotes) first, to enable the Board to decide on the scope.
The staff identified two alternatives for displaying linked transactions: either present the liability deducted from the asset on the face of the financial statement or in the notes.
It was recommended to use a notes approach for implementing the linked presentation principle. While Board members seemed to agree that note disclosure was appropriate, they were split over the scope issue. After some debate, the Board decided that for flowchart 1 a broader scope was to be adopted while for flowchart 2 in general only non-recourse transactions would qualify for linked presentation.
The staff proposed that IFRIC 18 Transfers of Assets from Customers should have an effective date of 1 July 2009 instead 1 May 2009. Because earlier application is permitted, an effective date of 1 July 2009 would prevent entities from using hindsight to determine fair values. Staff also proposed to include words that would require that transfers of assets from customers be measured using information that existed and was known at the time the transfers have occurred.
The Board discussed different aspects of discounting current tax, including discount rate and IAS 20 implications.
The staff brought back an issue that arose during the balloting phase of the upcoming ED on income taxes. The ballot draft proposed that current tax should be discounted. The staff asked the Board whether the ED should contain guidance on discounting. The Board debated different aspects of discounting current tax, including discount rate and IAS 20 implications.
There seemed to be agreement, where the deferral of payment is allowed by law, discounting was not appropriate. However, if an entity specifically negotiates a payment schedule for its tax liability, discounting would be applicable if material. However, Board members pointed out that this is more akin to settlement of a tax liability, and not in itself a tax issue. It was decided not to address discounting of current tax in the ED.
The staff presented papers outlining a proposed scope on the future work that arises from the Discussion Paper on Amendments to IAS 19
Project scope and timing
The staff presented papers outlining a proposed scope on the future work that arises from the Discussion Paper Amendments to IAS 19. Staff proposed to split the project in three parts and prioritise the items in order of importance. Each project section would result in a separate exposure draft. The proposed split was:
Recognition, presentation and related disclosures
Contribution-based promises
Comprehensive review of disclosures
Board members were not convinced that the proposed approach would be appropriate and wanted to know the key risks that led to the proposed schedule. Some Board members preferred a more comprehensive approach.
The Board agreed to reduce the three step approach to a two step approach:
Recognition, presentation, and related disclosures and minor issues
Accounting for contribution-based promises
The minor issues encompass:
Additional guidance on the discount rate
Multi-employer exemption
Attribution to periods of service when benefits are back end loaded
Accounting for plans with risk sharing or conditional indexation features
Definition of short and long term employee benefits
Tax relating to pension costs
Presentation of changes in defined benefit obligations and in plan assets
The staff presented its proposals on the following three questions:
Should the Board specify how the components of pension cost should be disaggregated?
Should any components of post-employment benefit cost be presented in other comprehensive income rather than profit and loss? If so, which?
Should the Board require such disaggregated components to be displayed on the face of the performance statements when material?
The Board agreed with the staff recommendation that pension cost should be disaggregated into employment, financing, and remeasurement components.
The Board discussed at length whether all components of pension cost should be recognised in profit or loss. Some Board members acknowledged that this will not be well received by some constituents and that the case for profit or loss recognition was weakened by the fact that the measurement model in IAS 19 was flawed. The chairman took a vote, and the Board agreed that all components should be recognised in profit or loss.
The staff recommended to the Board not to mandate disaggregation of the changes in the pensions obligation in the performance statements. The Board decided, however, to require this disaggregation. The agenda papers contained an example on how such disaggregation might be presented. It was found that the proposed presentation would require amendments to IAS 1. The staff was directed to consider the example again and bring back a new example at a future Board meeting.
Proposed amendment to IFRIC 14
The staff presented a proposed amendment to IFRIC 14 to clarify the accounting where an entity makes voluntary prepaid contributions and there is a minimum funding requirement. The staff recommended an approach that would treat the prepayment as partially recoverable. However, many Board members felt that the whole of the prepayment is recoverable and, hence, full recognition of the prepayment was appropriate. The chairman took the vote and the Board agreed. The amendment is to be exposed in due course.


Limiting their strikeouts at the plate to 4, Caston Softball won 13-0 in 5 innings. Olivia Boldry and Mikayla Kinser continues to stack plates (RBIs) with two each. Kinser, Harsh, Boldry each hit a 2-bagger. On the slab throwing the optic yellow pill was Harsh, who not only threw a no-no, but with some solid fielding behind her threw a perfect game.


"Hey everyone! I am Erum aka E.T. from VIBGYOR Krafts. This is my Hat trick post as GDT at Lulupu! I was so excited when I saw my card as one of the favs. This time I played along with Lulupu's sketch challenge in a different card style, no it's not shabby chic - a bit grungy this time around. I hope you will like it and I hope you will stop by my BLOG to leave a bit of love."
This color combination was given to me by a customer of mine and I was very unsure of it :) My card consists of two panels for the background. I heat embossed chevron background for the top panel and did second generation stamping on the blue panel. I added a deep red panel to add an oomph to the dull design and it made all the difference, the doily lace in soft pink adds interest and gels the blue with the background. After the background was all set, I diecut the flower, stamped a texty stamp on it and ink distressed it a bit so it wouldnt look stark white against the background. Added my favourite frame and some gears to bring everything together. In the end I decided to add a bit of sparkle with some glitter enamel dots! Thats it! I hope you like it."
You are pure genius and you know I love your work and u too..
Lovely card and superb color combo Erum!!
Happy to see Erum guesting here at lulupu..I am fan of her work..today's card is no exception :) !
Wow wow wow! This is gorgeous! LOVING the colors and the flower!!!!!
That is a stunning colour combination and composition.
I would say you nailed that color combination ... such stunning details.


text:
Unauthorized Access and the Statute of Limitations
I recently received this email, and decided to make it the focus of a blog post:
I noticed that the federal statue for unauthorized access into an electronic system has a statue of limitations of 2 years. Couldn't law enforcement break into electronic systems illegally and if they discover something illegal, just wait 2 years before bringing an indictment. Since most cybercrimes have statutes of limitations in excess of two years, wouldn't such a method effectively allow law enforcement to use a criminal method as an investigative technique without the fear of criminal repercussions? Am I missing something here?
It's a good question, a logical question. Even if we assume (as I do not) that law enforcement officers would deliberately violate the law to obtain evidence to be used to prosecute someone, this scenario hypothesized in this email still wouldn't work, for several reasons.
Let's begin with the statute of limitations. As Wikipedia explains, in common law countries like the United States, a statute of limitations is a statute "that sets forth the maximum time after an event that legal proceedings based on that event may be initiated." (According to Wikipedia, civil law countries – like France and Italy – have laws that do the same thing, but they're known as "periods of prescription" or "prescriptive periods.") Statutes of limitations apply to civil causes of action as well as to most crimes (murder, at least in the U.S., generally doesn't have a statute of limitations).
In Toussie v. U.S., 397 U.S. 112 (1970), the U.S. Supreme Court outlined the policies that are responsible for establishing and enforcing statutes of limitations:
The purpose of a statute of limitations is to limit exposure to criminal prosecution to a certain fixed period of time following the occurrence of those acts the legislature has decided to punish by criminal sanctions. Such a limitation is designed to protect individuals from having to defend themselves against charges when the basic facts may have become obscured by the passage of time and to minimize the danger of official punishment because of acts in the far-distant past. Such a time limit may also have the salutary effect of encouraging law enforcement officials promptly to investigate suspected criminal activity.
As the Supreme Court noted in U.S. v. Marion, 404 U.S. 307 (1971), statutes of limitations "provide predictability by specifying a limit beyond which there is an irrebuttable presumption that a defendant's right to a fair trial would be prejudiced." This means that once the statutory period has run, the person suspected of the crime can no longer be prosecuted.
That brings us to the issues raised by the email quoted above. Before we get into the substantive issues it raises, I need to note one correction: The statute of limitations I assume the author of the email is referring to appears in 18 U.S. Code § 1030(g), which, as I've noted before, creates a civil cause of action for anyone injured by conduct that violates one of the criminal provisions of § 1030. Section 1030(g) provides, in part, as follows:
Any person who suffers damage or loss by reason of a violation of [§1030] may maintain a civil action against the violator to obtain compensatory damages and injunctive relief or other equitable relief. . . . No action may be brought under this subsection unless such action is begun within 2 years of the date of the act complained of or the date of the discovery of the damage. . . .
Since the limitations period set out in § 1030(g) doesn't apply to criminal prosecutions, and since federal crimes usually have a statute of limitations, the question becomes, what is the statute of limitations for bringing criminal prosecutions for violations of 18 U.S. Code § 1030?
Federal criminal statutes usually don't include a statute-specific statute of limitations; instead, the statutes of limitations for various crimes are set out in a separate part of Title 18 of the U.S. Code. The statute of limitations for the crimes created by 18 U.S. Code § 1030 is the general five-year statute of limitations set out in 18 U.S. Code § 3282. U.S. v. Schaffer, 586 F.3d 414 (U.S. Court of Appeals for the Sixth Circuit 2009). Section 3282(a) says that "no person shall be prosecuted . . . for any offense, not capital, unless the indictment is found . . . within five years next after such offense shall have been committed."
All that means, of course, is that we need to modify the scenario set out in the email quoted above so it encompasses a five-year, rather than a two-year, limitations period. I don't think the scenario (i.e., officers violate 18 U.S. Code § 1030(a) by hacking into a computer or computer system) is a viable one even if the officers wait for the five-year limitations period to run, for at least two reasons.
One is that if what the officers/agents did came to light, they might still be prosecuted . . . somehow. Certain circumstances (like conspiracy) can toll (i.e., stop the running) of the statute of limitations; the reason is that unlike a substantive crime (e.g., theft), which is committed at a specific date and time period, a conspiracy is a continuing offense. Section 1030(b) of Title 18 of the U.S. Code makes it a crime to commit one of the offenses defined by 1030(a), which criminalizes unauthorized access.
So if the officers engaged in a conspiracy to violate 18 U.S. Code § 1030(a) by gaining unauthorized access to a computer or computer system, they could be prosecuted if the conspiracy continued into the applicable limitations period, i.e., into a period within five years of the bringing of the indictment. U.S. v. Coia, 719 F.2d 1120 (U.S. Court of Appeals for the 11th Circuit 1983). Courts have held that a conspiracy "can be deemed to continue as long as its purposes have neither been abandoned nor accomplished." U.S. v. Coia, supra. So if the officers entered into a conspiracy to commit unauthorized access in order to obtain evidence that could be used to prosecute John Doe, the conspiracy would continue until they either abandoned it or they had accomplished its purpose, i.e., using the evidence to prosecute John Doe. In other words, the statute of limitations might extend beyond the basic five-year period. The officers might also be open to prosecution by the state in which the crime occurred, if the state's statute of limitations is longer than the federal one (which is possible). Every U.S. state makes unauthorized access to a computer system a crime.
Even if our hypothetical rogue law enforcement officers are so determined to "get" John Doe that they break the law knowing they can be prosecuted (and are), that doesn't do anything to help John Doe. What Doe needs is to be able to prevent the prosecution from being able to use the evidence the rogue officers got by gaining unauthorized access to (what I am assuming) is his computer or a computer that held information about his illegal acts. In other words, he needs to be able to get the court to suppress the evidence because it was illegally obtained.
As I noted in a recent post, the fact that officers broke the law (state or federal) usually isn't enough, in and of itself, to have evidence they obtained as a result of their criminal activity suppressed. As the U.S. Court of Appeals for the Sixth Circuit explained,
there is no exclusionary rule generally applicable to statutory violations. Rather, the exclusionary rule is an appropriate sanction for a statutory violation only where the statute specifically provides for suppression as a remedy or the statutory violation implicates underlying constitutional rights such as the right to be free from unreasonable search and seizure.
U.S. v. Abdi, 463 F.3d 547 (2006). I don't know why someone would want to move to suppress evidence based on a statutory violation when the statutory violation "implicate[d] . . . constitutional rights" such as the 4th Amendment right to be free from unreasonable searches and seizures. It seems it would make more sense simply to move to suppress the evidence as having been obtain in violation of the 4th Amendment itself; here, you'd be relying on a constitutional provision, not on a statute.
Doe, then, could move to suppress the evidence the officers obtain as having been obtained in violation of his 4th Amendment rights (assuming, of course, that their unauthorized access targeted a computer or computer system in which Doe had a 4th Amendment reasonable expectation of privacy). As I noted in an earlier post, the U.S. Supreme Court has not found the two coextensive, i.e., has not found that a violation of statutory law necessarily established the 4th Amendment expectation of privacy that is required for law enforcement conduct to constitute a "search."
As far as I can tell, the ultimate reason why the scenario outlined above won't work in practice is the 4th Amendment problem. If officers went rogue and deliberately violated 18 U.S. Code § 1030(a) (or some state unauthorized access statute) in order to obtain evidence to be used to prosecute our friend Doe, the 4th Amendment would bar the use of the evidence as long as their conduct violated Doe's rights under the 4th Amendment.
In this situation, the government therefore couldn't use the evidence as long as the officers/agents were acting as law enforcement officers and not on their own behalf. As I noted in another post, the 4th Amendment only protects us from state action, i.e., from law enforcement officers who are acting as law enforcement officers. That seems to be the case in the scenario outlined above, since in that scenario the officers commit the unauthorized access to get evidence to be used to prosecute Doe for some crime or crimes.
The prosecution might, though, be able to show that even though the officers did this to get evidence that could be used to prosecute Doe for a crime, they weren't really acting as law enforcement officers when they engaged in the unauthorized access. If the prosecution could, for example, show that the officers did this for purely personal reasons – maybe they were angry with Doe for some reason and wanted to "get" him – that might mean there was no state action and the 4th Amendment wouldn't apply.
Is the statute of limitations really 2 years?
Restitution and Proximate Cause
"Fantasy Alone"
The Councilman, Spyware and the Computer Fraud and...
Cyber-Extortion
Borders, Laptops and Exigencies
Murder, Text Message and the 6th Amendment
Friending the FBI
Consent Search Issues
"Pretext Communications" and the Right to Remain S...
Hyperbole or "True Threat"?
"Unauthorized Access" Strictly Construed
4th Amendment, Flash Drives and Surgery
Unauthorized Access and the Statute of Limitations...
Jurors, "Experimentation" and Misconduct

redpajama_set_name: RedPajamaCommonCrawl


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text:
Man charged with attempted murder over incident at Bill Shankly-themed hotel in Liverpool
Bill Shankly remains an icon for Liverpool fans and the hotel (not pictured) was created in his honour
A man has been charged with attempted murder after another man fell from height at a luxury Bill Shankly-themed hotel in Liverpool.
Craig Looby, 27, is also charged with wounding after the 34-year-old man fell from a fourth floor balcony shortly before 6am on Christmas Eve.
The Liverpool Echo reports that Looby, who currently lives in Dubai but is originally from Liverpool, got into a fracas with the other man shortly before he fell. They were both attending an event at the hotel.
Looby was arrested at the scene and appeared on December 26 at South Sefton Magistrates Court. He has been remanded in custody to appear at Liverpool Crown Court on Tuesday January 23 2018.
The 34-year-old man suffered serious but non-life threatening injuries in the fall. He was taken to Aintree University Hospital where his condition is described as improving.
The hotel, which opened in 2015, has been designed as a shrine to Bill Shankly, the former Liverpool football manager who turned the club into a superpower in the 1960s.
Aimed at Liverpool fans, the building is adorned with Shankly memorabilia, from quotations embedded in the walls and roof to a pair of boots in the lobby. The hotel also offers Shankly-themed tours to interested parties.
Bill Shankly
Shankly Museum
Craig Looby
Merseyside Police


Safaree just did a total 180 on his commitment to attend the 'Love & Hip Hop' reunion … a move that could cost him some serious cash.
Sources close to the situation tell TMZ, Safaree was supposed to appear in Atlanta Wednesday to shoot the 'LHH' show. We're told last Friday he was committed to do the special — but he had a change of heart on Monday — backing out due to what he called safety and mental health concerns.
Our sources say VH1's parent company, Viacom, promised Safaree they'd put necessary measures in place to make sure he felt safe — including additional security if a fight broke out — but he wouldn't budge.
Safaree's no-show certainly didn't sit well with network honchos … who fired off a legal letter warning Safaree if he didn't attend, he could be on the hook for substantial damages.
Safaree's manager, David Weintraub, tells us he's encouraged the reality star to fulfill his obligations to the network. However, the decision on how he handles his contractual commitments is ultimately up to Safaree.
Viacom has also threatened to bar Safaree from appearing on any other TV shows while under contract … limiting his ability to make additional income.


Yay, at last I had a chance to update this blog again. Updating each of my blog has become a hard task for me. There are times that I can only update a specific blog every time I have an assign task to do. Annoying sometimes since my first intention on having my own blog is to chronicle what is happening in my life.
Spider Vein is a group of widened veins that can be seen through the surface of the skin, according to medicinenet.com.
I personally knew someone who got a spider vein in her legs. Some says it is cause of pregnancy but other people said it is because of too much standing and wearing high hilled shoes. Luckily I did not get any of this while I am pregnant with my son four years ago. But my friend is not that lucky because she spider vein started to show up when she was five months pregnant to her first baby. The thought of getting rid of it when she gives birth did not happen. That is why she having a hard time dealing with it especially if she needs to wear a short pants.
Geezz.. I can not believe... I am not updating this blog for many days now. The reason? Well, I do not have any reason actually, I am blogging everyday but I do not have any exciting story to share for this blog so I end up neglecting this blog and my other blog.
Hayy.. thats how to difficult to have a multiple blogs. There are times that you are running out of words.
Sometimes I really feel bad for my body .At present I am 30 years old. I have put on a lot of weight a year after giving birth to the little bugger. My waist has increased a lot past for more than three years. For few months now I've been struggling on how to loose weight little by little. Few days ago my boyfriend noticed that I am gaining again. Geezz.. no wonder because I ate a lot of mouth watering foods last month.
Often times I am thinking of trying to take slimming pills but I need to be sure that the pill I will be taking is safe and effective. While browsing the net I came across this Apidexin review. Now that I am done reading the some feed back from some users, am I ready to take the outcome?
Mr. Google has been updating since last week unfortunately this blog is not lucky like my other blog. Its been a ages now since I lost the PR of this blog. Hopefully, time will come that Mr. Google will reward this blog a pr that I deserve.
I guess I still need to work double effort to gain unique visitors. How about you guys? Are you lucky with google this time?
Finding the right home furniture can be difficult and tricky, that is why it is a must to be careful on choosing which furniture to buy. If you are planning to buy a SOFAS for your home I advise you to visit Spacify.com. Spacify offer a wide selection of home furniture such as, bed room furniture, living room furniture, office furniture, home furnishings, contemporary chairs, modern tables and a lot more. Currently they are offering free shipping and 30% in thier selected products.
What I love in Spacify furniture is that they have a they has a unique and trendy looks and made of high quality materials. If have enough money I would love to have the sofa in the picture.


On behalf of all members and staff of the International Buddhist Confederation, I offer my deepest sympathies to our brothers and sisters in Nepal and all the Nepalese diaspora for the terrible tragedy that has struck their homeland.
Thousands of innocent lives have been lost, and tens of thousands of our brethren have been rendered homeless. Numerous structures that were a symbol of our shared spiritual and cultural heritage have been reduced to rubble by the powerful tremors.
In this hour of need the International Buddhist Confederation offers all its prayers, and appeals to the compassion of all members of the Sangha to pray and contribute for the relief and succour of all our brothers and sisters who have suffered this cataclysmic tragedy.


text:
Tag / Verizon
Tuesday August 13th 2013 Tuesday December 31st 2013 by Xavier Voigt-Hill
Signs of the third Vu-pocalypse appear as LG prepares to resurrect the square phablet
Leak, Phablets, Smartphones
800, Berlin, G2, IFA, II, III, Intuition, Leak, LG, Optimus, Phablet, Snapdragon, Verizon, Vu
Remember LG's ridiculous Optimus Vu, the 5″ phablet with a 4:3 1024 x 768 display? Or its international variant, which was one of the few devices to call itself a phone and carry a Tegra 3 processor? Or Verizon's variant, dubbed Intuition, which could only muster a review score of 4.4 from The Verge? Or the Vu II, which took the original device and bumped the internal hardware up to appropriate levels for a 2012 flagship?
There's a reason nobody (except me) remembers these things. It's because they were horrible. And yet, LG just doesn't know when to stop. Continue reading →
Tuesday July 30th 2013 Tuesday December 31st 2013 by Xavier Voigt-Hill
Digixav Podcast 014 – July 30th 2013
Podcast, Technology
625, A10, Android, BlackBerry, Chromecast, Chromekey, Dongle, Droid, Featured, Galaxy, HDMI, HTC, Leak, Lumia, Max, MAXX, Mini, Moto X, Motorola, Nexus, Nexus 7, Nokia, One, picass, Podcast, Purple, S4, Samsung, Ubuntu Edge, Ultra, Verizon
https://digixav.files.wordpress.com/2013/07/digixav-podcast-014.mp3
For the one true episode 014 of our now adolescent podcast, Xavier and Chris make up for lost time by talking about everything important since the Lumia 1020 happened. It turns out that this includes a fair bit about the 1020 itself, but our dynamic duo (sorry Henry) also trawl through news about its baby big brother, a new family of Droids from Motorola and Verizon with the Moto X launch looming later this week and HTC's quest for profitability with One variants both big and small. Samsung, on the other hand, go full-on with the purple and Canonical decide that a crowdfunding campaign to make an Ubuntu phone with a sapphire crystal display makes perfect sense. There's also a new BlackBerry leak if you're into that kind of phone and Google's new Nexus 7 and Chromecast streaming HDMI dongle thing.
Right click and save this link to download, and you can subscribe (and rate and review the show) using iTunes! Don't fancy iTunes or use a different podcatcher? Here's our RSS link!
If you have any feedback, questions or comments, tweet us or send us an email to podcast@digixav.com. We'd love to hear from you!
Thursday June 20th 2013 Tuesday December 31st 2013 by Henry Hunt
HTC Butterfly S flutters into Taiwan following flurry of leaks
Android, BoomSound, Butterfly, HTC, One, S, Snapdragon, Taiwan, UltraPixel, Verizon, Verizon Ruining Things
Tuesday April 9th 2013 Tuesday December 31st 2013 by Xavier Voigt-Hill
Digixav Podcast 005 – April 9th 2013
4K, 928, AT&T, Batman, Bioshock, EE, Facebook, First, Gadget Show Live, GRID 2, Home, HTC, Infinite, James Blake, Lumia, Microsoft, Nokia, One, OneRepublic, Pink, Podcast, RT, Sergey Brin, Surface, Tesla, Verizon
Following on from our triumphant trip to The Gadget Show Live last week, Xavier and Chris leave Henry in the dark ages for the fifth episode of our podcast. Sticking mostly to topic for the first time ever, we talk about everything from Facebook's attempt to take control of Android with Home and the HTC First, Nokia's Verizon-bound Lumia 928, our experiences in the review period of the Microsoft Surface RT, the complimentary content that comes with Sony's new $699 4K media player and, the biggest news of the year, Sergey Brin's bright pink Batman Tesla. We also branch out into culture talk with our favourite new media and Chris gets philosophical…somewhere.
If you have any feedback, questions or comments, tweet us or send us an email to podcast@digixav.com. We'd love to hear what you think! Continue reading →
Thursday February 21st 2013 Monday May 27th 2013 by Xavier Voigt-Hill
Google announces Chromebook Pixel, its first premium laptop
Chrome, Chromebook, Drive, Google, Laptop, OS, Pixel, Verizon
At a press event in San Francisco today, Google has unveiled the Chromebook Pixel, the latest addition to the expanding line of Chrome OS-based laptops. As one of the company's first ventures into hardware, the Pixel represents a change of direction with Google's strategy, and the hardware inside shows that Google is pitching it towards a higher end of the market than existing 'disposable' models from the likes of Samsung, Acer, Lenovo and HP.
The Chromebook Pixel has a 1.8GHz Intel Core i5 processor and 32GB of solid state storage coupled with 1TB of additional Google Drive storage free for 3 years, usually costing $49.99 per month. A 720p HD webcam sits above the market-leading 239ppi 12.85″ 2560 x 1700 touch display and, with its £1,049 ($1,299) price tag, the machine is being pitched as the world's first premium Chromebook, and the company will be shipping it next week via Google Play and through retail partners, with a $1,499 model with twice the internal storage and support for Verizon's LTE network set to hit US stores in April.
Source Google Blog
Wednesday January 23rd 2013 Wednesday January 23rd 2013 by Xavier Voigt-Hill
Delayed Samsung Ativ Odyssey Windows Phone will hit Verizon shelves on January 24th
4G, 8, 822, 8X, Ativ, Droid, HTC, LTE, Lumia, M, Motorola, Nokia, Odyssey, Phone, RAZR, Release, Samsung, smartphone, Verizon, VZW, Windows
Microsoft's Windows Phone 8 launch event was headlined by the appearance of Jessica Alba, but otherwise very little unknown information surfaced about the operating system or the devices it would appear upon. One smidgen of news that did emerge, however, was that a Samsung device, depicted by a lonely silhouette and named the Ativ Odyssey, was in the pipeline for a December release on Verizon in the US. Of course December came and went without a release, but CES gave Samsung the opportunity to show the 4″ Windows Phone 8 device to the world. Now, a press release has stated that the phone will be available sooner rather than later, with stores set to receive the Ativ Odyssey and Valentine's Day editions of the Nokia Lumia 822 and Motorola Droid Razr M tomorrow (January 24th).
The Odyssey joins the Lumia 822 and HTC 8X in Verizon's lineup of LTE Windows Phones, and its microSD slot and 2100mAh battery should win it some fans, although the 800 x 480 screen resolution and 5MP camera show that it is pitched towards the lower end of the market. As with almost all other Windows Phone 8 devices, the package comes powered by a 1.5GHz dual-core Qualcomm Snapdragon S4 chip accompanied by 1GB of RAM, and it will be available for $49.99 with a new 2 year contract, while whispers of a European launch remain unconfirmed but not impossible.
Source Verizon Wireless
Wednesday September 5th 2012 by Xavier Voigt-Hill
Motorola set to unveil Droid Razr HD at New York event: Stream it live at 2PM EDT/6PM GMT/7PM BST/8PM CEST
Android, Blur, Droid, Event, Google, HD, Ice Cream Sandwich, Live, MAXX, Motoblur, Motorola, New York, Pentile, RAZR, Stream, Verizon, Video
In what is supposedly the day's main event, Motorola and Verizon have a big announcement planned. We expect to see the Droid Razr HD tonight, but Motorola's stream page promises a few surprises. If you want to see things happen, tune in below at 2PM EDT/6PM GMT/7PM BST/8PM CEST or whatever time it will be for you. Can the Google subsidiary live up to their showstopping promises?
Via The Verge Forums
Tuesday May 15th 2012 Tuesday May 15th 2012 by Ali Wilson
Techslice: The new iPhone rumour mill
Smartphones, Techslice
A5, A5X, A6, Apple, AT&T, Foxconn, iPad, iPad 2, iPhone, iPhone 4G, iPhone 4S, iPhone 5, iPhone 6, LTE, Rumours, Siri, Sprint, Steve Jobs, Techslice, The new iPhone, Tim Cook, Verizon, WWDC
Techslice is a column by Ali Wilson. Views expressed are not necessarily those of Digixav.
In October 2011, Apple released their latest iPhone: the iPhone 4S. A lot of people were disappointed with the result that came 18 months after the 4 and were expecting something a bit more, well, new. By sight, the iPhone 4S is the same as its predecessor, the iPhone 4. The only major differences for a year of development were a dual-core A5 processor from the iPad 2, Siri and 3 additional megapixels in the camera.
So with so few differences in the last upgrade, we are expecting great things from the iPhone 5/iPhone 4G/iPhone 6/new iPhone. There has been a concept design released and, as you can see, it does look very different to the previous model.
Straight away, the first thing we notice is potential design overhaul of the new iPhone. Apple may reverted towards their old curved design from the original models. The shape is a lot less square and is much more rounded, a lot like the new Samsung Galaxy S III. The screen size may increase from the current 3.5″, with rumours circling that Apple may enlarge it to a whopping 4.8″, although Steve Jobs would turn in his grave. He was in staunch opposition to larger screens as he (rightly) thought that they made the iPhone resemble an Android phone.
The sixth installment to the iPhone series is said to be being released just over a year after its older brother. It was thought that if it was released earlier, then the new iPad's sales would not be as high. Apple have therefore left a six-month gap between the iPad and the iPhone's release. It is rumoured for early October 2012.
So, if you're thinking of investing in an iPhone 4S, think again. It should be worth the wait of (potentially) just six months, because Apple could change everything. Again.
Thursday April 19th 2012 Monday April 23rd 2012 by Xavier Voigt-Hill
Apple unveils iPhone 4S adverts with Zooey Deschanel and Samuel L. Jackson
Retail, Smartphones, Video
Advert, Apple, AT&T, iPhone 4S, New Girl, Samuel L. Jackson, Siri, Snakes on a Plane, Sprint, Verizon, Video, Zooey Deschanel
We've reported on Apple's iPhone 4S advertising before, so when we spotted some new ads on the internet that were showing off Siri, we knew you needed to see them. One of them even has Zooey Deschanel in the rain. The other has Samuel L. Jackson looking for organic mushrooms on a plane.
Tuesday March 27th 2012 Tuesday March 27th 2012 by Xavier Voigt-Hill
Android phones caught stealing names from condoms
Editorial, Retail, Smartphones
Admire, Android, AT&T, Cruise, Desire, Electrify, Elite, Epic Touch, Eva Longoria, Fascinate, Hero, HTC, Indulge, Intensity, Intercom Blog, LG, Name, Replenish, Rezound, Rumor Touch, Samsung, Sensation, Skyrocket, smartphone, smartphones, Sprint, T-Mobile, Tingle, Touch, Transform Ultra, Ultra Thin, Verizon, Vitality, Wildfire
We all know how ridiculous Android device names can be, but this chart from the Intercom Blog really alarms me. To quote the author:
If your product isn't a condom then don't name it like one
Don't know what I mean? Have a look below.
NB: There is actually a phone called the LG Rumor Touch, but it is a dumbphone so it doesn't count here. This is an advert for it:


In concert with clients' overall programmatic objectives, we analyze the site and its resources, including water quantity and quality, categorized by source. These include imported water, stormwater and runoff, wastewater, groundwater and surface water. From this data, we assess current and projected water usage. We also calculate nutrient values for effluent, before committing data to cost/benefit analyses. Sometimes community and agency engagement is necessary at this phase.
To implement our designs, we are available to train builders and operators. Sometimes, we conduct and supervise the construction. Our contractors do the demolition, excavation and utility installation, then establish grading and drainage. Afterward, crews install hardscape, bioremediation structures, interpretive signage and planting. Following construction, we complete certification and documentation. We also train client's maintenance and/or monitoring staff.
To implement our designs, we are available to train builders and operators. Sometimes, we conduct and supervise the construction. Our contractors do the demolition, excavation and utility installation, then establish grading and drainage. Afterward, crews install hardscape, bio-remediation structures, interpretive signage and planting. Following construction, we complete certification and documentation. We also train client's maintenance and/or monitoring staff.


text:
Non-degree courses
Qualification indicator
Academic entry explained
Transnational, Global and Spatial History MLitt
Transnational, Global and Spatial History (MLitt) 2021 entry
This course promotes new transnational perspectives and ways of seeing the past through an explicit appreciation of scale in space and time. Students explore a range of approaches to the study of global trade, the development of networks, comparative history and cross-cultural encounters.
Apply now Register your interest
After the MLitt
Postgraduate, leading to a Master of Letters (MLitt)
Start date: 6 September 2021
End date: 30 September 2022
Information about all programmes from previous years of entry can be found in the archive.
One year full time
A good 2.1 Honours undergraduate degree in a subject-related area. If you studied your first degree outside the UK, see the international entry requirements.
English language proficiency. See English language tests and qualifications.
The qualifications listed are indicative minimum requirements for entry. Some academic Schools will ask applicants to achieve significantly higher marks than the minimum. Obtaining the listed entry requirements will not guarantee you a place, as the University considers all aspects of every application including, where applicable, the writing sample, personal statement, and supporting documents.
Home: £9,900
Overseas: £20,370
Find out about scholarships and funding.
Further particulars regarding tuition fees.
Wednesday 11 August 2021. Applicants should apply as early as possible to be eligible for certain scholarships and for international visa purposes.
CV or résumé. This should include your personal details with a history of your education and employment to date.
a sample of academic written work (2,000 words)
two original signed academic references
academic transcripts and degree certificates
evidence of English language proficiency (required if English is not your first language).
For more guidance, see supporting documents and references for postgraduate taught programmes.
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Watch current students and staff discuss the teaching facilities, research opportunities and student life at Scotland's first university.
The MLitt in Transnational, Global and Spatial History is a taught postgraduate programme run by the Institute for Transnational and Spatial History (ITSH) in the School of History.
This programme provides a unique introduction to the emerging field of spatial history, including the study of representations of space, landscapes, mental maps, spatial practices and topographies of memory.
This programme promotes new transnational perspectives and ways of seeing the past through an explicit appreciation of scale in space and time.
Students will explore approaches to the history of cities as hubs, transfers and travel, the circulation of ideas and the migration of peoples.
Students will explore a range of approaches to the study of global trade, the development of networks, comparative history and cross-cultural encounters.
Students will gain proficiency in powerful tools for mapping, geographic analysis and the study of social networks as well as skills in the use of non-textual sources and overcoming the challenges of translation and multi-lingual archives.
Teaching format
Teaching methods include seminars, fortnightly tutorials and practical classes. Class sizes range from individual supervision up to 12 students. The modules are assessed by coursework only; there is no final exam.
Students will spend the final three months of the course focusing on researching and writing the final assessment piece for the MLitt, a dissertation of not more than 15,000 words.
Further particulars regarding curriculum development.
The modules in this programme have varying methods of delivery and assessment. For more details of each module, including weekly contact hours, teaching methods and assessment, please see the latest module catalogue which is for the 2020-2021 academic year; some elements may be subject to change for 2021 entry.
Global Times - Plural Spaces (1 and 2): offers a strong foundation in the major approaches to comparative and transnational history as well as the emerging field of spatial history.
Students choose two optional modules. Here is a sample of optional modules that may be offered.
Building Britain: The Construction and Deconstruction of Britishness since 1707: explores the concept of 'Britishness' and its construction and deconstruction from 1707 to 2000.
Directed Reading in Modern History: designed to encourage the development of skills of historical analysis through concentrated study of a topic chosen by the student prior to the dissertation.
Disease and Environment (c.1500–2000): examines the manner in which sickness and death have shaped human history, both biologically and culturally, over the past 500 years.
Environmental History: Nature and the Western World (1800-2000): studies environmental history over the past two centuries in an international context.
Perceptions of Central and Eastern Europe: examines perceptions of Central and Eastern Europe which have undergone significant transformation since the emergence of modern nationalism in the mid-19th century.
Political Thought and Intellectual History: offers a rich and varied graduate-level introduction to the political theory and intellectual history of the early modern period.
Skills in Transnational History: leads to the acquisition and development of skills in the digital humanities and skills required for using specific historical sources.
The Creation of an Atlantic World: introduces students to the concept of the Atlantic World, a unit of analysis used by historians to understand the changes wrought in the western hemisphere by the British, French, and Iberian discovery and settlement of the Americas, and by Europe's slave trade with Africa.
Themes in American History: examines a selection of the most important issues in the history of North America, from its foundations as European colonies onwards.
Themes in Middle Eastern History: looks at a variety of theoretical and disciplinary approaches, including Orientalism, as well as exploring questions of nationalism, statehood and identity.
War, State and Society in Early Modern Europe and New Worlds: explores the transformations in the size, scale and scope of European warfare between the late 15th and late 18th centuries.
Optional modules are subject to change each year and require a minimum number of participants to be offered; some may only allow limited numbers of students (see the University's position on curriculum development).
Student dissertations will be supervised by members of the teaching staff who will advise on the choice of subject and provide guidance throughout the research process. The completed dissertation of no more than 15,000 words must be submitted by a date specified in August.
If students choose not to complete the dissertation requirement for the MLitt, there is an exit award available that allows suitably qualified candidates to receive a Postgraduate Diploma. By choosing an exit award, you will finish your degree at the end of the second semester of study and receive a PGDip instead of an MLitt.
The modules listed here are indicative, and there is no guarantee they will run for 2021 entry. Take a look at the most up-to-date modules in the module catalogue.
If you're interested in studying at St Andrews, join us on a virtual visiting day or daily information session to find out about our courses, how to apply, and to meet current students.
Join our Admissions team for one of our upcoming virtual events. During these events, you can find out more about studying at St Andrews and what it will do for your future.
The School of History is home to a number of seminars which meet regularly throughout the teaching period from September to May. Papers are given by both St Andrews historians and invited guests.
The Institute for Transnational and Spatial History hosts regular guest lecturers, events and reading groups.
The School of History is pleased to be able to offer a number of competitive scholarships which contribute to the fees and maintenance for postgraduate study.
Language Bursaries enable students to undertake intensive language courses abroad during the summer before their programme begins.
School of History MLitt Awards offer the cash equivalent of one year's home fees and cannot be held in conjunction with other awards offering full fees and maintenance.
Find out more about postgraduate scholarships.
Recent Graduate Discount
The University of St Andrews offers a 10% discount in postgraduate tuition fees to students who are eligible to graduate or who have graduated from St Andrews within the last three academic years and are starting a postgraduate programme with the University of St Andrews.
Many graduates continue their education by enrolling in PhD programmes at St Andrews or elsewhere.
History postgraduates go on to pursue careers in a range of sectors including:
The Careers Centre offers one-to-one advice to all students on a taught postgraduate course and offers a programme of events to assist students in building their employability skills.
St Katharine's Lodge
KY16 9BA
Email: pghist@st-andrews.ac.uk
History website
Admission to the University of St Andrews is governed by our admissions policy.
As a research intensive institution, the University ensures that its teaching references the research interests of its staff, which may change from time to time. As a result, programmes are regularly reviewed with the aim of enhancing students' learning experience. Our approach to course revision is described online (PDF, 72 KB).
The University will clarify compulsory fees and charges it requires any student to pay at the time of offer. The offer will also clarify conditions for any variation of fees. The University's approach to fee setting is described online (PDF, 84 KB).
Study at the University of St Andrews and experience the world-class teaching and cutting edge research of Scotland's first university.
Subjects at St Andrews
Classics, Greek and Latin
Teaching English to speakers of other languages (TESOL)
St Katharine's West
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Email: admissions@st-andrews.ac.uk
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Browning, Elizabeth Barrett (1806-1861) Autograph Letter Signed and Envelope Addressed and Signed by Robert Browning (1812-1889).
Single page, inscribed on one side. To Hiram Powers (1805-1873) arranging evening plans with friends. The small sheet tacked down at the corners to a piece of mat board, in a larger velvet mat with a portrait of Elizabeth Barrett Browning, old folds, 3 1/2 x 5 1/4 in.
[and] a black-bordered mourning envelope addressed to Sir John Simeon (1815-1870) on the Isle of Wight, by Robert Browning, signed, 29 December 1868, with stamp and postmark, tacked to mat board, in a larger velvet mat with a portrait of Browning, 4 3/4 x 3 3/4 in.
Mr. and Mrs. Clarke & Mr. Spring [?] will spend this evening with us. They were at first unwilling to come on the ground of having a past promise from you that you would go to them, but we over-ruled the difficulty by proposing thereby to persuade you to come to us instead and meet them here. Do come at eight, if you can. I am afraid of asking Mrs. Powers but if the bait of a piece of America could catch her, so much the better for us and everybody.