War Is Peace, Freedom Is Slavery, Ignorance Is Strength

1984 for whatever length of time that legislatures have existed, the individuals they governed dreaded them. This dread and the longing to improve these legislatures have let to innumerable various endeavors to consummate government. From the most liberal vote based system to the most smashing autocracy, governments have all confronted a few inadequacies. Due to the shortcomings inborn in all administrations, different kinds of administration have been the subject for some creators. The late author Ayn Rand composed numerous books on the difficulty that a communist government could bring and embraced the ideals of independence. She felt that by permitting government to confine our individual opportunities, we were condemning ourselves to an unavoidable passing. She composed that â€Å"We are quick moving toward the phase of a definitive reversal: the phase where the legislature is allowed to do anything it satisfies, while the residents may act just by consent; which is the phase of the darkest times of mankind's history, the phase of rule by savage force† (Rand). Rand understood that an administration with a lot of control would not have the option to help however overextend. In spite of the fact that George Orwell passed on seven years before the distribution of Ayn Rand’s most notable novel Atlas Shrugged, he held a similar dread of an almighty government. Orwell felt that with the new innovation showing up during his life and the ever-expanding intensity of government, the legislators could decide to control each feature of the citizens’ lives. The tale 1984 is a delineation of what Orwell thought would occur if an extremist system were left unchecked by the individuals. He portrays this oppressed world in 1984 by the marvelous utilization of both imagery and incongruity. Orwell lets practically no time go before he brings imagery and incongruity into his story. He starts his novel by saying that â€Å"it was a splendid, cold day in April, and the timekeepers were striking thirteen† (Orwell 1). By saying that it was a splendid day in April, Orwell gives the peruser a feeling that there is trust. April, a month in the spring, is an image of a fresh start and is an exemplary artistic apparatus for indicating the start of a novel. Orwell’s notice of a brilliant day is another reference to the expectation despite everything present in the lives of the characters. Had Orwell expressed that the day was dim or diminish, it could have given the peruser a totally extraordinary point of view toward how the characters lives may turn out. Regardless of these two hopeful images, Orwell likewise tosses in two foreboding images in a similar sentence. The explanation behind doing this is to established a pace of incongruity that brings through the remainder of the book. Notwithstanding depicting the day as brilliant, Orwell additionally depicts it to be cold. This is his unpretentious method of illuminating the peruser that not all things are well in the characters’ lives. Orwell additionally thought that it was essential to tell the perusers that the tickers were striking thirteen, a foreboding number for some social human advancements. A case of this is in Christianity where Judas, the thirteenth individual to be situated at the last dinner, later double-crossed Jesus. (Imprint 14. 10-11) The improvement of the plot of 1984 is loaded with instances of incongruity. Orwell for all intents and purposes illuminates the incongruity for the peruser when he composes, â€Å"Even the names of the four Ministries by which we are represented show a kind of impudence in their intentional inversion of the realities. The Ministry of Peace worries about war, The Ministry of Truth with lies, The Ministry of Love with torment, and the Ministry of Plenty with starvation† (Orwell 178). This is a significant case of incongruity since it is utilized to show the total detach from the ethics and standards of a free society. The principle character, Winston Smith, is to some degree an unexpected character himself. He isn't the run of the mill hero. Most heroes are solid, husky and bold, while Winston is slight and has a ulcer on his leg. Winston is utilized in the â€Å"records† branch of the Ministry of Truth. In spite of its respectable name, The Ministry of Truth is really the part of government that amends the past to make the lies of the current valid. Truth be told, Winston’s work is to revise history to meet current needs. Another prevailing case of incongruity is the Party’s trademark: â€Å"WAR IS PEACE, FREEDOM IS SLAVERY, IGNORANCE IS STRENGTH† (Orwell 17). The trademark is a case of shallow verbal incongruity. In any case, upon closer assessment, it reveals more insight into Orwell’s plan. By expressing that â€Å"war is peace†, Orwell sends particular messages to two tremendously various gatherings. To the proles, the everyday citizens, â€Å"war is peace† can be perused at its most exacting significance, that there can one day be harmony by vanquishing the adversary and making sure about triumph. In spite of the straightforward understanding the proles have of the motto, those in the Inner Party, the gathering of individuals responsible for Oceania, have a significantly more insidious comprehension of it. To them, the trademark speaks to the shell game that they play with the normal resident. Much like the road speculator taking wagers on which shell the stone is under, the Inner Party guarantees that the populace is centered around whatever nation Oceania is battling, as opposed to on the pioneers of the nation. This case is additionally upheld on page 161 where Orwell portrays the purposelessness of the wars that are being battled. â€Å"None of the three superstates ever endeavors any move which includes the danger of genuine defeat† (Orwell 161). Instead of attempt to end the wars, they keep battling to keep the psyches of the regular workers busy with detest. The pioneers in 1984 saw that it was not beneficial to advocate a severe good code since it restricted their capacity to control the people. Saul Alinsky shows a later case of this kind of intuition in the book Rules for Radicals. Alinsky, a network coordinator, plot a lot of rules for individuals to follow as a tricky methods for picking up and looking after force. He saw that so as to look after force, things, for example, ethics and morals should have been adaptable. One of his most significant standards was that â€Å"generally, achievement or disappointment is a forceful determinant of ethics† (Alinsky 15). It is a sheltered suspicion that if Alinsky’s rules were accessible to the Inner Party, they would know precisely how to utilize them. The absolute most grounded instances of incongruity in 1984 are the characters in the Junior Anti-Sex League. The name is run of the mill of an association in a tragic culture that tries to defame whatever causes one gathering to appear to be over another. Much like the Ministry of Love that handles the jails and order, the Junior Anti-Sex League is a Catch 22 also. As a matter of fact, the individuals from the group are exceptionally wanton. One of the fundamental characters engaged with the Junior Anti-Sex class is Julia. Ironicly while on a journey with the Junior Anti-Sex League, she finds where she and Winston initially start their issue. At the point when Orwell depicts her, he discusses â€Å"her sweet flexible abdomen, which appeared to request that you encompass it with your arm† (Orwell 17) and portrays the red band around it. Ironicly Orwell would go to such extraordinary lengths to portray Julia as an alluring female character, since she is an individual from the Junior Anti-Sex League. Regularly, those related with bunches that uphold woman's rights attempt to make light of their elegant qualities. It is likewise amusing that the scarf around her abdomen is red. Red is a shading most connected with energy and love, ideas that the Junior Anti-Sex League didn't concur with. One of the key inhabitants of the Junior Anti-Sex League is virtue. When utilizing imagery, most creators pick the shading blue so as to pass on a feeling of â€Å"loyalty, loyalty, steadiness, and chastity† (Jaffe). This is the reason The Virgin Mary is normally painted sporting blue. A case of imagery, productive all through the story, is that the lives of the characters are in â€Å"telescreens†. A telescreen is a gadget that â€Å"received and transmitted simultaneously† (Orwell 6), and permitted Big Brother to watch out for the individuals. The telescreens straightforwardly represented the unavoidable idea of an extremist government’s want to control the people. For a mind-blowing duration, Orwell had encounters that helped shape his perspective on these administration types. As a youngster, Orwell filled in as a harmony official in Burma. There, he saw the manner in which the British government rewarded the local Burmese individuals. Orwell got insulted with the barbarism that infested the British Imperial and in the long run distributed two of his most celebrated papers, â€Å"A Hanging† and â€Å"Shooting an Elephant† (Brunsdale 7). Orwell was likewise ready to see the revulsions submitted by the Soviet Union, â€Å"where an expected 7,000,000 died in 1940 alone† (Tolstoy 283). Due to his background, Orwell utilized the telescreens as a representation for how governments misuse their capacity, and to reveal insight into his dislike for authoritarianism. As the story advances, Winston finds a classical shop. In addition to other things, Winston buys a glass paperweight. Inside the glass is a bit of coral. Orwell portrays the paperweight as a â€Å"heavy piece of glass, bended on one side, level on the other† with a â€Å"strange, pink, tangled article that reviewed a rose or an ocean anemone† (Orwell 80). Winston is dazzled by how enormous the coral appears to him and feels that it has a feeling of changelessness and significance. â€Å"Winston’s [paperweight] has a bit of coral implanted in it, and he looks at it eagerly, astounded that anything so fragile could make due in a severe age† (Shelden 431). The paperweight is significant for two reasons. One is to show how little the individuals know about how old something is. The paperweight is the modest kind of scratch nack that would be found in a blessing shop at a medical clinic or a truck stop. Be that as it may,

Motherboards essays

Motherboards expositions Motherboards are the fundamental piece of a PC framework. Additionally considered a primary board a motherboard is answerable for associating all the parts of a PC framework and permitting them to impart between one another. In 1924 the Tabulating Machine Company was renamed to IBM. Hewlett Packard was established in 1939. The main transistor was developed in 1947. In 1967 IBM made the main floppy plate. In 1968 Intel Corp was established. In 1970 the main microchip was conceived just as the primary Random-get to memory module also called RAM. In 1972 Compact plates were concocted. In 1975 the main PC hit the market with one kilobyte of memory. Its expense was around $397. In 1981 the Commodore is discharged which later turns into the universes most well known PC. In 1985 Microsoft and IBM start cooperating on their new working framework called windows. These are the central matters on the historical backdrop of motherboards. This history was found at www.motherboards.org. On the Website www.howstuffworks.com it depicts motherboards like a little size of a city. The principle chips take power from one source and the data goes on a various path thruway to get to the entirety of the segments of a PC framework. Throughout the years motherboard sizes havent truly changed yet the usefulness of the primary board has considerably expanded. A motherboard is a multi-layered printed circuit board. Copper circuit ways called follows convey signs and voltages over the motherboard. Various layers convey various information to and from the profiles, processor, and memory transports. One of the most basic pieces of a motherboard are the fans. Fans are utilized to cool the various parts of the motherboard just as the PC down to a temperature that will push out pinnacle execution out of the PC. At the point when power is going through a PC framework it creates expanding heat. This alongside thickness an... <!

Two of the most important things Essay Example Essay Example

Two of the most significant things Essay Example Paper Two of the most significant things Essay Introduction In showcasing two of the most significant things are the promoting division and the advertising blend. Regardless of whether you think of a â€Å"gee-whiz† item, on the off chance that you don't utilize the correct promoting fixings the outcome can be devastating.Nowadays, Sony is the one of the most effectively developing electronic organizations on the planet yet it can't be credited just to the innovation and the innovation.Sony’s showcasing division comprises of four unique lines: hardware (camera, PC, camcorder, TV, Walkman, MP3 players), Sony Music and Sony Pictures, advanced amusement (Play Station) and cell phone (SonyEricsson).One of the greatest strides in Sony’s life was the point at which the Sony Computer Entertainment area was set up with the Play Station 1 (PS1) idea, and later created with the Play Station 2 (PS2) concept.By the mid-1990s, the entire organization was in a profound funk. Its benefits had sunk from a high of $1,3 billion out of 1992 to lost $3,3 billion of every 1995. The arrangement was the Play Station division in 1993. Under 5-years after the fact, the Play station business had developed to accomplish an unfathomable 40% of Sony’s $3 billion in working benefits and these days, it brings almost 50% of the company’s benefits and Sony possesses the greatest offer from this market in the world.So how was this achievement compromised?Task 1SEGMENTATIONSony undertakings to comprehend its clients however much as could be expected. The advertising division makes the procedure progressively proficient and viable. It separates the market into little pieces and targets individuals who have a place with a similar gathering and feel a similar want for a product.Geographic:Sony obviously goes all out for to gracefully singular clients. The organization moves its endeavors in three key markets: USA, EU and Japan however it is likewise spoken to in 200 nations with help in 68 dialects. Such an all around port ioned showcase permits the association to concentrate explicitly on the necessities of their specific markets. The Sony Computer Entertainment America (SCEA) has been set up by Sony to concentrate explicitly on the USA showcase while the Sony Computer Entertainment Europe (SCEE) thinks about the European consumers.A genuine case of how this has appeared is that its support and advertising of the item for the Japanese market. Sony concentrated on the way that in excess of 20 million individuals have fast web associations and henceforth it offers PS2 with on-line function1. Be that as it may, in the USA advertise the circumstance was unique and they understood that the rendition didn't have an on-line function.Mr. Jack Tretton, VP of SCEA says: † 20% of clients pick the on-line PS2 and its 80% pay the less expensive disconnected product.†In the European market the EU part nations command, particularly Western Europe. The significant programming journalists are situated in London, Paris, and Vienna to gracefully the immense game demand.Demographic:Gender before all else, most programming created was explicit to the youthful male, such as battling and shooting match-ups. Before long, notwithstanding, Sony understood that it could profit by the female citizenry as well. In 2004, it propelled its development: the Eye Toy. It is an uncommon camera which players can see themselves on the screen progressively and play table tennis, boxing, cleaning windows and drumming for instance. This has been an achievement in 2003-2.4 million pieces were sold. (Record 2004)Age-The PS1 support in fact is mediocre compared to the PS2 that it is likewise less expensive. It has less forceful games so it is ideal for individuals age somewhere in the range of 6 and 11. PS2 is increasingly proficient both in equipment and programming thus the age division is somewhere in the range of 12 and 19.The most up to date Play Station reassure will likely be advanced in 2006 with extr aordinary highlights. The processor may be executed from the pioneer IBM innovation, which is utilized in the popular Power-Apple PC. It will likewise have web modem so even grown-up players can discover get to the Internet playing on the system against each other.Psychographic:In Japan, Sony portrays the Play Station 2 as a completely new dohyou, utilizing the Japanese world for sumo ring. Some of the time playing a game can mean something beyond fun. Individuals like playing and winning. It very well may be progressively genuine even among grown-ups. These individuals with achiever and yearning characters like to â€Å"challenge everything† (EA GAMES-one of the greatest programming maker company).Behavioural:Benefit-Sony’s procedure depends on the way that it attempts to convince customers that its image offers the best quality for their cash and it is not the same as the others.The new PS2 for instance, is, overly light contrasted with different consoles, along thes e lines it is versatile and youngsters can take it with them on vacation, for instance. With the portable idea, Sony attempts to press out Nintendo’s palm consoles.Loyalty-The clients feel solid dedication to the Play Station brand. Above all else, it originates from the conviction that the nature of the item and administration fulfill the clients on a significant level. Also, there is a connection between's the two consoles.Compatibility-The original of clients who experienced childhood with PS1 want to purchase PS2 on the grounds that they can play with their old games on the new machine. This reality and the brand devotion guarantee that over the long haul individuals become medium or even substantial users.Task 2 (A)MARKETING-MIXThe showcasing blend is the one of the most significant things in promoting. The hardest thing is to discover the best blend from the current ingredients.Product:Brand name-Sony consistently attempts to convince shoppers that its image offers the best quality for them. The company’s objective is to construct a solid brand name to catch shopper unwaveringness and inclination. The Sony name is equivalent with quality and worth, while the Play Station name recommends the idea however it is obviously distinguished independently from the fundamental brand.Hardware-The organization spends tremendous sums on innovative work and is the first to create items. When PS2 was first propelled, Sony had made a machine, which was driving edge its highlights incorporated a 128-piece processor called the â€Å"Emotion Engine† which was multiple times quicker than a Pentium chip of the equivalent vintage.Sony is the main organization in the diversion advertise which offers such huge numbers of various structures of equipment: present day silver, genuine dark and cutting edge transparent.The likewise produce in excess of 30 beneficial units.Software-From the starting Play Station was created in union with the greatest programming organizations, for example, 3DO, EIDOS, NAMCO UBISOFT and EA GAMES. It made it ready to deliver considerably more programming games in the beginning periods. Of late it has given it a major preferred position when opponents need to step into the amusement showcase. The key is the scope of games-PS 1 and 2 offer in excess of 1500 games to its new consoles while Microsoft under 500.Service and experience-Sony positions client care profoundly both when buying. In the principle this is conveyed by means of the Internet through their extremely famous www.playstation.com landing page. The clients discover item and specialized counsel, just as having the option to interface into different PS clients to talk about issues. They can request and purchase equipment and programming support, play in systems and in the event that someone is enrolled in the database, they will get uncommon offers and a ton of helpful data by email. It unites the clients and adds to the experience of being a piece o f Play Station.Price:Sony utilized hostage item estimating for its dispatch, attempted to sell its consoles on moderately modest and bring in cash on computer games, thus it had the option to diminish support valuing and increment its net revenue on games titles †to sixty-five percent in 2002. (List 2002)The PS2’s greatest adversary was Microsoft’s X-Box reassures which were presented in 2001 however it couldn't break into the market despite the fact that its cost is $99 against PS2 which is $149. Sony responded in 2003 with another PS2 Satin Silver Edition and it expanded deals by 15% on the grounds that the new item wave was at the privilege time.Microsoft’s value technique is straightforward, it attempts to diminish the cost. Then again, Sony offers its consoles with 2 free games to entice costumers to purchase instead of decrease its cost and follow the adversaries. Sony likewise has not entered the market at the ease end, which its adversaries have nee ded to do so as to contend yet have depended on its â€Å"Quality† picture to help such an evaluating system. It focuses on the way that individuals frequently feel that if something is generally modest, it must be low quality (regardless of whether it isn't true).Place:Sony presents its Play Station idea in Asia, Europe, Africa, America and Australia.It advances its consoles in master shops, grocery stores, especially play shops and other comparable spots. Here costumers likewise can play with and test the new equipment and programming with the accessible consoles.Every year the Play Station truck goes around America, consequently an open door presents that clients can play and test the new games free in a modern surrounding.Promotion:The endeavor spends a ton of cash on crusades particularly in the USA to crush out its greatest opponent from the second greatest market2.Task 2 (A)THE U.S.PWhen first PS1 was propelled in 1994, it was the ideal time to get the new PC age and m ake for them another amusement world. Ken Kutaragi conjured up this new computerized world. Kutaragi conceived a PC business with character, fun and feeling. After two years’ advancement engineers achieved the formation of Play Station (PS1) with an absolutely new chip with a plastic shell. It was the first to consolidate a 32-piece processor, an illustrations chip, and a decompression motor on a similar bit of silicon, also called a framework on-a-chip. After this large advance the diversion pr

Movie Review Of The Last Song Film Studies Essay

Film Review Of The Last Song Film Studies Essay For those sad sentimental who get caught by the plots or implications of any Nicholas Sparks tale, at that point The Last Song is the film of the year to see. In The Last Song, Sparks catches the core of his crowd by presenting topics of first love with certain traces of uniqueness all through the film. In his past movies, for example, Dear John, The Notebook, and A Walk to Remember, Sparks effectively advances the impression of youthful love with the system of expectation. This makes it the perfect plot for any great sentimental. As first time screenwriter Sparks adequately conveys to his crowd a more nostalgic film than any other time in recent memory. The Last Song recounts to the anecdote about family, kinship, catastrophes, and reconnecting connections. The Last Song is the story of a defiant melodic wonder named Ronnie (Miley Cyrus) who sent to her dads sea shore house by her mom Kim (Kelly Preston) alongside her more youthful sibling Jonah (Bobby Coleman) for the late spring. Ronnie is very severe towards the stay with her dad Steve (Greg Kinnear) on the grounds that she reprimands him for the separation and leaving the family. She even quits playing the piano and rejects her acknowledgment into Julliard in spite of him. Dour and pulled back at everybody, she investigates the town and sea shore and chances upon a nearby kid named Will, (newcomer Liam Hemsworth) an affluent, volleyball playing hunk that gets enchanted by her and experiences passionate feelings for Ronnie. In spite of Ronnies resistant disposition, Ronnies mother Kim trusts that the stay will give the opportunity for both Ronnie and Steve to revive their relationship. The film by and large unites every one of the 3 connections of equal love of those between a dad an d little girl, beau and sweetheart, and sibling and sister. Above all the film gives the crowd the opportunity for Cyrus to split away from her generally realized Disney mainstream society marvel. Miley Cyrus unquestionably got a challenging situation to deal with in this film in playing the job of Ronnie in The Last Song. Referred to for her well known job as Hannah Montana on the hit Disney Show Hannah Montana, Cyrus is offered the opportunity to reprieve out and about, isolating from her whimsical job by progressing into an increasingly full grown job. She shockingly changes herself of what we hope to find in the film in the character of Ronnie, making her adorable and very captivating. Starts even had Cyrus at the top of the priority list while composing the story and throwing the job for the film. This film gives her the possibility to be paid attention to in later movies by gradually splitting ceaselessly from her well known adjust sense of self. In being her first grown-up job, Cyrus depicts everything from a thoughtful companion and girl to sulking and grieved rascal. Cyrus is incredibly appealing in the method of a young lady you may really need to approach. Her actin g is not kidding, and in working with such entertainers like Kinnear, the film splits from your run of the mill kid meets-young lady story line. Chief Julie Anne Robinson even works admirably as to concentrating on each character by building up a dread of relinquishment in Ronnie due to the separation. As the film advances you notice her character change into the sort, cherishing young lady she was went out to be. Crowd watching the film can ideally take Cyrus genuine as an on-screen character and like the new Miley. Character and appeal can be seen through both Ronnie and Miley, yet above all however the assistance of the supporting entertainers and on-screen characters. With the assistance of her supporting cast and on-screen characters, the pigeonholing in The Last Song gives the film maximum capacity. Her costar Bobby Coleman, (who assumes the job of her more youthful sibling Jonah) gives the film a greater amount of a passionate position by making cutesy colloquialisms and drawing out the privilege enthusiastic emotions in the film without going over the edge or excessively little. Kinnear plays an extraordinary character in the film by being the thoughtful father, with his own mystery and inconveniences that are later found in the film. His character Steve draws out the best in all the characters in the film, which really unites the film all. Indeed, even the science between both Cyrus and Kinnears job as little girl and father give a viable tragedy for fathers and their girls. Kelly Preston, who depicts Ronnies mother Kim, shows her jobs as the mother very well, in spite of her absence of appearance in the film. With respect to newcomer Liam He msworth, he plays your common fantastic hunk; hes decent, chips in on his extra time, and catches the core of essentially any adolescent young lady. Other than concealing his Australian intonation, Hemsworth had the option to convey the job of what is by all accounts the ideal beau, yet as the crowd makes sense of experiences difficulties of his own. Throwing both Hemsworth and Cyrus to play the on-screen couple brought incredible science between the two characters. The two Sparks and Director Julie Anne Robinson can make certain to be evaluated for elegantly composed screenplay just as throwing. Contrasted with the novel, the movie follows straightforwardly with the book, in spite of overlooking some minor foundation subtleties from the book. By and large the crowd can catches the messages inside the film and relates can to each character here and there, regardless of whether its encountering first love, the connection between a dad and little girl, or how close we truly are to a sibling. The fundamental subjects of the film will in general arrangement with expectation, confidence, and the relationship one can have with someone else. Generally, The Last Song is an extraordinary family film to see with anybody all things considered. In conveying messages on fresh opportunities and the minutes in life that lead us home, this should offer crowds to allow Cyrus another opportunity at an increasingly full grown job like The Last Song.

How to Start a College Admissions Essay TKG

How to Start a College Admissions Essay It’s hard to write about yourself. We’re used to it, but you don’t have a lot of practice doing it so it’s probably really hard for you. So, what’s the best way to approach writing an important essay about yourself? Outsource and get help. We’re kidding. Sort of.When our students are truly stuck we suggest that they create a social experiment of sorts to get their brains ticking. We have them text 3-4 friends and ask their friends to describe them in 3 adjectives. While there is a pretty good chance that you’ll receive some adjectives that are similar, you really just need 1 adjective to spark some thought.Once you receive the adjectives, think about why your friends might have chosen these adjectives. Write down a 1-2 sentence explanation of where you think they got that adjective from or what might have inspired them to say that about you. A big part of this process is being self-aware and humble, but you’re allowed to self-indulge and reflect during this initial br ainstorm phase. In fact, it is crucial that you do. It’s powerful to see all of your adjectives together, so make sure you list them out.After you’ve come up with your list, look at your adjectives and see what they inspire. Think about your essay as a story and all you have to do is start writing your story from the beginning. Sometimes it helps to write an introduction to your essay that you might not end up using, but purely to get yourself into the mindset of the story. A personal contextualization of sorts, if you will.Here’s an example for you: we had a student who was utterly at a loss for what to write. We had her text her friends and here’s what they came up with:StrongConfidentBraveCompetitiveProtectiveCaringAthletic  Of course these adjectives paint a picture of a secure, self-assured, poised person. We dug into each of these adjectives and sussed out stories that could act as examples and specifics displays of these adjectives to come up with the essay that she e nded up writing. We focused on the athletic/protective/brave components and fleshed out the essay based on one of those stories. Ultimately, you know how your friends and others perceive you but it’s an entirely different experience asking those around you to be reflective and share these adjectives with you. It ends up being inspiring in every case that we’ve seen.It’s hard to write about yourself. We totally get it. Every word that you write about yourself seems less than credible and cheesy, but that’s why the essay should end up reading like a story. You’re telling a story to the admissions reader about something that you did and a part of your personality that they wouldn’t be able to decipher from reading your application. Sure, they know that you’re hardworking and intelligent based on your GPA, test scores, and recommendations. But words like “brave,” “caring,” and “strong” are harder to determine.Your essay marks the start of a big part of the rest of your life: it’s called self-advocacy and you’re going to have to do this forever if you want to continue to succeed and challenge those around you. So take this as an opportunity to advocate on your own behalf and tell a great story that will make the admissions readers want to know you. You’re interesting, nuanced, complex, and compelling. Force them to listen to your storyâ€"your story deserves to be heard just as much as the next person and you have to start somewhere. So get to texting your friends.If you need help or are having trouble figuring out what to do with these 10 or so adjectives, call us. We’re here to help and we love helping our students tell their stories.

The prevalence of Autism Spectrum Disorder - Free Essay Example

The prevalence of Autism Spectrum Disorder has nearly doubled in recent years, and the numbers are staggering: nearly 1 in every 59 children are diagnosed with autism in the United States alone. Yet, there are so many questions surrounding the complexity and increase in diagnoses of this condition that affects so many in such diverse ways. (Autism Speaks) How autism originates in the first place and its impact on communication, both verbal and nonverbal, are questions that need to be continually scrutinized in order to better accommodate those who are affected, and, in turn, educate those who interact with the disorder in the most meaningful ways.. According to the Diagnostic and Statistical Manual of Mental Disorders (DSM-5), â€Å"people with Autism Spectrum Disorder have difficulty with communication and interaction with other people, restricted interests and repetitive behaviors, and symptoms that hurt the person’s ability to function properly in school, work, and other areas of life.† (National Institute of Mental Health) Although autistic characteristics can manifest themselves in so many different ways, concern surrounding communication reverberates as the trademark characteristic of ASD, with symptoms of the disorder, such as â€Å"difficulty with social communication and interaction, restricted interests, and repetitive behaviors† usually showing by the age of two or three. (Autism Speaks) For instance, a child might not understand how to work cooperatively in a group or look someone in the eye and make an introduction. Children with autism also often have trouble understanding the point of view of others, matching facial expression with what is being communicated, and having an â€Å"unusual tone of voice† that often sounds flat. (National Institute of Mental Health) Although symptoms of autism â€Å"must be present in the early developmental period,† often, understandably, many of these symptoms do not make themselves evident until a child is placed in situations that require more complex use of these skills, such as a school or another educational setting. (Autism Speaks) In order to begin to delve into the impact of ASD symptoms on modes of communication, it is vital to understand the complexity and uncertainty around the anatomical origin of autism in the first place. While there is no known specific biological cause, one of the strongest cases is for a genetic link, with â€Å"research suggest[ing] that genes can act together with influences from the environment to affect development in ways that lead to ASD.† (National Institute of Mental Health) This, in turn, influences how neurons, the specialized cells that are responsible for transmitting nerve signals, â€Å"connect and communicate with each other in the brain.† (Bhandari, Tamara) In reference to this statement, a study conducted at The University of Washington School of Medicine in St. Louis found that rats that lacked the gene absent in many of those with ASD in turn displayed an overabundance of connections between brain neurons, and this, in turn, influenced their basic abi lity to learn (Bhandari, Tamara). According to Azad Bonni, the head of the Department of Neuroscience at Washington, â€Å"This study raises the possibility that there may be too many synapses in the brains of patients with Autism.† (Bhandari, Tamara) According to Bonni, this overabundance of synapses and â€Å"miscommunication among neurons in the developing brain, correlates with impairments in learning, although we don’t know how.† (Bhandari, Tamara) There are six genes, called ‘ubiquitin ligases,’ which â€Å"attach a molecular tag called ubiquitin to proteins† at the focus of this study. (Bhandari, Tamara) These genes tell the brain which proteins should be kept and which should be thrown out. The same study looked specifically at one of these six genes: RNF8, the gene that is believed to mutate in those with ASD. This gene was removed from neurons in the cerebellum of mice, and â€Å"researchers found that neurons that lacked the RNF8 protein formed about 50 percent more synapses than those with the gene.† (Bhandari, Tamara) Although the mice walked normally, associated with motor function of the cerebellum, they were unable to learn new motor movements, a key symptom of ASD. Those with autism often display difficulty building social skills and simple skills like eye contact, bouncing a ball, or gauging how much energy to exert when lifting or pushing. (National Institute of Mental Health) The mice without an RNF8 gene were also unable to pick up a basic new skill, learning to close their eyes when a puff of air was blown at them: closing their eyes only ? of the time compared to those with a functioning gene closing their eyes ? of the time, a delayed and misunderstood reaction. (Bhandari, Tamara) Those with autism often can’t focus on one task for too long, or become consumed with a task, such as trying to put a puzzle together or sort objects. The study also reverberates the importance of the cerebellum â€Å"in higher cognitive functions such as language and attention, both of which are affected in autism.† (Bhandari, Tamara) While it would be thought that an increase in neural connections would increase brain function, it actually lead s to a repetitive and remediated nature of thought and action. Two trademarks of Autism are language delays and intense attachment to specific objects, both of which directly correlate with some lack of higher level thinking skills. (Bhandari, Tamara) Another study at Columbia University Medical Center adds more meaning to these findings, by associating this overabundance of synapses in the brain with a â€Å"slowdown in a normal pruning process during development.† (Gudsnuk, Kathryn, et al) Normally, â€Å"a burst of synapse formation occurs in infancy, particularly in the cortex, a region involved in autistic behaviors.† (Gudsnuk, Kathryn, et al) Normally, pruning takes out about half of the synapses, but, in the study, which looked at brains of those with autism who died from another cause, the pruning process had not done its job to the extent that it does in most brain cortexes. (Gudsnuk, Kathryn, et al) While this is just a correlation between a few studies, the new light it is shedding on brain formation and ASD is vital. It is also worth examining the function of the superior temporal sulcus in those with autism, which controls processing of visual information, and its role in â€Å"inability to interpret body language, facial expression, and gestures.† (Driver, Janine) Those with ASD often mistake gestures or do not realize the significance of what body language is communicating. This symptom of ASD was put to the test in research conducted by the University of Durham in 2009. The study presented autistic individuals with cartoon pictures showing specific emotions (happy, sad, angry), directions, and gestures without the use of faces or language.The participants had to rely solely on body language, such as skipping or clapping to come to a conclusion about how the figure was feeling. The study concluded that â€Å"participants had a tremendously difficult time reading the emotion and/or deciphering the direction of movement,† which is believed to be related to the gene mutation referen ced earlier which directly affects social ability. (Driver, Janine) According to Janine Driver, a contributor to Psychology Today, â€Å"These individuals are unable to decipher the communication cues bombarding them; resulting in not only a diminished capacity to properly communicate their wants to others, but an inability to feel empathy or socially relate to those around them.† (Driver, Janine) It doesn’t necessarily mean that they aren’t feeling, they are just unable to show it the way most people do. For example, during a pep rally, a student with ASD may misassociate cheering and noise as scary sounds, rather than excitement and become nervous. There isn’t a same mechanism present for decoding these sensory signals and reacting accordingly. Another study conducted by Dr. David Matsumoto interestingly examined body language of Olympic athletes. He saw a trend in how these people reacted to feeling certain emotions. While this doesn’t seem revolutionary, some of his subjects were blind, and yet still responded with basic physical movements and gestures representational of the emotion they were feeling. He therefore came to the conclusion that â€Å"it is reasonable to conclude that many of the behaviors, gestures and expressions we use to convey our feelings are deeply imbedded in our distinctly human code.† (Driver, Janine) This provides evidence that although there may be environmental risk factors for developing ASD, a genetic link cannot be ignored. While autism is not exclusionary to a specific race, gender, or socioeconomic class, there are some possible environmental risk factors associated with ASD, such as having a sibling with the disorder or older parents, having certain genetic conditions such as Down Syndrome, and a very low weight at birth. (National Institute of Mental Health) Some risk factors have also been debated more than others. According to Autism Speaks, â€Å"prenatal exposure to the chemicals thalidomide and valproic acid has been linked to increased risk of autism.† (Autism Speaks) Other possible environmental factors include deadly viruses or infections, such as rubella, and childhood immunizations. While none of these risk factors are completely inclusionary of those with Autism, many factors alongside observation of behavior are used in diagnosing ASD. After taking into account some of the possible biological causes and environmental risk factors associated with autism, it is also important to acknowledge a more individualized aspect of ASD: the environment that is created around the individual. As a special education teacher, I witness, everyday, the effects that educational and social influences can have on those with ASD and their communication skills. I have one student, in particular, who reminds me every day that genetics don’t paint the entire picture of what he is capable of. He is a freshman in high school, nonverbal, and speaks in only short phrases, characteristic of ASD, and often speaks in a repetitive nature. This is called echolalia, and is a â€Å"repeating of words or phrases.†(National Institute of Mental Health) If his social worker is coming after school, I usually hear about it intermittently throughout the entire day: it’s what he’s thinking about. Another trademark characteristic o f Autism that he exhibits is a narrow scope of topic and interest, but, nevertheless, there’s a brain process going on there. We affirm his thinking because it gives us a window into what is going on inside his head, and he is often excited when something he says is repeated back to him or if someone makes a connection to a movie he references. At the beginning of the year, he knew where Wisconsin was on a map. We learned two states every day, and he now knows forty-three states and counting and can put a map of the United States together by memory. I am reminded everyday that although his brain processes may be inhibited and limited, the science says so, and he he can’t have conversations with the depth that most can, there are a lot of processes occuring in his head, and I need to be cognizant of that. He has an amazing memory: almost photographic in some ways. He, and so may others, are capable of learning and thinking for themselves, we just need to give them the a venues to do so within their abilities. Autism Spectrum Disorder does not fit a specific mold, and small victories look different for every child. This specific student comes from a home of extremely low socioeconomic status, and I have reason to believe that most of his interaction and opportunity to communicate comes from interaction with social workers and school personnel. I have seen, first hand, how surrounding a child with caregivers and teachers who support a child with ASD in positive and meaningful ways can make all the difference in the student’s ability to be emotive and communicate. Students make a concentrated effort to interact with my freshman student with autism. They play sports with him and give him high-fives in the hallway. He will often laugh when someone says something he thinks is funny and he can point to objects he wants or doesn’t want. He can communicate, as basic as the interactions may be, he just has to be given the opportunity to do so. I witness everyday the bombardment of stimuli he tries to take in on a daily basis. He often covers his ears during lunch if there are too many discussions going on around him. He used to scream. I learn more every day about what it means to accommodate a student with ASD. Early intervention, creating a loving and supporting environment, and providing opportunities to communicate using an array of available modes, including talkboards, pictures, flashcards etc., are vital in supporting someone with ASD in and out of the classroom. One method of interaction, coined by Melanie Nind and Dave Hewett, authors of â€Å"Access to Communication,† is called Intensive Interaction. This practice â€Å"makes use of the range of interactive games that have been shown to occur in interactions between infants and their primary caregivers.† (Nind, Melanie Hewett, Dave) It takes into account the gap in basic ability to communicate present in those affected by ASD, and â€Å"incorporat e[s] interactive play intodaily routines in school.† (Nind, Melanie Hewett, Dave) One example that is given is using changing clothes, or â€Å"dressing situations,† such as putting on a jacket and boots, often a â€Å"non-personal and stressful routine† into a playful game, allowing for a more meaningful connection. (Nind, Melanie Hewett, Dave) This connection allows the student the opportunity to respond in a non-risk environment, creating a more enjoyable experience. Nind and Hewett found that, by using what they call â€Å"free-flowing interactive play,† that was integrated into a daily schedule, they were able to better gain the attention of the students and allow them opportunities to express themselves. I see, everyday, the importance of showing my students with autism that although they may not be able to completely express their emotions to me, I validate them and can still reciprocate the emotions I know they are feeling. It is important to be adaptable, modifying tasks, jobs, and communication modes so that they are accessible. The student I referenced earlier was, for the first time, given a talk board app loaded onto an iPad this year. I watched his face light up as he was able to use technology, something he loves, to point to movies he likes and to talk about or foods he is making in class that day. The words are repeated back to him through headphones. I have to remind myself on a daily basis to give him my all, because he deserves it. I don’t think, even with all of the research out there, that there is any replacement for that dedication.

Fetal Alcohol Syndrome FAS Essay - 2732 Words

Could you ever imagine feeding your infant alcohol through a bottle? This is equivalent to what alcohol does to the fetus in the womb. This results in a tragic disease known as Fetal Alcohol Syndrome. Alcohol can affect a human body in many different ways. Alcohol can be the highlight of a party and make anything exciting, but also can seriously alter human life. It’s quite often that we see on the news another victim dead, or in critical condition because their signs and symptoms were loud enough for others to notice, because a baby cannot speak for itself it isn’t able to show signs of Fetal Alcohol Syndrome (FAS) is effecting it. Most mothers would agree that they would not feed their infant alcohol through a bottle so why do they†¦show more content†¦It isn’t as common for brain damage to occur in the last trimester, but brain damage is at its highest vulnerability rate 15-25 days into the pregnancy. Malformations common to these areas suggest that structural damage commence early ( Caleekal 1). This information could greatly help determine on how much of the effects a child will have of Fetal Alcohol syndrome, but there is still no safe amount of alcohol a pregnant women should be safe to consume. Alcohol is a chemical that is toxic to the developing of the Central Nervous System(Stratton et al.2). According to The Sunday Times ,just one glass of wine a week can make babies â€Å"jump† in the womb throughout a nine-month pregnancy. The Sunday Times also reported that â€Å"experts believe this abnormal hyperactive behavior is the result of alcohol slowing or retarding the formation of the central nervous system.† Even before the actual child is born it faces problems that it has no control over and these problems will continue to hinder the child for the rest of its life. There is no known cure for Fetal Alcohol Syndrome, no medication to control the side effects, the cure may seem simple and it is do not drin k if you believe or suspect that you may become pregnant. Unfortunately, the simple cure still does not work. However, there are some ways to prevent Fetal Alcohol Syndrome from claiming another victim. A woman who consumes alcoholShow MoreRelatedFetal Alcohol Syndrome ( Fas )1404 Words   |  6 Pagesdisorders is Fetal Alcohol Syndrome (FAS). According to Feldman (2009), Fetal Alcohol Syndrome is a disorder that is induced by pregnant women who have consumed alcohol during the duration of their pregnancy, possibly resulting in mental deformity and delayed the growth of the child. Some characteristics of FAS include growth deficiency and central nervous system dysfunction (Mattson, 2006). Although the child may not be diagnosed with Fetal Alcohol Syndrome, if the child was exposed to alcohol duringRead More Fetal Alcohol Syndrome (FAS) Essay925 Words   |  4 PagesFetal Alcohol Syndrome (FAS) One of the leading causes of mental retardation in the United States is fetal alcohol syndrome or FAS. Alcohol is the most commonly abused substance by pregnant women because its legal and socially acceptable. A greater majority of young women are not aware of the complications that are involved with pregnancy. They see pregnancy as a way of bringing a life into the world but do not use the necessary safety measure in their dietary habits to prevent such damage orRead MorePrenatal Alcohol During Pregnancy Results Of Fetal Alcohol Syndrome ( Fas )1497 Words   |  6 Pagesprenatal ethanol exposure. Alcohol. 2013; 47 (2): 109-120. Introduction Consuming alcohol during pregnancy results in Fetal Alcohol Syndrome (FAS). The spectrum of FAS ranges from barely detectable to severe functional and cognitive birth defects. In the United States approximately 9.1 out of 1,000 live births exhibit some degree of FAS spectrum. Although excessive consumption of alcohol is considered a human teratogen the biochemical mechanism and the developmental origins FAS spectrum remain unclearRead MoreEssay on Fetal Alcohol Syndrome1390 Words   |  6 Pagesin this essay is Fetal Alcohol Syndrome (FAS); caused by alcohol consumption during pregnancy. Since the alcohol is consumed in such a developing stage of the fetus, it can potentially cause many different complications in the unborn child. Fetal Alcohol Syndrome could easily be prevented with more awareness to the issue and its defining characteristics, how it affects the fetus during growth, and finally the long-term effects on the individual’s life. The science behind FAS will be explainedRead MoreFetal Alcohol Syndrome Essay1699 Words   |  7 PagesFetal Alcohol Syndrome Fetal Alcohol Syndrome (FAS) is a condition affecting children born to women who drink heavily during pregnancy. There are three criteria used to describe the effects of prenatal alcohol exposure and to make a diagnosis of FAS. The first of these is a pattern of facial anomalies, these features include: #61558; Small eye openings #61558; Flat cheekbones #61558; Flattened groove between nose and upper lip #61558; Thin upper lip These characteristicsRead MoreThe Disorder Of Fetal Alcohol Syndrome1018 Words   |  5 Pagesthe the disorder Fetal Alcohol Syndrome .This paper will aim to discuss what the disorder is ,it s history how it is diagnosed and the treatment and prevention of this disorder. Taking a sip a int hip Introduction :Behold, thou shalt conceive, and bear a son; and now drink no wine nor strong drink, neither eat any unclean thing(Bible-Judges 13:7).It has been known throughout history that the effects of alcohol use in pregnancyRead MoreThe Truth About What Alcohol Abuse Does to a Fetus1118 Words   |  5 PagesThe Truth About Fetal Alcohol Abuse Would you have ever thought of physically, mentally, and/or emotionally harming an unborn child? In the 1990s people have noted the significant impact alcohol-related birth defects are having on our society then and now. My essay will discuss alcohol consumption among pregnant women and its adverse effects on fetal development. Fetal Alcohol Syndrome or FAS is physical and mental health problem that destroys a childs learning development.Read MoreThe Effects of Alcohol from Utero into Later Life600 Words   |  3 PagesThe Effects of Alcohol from Utero into Later Life During the ten months of gestation, the ever-growing fetus goes through the stages and changes of becoming a functional human. Unfortunately for some, these children will not get the full advantages of life because of the choices of another. Fetal Alcohol Syndrome (FAS) has been calculated to have an impact on nearly forty thousand infants a year (fasdcenter). To really see the magnitude of the effects of this easily preventable disorder, researchersRead MoreFetal Alcohol Syndrome942 Words   |  4 Pages Fetal Alcohol Syndrome According to Seaver, Fetal Alcohol Syndrome (FAS) is birth defects causing learning, and behavioral problems in individuals whose mothers drank alcohol during pregnancy. This disorder is very serious, yet it is recognized as one of the most preventable. This causes major issues, when something so serious could be prevented but is not. Fetal Alcohol Syndrome is a problem because it leaves a permanent effect on the unborn child, but some solutions could be educating women andRead MoreThe Effects Of Alcohol During Pregnancy On Children1041 Words   |  5 PagesAlcohol is a TERATOGEN, meaning that it will cause developmental damage to a FETUS or EMBRYO. The degree to which a TERATOGEN wreaks havoc on an unborn child largely depends on four factors: dosage, heredity, age, and additional negative factors. The most vulnerable prenatal period is during the stage of embryonic development, which occurs between the third and eighth weeks of pregnancy. Once alcohol penetrates the PLACENTA an d enters the fetal bloodstream it hinders the neurons inside the child’s

Freedom Of Speech A Theoretic Approach - Free Essay Example

Sample details Pages: 17 Words: 5059 Downloads: 10 Date added: 2019/05/13 Category Law Essay Level High school Tags: Freedom of Speech Essay Did you like this example? Freedom of Speech: A Theoretic Approach INTRODUCTION The Constitution â€Å"demands that content-based restrictions on speech be presumed invalid and that the Government bear the burden of showing their constitutionality.†[footnoteRef:1] That is to say, anything recognizable as a conception of freedom of expression must require that government, at least in its capacity as regulator, maintain a position of neutrality regarding messages. However, there are content-based restrictions on speech that have been allowed but only in a few instances such as incitement, obscenity, defamation, speech important to establish criminal conduct, fighting words, child pornography, fraud, true threats, and speech creating a serious and imminent threat the government has the power to prevent. As hate speech and rumors proliferate social media, many countries have attempted to implement â€Å"fake news† laws. Don’t waste time! Our writers will create an original "Freedom Of Speech: A Theoretic Approach" essay for you Create order Malaysia, Sri Lanka, and Myanmar have all seen an increase in â€Å"fake news† and have attempted to criminalize anyone who delivers â€Å"fake news† including Brazil, Germany, France, and Kenya. Moreover, according to the decision in U.S. v. Alvarez, the United States has attempted and failed to criminalize â€Å"fake news.† [1: Ashcroft v. American Civil Liberties Union, 542 U.S. 656, 660, 124 S.Ct. 2783, 159 L.Ed.2d 690] Malaysia passed a law that would punish citizens on social media or those who are working at a digital publication for spreading fake news with a $123,000 dollar fine along with a possible prison sentence of up to six years. In France, the parliament has passed a law that targets fake news. The new law will impose a quick-response judicial review of potentially â€Å"manipulative† information shared during electoral periods. The new law will allow election candidates to sue for the removal of contested news reports during election periods, as well as forcing platforms such as Facebook and Twitter to disclose the source of funding for sponsored content.[footnoteRef:2] Germany introduced a plan that fined social media platforms if they did not remove posts that included hate speech. However, in the Philippines, the regulators stated that banning fake news in their country would be outright unconstitutional. The movement to ban fakes news is trending and nations like the United States are trying to come up with a solution that does not abridge the First Amendment. One way to curb fake news without abridging the First Amendment is allowing or encouraging companies or the market to handle it. For instance, YouTube is making a $25 million dollar investment to â€Å"improve its news features, joining Facebook, Apple, and parent company Google in campaigns to curb fake news†¦Ã¢â‚¬ [footnoteRef:3] Additionally, companies like RedPen are reducing the problem by using a combination of innovative technologies, including AI, natural language processing and sentiment analysis, to for multiple angles of a trending story in a single user interface. This information is great for companies; but what can the government do? Unlike private companies, the government is in a tough predicament due to the constraints of the First Amendment. The Government cannot censor speech while private companies can. To fully understand the concept of fake news, we have to look further into the past pre-trump era. [2: YOUNG, ZACHARY French Parliament passes law against ‘fake news’ 7/4/18, 12:44 PM CET Updated 7/4/18, 1:15 PM CET] [3: Olenski, Steve. â€Å"5 Ways Brands Can Combat Fake News† https://www.forbes.com/sites/steveolenski/2018/07/12/5-ways-brands-can-combat-fake-news/#5e6f771448f6 ] Fake news is not a new concept and has been around for quite some time. Even in 1938, a radio broadcast adaptation of H. G.Well’s drama The War of the Worlds frightened an estimated one million residents.[footnoteRef:4] The residents believed what they heard on the radio station was, in fact, happening since the radio was the main source of media in the 1930s. Currently, now that online platforms, particularly social media, are becoming the main sources of news for a growing number of individuals, misinformation seems to have found a new channel.[footnoteRef:5] Fake news is the intentional and verifiably false information that could mislead readers.[footnoteRef:6] Social media has changed news distribution and has challenged traditional beliefs of how news should look. Quick snippets of information from innumerable sources delivered every second of the day would cause a lot of confusion. [4: Edson C. Tandoc Jr., Zheng Wei Lim Richard Ling 2018] [5: Tandoc 2018] [6: Id.] The news is supposed to be based on truth, but who decides what the truth is? Statements are true if they correspond to the facts in the world. Truth is not absolute but maybe its relative to the culture, nation, ethnic backgrounds, and schools of thought. For example, science is a way to make the truth more absolute. There are methodologies, case studies, and empirical research that make of the paradigm of science. However, even with the scientific methods, we still find disagreement. The truth tends to be relative to a particular frame or reference. In order to determine what news is considered fake, we must look at what is the nature of â€Å"real news.† Traditionally, the news was expressed by journalists who adheres to a code of professionalism. A journalist must be objective and accurate. Above all, provide citizens with accurate and truthful information so they can be free and self-governing. With that responsibility, there comes liability. A journalist must stray away from providing misinformation and never provide disinformation. While misinformation refers to â€Å"the inadvertent sharing of false misinformation,† disinformation refers to â€Å"the deliberate creation and sharing of information known to be false.†[footnoteRef:7] Traditional news forums have printed misinformation plenty of times. Trump credits himself as being the creator of the term but the term has been around for a while. It was used heavily in campaigns during the 90s. [7: Wardle 2017 para. 1.] Since 2016 the Supreme Court has made references to how ambiguous and vague the phrase is. For instance, in Cohen v. California, the statement â€Å"fuck-the-draft† tapped directly into the vagueness issues and definitional difficulties afflicting the statutory phrase â€Å"offensive conduct† and whether, in turn, â€Å"fuck† fell within that definition.[footnoteRef:8] At the most fundamental level, fake news is a speech based phenomenon[footnoteRef:9]. It typically features words and may involve images. The First Amendment, thus, is relevant to the extent that restricting fake news necessitates government action targeting its producers and disseminators. The possibility of such government regulation is much more than just a hypothetical. California attempted to pass a bill that made it illegal to knowingly and willingly make, publish, or circulate on an Internet Website, or cause to be made, published, or circulated in any writing posted on a website, a false or deceptive statement designed to influence the vote on either a voter or candidate for office.[footnoteRef:10] Eventually, the bill was struck down. The major barrier, of course, is that political speech lies within the heart of the First Amendment. The Supreme Court and lawmakers must first understand what â€Å"fake news† actually means before any useful law can be passed. First, statements of opinion are not considered fake news. One possibility is that fake news consists of content that conveys the impression of being a real news article in print or, more appropriately, on the Internet.[footnoteRef:11] [8: Cohen v. California, 403 U.S. 15, 25 (1971).] [9: Calvert, Clay. First Amendment Law review. Vol 16. Pg. 156] [10: Id. ] [11: Id. at 161] For the purposes of this paper, the term fake news will be an intentional sharing of false information that gives the impression of being a real news article in print or on the Internet. This paper will determine whether fake news should be protected by the First Amendment, explore recent court decisions including Alvarez, apply Free Speech Theory and determine which theory or theories are best equipped to address the implications of the fake news, particularly, the news that was spread before the 2016 Presidential election. ANALYSIS A. United States v. Alvarez In Alvarez, Justice Kennedy stated Content-based restrictions on speech are subject to strict scrutiny and are almost always invalid, except in rare and extreme circumstances. While low categories of speech, such as defamation and true threats, present a serious and imminent threat, false statements alone do not present such a threat. Congress drafted the Stolen Valor Act too broadly, attempting to limit speech that could cause no harm.[footnoteRef:12] This principle regarding causation of harm, drawn from Justice Anthony Kennedy’s plurality opinion in United States v.Alvarez, becomes most relevant if the government attempts to regulate fake news.[footnoteRef:13] The Alvarez rule that proof of causation of harm must be demonstrated to uphold a content-based restriction on speech under strict scrutiny springs from the Court’s 2011 decision in the violent video game case of Brown v. Entertainment Merchants Association. The majority concluded that punishment for false stat ements are improper and unconstitutional. Hence, Justice Breyer agreed with the overall decision but not in the analysis. Justice Breyer stated that instead of applying strict scrutiny, intermediate scrutiny is warranted. Even with applying intermediate scrutiny, punishment for false statements, the Stolen Valor Act, in this instance would be unconstitutional because it violates intermediate scrutiny and it applies to situations that are unlikely to cause harm.[footnoteRef:14] However, the dissent essentially stated that the Stolen Valor Act could not have been drafted any narrower, while still preventing the substantial harm caused by false statements concerning military decoration.[footnoteRef:15] [12: United States v. Alvarez, 567 U.S. 709 (2012).] [13: Id. at 725.] [14: Id.] [15: Id.] The best argument made in the opinion is the concurrence by Justice Breyer and Kagan. Intermediate scrutiny or the proportionality analysis should be used because the statute works First Amendment harm, while the Government can achieve its legitimate objectives in less restrictive ways. This approach is necessary if the First Amendment is to offer proper protection in the many instances in which a â€Å"statute adversely affects constitutionally protected interests but warrants neither near-automatic condemnation (as â€Å"strict scrutiny† implies) nor near-automatic approval (as is implicit in â€Å"rational basis† review).†[footnoteRef:16] However, the dissent points out that â€Å"there are broad areas in which any attempt by the state to penalize purportedly false speech would present a grave and unacceptable danger of suppressing truthful speech.†[footnoteRef:17] In fact, the court has not extended First Amendment protection on several occasions. The dissent points out several examples such as defamation of a public official. The dissent further leans on New York v. Sullivan stating â€Å"[e]ven a false statement may be deemed to make a valuable contribution to public debate, since it brings about ‘the clearer perception and livelier impression of truth, produced by its collision with error.†[footnoteRef:18] The dissent believes the plurality fears that we will see laws making it a crime to lie about civilian awards such as college degrees or certificates of achievement in the arts and sports.[footnoteRef:19] The dissent believes that the Stolen Valor Act is a narrowly tailored law to address an important issue. Congress was entitled to conclude that falsely claiming to have won the Medal of Honor is qualitatively different from even the most prestigious civilian awards and that the misappropriation of that honor warrants crimina l sanction.[footnoteRef:20] Although the dissent makes a good argument, the plurality made the best argument that I align myself with. False statements should not be regulated by the government unless it essential the elements of a crime such as Fraud. [16: U.S. v. Alvarez at 731] [17: Id. at 751] [18: J. Mill, On Liberty at 15] [19: U.S. v. Alvarez at 753] [20: Id. at 754 ] The plurality and concurrence fear that the government will misuse and overreach if the government is allowed to regulate. Because the statute, as drafted, applies even in a family, social, or other private contexts where lies are unlikely to cause harm, it creates too significant a burden on protected speech.[footnoteRef:21] The government could achieve its goals in a less burdensome way. The best solution to restrictions of speech, in this case, is intermediate scrutiny. [21: Id.] B. REGULATION Speech regulation is adopting policies and taking actions designed to reduce the prevalence of one or more classes of speech; therefore, it is an effort to reduce the amount of particular speech. Even mature democracies struggle with the issue of fake news. On January 1, 2018, Germany announced that it would begin to enforce a law, known as NetzDG, requiring social media sites to remove hate speech and fake news within 24 hours or face fines of up to 50 million Euros.[footnoteRef:22] The European Commission’s High Level Group on fake news and online disinformation take a 5 pillar approach to the fake news concept. In March 2018, the High Level Group issued a report concluding that although disinformation may not necessarily be illegal, it nevertheless is harmful to democratic values. This approach reminds me of the Harm Principle and although apparently avoiding â€Å"any form of censorship, either public or private,† it advocates greater self-regulation in the short te rm, with a long-range goal of developing a Code of Practices to encourage transparency, media literacy, diversity, the development of tools to â€Å"tackle† disinformation, and further research to monitor and assess the sources and impact of fake news.[footnoteRef:23] On the other hand, also in March, the Dutch Parliament voted to retract EUvsDisinfo.eu, a European Union website created by the East Stratcom Task Force in 2015 to report disinformation and fake news allegedly spread by Russian actors. Its Dutch opponents characterize it as a state publication that â€Å"passes judgments whether a publication in the free media contains the correct views or not. If your publication ends up in its database, you’re officially labeled by the EU as a publisher or disinformation and fake news.†[footnoteRef:24] [22: European Commission, â€Å"A multi-dimensional approach to disinformation.† ] [23: Id.] [24: Id. at 18.] These examples illustrate how problematic it can be when governmental entities become arbiters of what is true and what is fake. As the Dutch critics argued, governments should be loath to interfere in freedom of the press because â€Å"it makes it impossible for the truth to emerge in the public debate.†[footnoteRef:25] The marketplace of ideas must have been an underlying reason in the Dutch critic’s argument. It was definitely at the core of the pivotal 1964 U.S. Supreme Court decision, New York Times v. Sullivan. [25: Id. at 22] The Sullivan case arose during the civil rights movement, involving a Montgomery, Alabama, public safety commissioner named L.B. Sullivan, who sued the New York Times after it published a fundraising advertorial that described law enforcement actions designed to discourage protests by activists such as Martin Luther King Jr. and his followers. Sullivan claimed that the ad, which made several factually inaccurate allegations about the Montgomery police, had defamed him personally, even though he was not identified by name or title. In other words, Sullivan claimed the publication was fake news. He sought and won $500,000 in damages, without being required under Alabama law to prove that his reputation was actually harmed. But in a decision by Justice William Brennan, the high court reversed, concluding that under the First and Fourteenth Amendments, public officials like Sullivan could prevail in a libel suit only if they were also able to show not only falsity but actual malice on the part of the publisher. In other words, a publisher had knowledge that the statement was false, or proof that the publisher acted with reckless disregard for the truth. A showing of hatred or ill will, known as common law malice, is not sufficient to meet that test. According to Justice Brennan, because some factual errors are inevitable even in the most careful news reporting, this protection is essential to avoid media self-censorship, to promote vigorous reporting on government and public officials, and to preserve our â€Å"profound national commitment to the principle that debate on public issues should be uninhibited, robust and wide-open.† In subsequent years, the First Amendment protection expanded to include lawsuits by public figures as well as government officials. Alleging falsity was not enough. No doubt this situation is what prompted Donald Trump, first as a candidate and then as president, to float the idea that the law should be changed. Regulation should increase due to the swelling fabrication of news that is highly contentious. When there is social tension, especially if there are serious political, religious, racial or cultural differences, then people will be more vulnerable to fabricated news.[footnoteRef:26] The items can also be shared on social media and thus further gain legitimacy since the individual is receiving them from people they trust.[footnoteRef:27] This is a problem because most young and middle age, and a growing number of past generations rely heavily on social media for their news source.[footnoteRef:28] [26: Kirtley, Jane â€Å"Getting to the Truth: Fake News, Libel Laws, and â€Å"Enemies of the American People† American Bar Association] [27: Id.] [28: Head, Alison. â€Å"How Students Engage With News.† https://www.projectinfolit.org/news_study.html] C. Freedom of Expression and Free Speech Theory A marketplace of ideas approach provides the community with the opportunity to hear all ideas whether good or bad. The marketplace of ideas is imperfect but essential to facilitate the search for truth. This approach, because of the immense volume of ideas, allows for good ideas to emerge. The theory is that truth beats error in the competition of ideas. This concept and process is beneficial in discovering the best truth because the individual is exposed to a variety of paradigms and ideologies which help build a better, more tolerant, community. This approach does not silence the expression of opinion or ideas whether good or bad. Furthermore, under the Justice Holmes approach to the marketplace of ideas, the approach does not consider whether government interference is desired in order to prevent harm. It does state, however, that government interference should be minimal so that the truth would not be tainted in the marketplace. Notwithstanding where the government can actively e ngage in speech to further governmental ideas, you can infer that this approach is at the foundation of the Alvarez opinion. Under this approach, false statements are inevitable if there is to be an open and vigorous expression of views in public and private conversation, an expression the First Amendment seeks to guarantee.[footnoteRef:29] The marketplace of ideas is a great theory, however, this theory is based on an important assumption. [29: United States v. Alvarez, 567 U.S. 709, 718 (2012)] If there is fake news, there must be truth out there somewhere. If we accept that there is fake news then the assumption is that everyone is in search for the truth or best truth. This theme has been endorsed by famous writers of many eras. John Milton stated â€Å"Let Truth and Falsehood grapple; who ever knew Truth put to the worse, in a free and open encounter.†[footnoteRef:30] And Justice Oliver Wendell Holmes, in his famous dissenting opinion stated â€Å"[W]hen men have realized that time has upset many fighting faiths, they may come to believe even more than they believe the very foundations of their own conduct that the ultimate good desired is better reached by free trade in ideas – that the best test of truth is the power of the thought to get itself accepted in the competition of the market.†[footnoteRef:31] Since 2016, it seems clear that marketplace competition forces, standing alone, will not drive fake news from the field of expression.[footnoteRef :32] For some people, the truth may be outweighed or overpowered when grappling, more like passively accepting, fake news. [30: Milton 1644] [31: Abrams v. United States 1919, 630] [32: Calvert, Clay. First Amendment Law review. Vol 16.] The marketplace of ideas approach focuses on speech maximization which increases the amount of speech in particular classes through forums, media, speech tokens and types. This specific method is offered to combat fake news or false information. However, in a marketplace full of bad ideas, flooding the market with good ones does not seem to solve the problem. The marketplace could be chaotically flooded with ideas making it hard to discern and extract the good ideas from the bad. This will further exacerbate the problem and lead to misinformation being distributed making it difficult for individuals to extract the best truth. Additionally, the marketplace of ideas will become the marketplace of opinions or fake news. For instance, social media outlets such as Facebook makes it extremely difficult for citizens to discern the truth. I know the marketplace of ideas is not the marketplace of facts, but I believe the pioneers of the theory thought it should be a place of competing ideological convictions and fidelity to the true idea. Currently, there is a shift towards a preference for online news resources. In a study conducted by Alison Head found that the high school and college population is no longer on Facebook. The study indicated that high school and college students get their news from real-life discussions with peers (93%) and not just from social media (89%).[footnoteRef:33] Professors were considered a significant news source as well (70%), but librarians were not as effective as a source of news (7%).[footnoteRef:34] The most common source of news is memes, instagram, and snapchat. Head states that the tech giant Facebook is dying. Seeing this change, you would think that citizens would be more aware of fake news. People who understand fake news as a reality should rightfully be more skeptical about the veracity of what they read rather than accepting it blindly or at face value.[footnoteRef:35] If a consumer knows that fake news exists, it should encourage the consumer to be a more attentive, active, and always challenging the status quo. Some would even look at fake news circulating the market as a benefit because unfortunately, fake news will always circulate the marketplace, we just have to educate ourselves with discernment. [33: Head, Alison. â€Å"How Students Engage With News.† https://www.projectinfolit.org/news_study.html ] [34: Id.] [ 35: Calvert, Clay. First Amendment Law review. Vol 16.] Today, no matter whether the information is true, marketing is most important. Even when the idea itself is fake, as long as the party distributing the false information claims that the opposing idea is â€Å"fake news† they have an upper hand due to market trends. For example, a republican claiming that a democrat is conveying fake news. Maybe we should focus on real news and, specifically, ways to make it more appealing to the massive number of Americans who bypass reading traditional daily newspapers and watching local television newscasts produced by reputable organizations.[footnoteRef:36] Therefore, the marketplace of ideas approach alone may not be the best solution to solving fake news. There is no doubt that tackling fake news is a muti-faceted approach. We need news literacy. We need to educate ourselves on how to vet disreputable reputable sources, and how to properly research. However, here, we will focus on the theory or theories that will help weed out fake news without abridging the First Amendment. [36: Benton, Joshua Get Serious About Getting Rid of Fake News, NIEMAN REPS., Fall 2016, at 38, 39.] The regulation of fake news might even be contradictory to the marketplace principle. However, the Harm principle might play a major role in regulating fake news. Under the Harm principle fake news would be okay so long as it does not cause anyone harm. Moreover, the only purpose that power can be exercised over any member of the civilized community, against his will, is to prevent harm to others. This principle is grounded in Utilitarianism. Under the Harm Principle, individuals are free to drink, smoke, or use drugs even though this harm is self-inflicted. However, the moment that self-infliction begins to hurt others, such as drinking and driving, it must be stopped. More specifically, the only time government can interfere or suppress an individual’s complete liberty is to prevent harm to others. For example, the pizzagate scandal. a man carrying an assault rifle walked into a pizza restaurant in Washington, DC. He was intent on investigating on his own whether the restaurant, Comet Ping Pong, was the headquarters of an underground child sex ring allegedly run by the presidential candidate Hillary Clinton and her former campaign manager, John Podesta.[footnoteRef:37] The man was motivated by stories disseminated through right wing social media outlets. He entered the restaurant and fired several shots in the ceiling. This would be fake news that has caused harm. Fortunately, no one was injured by the gunshot but there was a definite probability of it happening. [37: Lopez, German. â€Å"Pizzagate, the fake news conspiracy theory that led a gunman to DC’s Comet Ping Pong, explained† Dec. 2016.] John Stuart Mill’s harm principle suggests that â€Å"the only purpose for which power can be rightfully exercised over any member of a civilized community, against his will, is to prevent harm to others.†[footnoteRef:38] As so eloquently summarized by Professor Frederick Schauer, this means â€Å"that society may proceed only against genuine harms and not against other forms of individual or social discomfort.†[footnoteRef:39] What then, in reference to Millian theology, is the â€Å"harm to others†[footnoteRef:40] caused by fake news? [38: Mill, John S. On Liberty 80 (David Bromwich George Kateb eds., Yale Univ. Press 2003).] [39: Schauer, Frederick On the Relation Between Chapters One and Two of John Stuart Mill’s On Liberty, 39 CAP. U. L. REV. 571, 574 (2011).] [40: Mill, On Liberty, note 33 pg. 80] Identifying the harm or harms that we fear fake news produces is a condition precedent or any effective corrective action, be it through legal or private channels. One important step that lawmakers seeking to regulate any speech-based phenomenon must take is to â€Å"identify, with precision and specificity, the actual problem that the speech caught in the legislative crosshairs allegedly causes.†[footnoteRef:41] In other words, when it comes to fake news, one must â€Å"pinpoint the precise harm, not just some generalized, indistinct worry.†[footnoteRef:42] Mill’s underlying argument that freedom of speech allows poor ideas to be discussed, criticized, and defeated.[footnoteRef:43] But if that were true, why are having such a difficult time discerning the truth from fake news? In short, news is no longer found on traditional forums and access to resources has increased dramatically. [41: Calvert, Clay. First Amendment Law review. Vol 16.] [42: Id. at 256] [43: M ills, J. On Liberty, Chapter 4] The Marketplace of ideas approach is not so much concerned with harm, as it understands that not everyone will be in the majority. Which is why merging this idea with the Harm Principle seems proper. The marketplace of ideas is concerned with the truth. Truth causing harm is okay as long as the truth benefits the majority. Likewise, under the Harm Principle, if understood liberally, – i.e., taking into consideration that the principle of utility is its foundation, – harm is okay so long as it brings the greatest amount of happiness to the greatest number of people.[footnoteRef:44] It is the combination of the Marketplace approach and Mill’s Harm principle that regulation is likely to succeed. Combining these concepts almost looks a bit like an intermediate scrutiny approach the concurrence discussed in Alvarez. However, there is another method that may help in regulating fake news and it concerns private entities such Facebook. [44: Nahra, Cinara. (2014). The har m principle and the greatest happiness principle: the missing link. Kriterion: Revista de Filosofia, 55(129), 99-110.] Most people today are acquiring their news from a source not deemed a forum or media corporation or outlet. Because of this, fake news has increased exponentially. Companies like FB are in a peculiar situation. Although they are indeed private companies; they are so massive that most people use its platform to engage in speech-related activities. One idea offered by Joshua Benton is that Facebook could hire editors to manage what shows up in its trending section, one of the major ways misinformation gets spread and a team of journalists and â€Å"charge them with separating at least the worst of the fake news from the stream.†[footnoteRef:45] A lot of this can be easily done with Facebook’s algorithm. Matter of fact, the outrageously fake news could be weighted a certain way in the algorithm. Facebook does have regulations and safeguards in place in reference to the freedom of expression. Facebook policies, although not all of them are known, have limitations on an individual’s freedom of expression. This all typically depends on the social movement and newsworthy content at the time. Facebook also states that it will remove content that attacks gender, age, sex, and race. Facebook has also decided to take down false information or fake news that is intended to immediately incite violence and physical harm. This is all dependent upon a user reporting the issue and the context of the issue. However, there are some issues with this. There is a possibility that by allowing social media companies to help regulate the market, you could be infringing upon the companies rights. Moreover, it may be difficult to prevent these companies from violating the First Amendment rights of individuals who wish to speak on the Internet. A possible solution would be to categorize companies like Facebook as a designated forum then the government will have more room for regulation. [ 45: Benton, Joshua. Get Serious About Getting Rid of Fake News, NIEMAN REPS., Fall 2016.] APPLICATION Although the public forum doctrine playing role, it does not solve the fake news issue. The best approach would be a combination of the marketplace of ideas approach, Harm Principle and Intermediate Scrutiny must be at the heart of restricting fake news. What does this mean? The approach I offer is one of a balancing test. Balancing the marketplace of ideas and the harm. Moreover, if the government is to intrude in this area in any way there must be some form of intermediate scrutiny. If Congress decides to put a statute in place, it must be narrowly tailored to achieve a legitimate governmental interest. If there is a less restrictive way than the statute proposes, then the statute is unconstitutional. I do not believe in punishing companies in order to achieve this goal unlike Germany. I believe hate speech is a necessary evil as long as it avoids becoming a true threat. However, we must encourage thoughtful forms of expression. One way to do so, similar to utility companies and their Energy Efficient programs in various states, is to offer an incentive. One incentive may be a capped tax break for the percentage of investment. However, unlike the Energy Efficiency programs there will not be any lost net revenues recovered because the amount of information trafficked through social media sites are innumerable. The government should first offer the incentive and if no one participates in the program the next step would be to construct a statute. On the other hand, I believe companies will be eager to participate because

Christianity ( Religion ) On Christianity - 1349 Words

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