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Year Ahead: Big IP Developments Loom For US Law In 2015
21/01/2015 by Steven Seidenberg for Intellectual Property Watch Leave a Comment
2014 brought major changes to the United States intellectual property system, particularly in the area of patent law. 2015 promises more of the same, as the new Supreme Court ruling in Teva Pharmaceuticals USA v. Sandoz attests. Here's a discussion of Teva and other key cases and developments to watch this year.
Defining "patent-eligible subject matter." This was the biggest US IP law development in 2014. It is likely to remain so in 2015, as the US deals with the ramifications of last year's major Supreme Court decision in Alice Corp v. CLS Bank Int'l [pdf].
Alice dramatically toughened the requirements for business methods and software to be deemed patent-eligible subject matter. In the wake of that ruling, both the courts and the US Patent and Trademark Office (USPTO) have been striking down existing software and business method patents with abandon. The USPTO also has been rejecting a large percentage of patent applications covering software or business methods.
However, the Supreme Court's ruling in Alice created a lot of uncertainty in this area of the law. "It didn't define precisely what is patent-eligible subject matter," said Eugene J. Bernard, a partner in the Denver office of Kilpatrick Townsend & Stockton, a law firm. As a result, he added, "some decisions last year and more this year will attempt to define what the standard is."
One important case to watch is DDR Holdings v. Hotels.com [pdf]. In that case, the Federal Circuit Court of Appeals (often called the country's "patent court") recently upheld a software patent against a challenge that it claimed patent-ineligible subject matter. But that 2-1 ruling may not end the matter. Many patent experts are waiting to see if the decision will be reviewed by the Federal Circuit en banc or perhaps by the Supreme Court. Such a higher-level review could provide much needed guidance on when, if ever, software or business methods will be deemed patent-eligible subject matter.
Teva Pharmaceuticals USA v. Sandoz. This decision [pdf], issued 20 January by the US Supreme Court, determined how much deference the Federal Circuit must give to trial courts' patent claim constructions. Before the ruling, the Federal Circuit gave no deference at all and reviewed claim construction de novo.
The Supreme Court overturned this standard and required the Federal Circuit to defer to the trial courts' factual determinations, overturning them only if a trial court made a "clear error." This significantly changes US patent litigation, weakening the power of the Federal Circuit and making it tougher for the losing party in a patent infringement case to overturn the trial court's verdict.
There will likely be fewer appeals now, but trials will probably become longer and more costly. Prior to the high court's ruling, claim construction hearings were largely done on paper. Now, "district courts will move towards hearing more testimony. We will see a trend back towards mini-bench trials on claim construction. That will potentially slow down the claim construction process," said John B. Sganga, Jr., a partner in the law firm of Knobbe, Martens, Olson & Bear, LLP, in its Irvine, California office.
B&B Hardware v. v. Hargis Industries. This Supreme Court case, like Teva v. Sandoz, focuses on how much deference the courts should give to USPTO determinations. But this case, unlike Teva, concerns trademark law.
The issue in B&B Hardware is this: When the USPTO determines that a mark cannot be registered because it is confusingly similar to another mark, does this determination subsequently bind a trial court? Or can the court decide on its own whether or not the marks are confusingly similar?
Many experts predict the Supreme Court will seek a middle course, reflecting the fact that USPTO proceedings are more abbreviated than court proceedings and do not address all the facts and issues that arise in litigation.
"I think the Supreme Court will decide that there should be some deference to USPTO decisions, but not always. If the facts and the analysis are same in the USPTO proceeding and the court proceeding, there would be some preclusive effects. If not, there would be no preclusion," said Joanne Ludovici, a partner in McDermott Will & Emery, who works in the law firm's Washington, DC office.
Should the Supreme Court approve some sort of preclusion, a good deal of trademark litigation will become faster and cheaper. "This will narrow the issues that get to court and reduce costs of litigation," said Ludovici.
Patent reform legislation. The last session of Congress almost enacted major patent reform. The House of Representatives passed the Innovation Act by a lopsided margin of 325 to 91, but thanks to opposition from pharmaceutical and biotech firms, the bill never received a vote in the Senate.
This year promises to be different. Now that the Republicans have taken control the Senate, many observers expect the reforms found in the Innovation Act will be passed by both houses of Congress in the US Congress and signed into law by President Obama. The reforms include:
limiting discovery in patent infringement suits;
requiring the losing party in a patent infringement suit to pay the winner's costs, unless the loser behaved reasonably in bringing and conducting the lawsuit; and
allowing vendors to protect their customers against infringement suits, when these suits are based on the customers' using the vendors' allegedly infringing goods or services.
These changes would make life much harder for those seeking to exploit dubious patents, particularly so-called "patent trolls." But the effects of patent reform could go much further, depending on the precise terms of the legislation, many experts warn.
"The challenge is to legislate in such a way that you address the enforcement of bad patents without stifling the enforcement of good patents," said Natasha H. Moffitt, a partner in Atlanta office of the law firm of King & Spalding.
Inter partes review goes on trial. Since it became available on 16 September 2012, inter partes review (IPR) has become an extremely popular way to challenge the validity of issued patents. This administrative procedure before the USPTO allows challengers to quickly and cheaply attack patents using prior art that was disclosed in earlier patents and printed publications.
"People have been filing IPRs left and right," said Bernard. "It is much cheaper than patent litigation in district courts, maybe 1/5 to 1/10 the cost."
Now, however, these IPR decisions are coming under judicial scrutiny. That could have profound consequences.
"In the past several months, the Federal Circuit has begun hearing appeals from IPR decisions. When those [appellate rulings] come down, we will know a lot more about how the Federal Circuit views those IPR procedures, whether the court accepts the rules and procedures the USPTO has been using. And we will know how much deference the Federal Circuit will give to IPR decisions. We will know a lot more about the long-term prospects of IPRs," said Charles T. Steenburg, a partner in the Boston law firm of Wolf, Greenfield & Sacks.
Rudderless USPTO. The USPTO has been without a director for two years, since David Kappos left at the end of January 2013. This has hurt the agency's performance. "The USPTO has been slow to address a lot of recent changes, such as court rulings on patent-eligible subject matter, and it has had trouble implementing programs to issue patents faster. That's because there has been no top person at the USPTO to push things through the bureaucracy," said Bernard.
Finding a replacement for Kappos has been difficult because powerful business interests strongly disagree about how the USPTO should treat patents. Silicon Valley firms, which fret about patent trolls and a plethora of overly broad patents, want the USPTO to make it harder to get patents and easier to challenge them. Pharmaceutical and biotech firms want the opposite. Because their fortunes often are based on a small number of patents, pharma and biotech companies want to easily patent their lucrative discoveries and strongly protect these patents against legal challenges.
Experts are waiting to see if 2015 brings an end to the political deadlock.
Trade secret legislation. Because US patent law has changed in recent years, making it difficult or impossible to patent certain inventions, a growing number of companies have been using an alternative means to protect their inventions. They have been keeping the details of their inventions under wraps and claiming the protection of state trade secret laws.
But there is a problem with current trade secret laws. They vary a great deal from state to state, creating problems for companies that do business throughout the US.
Thus, there has been a push to enact a federal trade secrets law. "This was proposed in the last Congress, but there was little activity on it. With the Republicans now controlling both houses of Congress, I think there is much more likelihood that this will get passed," said Christopher K. Larus, a partner in the Minneapolis office of law firm Robins Kaplan. He added, "This has broad support across the business community. There is a significant likelihood that trade secret law will become federalized."
Restatement of Copyright Law. There are two basic sources of copyright law in the US: Congress and the courts. There may soon be a third source, a Restatement of Copyright Law.
The respected American Law Institute (ALI) has produced Restatements on many aspects of US law, including contract law, tort law, and property law. Each Restatement attempts to clarify one area of the law by setting out black letter rules, explaining the principles behind the law, and suggesting some ways in which the law should develop in the future.
These Restatements are secondary authorities that have only persuasive effect. However, because they are painstakingly created by eminent legal scholars, the Restatements are often quite persuasive. Courts, government agencies, and legislative bodies regularly rely on the Restatements to explain what the law is and should be.
In 2015, the ALI will begin work on a Restatement of Copyright Law. It will address some of the most contentious issues in copyright law, including the scope of copyright protection, the circumvention of copyright protection systems, and fair use.
This Restatement may promote a better version of copyright law, one that is less influenced by large content providers and that provides greater fairness to users of copyrighted works. "This opens a new arena for how copyright should work, one that isn't Congress or the courts. It will be more balanced than what goes on in Congress," said Prof. Jessica Litman of University of Michigan Law School.
Meanwhile, last year, a series of congressional hearings on the review of copyright law were held, following the 2013 US Copyright Office call for copyright reform. It remains to be seen how this will be taken forward under the new Congress.
Steven Seidenberg may be reached at info@ip-watch.ch.
"Year Ahead: Big IP Developments Loom For US Law In 2015" by Intellectual Property Watch is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License.
Filed Under: Features, IP Policies, Language, Subscribers, Themes, Venues, Copyright Policy, Enforcement, English, Finance, IP Law, Innovation/ R&D, Lobbying, North America, Patents/Designs/Trade Secrets, Regional Policy, Trademarks/Geographical Indications/Domains


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These monthly recent pins posts have become such a welcomed + interesting exercise. I first browse content recently pinned to my Pinterest account. Then I pick a few that jump out or I particularly love. Next, I group nine of those together based on what goes with what and coordinates well enough to make a final collaged image I'm obsessed with.
But then when I go to post it – and really get a good look at them collectively – THAT'S when the real magic happens for me. I start to sense themes. I start to see what's been resonating with me below the surface. Sure, the colors and the content are obvious, but it's the themes I see intertwined – that I didn't notice when choosing or grouping – that strike me the most.
Some themes I see: Lines. Lining things up. Circles. Things peeking out from behind something else. Layers. Overlap. Femininity. Lone females. Repetition. Freshness. Slate. Soft drop shadow. Searching. Down time.


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Title* Mr Mrs, Ms civilité*
"Paddington first appeared on television in 1975 in a series of 30 five minute programmes which were designed and directed by Ivor Wood and made in the UK by FilmFair Ltd."
Paddington first appeared on television in 1975 in a series of 30 five minute programmes which were designed and directed by Ivor Wood and made in the UK by FilmFair Ltd.
The films were made using a stop-start animation technique and were unusual in that they combined a three-dimensional Paddington puppet with two-dimensional backgrounds and other characters.
In 1979 a second series of 26 episodes were screened and they were awarded a silver medal at the New York Film and Television Festival, the first British animated series ever to win a major award.
All 56 episodes were written by Michael Bond and narrated using the wonderfully distinctive voice of Sir Michael Hordern.
These were followed by three half hour television specials, including "Paddington Goes to the Movies" in which Paddington was seen dancing the famous Gene Kelly routine from "Singing in the Rain".
Nine years later an animated cartoon series was made by the US company, Hanna-Barbera.
Then in the late 1990s a brand new, fully animated cartoon series was made by the Canadian company, Cinar. Unlike the earlier FilmFair series, all the characters were given voices. Although many of the episodes were based on original stories from the books, new storylines were also introduced which took Paddington and his friend, Mr. Gruber to different countries and places throughout the World.


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Restrictions on Overseas Shipments to Army Personnel
Order of the Postmaster General
Order No. 19687, dated January 7, 1943
The War Department has informed the Post Office Department that in view of the heavy demands being made on cargo space for military shipments and because of the limited facilities available to commanders of theaters of operations for delivery of mail, the volume of mail dispatched to overseas destinations must be kept to a minimum.
Therefore, in accordance with the recommendations of the War Department, the following restrictions on mail for Army personnel addressed to A.P.O.'s overseas, other than official shipments and shipments to military agencies, shall become effective January 15, 1943.
1. No parcel exceeding 5 pounds in weight, or 15 inches in length, or 36 inches in length and girth combined, shall be accepted for dispatch to A.P.O.'s overseas for individuals. (It is contemplated that there will be no exceptions to the weight and size limits for parcels to individuals.)
2. Except as hereinafter provided, no parcels shall be accepted for dispatch to A.P.O.'s outside the continental United States unless they contain such articles only as are being sent at the specific written request of the addressee, approved by the battalion or similar unit commander of the addressee.
3. Individual copies of newspapers or magazines shall be accepted for dispatch to A.P.O.'s outside of the continental United States only where subscriptions are specifically requested in writing by the addressee or for which subscriptions are now in effect. Such copies to individuals shall be accepted only from publishers who shall place on the wrapper, or on the publication when a wrapper is not used, a certificate (which shall be regarded as sufficient to authorize their acceptance) reading as follows:
"Mailed in conformity with P.O.D. Order No. 19687."
4. No circular matter of the third class should be presented for mailing to A.P.O.'s overseas, as the War Department advises that it will not be dispatched from ports of embarkation.
5. V-mail will be transmitted, either when microfilmed or in its original form, to all A.P.O.'s overseas and transported by airplane where such facilities are available. Although letters prepaid at the air mail rate of 6 cents per half ounce will continue to be transported by airplane as far as the ports of embarkation, the War Department advises that no assurance can be given that such letters, other than V-mail, will be dispatched by airplane from ports of embarkation to localities overseas served by V-mail.
Referring to restriction 2 above, the War Department states that individuals serving overseas desiring to request the mailing of parcels to them will be required to include in their request the following:
1. A general description or name of article requested.
2. The grade or rating, the complete address, and the signature of the individual (addressee) making the request.
The request will be presented to the battalion or similar unit commander who will approve it when the circumstances justify. Requests of officers not assigned to organizations or separate units will be approved by the next higher or theater headquarters. In case the individual making the request is a civilian, the request will be approved by the commanding officer of the installation concerned.
Parcels addressed to individuals at A.P.O.'s overseas must be accompanied with the approved written request from the addressee set forth when presented for mailing. The request shall be postmarked by the accepting employee in such manner as to prevent its reuse and then be returned to the sender.
Mail addressed for delivery to A.P.O.'s outside the continental United States shall embrace all that which is addressed to such A.P.O.'s in care of the postmasters at New York, N.Y., San Francisco, Calif., Seattle, Wash., New Orleans, La., Miami, Fla., or Presque lsle, Maine.
Mail of any character originally addressed to individuals at Army posts, camps or stations in the continental United States and received at such places after departure of the addressees for an overseas destination will be forwarded.
The restrictions of this order apply only to personnel of the United States Army and to contractors and civilians served through A.P.O.'s outside the continental United States. They do not apply to mail for personnel of the Navy, Marine Corps or Coast Guard, nor to international mail which will continue until further notice to be subject to the provisions of Order No. 17471 of April 30, 1942, and the general permits thereunder insofar as applicable.
None of the restrictions in this order apply to official shipments and shipments to military agencies overseas nor to any mail from A.P.O.'s outside the continental United States to points in the United States.
Postmasters shall return to the senders, marked "Dispatch prohibited by Order No. 19687" any prohibited matter obviously accepted for mailing after January 15, 1943.
This action is prompted by military necessity and it is believed that the public will cheerfully comply.
3 thoughts on "Restrictions on Overseas Shipments to Army Personnel"
Suzanne S. Barnhill says:
You have no idea how thrilled I was to find this page! If you look at my post at http://walkthoughts.wordpress.com/2013/01/13/what-is-a-five-pound-box/, you'll see why.
But I am also very pleased to have found your site because you have done what I have contemplated doing with my father's WWII letters from Italy. I've "published" a 756-page transcription for my brothers and a few other interested parties, but I thought there might be enough of general interest to warrant publishing them online. The letters date from August 1944 to approximately August 1945, and I had thought of posting each letter on the day 70 years after it was written (beginning in August 2014, obviously). But I suspect your site may have discouraged me more than it encouraged me, as you've done such a great job with it!
Suzanne, thank you for your kind words and I enjoyed reading your post very much. My project has moved ahead in fits and starts since my mother died in August 2011. I have about a half-year's worth of letters to transcribe and I've been off the horse for a bit now. But please don't let my project discourage you from doing the same with your father's letters. To be honest, I don't think my uncle has any giant insights to share through his letters, but I suspect in the aggregate, all of us with these sorts of letters have something to share with the world, so I think it's a worthwhile endeavor.
Thanks for your encouragement. Since I posted my comment I've spent some time working my way back to your first post and starting there. It will take a while to read through all of them, but I feel sure I'll find some more tips I'll wish I'd had before I had Dad's letters printed. I was just relieved to see that the information on five-pound parcels had been posted fairly recently (about the time I was putting my book to bed, in fact), so it wasn't something I'd missed in my earlier fruitless searches.


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Business, Digital, Social mediaComments Off on What does the Snapchat IPO mean for the media industry?
In terms of its user base, Snapchat is still lagging behind players like WhatsApp and Facebook Messenger. But Snapchat has much higher penetration among millennials, and is increasingly central to their usage habits. And what also sets Snapchat apart is its user-friendly, stylish, and adaptable news and content feeds.
Media owners are increasingly having to adapt digital strategies: where engagement used to be about driving eyeballs to their sites, it is now about placing content to where people actually spend time. The obvious winner here is Facebook, which now dominates the online publishing space; this year, it appears to have made more in advertising revenue than the entire US print newspaper industry. Publishers get a share of that, but every tweak in Facebook's algorithm can have a huge impact on their revenues.
So Snapchat's growth is also a glimpse of another future twist for media owners. While apps like WhatsApp and Telegram allow people to share articles (and the click-through rate is generally high), what sets Snapchat apart is those feeds I mentioned. Big online publishers can't just flood the app with links to their content. In fact, many now have a distinct Snapchat strategy (or have one in the works), and its young user base is a big reason. Many of the youngest internet users rarely visit a newspaper website, so this is a way for big publishers to try and build some brand loyalty early on within that hard-to-reach group.
Over the last few months, two very senior decision-makers at newspaper companies have told me they think the desktop will die before print. I can see the logic – mobile is fast becoming the main point of access for many internet users. Snapchat is therefore doubly interesting to publishers as, in addition to being a link to previously untapped groups, it provides access to a large and engaged community of mobile users.
So a double win for publishers if they get in on Snapchat? Well, not quite yet. There are problems with monetisation. One contact, who runs a newspaper publishing business, says that 'standard online display just doesn't work on mobile. The only things that works are video, audio and native'. So, big publishers can't just slap their usual ads on pages are expect them to work. They need to find a new solution for this destination. However, if they can work that out, there could be rich returns as video, audio, and native ads also encourage higher engagement, and often higher rates, than standard display.
A further pitfall is that, so far, it's very difficult to track levels of Snapchat engagement. Its analytics reporting remains sketchy, certainly compared to Facebook, which provides a huge amount of data for publishers and advertisers. It will need to improve significantly on that score if it's looking to justify that flotation number. And the problem with focusing primarily on younger users is that they can be very fickle – it's perfectly possible they could desert Snapchat in their droves if it becomes unfashionable, or if something more exciting comes along.
Either way, we watch how this one develops with interest.


Mr. Young is a business and technology executive with 10+ years of leadership experience across multiple industries including Education, Government, Financial Services, Telecom, and Professional Services. Mr. Young currently serves as a Managing Director for Acumen Solutions' Education practice. He is responsible for all of the solutions provided to Acumen Solutions' education clients, such as the NYC Department of Education, Dc Public Schools (Charters), KIPP, City Year, and more. Mr. Young's core delivery focus is cloud-computing solutions with a specific focus on the Salesforce.com CRM.
Before taking over the Education practice, Mr. Young was the Managing Director of the Public Sector practice with a specific focus on Web 2.0 technologies and cloud computing. He was responsible for the management of strategic Public Sector accounts including the General Services Administration (GSA), the Securities and Exchange Commission (SEC), the State of New Jersey, the U.S. Army, the Department of Health and Human Services, The Carlyle Group, Fannie Mae, and Freddie Mac. This role included a mixture of sales, delivery, and practice management responsibilities.


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For The Love of Leggings
Livia Margulies Shows How to Live The Ultimate Active Lifestyle, and Look Good While Doing It
Article Michelle Guerrero
Livia Margulies grew up on the beaches of Rio de Janeiro, where movement is a way of life. She walked to the beach, hiked the coast and played in the ocean almost every day. She walked to school, roller-skated for fun and started exercising at the gym when she was 12. People in Rio wear moisture-wicking clothes built for an active, tropical lifestyle. High-quality spandex is a must, yoga pants are the standard and clothes built to last are the norm.
"My love of leggings began there," Margulies says. "When I moved here I couldn't find a good pair. I bought the expensive ones and the color faded and the material quickly wore out. So, when friends went to Brazil, I had them bring them to me."
Today, Margulies calls North Scottsdale home, but still lives an active lifestyle. She's a busy mom of two 5-year-old twins and a 3-year-old daughter. She also runs a company she started nearly two years ago, Liv Rio Sportswear. All of this and she manages to make time for the gym every day.
This super mom joined forces with her cousin, who's a talented designer. They talked fabrics, style and manufacturing and created the perfect legging for active women. Her pieces hold up great in the desert and tropics because the fabric is breathable and designed for high heat. They're also designed for women of all shapes and sizes.
"My persona for my brand is me. A mom who doesn't have time to go to the gym and change afterwards. Our pants are all-day pants. You can go to the gym, sweat, pick up your child and attend activities afterwards," Margulies says.
When she's not in the gym, chasing kids or running her company, she enjoys mentoring female entrepreneurs and encourages stores to buy locally.
"Designers struggle, but there is talent here and the talent doesn't need to leave Arizona," Margulies says. "We can all grow together. I have a good brand and have good people to help me."
Margulies understands what women need and does what she can to give them what they want.
"We need to be strong," she says. "When our kids don't sleep, it's nice to wear clothes that are comfortable. You're going to feel good, be sexy and power through the day."
Learn more at LivRioSportswear.com, Facebook and Instagram. Liv Rio Sportswear can also be purchased at Heidi Boutique, Carmen Boutique, Voila Boutique, Blush Boutique, Recess Endurance, Moda Forte Boutique and The Biltmore Studio.
www.lifestylepubs.com
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CJAD 800 75th
Prince Harry and Meghan Markle quit social media: report
Prince Harry and Meghan have quit social media after growing disillusioned by the "hate" they have found on sites like Facebook and Twitter, a U.K. newspaper reported on Sunday.
The couple were rejecting social media in both a personal and professional capacity as part of their new "progressive role" in the United States, the Sunday Times said.
A source close to the couple told the newspaper they had "no plans" to use social media for their new Archewell Foundation and were "very unlikely" to restart utilising platforms personally.
The Duke and Duchess of Sussex, who moved to California last year after abruptly resigning from British royal duties, have previously had prominent presences online.
They amassed more than 10 million Instagram followers to their Sussex Royal account while they were working royals.
But the couple have also previously complained about their treatment on social media, as well as in the British press.
Meghan described past trolling of her as "almost unsurvivable" while Harry issued an unprecedented statement in 2016 denouncing "the racial undertones of comment pieces" and "the sexism and racism of social media trolls".
Last year they launched a wide-ranging non-profit organisation, Archewell, after giving up their "Sussex Royal" brand as part of the terms of their departure from frontline monarchy duties.
They have started other creative ventures, including signing a deal with Spotify to produce podcasts that tell "uplifting and entertaining stories".
The couple also signed a multi-year contract, reportedly worth tens of millions of dollars, with streaming giant Netflix to produce "impactful" films and series.
Meanwhile Markle, a former television actress, narrated a wildlife documentary on Disney+ in 2020.
Quebec is pursuing yet another strategy to bolster its dangerously understaffed nursing ranks. It will speed up foreign-trained nurses' authorization to do vaccination and testing, Quebec's professional order of nurses has confirmed.
Dozens of people say Bloc Quebecois Leader Yves-Francois Blanchet has blocked them on Twitter after they criticized his statements about Transport Minister Omar Alghabra.
Nearly 1,500 tickets for curfew violations were handed out between Jan. 11 to 17, Quebec's Ministry of Public Security announced on Twitter on Monday
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Trevor Noah and Angelo Lozada to perform stand-up comedy twice in one night at
Bob Carr Theater
Published by Sareth Ney on Nov. 13, 2017 at 6:22 p.m.
Photo credit: Trevor Noah's Facebook page
Photo credit: Stewie Vill
ORLANDO, Fla. – Trevor Noah and Angelo Lozada are set to take the stage twice in one night at the Bob Carr Theater, on Jan. 27. The first starts at 7 p.m. and the second will begin at 10 p.m.
While residing in South Africa, Noah hosted two seasons of "Tonight with Trevor Noah" and "South Africa's Music, Television, and Film Awards".
In 2014, Noah became a contributor of "The Daily Show with Jon Stewart".
Awards and accolades for Noah were being nominated for the MTV Africa Music Awards "Personality of the Year". He would go onto win in 2015. He has performed in front of sold out crowds on five continents. He was declared as the most successful comedian in Africa. His television show, "The Daily Show", has won an Emmy and Peabody Award. It was nominated for a Writers Guild Award. He was the subject of David Paul Meyer's award winning documentary, "You Laugh But It's True". Noah's book, "Born a Crime: Stories from a South African Childhood" was a New York Times Bestseller and nominated for two NAACP Image Awards.
Noah's latest comedy special, "Afraid of the Dark", premiered on Netflix in 2017. It was filmed at Beacon Theatre in New York.
Lozada is an actor, director, stand-up comedian and writer. Film works include: "Arrangemnent", "Kiss and Run", "Blind Leading The Blind", "Harlem Hostel", "Un Ghost", "Accountable", "Nick The Doorman", "On Top", "My America" and "Ned Rifle".
Television credits for Lozada consist of: "My America" and "Get Some!"
As a writer, Lozada wrote: two episodes of "BET's Comicview", one episode of "1st Amendment Stand Up", "Accountable", "Grinding", "Final Notice" and three episodes of "Get Some!"
One director credit was listed under Lozada's name and it was for "Accountable".
Credited as Lozada where he appeared as himself were the following: two episodes of "BET's Comicview", "Habla", "1st Amendment Stand Up", "Stand-Up 360: Muy Caliente Edition 1", "Stand-Up 360: Muy Caliente Edition 2" and "Gotham Comedy Live".
In the television series documentary of "Gotham Comedy Live" (2014), Lozada was credited for the documentary titled "Best of Season Four: New York, the City That Never Bleeps".
Along with Tammi Cubilette, Lozada co-hosts "Lozada Lowdown Live" at the Gotham Comedy Club.
Tickets to attend the 7 p.m. Noah and Lozada's performances are $39.50, $49.50, $59.50 and $85. Vouchers for the 10 p.m. show are $49.50, $59.50 and $85. The prices exclude fees.
Trevor Noah's upcoming appearances:
* - Indicates Sold Out
Nov. 17 - Orpheum Theatre, Minneapolis*
Nov. 19 - O'Reilly Family Event Center, Springfield, Mo.
Nov. 20 - The Masonic, San Francisco*
Nov. 21 - Sacramento Community Center Theater, Sacramento, Calif. *
Nov. 22 - Luther Burbank Center for the Arts, Santa Rosa, Calif. *
Nov. 26 - The Masonic, San Francisco
Dec. 1 – The Paramount Theatre, Seattle*
Dec. 2 – The Paramount Theatre, Seattle
Dec. 8 - Landmark Theatre, Syracuse, N.Y.
Dec. 9 - Palace Theatre, Albany, N.Y.
Dec. 15 - du Forum, Abu Dhabi, United Arab Emirates
Jan. 12 - Radio City Music Hall, New York
Jan. 14 - Borgata Hotel Casino & Spa, Atlantic City, N.J.
Jan. 19 - Arlington Theatre, Santa Barbara, Calif.
Jan. 20 - Dolby Theatre, Los Angeles*
Jan. 20 - Dolby Theatre, Los Angeles
Jan. 26 - Seminole Hard Rock Hotel & Casino, Hollywood, Fla.
Jan. 27 - Bob Carr Theater, Orlando, Fla.
Feb. 2 - Bass Concert Hall, Austin, Texas
Feb. 15 - The Wilbur, Boston*
Feb. 17 - The Wilbur, Boston
Feb. 23 - Fox Theatre, Detroit
Feb. 24 - Belk Theater at Blumenthal Performing Arts Center, Charlotte, N.C.*
Feb. 24 - Belk Theater at Blumenthal Performing Arts Center, Charlotte, N.C.
March 3 - Bellco Theatre, Denver
March 24 - Moda Center at the Rose Quarter, Portland, Ore.
April 13 - Comerica Theatre, Phoenix
April 14 - Centennial Hall, Tucson, Ariz.
May 19 - The O2, London, England, United Kingdom
May 20 - Ziggo Dome, Amsterdam, Netherlands
Aug. 10 - Foxwoods Resort Casino, Mashantucket, Conn.
Sareth Ney is the journalist for A Quarter and Dream Pictures. He holds a Bachelor of Science degree in Mass Communications from Colorado State University-Pueblo. He is a former apprentice to master of horror, Clive Barker. He is a Wu-Tang Clan inspired superhero, Wu-Man Chu. He is an award-winning short filmmaker; his goal is to write 150 articles in select time zones, he inducts every article into his hall of fame, is a stand-up comedian, motivational speaker, philanthropist, founder and co-host of Pueblo's Independent Multimedia Podcast, is the festival director at Sareth-Fest Music and Comedy Festival and Corazon Comedy Festival.


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SSR Regular and Emeritus Members in good standing may nominate worthy individuals for the SSR Awards according to the guidelines published annually. The awards are made solely to recognize outstanding contributions to the reproductive sciences and bear no obligation to the recipient or to the donor.
Carl G. Hartman Award
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Named for a distinguished reproductive biologist, this is the Society's highest award. It recognizes a career of research and scholarly achievements in the field of reproductive biology. It is not required that the nominee be a member of the Society. More Details...
SSR Research Award
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This award recognizes an active, Regular Member of the Society for outstanding research published during the previous six years. More Details...
SSR Jansen Distinguished Leadership and Service Award
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This award recognizes a member of the Society who has demonstrated unselfish service and leadership in advancing the discipline of reproductive biology. More Details...
Virendra B. Mahesh New Investigator Award
Supported by the Virendra B. Mahesh New Investigator Fund.
This award recognizes an active, Regular Member of the Society for outstanding research completed and published within 12 years after receiving the Ph.D. or other equivalent professional degree. More Details...
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Supported by the SSR Trainee Mentoring Fund.
This award recognizes an active, Regular Member of the Society who as a mentor has had a significant impact on Trainees within the SSR. The Trainee Mentoring Award is intended for individuals who exceed the basic roles of an academic advisor and becomes a mentor to those with whom they interact. More Details...
Janice Bahr Junior Scientist Travel Award
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This award recognizes a Regular Member of the Society, an active Assistant Professor or position of similar rank on the tenure track. More Details...
Fuller W. Bazer SSR International Scientist Award
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This award recognizes an outstanding International Scientist who has consistently demonstrated excellence in research and graduate education at an institution outside of North America. The individual demonstrates outstanding potential for leading and directing scientific research overseas. More Details...
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*Warning* don't try this at home with your current AK magazines. Especially your steel reinforced magazines!
Bought two to try out. 1 works. 1 won't feed properly. Both lock in nicely with little wiggle.
anyone who says these mags have slop or wobble is poorly informed and ignorant. they are using them in their junk out of spec century guns. i didnt have to file or fit this mag to anything. right out of the shipping box, these mags do not have any wobble what so ever in an in spec receiver. i just built my ak105 on a "recreator receiver", these mags fit so well, that im going to order a few more. the lock is so solid side to side and up/down. these mags fit all my other ak74 guns perfect as well. they cycle just as they are suppose to. not 1 issue period! dont pay attention to the ignorant people who say otherwise as they are totally wrong in every way shape and form.
I ordered one to try it out. Fits well in all my ak74 variants including the cetury tantal I have. Testing fit between military metal mags and this one show the amount of free play in the mag well is almost identical. Floor plates are the same as military ones, maybe a hair thicker even. No feeding issues out of a variety of 74s. I'd say it's just as reliable as any surplus mag I've used.
Whomever adjusted your magazine latch for fitment must have used a Tapco mag which has an oversized locking lug. These fit into our Saiga and Vepr Conversions nice and tight and we have zero wobble or feeding issues. When we fit Tapco mags for our rifles we always adjust the rifles for surplus mags and file the Tapco mags down that are included in the rifle box to prevent this from happening when using surplus mags. Easy fix is to replace your trigger guard latch if you have this problem and plan to use overseas produced mags. We always get returns or complaints on the Tapco mags since they are oversized and no one wants to file on them so these were done to exact specifications.
These mags look good, that's about it. They are thin, and the floor plate bends easily when dropped. The mags feed fine when not touched, but they are very loose. If you push forward or pull back they fail to feed about half the time. It's an AK mag, it should work as well as an AK, but it does not. Two different mags, two different rifles, same result. Surplus mags function 100% of the time in both rifles. I would rather they be thick so they could be filed down, but too loose there is no fix.


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Shooting Script
Inception Store
Final Scene
Inception Music
Featurette(HD)
Inception Ending
Blog that aggregates theories about the ending of the movie Inception
IMDb – My long theory on 'the long con'. SPOILERS!!!!!
by InceptionEnding
in Inception Ending
"…For me, the three biggest issues with taking this movie as "reality" have been:
1) Mal's suicide and Cobb being framed for murder. It just doesn't hold in "reality". Even if he had been charged with it, he would certainly be acquitted by any relatively good lawyer. Even Cobb's reason for not seeing his kids' faces seems weird: How many times in your life "right now or never" was that strong that he couldn't even take one minute to say goodbye to his kids, who were only a few yards away.
2) Saito's omnipresence: He can clear Cobb's charges with a phone call, he can set up Cobb and Cobol just to have an "audition", he can sabotage Fischer's plane, he buys a whole airline (even before knowing they needed the plane), he can rescue Cobb from Cobol's thugs and make them magically disappear as soon as Cobb gets in his car. It seems quite ironic that this man with, apparently, infinite powers, can't compete with Fischer's company.
3) Ariadne's uncanny knowledge. OK, she's gifted, she's a "natural". She can create from the first moment. I can buy that. But, even in her first dream with Cobb, she already knows that Cobb can't build anymore, she knows why Cobb can't build anymore, she knows that there is something very wrong with his subconscious (why doesn't she think, instead "OK, i was told not to change too much, and i did. I had it coming" or, "getting into people's subconscious is dangerous in general" )
Now, the fact that these things contradict reality, doesn't mean that they have to be part of a dream: There's other things that contradict reality, two of which are: Deception and the fragility of memory. Nolan dealt with them before, in "The Prestige" and "Memento" respectively. I think that for this movie, he grabbed this concept again, and added dreaming, as a third element.
The background of the story:
Cobb and Mal went to Limbo, Cobb planted the Inception in Mal, they came back, Mal killed herself.
Cobb couldn't cope with it. The guilt and horror for what he did consumed him, he ran away not afraid of the law, but afraid and ashamed of himself: He may have thought himself unworthy of enjoying being with his kids, he may have been afraid of, at some point, damage them like he damaged Mal.
Consciously, though, he wants to see them. But in his subconscious, he doesn't deserve them. The only thing he has is his dreams and, just like a guilt ridden person can drown himself in alcohol or drugs, he drowns himself in dreams. His subconscious creates a scenario in which he is a fugitive, not allowed to go back to his kids again. His subconscious provides an excuse, and traps him. After so much dreaming, it's that scenario, created by his own mind, that he recognizes as "memories".
Like the old man said "the dreams have become his reality".
He's gone insane, and is suffering his insanity.
His friends, co-workers and Miles humor him (because it's all you can do with a madman), and play along. He can still work, he's still good at it. But as time goes by, his subconscious starts interfering more and more, and he's becoming a bomb about to explode.
Miles figures out that, if they can't help him in reality, they can at least try to perform some "therapy" in a dream: Enter Ariadne, trained in the basics of "navigating" people's minds by Miles, and who learned all that Miles knows about Cobb.
At the same time, Saito, a powerful business man, wants to destroy his competition and has heard of Inception. He might have contacted Eames first: There is a not too clear relation between Saito and Cobol, and the fact that Eames was living in "Cobol's backyard" makes us think that Eames may have done some work for them.
Maybe Eames accepted the job and attempted the Inception (he says he tried it before, and failed). Eames knows Cobb, so he must have been aware of his delusion, and comes back to Saito with a counterproposal: "I know a guy who can do it, a guy who has gone deep enough before. But you will have to offer more than money to this guy for him to accept. If you want this job done, you'll have to do a little something for us"
Eames, being a forger, is the one who has the deepest understanding of people's minds, and he's also an expert con man. He knows that the only way to bring Cobb back to his family is to play into his delusion, and give him a way out from within the delusion.
Miles and Eames get in touch and realize that their plans are the two sides of a coin: Miles will help Cobb get rid of his guilt with the help or Ariadne, and Eames, by means of Saito, will give Cobb a way back home.
Nash is probably not only alive and kicking, but enjoying a load of money given by Saito as "severance pay" (plus some extra for taking a few punches). Why would Nash betray Cobb? It always bothered me. He didn't. But the plan needed Ariadne, and making it look like Nash had betrayed them, and that Saito handed him to Cobol was the only way to make sure that Cobb wouldn't hire him back.
The Mombassa sequence was orchestrated by Saito. Chances are Cobb is being chased by Saito's men. The purpose? To make Cobb believe that Saito is a reliable man, to build trust. To make Cobb believe that Saito will deliver when the time comes.
Saito has the same reasons to go into the mission. Eames's line when they visit Yusuf "this is no job for tourists, Mr. Saito" was probably just part of the "acting", and the weird exchange of knowing smiles between Saito and Eames near the end might point at that.
I don't want to make this even longer than it is, so i'm not gonna go through all the scenes of the movie according to this theory. You probably already got the gist of it.
Just one more thing: I think Arthur is clueless for the most part. Not 100% sure, but his dialogues with Ariadne when they're alone points in that direction.
How could Arthur be kept out of the loop? Well, it seems to be agreed upon that he lacks imagination. "You need imagination to perform Inception", Eames says, and you need a lot of imagination to perform a long con. Also, he's Cobb's closest collaborator. If Arthur knew, the risk of Cobb finding out would increase exponentially.
The end is real. Cobb is the last one to wake up. He has forgiven himself, and let go of Mal. He looks at Saito, as if reminding him of what he has to do. Saito (still confused after his Limbo experience) has nearly forgotten the last line of the play: To make a phone call that Cobb (as all of us) will assume is what he needs to go back safely into the US.
The long con worked perfectly, and Cobb is now back home to his family…."
—http://www.imdb.com/title/tt1375666/board/thread/168490767
IMDb – Kupotek – The Ending is Reality "The ending is reality. Cobb seeks Saito in Limbo where they remind each other the world is not real, Saito's gun appears, and the sedative had worn off. How do we know, because when they come out of Limbo, everyone is wide awake and alert, (key word being "alert"). It seems pretty...
IMDb – My theory of Inception's ending (Spoilers) "I believe Christopher Nolan has given us an ending to understand ourselves. The moment Cobb meets the elderly Saito is when we achieve the finale of the film in chronological order. Even though it was the first moment we see when Inception starts, it really happens last before any other...
Patricio-INTP – My Inception Theory "…Okay, from the last shot we know that he is still dreaming. I actually suspected this from an earlier scene, mentioned below, but also because his kids seem to not have grown any. Before I went into the theater, I had numerous theories about what the 'twist' is, knowing this...
IMDb – FAQ for Inception "Was the end a dream or reality? Although no one can prove it one way or another, unless that person is Chris Nolan, it is hard to say. But the more likely answer, is that the end was reality. This can pretty much be proven without any holes. Explanation: The...
Nolan Fans Forum – My Theory on Cobb and the Ending "I am convinced that Cobb is still dreaming at the end from some pretty cohesive clues; of course, please debate with me on my theories! I'm quite sure now, but I might not have caught something that you did . 1) The two sets of children: In the credits, there...
Ed August 18, 2010 at 1:24 am
The only problem with your explanation is that it is too intricate and too complex. You have read far too much into the storyline and introduced too many possibilities that the writers would have to have made apparent to the audience to get the point across. However, I think your take on the ending is accurate. It was real, in the end, and he really did make it back to his kids. My reason why is much more simple. If he hadn't made it back to his kids, then that means he didn't make it out of limbo. If he didn't make it out of limbo it could only be because he forgot that he was in limbo and began to believe limbo was real. If this was the case, he wouldn't have remembered that he was really on an airplane trying to plant an idea and a businessman's mind during the flight. He would have had to deny that reality and quit fighting to wake himself and Saito from the dream. That's why the ending has to be the reality and the top really will stop spinning. Unless, of course, the entire movie was inside Cobb's dream to begin with and he never really escaped the original limbo that he was in with his wife. That is the only way that the ending couldn't be reality.
I had this really long addendum to the possibility that Cobb may have really just been stuck in his own original limbo from the beginning. At first I was convinced that the end really was still real, but wanted to flesh out the possibility that it may not have been. However, it got deleted so I will post my musings in shortened version:
So his wife really got out of limbo but he didn't. He keeps encountering her because she is really trying to get him out. Unfortunately, after so many times with no success, she finally gives him up but lets him down easy by letting him think that he was right. That way he can live out the remainder of his real life happy in limbo.
I then went on to talk about how this still couldn't be accurate because Cobb has this constant drive to escape the dream and get back to reality. A drive he wouldn't have if he had really been trapped in limbo ( in which case he would simply be convinced that limbo was reality). At this point, I realized that at the end, he WAS convinced he was in reality and it was the reality he wanted. Therefore, it could have been that he really was just hopelessly trapped in limbo.
After all of this, I conceded to the fact that the writers of this really were completely iron tight in their ambiguity. For that, I commend them. Best movie I have seen in many years. Possibly even ever.
Bufgu - El Calde August 23, 2010 at 1:39 am
Let me, after viewing many valid and thorough posts and hypotheses, present a different idea, if only for discussion, since we can argue all these points back and forth.
What is truly fascinating about this movie is how Nolan can make tangible even the most abstract things within the flow of the movie that it seems perfectly acceptable. 1.An actual elevator to go "deeper" into Cobbs brain from the beach to the hotel. 2. an actual architect rendering these levels for the dreamer to fill with information that is revealing to the extractors, or inceptors in this case. These are all almost silly when discussed but fully plausable for those who saw it. Also well done is the exaggeration of dreams based on actual factors. When Arthur is flopping in the van, the entire hotel shifts axis and everyone floats as if in a space simulation parabolic flight. In the fitst extraction, an Entire building begins to flood from the top windows. The avalnch in the third fortress level. Each further level one goes into, the more exaggerated even a little event feels (whch is why they use the kicks at the very least).
So with that in mind, I will say the whole movie is a dream and an exaggeration of a fully relatable problem many fathers faec with their children in the corporate day of age. He is always on the road, going from place to place, losing touch with his kids, who he would love to be there, and his wife, who he must have arguments with. He has lost reality by ways of his constant and demanding job (one could even question if he is an actual dream grifter/incepter – or that is just his symbolism for someone who is in psychology or even something like advertising where he can manipulate the mind into wanting to buy a product or figuring out what focus groups like–which is why i can even believe someone saying this movie is actually in the past {look at the clothing and hairstyles emphasizing the 1920 to 40s–then again the hotel had modern technology.. anyways).
He is a man always on the run, and in his dream, he had fabricated that it is not his fault he is constantly o nthe road —
1."numerous anonymous corporations are constantly chasing you. ", which Cobbs wife uttered to him and questioned whther or not HE was dreaming, when they were both in limbo before she stabbed him.
2.a. His wife turned him in to force him to "take a leap of faith" with her and go into reality by jumping off the ledge. b.He is not allowed to go into the country because of this or he'll be shot. c. Others seem to know about this without being told.
3.his kids are never facing him, but turning and runnin away, almost going on childhood withouthim.
4.His guilt creates a wife who is a menace and dangerous (which he calles a shadow) , even though she seems so pretty and harmless, as an excuse to leave as if he doesn't have one good enough for himself.
So He is using companies and work as a scapegoat. He feel compelled to work just as much as he does to be with his kids. But the pressures of the corporate empire press down on him more than his guilt.
In this movie, his dream, his wife jumps off the ledge wanting to get out and into reality. She does this because she confuses reality with dreams based on his inception and follows his advice from a deeper dream to escape (by riding the rails so to speak). In actuality, its Cobbs own confusion of reality and perception of his day to day jobb. Cobb projects his wife, instead, being confused, and he jumping off the ledge is his own manifestation of him feeling he is losing his relationship with his wife. It's exaggerated, since it's symbolic in a dream, like the avalanche and the turning hotel. The reasons he is banned from the US based on this are almost absurd, since the police can find out the verdict fairly simply.
Cobb cannot jump with her, and be in a commitement with her forever, like he promised in marriage, his own perceived dreams by wearing the ring, and numerous times in the dream, because he is so reluctant to abandon his alternate reality: his demanding job -his day to day reality,, his dreeam/this movie and take a leap of faith to his family and kids.
Saito, is his fantasy. A man who can come and fix everything for him — by force no less. he can make a call, he can let him be with his kids. how? by Cobb convincing an heir to a corporate kingdom, to break it up into less powerful entities. How convenient. Cobb;s ticket to his family is by breaking up the establishment: convincing a corporate titan, the future runner of an international empire, to lay off, for lack of a term, and demagnify its hold of Cobbs everyday life. This is cobbs dream, a man to come sweep him and save him. Saito asks him to take a leap of faith, and cobb does… for a man in order to break up an empire first, family and guilt next. He cannot go back unless he takes care of his hecktic work situation and he cant take care of the work situation(by breaking apart the oppressive companies —the inception mission) until he can deak with his guilt.
The whole movie has a continuous loop theme. 1.the endless staircase 2. the recurring characters 3. most importantly, the clockwise depiction of a dream Cobb scribbled to Ariande, in her dream, of a mind constantly processiong and creating in a loop. Cobb then draws a line saying "this is what we need you to do, create, so the mark can process". This line is what the movie is. Cobb processing his situation above the surface (not in the movie) and creating more based on that procession below the surface (what is shown in this movie). It is prefect how the movie, like a clock, basiclly ends where it began, on the 12, on the beach in Japan, but like a clock, the hand may still be on the same number but it is in a different time, not 12am but 12 pm. Saito is old, relecting now Cobbs anti-hero, the opposite of Saitos early depiction of a fantasy. Old and alone, regretting his inaction is saito, just like he told cobb not to be.
He is in his deep limbo here, on the beach, washed ashore on the coast of japan. his own mission to save, within himself, his sanity, is complete with the inception into fischer. He can go to his kids again, and not have to work. The totem spins, and just when it wobbles, the movie ends. It's not important, Cobb doesn't care anymore. He will stay in this state with his kids to leave reality and responsibility of work and fam.
The top – the top is cobbs totem all along, Not Mals. Why? The only totem not shown in the movie is either Cobbs or Mals. Many think the top is not cobbs, due to obvious scenes where it clearly shows her owning it. However, throughout the whole movie, Mal is a projection by Cobb. She is the only one guaranteed to not be in the movie. In no way is she hooked up to the machine on any level. Since the movie is a dream and all the figures in it are projections, Cobb can know their totems since he created them in his mind, whether his subconscious self knows about them or not. Since Mal enterred the dream with Cobb on the same level, and is now, one can argue, awake, Cobb's subconscious doesn;t know his wife's totem because she never showed it to him in reality. So, when he, in his limbo, projects his wife, his closest thing to him, he renders his token as hers since, when they entered the dream, he had no clue what she would use to know reality. By him projecting his wife to lock the totem safe in a vault, he is convincing himself on a deeply subconscious level that his wife's dream of them to be together and not have him jet setting for work are unrealistic (since in that dream they made in limbo they were together always). He then spins the top and changes reality to make her believe this is not possible. This is him trying to convince himself his work is worth it. He ends up regretting it because his wife jumps off a ledge because of this.
By spinning this deepest level top, his whole perception of a totem being a link to reality. On his deepest level, he changed the meaning to what a top spinning means. So when his wife jumps off the ledge and the top is still, it is his reality since he convinced himself it is. He is confused, just as his wife said, just as ariande said, just like michael caine said (sorry forgot his name), and his totem lost meaning. So at the very end, when the top spins and wobbles a bit, He is in a fantasy land, but it doesn't matter. He walks away to join his kids in a state he wants to be real and convinces himself to be, although it is not. He is in limbo.
how is that? well, the way the top wobbles is telling. nolan could have cut the scene at any time after the wobble, but only does when the top is perfectly upright. Of course, when filming, the top eventually fell, but when the screen is cut is totally arbitrary and the top looks as if it will recover. It is purposely vague, because this is scence is vague, even to Cobb, but it doesnt matter sinec he convinced himself to be able to accept the guilt of alienating his wife for work, at least in his make believe state. His kids, he can have now that the corporation is broken up and work is done. When he is in reality, he may have to quit his job, but for now all good.
why are the kids different? they are slightly different in dress and in positioning in the final scene which is extremely telling. Since in cobbs mind, he has not seen his kids in some time when he finally does his brain knows to render them a little differnt. However, his brain only has that one image to work with, so the alterations are ever so slight, but not enough to probably reflect reality, since he cannot.
who is ellen paige supposed to be. well, ellen paige is his own representation of a female young Cobb. A young Cobb, after college, would question cobbs actions constantly and and play counter to his actions. She is a flat one dimentional character, as is his wife, since they are projection by cobb to convince himself conflictiong things. They bother question if he views reality correctly and oppose his actions. They are made by a man to oppose a man, so its not deep. However, the college kid is described as being being "even better than"cobb was at her craft. the kid is his old self asking why do you do these things? old self knows. he views her as his better self.
A November 22, 2010 at 11:14 pm
He looks at Saito, as if reminding him of what he has to do. Saito (still confused after his Limbo experience) has nearly forgotten the last line of the play: To make a phone call that Cobb (as all of us) will assume is what he needs to go back safely into the US.
I don't think that's what happened. It was more like: Cobb and Saito look at each other to realise what they have just done in the dream and how they escaped and are successful in their goals. It was look of amazement, friendship and sacrifice (Cobb actually went into Limbo to bring back Saito alive) This was the most emotional part of the movie for me.
…continuing from post above…
And Saito was didn't need "reminding" or "convincing" in order to make the phone call. As soon as he realised what has just happened (he was saved from death by a friend who told him they could come to reality and "live together as young men"), he willingly reached out to make the phone call. Which is why this was a very emotional scene. Actually made me cry.
A November 24, 2010 at 12:23 am
It was the final musical score from the moment Cobb wakes up till the end of the movie that got me. And also Saito's shaken up looks when he woke up. He had just realised that he had been saved otherwise he was going to die. In the end they both needed to wake up from Limbo to help each other. Cobb for his kids and Saito for actually coming back to reality from the Limbo state.
Alfreda Robertshaw February 12, 2011 at 10:24 am
I was aware about this already, but still there are some beneficial bits which concluded the image for me personally, thanks a lot!
Cleo April 24, 2012 at 11:48 pm
I noticed right away that Eames doesn't like Cobb and won't look him in the face – it's very different from the way that Eames treats Arthur.
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Q: Create Alarm Clock Alarm Android I would like to know if there is a way to programmatically create an alarm clock event? I know with API 9, you can use the AlarmClock class set parameters and then pass them to the activity, but I would like to mimic this same action inside my app, without pulling up this activity.

A: You can still use the AlarmClock API. If you want to skip bringing up the AlarmClock activity add this extra:
i.putExtra(AlarmClock.EXTRA_SKIP_UI, true);

Though I have experienced a known Android issue where this extra causes the alarm to be created and saved, but it doesn't arm correctly (it won't ring go off when the time comes even though it appears as on).  The work around we found for this issue was to call startActivity() twice.  Thus far it has been working perfectly.

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Guys, no science in this one. Also, stay tuned for a better treatment of this topic from Archana Dayalu over at Policylab. I originally wrote this for policylab, but it turns out Archana had the same idea earlier. Hence you'll notice a completely different writing voice (it's not the fun one I use in my blog).
As I wrote in the past, outsourcing of manufacturing jobs allows the US to push all the pollution in manufacturing into other countries while enjoying lower prices of goods manufactured by cheap labor. Thanks to Kate Wang for bringing a recent NYT article to me attention.
Atmospheric modeling shows that transport of the export-related Chinese pollution contributed 3–10% of annual mean surface sulfate concentrations and 0.5–1.5% of ozone over the western United States in 2006. This Chinese pollution also resulted in one extra day or more of noncompliance with the US ozone standard in 2006 over the Los Angeles area and many regions in the eastern United States. On a daily basis, the export-related Chinese pollution contributed, at a maximum, 12–24% of sulfate concentrations over the western United States.
In other words, goods manufactured in China and consumed by the United States directly cause pollution in the western United States. The upside is that the former heavy manufacturing centers in the Eastern United States have outsourced to China, cleaning up the air of the Eastern US. The article points out that, given the dense population of the east coast, this is a net win for the US, at slight expense of the west coast and great expense of pollutants in China.
Air pollution in Beijing. One picture taken on a clear day, another on a smoggy day. This is the capitol city of China. This is the ugly side of outsourcing.
It remains unclear what the author's ultimate goals are. There is no international accounting of pollution. Either the authors are greenwashing--the practice of trying to make manufacturing or other industry look environmentally more friendly through the process of bullshitting--or they are anticipating some accounting system, either internal to China or external, in the future.
The authors argue for a different method of accounting for pollution associated with manufactured goods. Currently, all pollution is attributed to the producer. Chinese factories build the goods, China gets assigned the pollution in international ledgers. Consumption based attribution, they argue, would make more sense. The goods are made for American (and otherwise) consumption, and the pollution should therefore be attributed to America.
Disregarding whether this is right to do, or whether it would accomplish anything more than green-washing China's economy, let's explore several of the implications of this policy change. Specifically in a hypothetical world that has to account for pollution contained within products, which, aside from green-washing, would be the major reason to worry about pollution attribution. Manufacturing of these export goods requires significant amount of energy. The sulphur and black carbon that reaches the west coast specifically come from coal-fired ower plants. China puts few controls on emissions from these power plants, and the required rate of construction results in power plants that are significantly less efficient than those in the US. This means that every bit of energy produced and used in China, for manufacturing or otherwise, contains more pollution than it would in the US or any other developed country. Moreover, Chinese manufacturing is less efficient than developed countries for a variety of reasons.
The end result is that a good manufactured in China embodies more pollution than the exact same good manufactured in the US, Japan, Korea, Europe, or any other advanced nation. If policies were put in place to move to a consumption-based attribution of pollution, and that attribution had real-world implications on the cost or value of a product, Chinese goods would face a competitive disadvantage. The implications are pretty straightforward: either China cleans up its manufacturing and energy sector, greatly benefitting China and slightly benefitting the rest of the world from a pollution standpoint, or goods are produced in countries where they can be made for less environmental cost, hurting China's exports while healing its air quality and benefitting the rest of the world financially and environmentally.
While this attributing of pollution on the consumption side seems to mostly have net benefits, it only works if purchasers or producers are forced to pay for pollution they bring about. We are not currently in a world where either are held accountable for the pollution associated with manufacture of Chinese exports. In this, Jintai Lin's suggestion seems only like greenwashing: an attempt of finger-pointing for the destruction of China's air quality and environment.
The President's State of the Union Address. Geopolitics of Oil: Expanded US (and Russian) Oil Drilling and the Middle East's Bane.
What do the price of oil, the president's state of the union address, and middle eastern stability have in common? In the address, the President talked about fighting climate change, but the US is going full-tilt towards more drilling. While this sounds like hypocrisy, it actually puts the US and the world in a better position to deal with climate change. Sounds crazy? Keep reading. Here's a hint though: What would happen if the price of oil dropped to $40 overnight? Much of the Middle East power structure would collapse.
Because this is a science blog, I am writing science stuffs here.
I want to point out three things. First, in the 70s and 80s the US was one of the world's most prolific oil producing countries. A lot of this came from huge Texas fields, like Eagle Ford. And then the gigantic basins like Eagle Ford ran out of easily accessible oil, and US oil production collapsed. Now look at the ramp rate of production in the most recent years. The rate of increase in production is unprecedented. It's going up fast.
Notice the massive rate of increase of production. From 2008 to 2012, Texas alone increased production so much that it provided an additional 2% of the world's oil. North Dakota is producing nearly 1 million barrels a day, or slightly more than 1% of the world oil. Together, they produce 3.75 million barrels per day, 4% of the world's oil.
Let's put this in perspective. Iran produces 4 million barrels a day. North Dakota and Texas alone produce nearly this much. Look at those growth rates. Are they showing any signs of slowing down? No. In other words, the US is rapidly becoming one of the world's most prolific producers of oil.
Every single major play of the 70s and 80s is about to become a new Bakken.
That means going back to the days when the US was the largest oil producer in the world. That means Russia is also going to be able to ramp up production, once they figure out how to hydrofrack.
So the price of oil is going to drop in the future.
This would mean less military spending, which would in turn mean more domestic investment (or lower taxes, but our ailing infrastructure and gutted R&D budget really could stand to be brought back up to where it was when the US rose to become the world's only superpower).
The second implication of this glut of oil is much more far-reaching. It means is lower oil prices worldwide. If oil drops below $75 a barrel, even Saudi Arabia struggles. It'll be hard for the Middle East to make trouble when they cannot afford to. Now let's say hypothetically that Iran funds terrorist groups (I haven't researched this and don't know whether it is true, so it's a hypothetical). If the price of oil drops to the point where they can no longer profitably produce, then suddenly our hypothetical country cannot fund terrorism. And we save moneys from no longer needing as much anti-terrorism programming.
In other words, we save money because we won't be sending military to the middle east, and because terrorism will potentially be more poorly funded.
Let's sum up: produce more oil, the price of oil drops, countries and companies make less money from oil (mostly countries, companies have a way of maximizing profits pretty well), since countries have less money, they can't push their state agendas as much.
So, pretty much, drill more in the US (where we can regulate emissions), save a ton of American (and European) money by no longer having to make sure there is peace around oil resources, use that money to fix all the problems we've created with the environment. In other words, more drilling is a potential long-term solution because it will eventually free up more funds in the federal budget.
It's my guess that the president can't say, "We need to drill in the US to make it so we don't have to spend money stabilizing the Middle East. Once that is no longer a problem, we can use the extra money to address climate change."
Some criticisms: If the decrease in the price of oil results in more oil consumption, this would be bad for the environment. We need to continuously improve efficiency of vehicles and industry, and decrease our demand for oil and fossil fuels. Any money saved from military intervention happening less should be driven towards this goal.