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Wednesday, August 26, 2020
The Education of Little Tree Movie Review
In the film, The Education of Little Tree, the little fellow learns a considerable lot of lifeâ⬠s most significant exercises. Three of the exercises that I feel are most significant are; ââ¬Å"The Wayâ⬠, how to gain from ones errors, and finding your mystery place. In the individual assessment that follows, I will examine why I feel that these are such significant exercises. Little Treeâ⬠s grandparents, with some assistance from Willow John, show him ââ¬Å"The Way [of the Cherokee]â⬠. I feel this is one of lifeâ⬠s most significant exercises. Not really the Cherokee way, however the lifestyle all in all. This exercise helpâ⬠s us to comprehend that things may not generally work the way that we might want them to. In my eyes, this is on the grounds that we don't, and never will, totally be in charge of our lives. I accept that their is some force higher than ourselves that is in any event halfway control of our lives. I likewise accept that this more powerful, regardless of whether it be destiny or God, encourages direct us to a progressively complete life. To me life is an exercise in itself. It is every one of the a learning experience to set us up for the following life. One of my preferred pieces of the story is when Little Treeâ⬠s grandparents pass on, they state ââ¬Å"It has been acceptable. Iâ⬠ll see you soon. â⬠They see passing as a fresh start, not as an end. All through the film, Little Tree is committing errors and gaining from them. I additionally feel this is a significant exercise throughout everyday life. Committing errors is a piece of life. Gaining from them with the goal that we donâ⬠t rehash similar mix-ups can be hard once in a while. This can be applied to the study hall from numerous points of view. In the event that you remain out late the night prior to a test as opposed to examining and do inadequately on a test, whenever you should think about another option. One chance is to discover a way that letâ⬠s you go out and have a ton of fun, yet return home early enough to read the material for the test. I believe that the way Little Treeâ⬠s granddad encourages him this exercise by letting him commit errors as opposed to forestalling them is a similar way that an instructor or guardians should show kids and understudies. In the event that your folks or instructors donâ⬠t permit you to commit errors, you will most likely be less inclined to gain proficiency with the exercise. Despite the fact that they think they are working superbly by keeping these errors from occurring, the youngster or understudy may act insubordinately toward this. Finding your mystery spot can assist with showing you yourself. In this exercise, Little Tree discovered his mystery place was a spot to pass without anyone else. Everybody needs a spot this way. Some place to be separated from everyone else with your considerations. In a manner it causes you end up through self satisfaction. Little Tree finds out about what intrigues him, the riddles of his social foundation. This can be useful in ones training. It causes you find out about what you might want to do with your life. It can provide you guidance. It is additionally significant in light of the fact that no two individuals are actually the equivalent. Every individual has an alternate style of learning. An individual will get progressively out of their training in the event that they are instructed and learn in the style that concerns them. The exercises alluded to in this paper are only a not many that I accept are significant in a people training and in life when all is said in done. A people training never stops, we as a whole learn new exercises regular. It is simply ââ¬ËThe Wayâ⬠it is.
Saturday, August 22, 2020
Abortion - Man Cant Be Rightly Disposed of by Man :: Argumentative Persuasive Topics
Premature birth - Man Can't Be Rightly Disposed of by Man à à Temporal life lived in this world isn't related to the individual. The individual has as his own a degree of life that is progressively significant and that can't end. Real life is an essential decent, here underneath it is the condition for every other great. Yet, there are higher qualities for which it could be genuine or even important to be happy to open oneself to the danger of losing substantial life. In a general public of people the benefit of everyone is for every individual an end which he should serve and to which he should subordinate his specific intrigue. Be that as it may, it isn't his last end and, starting here of view, it is society which is at the administration of the individual, in light of the fact that the individual won't satisfy his fate with the exception of in God. The individual can be absolutely subjected distinctly to God. Man can never be dealt with essentially as a way to be discarded so as to acquire a better quality. à Concerning the shared rights and obligations of the individual and of society, it has a place with moral educating to edify hearts; it has a place with the law to indicate and compose outside conduct. There is unequivocally a specific number of rights which society isn't in a situation to give since these rights go before society; however society has the capacity to protect and to implement them. These are most of those which are today called human rights and which our age brags of having planned. à The primary right of the human individual is his life. He has different merchandise and some are all the more valuable, yet this one is basic - the state of all the others. Thus it must be ensured over all others. It doesn't have a place with society, nor does it have a place with open expert in any structure to perceive this ideal for a few and for nobody else: all segregation is insidious, regardless of whether it be established on race, sex, shading or religion. It isn't acknowledgment by another that comprises this right. This privilege is predecessor to its acknowledgment; it requests acknowledgment and it is carefully out of line to deny it. à Any segregation dependent on the different phases of life is not any more supported than some other separation. The privilege to life stays total in an old individual, even one extraordinarily debilitated; it isn't lost by one who is seriously wiped out.
Thursday, August 13, 2020
Morris, Lewis
Morris, Lewis Morris, Lewis, 1671â"1746, American colonial official, first lord of the manor of Morrisania in New York. The son of Richard Morris (d. 1672; see Morris , family), he was born in that part of Westchester co. that is now part of the Bronx, New York City. He inherited large properties in New York and New Jersey, and in 1697 his New York estate was patented as the manor of Morrisania. In 1702, Morris traveled to England to help bring about the fall of proprietary government in New Jersey. He became a bitter opponent of the arbitrary rule of Lord Cornbury, who was governor of both New York and New Jersey, and aided in securing his removal (1708). In 1715 he was made chief justice of New York, but a subsequent struggle with Gov. William Cosby resulted in his removal (1733). Upon the separation (1738) of New Jersey from New York, Morris became the first governor of New Jersey, serving until his death. His stern administration was marked by much opposition and quarreling. The Columbia Electronic Encyclopedia, 6th ed. Copyright © 2012, Columbia University Press. All rights reserved. See more Encyclopedia articles on: U.S. History: Biographies
Saturday, May 23, 2020
Descriptive Essay - Original Writing - 943 Words
Calliope sat straight up in a cold sweat her shoulder length hair cling to her head, she panted eyes wide in panic. Her hands clasped over her mouth stifling a scream. Calming down from her momentary hysteria and with a deep breath she examine her surrounding pristine blue above her, deep green grass a long with some wild flowers swayed around her. Standing up on wobbly legs she tried to remember where she was but, her mind drawing a blank on anything beyond her name. Walking down a small slope she saw clear body of water. ââ¬Å"That me!â⬠She shouted at her refection; in the water was a slender girl looking somewhere between thirteen and fourteen dressed in an embarrassingly frilly white gown stared back. Calliope prodded herself careful theâ⬠¦show more contentâ⬠¦Ã¢â¬Å"Iââ¬â¢m Katsi.â⬠She gave a small smile holding out her hand. ââ¬Å"Calliope.â⬠She took Katsiââ¬â¢s hand, fallowing her instinct her memory still beyond her reach. ââ¬Å"Aww such cute name, your definitely M.C.M.â⬠Katsi looked at her with a sisterly shake. ââ¬Å"Umm M.C.M.â⬠Calliope asked worried. ââ¬Å"Main character material.â⬠Katsi laughed, pulling Calliope along to a polished stone path. ââ¬Å"So Iââ¬â¢m guessing youââ¬â¢re here by luck.â⬠She asked talking as if Calliope was her best friend. ââ¬Å"Luck?â⬠Calliope asked confused, but was to nervous explain that in here mind she just started existing. ââ¬Å"Yup your luck.â⬠The red head giggled as she was pulled Calliope through golden gates that had something engraved in it that she couldnââ¬â¢t read. What do you mean? Katsi stop hearing Calliopeââ¬â¢s panicked voice. The grip on Calliopeââ¬â¢s hand changed she look up, Katsiââ¬â¢s gaze changed to something more protective. The taller girl pulled her along The three Ls that separate the schools more than the schools themselves. Her voice was a whisper snapping her fingers to get Calliopeââ¬â¢s attention ââ¬Å"Legacy. She pointed to a small group of giggling girls in pastel grown, Calliope stared at the group thinking how artificial they look in contrast Katsi ââ¬Å"Labor, which is what I am. She turn to Calliope and patted the shoulder And luck. Calliope smiled up at her new found friend, her eyes growing wide at the end of the straight path. It building dwarfing trees and as white as an egg toweredShow MoreRelatedDescriptive Essay - Original Writing1110 Words à |à 5 PagesI donââ¬â¢t know how I got to where I am, but Iââ¬â¢m here now, and I have to win if I want to live. I am in a game, and in order to live, I have to escape. Thatââ¬â¢s the thing, though: I donââ¬â¢t know how to escape. I was running for my life around this old house that looked like it came straight out of a horror movie. I doubled over and held my head in pain as I saw the static, which meant it was coming. I was being chased by what looked like a person but in no way acted like one. Just as it was about to appearRead MoreDescriptive Essay - Original Writing1102 Words à |à 5 PagesIt is on days like this when we stop to think about our life. Small drops of rain begin to dapple the cobblestone pavement as people whip out their umbrellas for cover. I continue sauntering down the busy street, relishing the feeling of a light shower. Moving with the mass of pedestrians, I stop at a crosswalk where I wait for the stoplight to turn green. A flower shop employee across the street scurries to bring in the numerous bouquets and close the doors as rain starts rolling down the displayRead MoreDescriptive Essay - O riginal Writing914 Words à |à 4 PagesDreamy I thought. Standing on the corner is a young guy with a smile. I see him here almost every day, so I linger for a while. He tells me his name, and I tell him mine. I m Ester, what s your name? I enquired. My names David .,He replied. We end up talking for a while and I asked him if he had ever left this city. He tells me of all these stories of the places where he s been, the distant lakes and mountains, and in valleys oh so green. I can see it in his eyes, he really has beenRead MoreDescriptive Essay - Original Writing974 Words à |à 4 Pages I was used to moving round, having a mother who liked to travel more than making roots was something I had gotten used to. Still, I had never gotten used to the loneliness of an empty house when she was out exploring, or the feeling of leaving behind someone who could have meant something to me. Our most recent move was Oregon. It was pretty, and I didnââ¬â¢t mind it, but it was much different than Florida. Not only was it opposite sides of the country, it felt as if it were opposite worlds. InRead MoreDescriptive Essay - Original Writing1012 Words à |à 5 Pageshave plenty of time in the next month to think about my feeling in regards to Kendrick. I needed to finish up the article and get it off to my editor. I should be able to get it done by tonight and send an email in the morning. I was thinking of writing my next article about the sea life around the Scottish coast. Since our salmon dinner last evening I thought I would do a piece about the commercial salmon farming that began in Scotland in 1969. In 2002 over 145,000 metric tons of farmed AtlanticRead MoreDescriptive Essay - Original Writing1561 Words à |à 7 PagesThereââ¬â¢s something I need to say and what follows may not be something that youââ¬â¢d expect, it wonââ¬â¢t be heartening or uplifting. If you remember today, I told you about going somewhere I wanted to go toâ⬠¦ Iââ¬â¢m not sure if you believed and accepted what I now confess as untrue; it is partly. I needed to pull away emo tionallyâ⬠¦ from you. You must have had fathomed that some degree of formality had seeped between us. Born of habit, formulaic greetings had become a routine. You presume that Iââ¬â¢m a close friendRead MoreDescriptive Essay - Original Writing1387 Words à |à 6 PagesI was wearing a beautiful blue dress with sapphire gems all around the chest area as I entered the ball with Ciel and Sebastian. I took a good look around here, the hallway was lined with gold. There was a servant ready to escort us to the ball room. Hello, come this way. He said, walking forward. Wow, this place is so fancy! I exclaimed, looking around. It s fake gold. Ciel bluntly replied, bringing my hopes down. I sighed. Ciel sounded like he wasn t in a very good mood. Ciel, lightenRead MoreDescriptive Essay - Original Writing1287 Words à |à 6 Pages In the morning, Caireann woke me up. She stood above my bed, shaking my shoulder. I opened my eyes, looking at her. Then I looked across the room to her empty bed. Andy s empty bed sat in the corner. I swallowed, climbing out of bed. Sleep well? Caireann asked me, starting out the door. Yeah, I said, going over to our small dresser. I had the bottom two drawers. Andy had the middle two, and Caireann had the top. I pulled open the drawers, pulling on a colorful tank top and a grayRead MoreDescriptive Essay - Original Writing1345 Words à |à 6 PagesLater that night, I was behind the wheel of my G-Wagon with Melissa in the passenger seat. She didnââ¬â¢t feel like driving since she was on the road all day and I understood so I didnââ¬â¢t mind when she asked me to. I had been tight-lipped. She kept eyeballing me as if she detected that something was bothering me but I just kept singing to my India Arie as if I was carefree. ââ¬Å"So are you going to tell me whatââ¬â¢s going on or noâ⬠Melissa said disrupting my own personal concert. I stopped singing and tookRead MoreDescriptive Essay - Original Writing1085 Words à |à 5 PagesI WAS SITTING IN a taxi, wondering if I had overdressed for the evening, when I looked out the window and saw Mom rooting through a Dumpster. It was just after dark. A blustery March wind whipped the steam coming out of the manholes, and people hurried along the sidewalks with their collars turned up. I was stuck in traffic two blocks from the party where I was heading. Mom stood fifteen feet away. She had tied rags around her shoulders to keep out the spring chill and was picking through the trash
Tuesday, May 12, 2020
Arthur Zimmermann - Profile
Arthur Zimmermann (October 5, 1864ââ¬âJune 6, 1940) worked as the German Foreign Secretary during 1916 to 1917 (mid World War 1), when he sent the Zimmermann Telegram, a diplomatic document that clumsily tried to trigger a Mexican invasion of the U.S. and contributed to Americaââ¬â¢s entry into the war. The coded message earned Zimmermanns lasting infamy as a hapless failure. Fast Facts: Arthur Zimmermann Known For: Writing and sending the historic Zimmermann NoteBorn: October 5, 1864 in Marggrabowa, East Prussia, Kingdom of PrussiaDied: June 6, 1940 in Berlin, GermanyEducation: Doctorate of law, studied in Leipzig and Kà ¶nigsberg (now Kaliningrad) Early Career Born in present-day Olecko, Poland, Zimmermann followed a career in the German civil service, moving to the diplomatic branch in 1905. By 1913, he had a major role, thanks partly to the Foreign Secretary Gottlieb von Jagow, who left much of the face to face negotiations and meetings to Zimmermann. Indeed, he was acting as Foreign Secretary alongside German Emperor Wilhelm II and Chancellor Bethmann Hollweg in 1914, when Germany decided to support Austria-Hungary against Serbia (and thus Russia), and enter the First World War. Zimmermann himself drafted the telegram giving notice of the countrys commitment. Soon most of Europe was fighting each other, and hundreds of thousands were being killed. Germany, in the middle of it all, managed to stay afloat. Arguments Over Submarine Strategy Unrestricted submarine warfare, which was likely to provoke a U.S. declaration of war against Germany, involved using submarines to attack any shipping they found, whether or not it appeared to be from neutral nations. Although America subscribed to an odd notion of neutrality at the best of times and warned early on that such tactics would draw them into the fray, U.S. civilian and shipping craft was a major target. Jagow remained German Foreign Secretary until the middle of 1916, when he resigned in protest at the governments decision to resume this style of submarine warfare. Zimmermann was appointed his replacement on November 25, partly because of his talents, but mainly because of his complete support of the submarine policy and the military rulers, Hindenburg and Ludendorff. Reacting to the American threat, Zimmermann proposed an alliance with both Mexico and Japan to create a ground war on U.S. soil. However, the telegram of instructions sent to his Mexican ambassador in March 1917 was intercepted by the Britishâ ââ¬ânot entirely honorably, but alls fairââ¬âand passed onto the U.S. for maximum effect. It became known as the Zimmermann Note, severely embarrassed Germany, and contributed to the American publics support for war. Americans were understandably angered by Germanys attempt to send bloodshed to their country, and were keener than ever to export it instead. A Lack of Denials For reasons still baffling to political analysts, Zimmermann publicly admitted the telegramââ¬â¢s authenticity. He remained Foreign Secretary for a few more months, until he retired from government in August 1917, largely because there wasnt a job for him anymore. He lived until 1940 and died with Germany again at war, his career overshadowed by one short communication.
Wednesday, May 6, 2020
Facts and Information on Greek Goddess Athene Free Essays
The culture of Greek mythology has impacted modern culture. The first ever written origin story of greek mythology took place around 700 B.C. We will write a custom essay sample on Facts and Information on Greek Goddess Athene or any similar topic only for you Order Now (Athena) Greek mythology impacted modern culture by the way people live and even design houses today. The religion of greek culture is based on time-honored observances and was rooted in the Bronze Age. Their religion was not based on toe thora or the christian bible, but it was based off of exchange. Individual worshipers where to give gifts to gods and goddesses as an expression of thanks, especially zeus the father of all gods. Athena the daughter of Zeus or is better known as the favorite daughter of Zeus. Athena also named Athene was one of the three virgin goddesses. (Athena) Athena came right out of Zeus with armor and ready to go; she was called into the existence.(Dââ¬â¢Aulaire) She was known as the goddess of the city for protecting her people. Athena was also known as to invent the flute, but she never played.(Athena) Athenaââ¬â¢s powers and the way she uses them towards people explains how she is the goddess of war and her influence on modern culture such as moral standards and language. Athena and her family have impacted their culture and todayââ¬â¢s modern culture. For instance the Olympics. The olympics started in Olympia, Greece, where itââ¬â¢s name was founded. Every four years the olympics was held for the god Zeus. A prizes from the olympics were fame and glory. The first olympic games was held by the athenians in the summer of 1896. In the summer of 1896 the olympics held 41 events. They brought 14 nations and 241 athletes to compete. The symbol of the rings represented the 5 participating continents: Africa, Asia, America, Oceania, and Europe. Greece held other games like the Ptythian games and the isthmian games. Those games where held for Apollo and poseidon. The greeks have affected political ways. The greeks created the first democracy, at first it was a monarchy then moved onto a oligarchy, and finally a democracy. Six Thousand adult male citizens were assembly members of the democratic government. The United States uses a representative democracy instead of a direct democracy, which was what the Athens used. (11 Greek Influences and Contributions to Todayââ¬â¢s Society) Athena also has played a role in the progress of the womenââ¬â¢s army. Athena has many objects named after her from dolls to yogurt bars and even a cosmetic line sold in California. The reason why they named the yogurt bar after her was because of the greek yogurt they used in the recipe. Donââ¬â¢t let the name fool you this bar is packed with artificial flavors and and unhealthy ingredients. Athena plays a big roll in the Barbie factories as each doll sells for 70 dollars to 100 dollars (ââ¬Å"Greek gods in American Cultureâ⬠). The cosmetic company states the company will provide you and safe and reliable, quality products, combined with uncompromised integrity and the spirit of philanthropy. The company states this cause athena was known to provide safety and is a reliable goddess. As the goddess of war, Athena has used her powers to win wars. An example is Athena and Hera as they fought against Paris in the Trojan war. (Athena) In 1260-1250 BC the Trojan war took place. The golden apple which was known as the Apple of Discord was given to Athena, Hera and Aphrodite. The three goddesses were commanded by Zeus to take the Apple to Paris. The contest turned into a bribery and not about beauty. Athena offered wisdom, skill for battles and the ability of warriors. Hera offered Paris the ability to control Asia and political powers. Aphrodite finally offered the attention and love from attractive women all over the world. Paris choose the beautiful women around the world, and luckily paris and Hera fell in love. The problem here is Hera being married to the king of sparta Menelaus. The news finally reached to Sparta and Greece. Menelausââ¬â¢ brother Mycenae heard the news first and was upset. In anger he sent an army to Troy, thatââ¬â¢s when Agamemnon and with the help of others came up with the Trojan horse. The trojan horse sat right outside the city of Troy to signify the end of the war. The greeks hid outside, and at night they snuck in and killed the entire city but women and children. The women and children were sold as slaves and Hera returned to her husband. Athena is an important goddess to many people and gods in every culture. She is the goddess of wisdom, courage, inspiration, civilization, law, justice, strategic warfare, mathematics, art, strategy, skill, and crafts. (Athena) One unique way Athena used her power is by blinding Tiresias when he saw her naked while bathing. (Athene) In a contest with poseidon to take dominion she produced and olive tree and a horse. (Athene) the powers of athena are from her parents Metis and Zeus. Athena got her powers of wisdom and crafty thoughts from her mother Metis. (Athena) Her powers progressed as she lived. Ancient greeks believed gods and goddesses would control their lives. The greeks would build buildings and statues to honor the gods and goddesses. Home life during the ancient greek times is different compared to modern day. Many people lived in a village or the countryside. Most houses where small and made of sun dried mud brick.(ââ¬Å"Ancient Greeks: Home Lifeâ⬠) After a few years the houses would crumble and later had to rebuild. Homes didnââ¬â¢t usually have a bathroom but they had public ones. Only the rich had bathrooms and a better home life. Most gods would at least have 50 servants per household. Men and women would wear tunics or what they called them ââ¬Ëchitonââ¬â¢. Women and most older men liked wearing the longer tunics but for the men they would wear them shorter. Many people wouldnââ¬â¢t wear sandals or boots. (Ancient Greeks: Home Life) High boots were worn when horse riding. Suntans were not cool in ancient greece. Many women used white lead to look pale. The white lead they used was harmful on their skin. It is obvious the greeks liked to wear a lot of jewelry because they are found in the tombs where they were buried. The difference in greek culture and modern culture. A similarity in the cultures are the way our society if or was formed. Most early cities had their own government which was located in the middle of the city. The greeks had marketplaces where people would socialize and shop. Which sounds similar to a modern day mall updated. The biggest city was the Athens in Greece. We almost have a similar style homes. Similar to old homes were built and still stand today in our culture. Many people like to design their houses according to the ancient greeks. A difference in modern society is that we donââ¬â¢t worship gods and goddesses anymore. Many of the gods and goddesses had slaves, and many. Now in our modern times itââ¬â¢s rare to have slaves. As for the clothes we donââ¬â¢t wear tunics like the greeks did. As of religion there are branches that lead to the religions we have today. In conclusion Athena uses her powers in many different ways like to fight wars and even blind tiresias from seeing her bathing. Although Athena was a strong warrior with bumps on the road she still managed to protect her city. Athena has left an impact on her culture and modern culture. Statues and buildings were built to honor all gods and goddesses. Now in modern society not many people honor all gods and goddesses, the way they used to back then. The way Athena expresses her powers pulls together the way she influenced modern culture just like our moral standards. How to cite Facts and Information on Greek Goddess Athene, Papers
Sunday, May 3, 2020
Business Law Concentrate Law Revision Study -Myassignmenthelp.Com
Question: Discuss About The Business Law Concentrate Law Revision Study? Answer: Introducation Contract contains a promise whereby part A promises to fulfil a particular undertaking and party B pays party A, a consideration value, which is decided between A and B, for undertaking the promise. In order to form a contract, which has legal validity, there is a need for the presence of offer, acceptance, consideration, capacity and intent[1]. The very first step, which leads to the formation of contract, is the presence of an offer. It is essential to make a distinction between an offer and an invitation to treat. The offer shows that the parties A and B want to create a contract, where as the invitation to treat shows that the parties A and B just want to negotiate upon the terms of the contract. The newspaper advertisements or commercials are deemed as an invitation to treat and not an offer[2]. In Partridge v Crittenden[3], the defendants conviction was quashed as the advert was deemed as an invitation to treat. It is also important to demarcate between offer, invitation to treat and a request for information, as was held by the court in Harvey v Facey[4] where no separate offer was deemed to have been made. Upon an offer being made in a successful manner, the acceptance has to be attained on this offer. The accounting has to be given by the party to which the offer had been made. So where the offer was made by A to B, B has to accept the offer. The offer can be revoked only till B does not accept it[5]. Also, there is a need to accept the offer in the manner in which it had been made, and if the terms are altered in the slightest of manner, it would result in a counter offer as was seen in Hyde v. Wrench[6], which would render the original offer useless. The acceptance date is taken to be such date when the acceptance communication is obtained by the offering party[7]. Though, the postal rules to acceptance is the exception of this rule as under this rule, the acceptance date is such date on which the letter containing the acceptance is posted by the accepting party. The raison d'tre behind this is that the postal office is given the status of the agent of the offering party and due to the operation of agency law, the acceptance by the postal office is to be considered as the acceptance by the offering party[8]. The date on which this letter reaches the offering party remains irrelevant. Upon the electronic communication, the Electronic Transaction Act, 1999[9] applies. The postal rules of acceptance are linked to the requirements of section 14 of this act. As per this section, the date and time on which the communication leaves the senders device, that is the date and time of the particular communication and not the date on which th e same reaches the receiver. This section is applicable for offer and acceptance both. Apart from these two elements, the formation of contract requires consideration as an element under which the parties mutually decide the value which has to be paid for the undertaken promise. There is a need for the consideration to have economic value for the contract to be valid[10]. The next requirement is to have the intention of forming legal relations. The parties also need to have the contractual capacity to create legal relations in terms of majority age and soundness of mind[11]. Application The facts of this case study are majorly concentrated upon the elements of offer and acceptance. The advert which Lianne saw in the newspaper, on the basis of Partridge v Crittenden, would be deemed as an invitation to treat as it invited quotes from the parties who wanted a party to be hosted. Section 14 of the Electronic Transaction Act and the postal rules of acceptance also play a crucial role in this case study. As the emails were exchanged in this case, on the basis of this section, the date of the communication would be the date on which it was sent and the date on which the receiver read it, would remain irrelevant. The email which was sent on 10 Jun, the very first one in the chain of emails, would be considered as a request for information on the basis of Harvey v Facey since Lianne only requested information under it. The reply to this email was also not an offer as only information was being swapped under this. The three hour afterwards email was the point where the offer was made. On this, a counter offer was made with reduced amount as there was a change in the terms of the original offer. Again, a counter offer was made with particular conditions and the higher consideration amount and this offer was valid for a specified time period only. The offer was made on 10 Jun so, it expired after seven day period on 17 Jun. Hence, it was not valid on 20 Jun when Mary stated that the price had changed. The communication of Lianne on 20 Jun would not be an acceptance. When Mary quoted $10,000 on 20 Jun that was when the new offer was made. And the acceptance was attained on this as Lianne sent an email regarding the same. However, later on she sent an email to revoke this acceptance, which would not be valid as the offer ahs to be revoked before acceptance is given. The reading or non-reading of the emails would remain irrelevant on the basis of postal rules of acceptance and section 14 of the Electronic Transaction Act. The value of consideration has already been established and the other elements of contract have been assumed as being present as the contrary to prove this is not present. This means that a contract had been created between the two parties. The Competition and Consumer Act, 2010 was an act brought out in the nation, for protecting the consumers and for ensuring that the competition is properly followed in the nation. Under schedule 2 of this act, is the Australian Consumer law, which is the key legislation for safeguarding the consumers. A consumer is such a person, as per section 3 of ACL, who takes services or purchases goods to the value of $40,000 in the nation, for their own use or consumption. Through section 18, the businesses are prevented from indulging in misleading and deceptive conduct. And through section 29, the same restriction has been placed with regards to false or misleading representation. The facts of this case study show that Lianne is a consumer as she undertook the services of Mary and entered into a contract with her for a value of $9,500. These services were used for her personal party. And so, as per section 3, Lianne is a consumer. By not fulfilling the terms which were promised, Lianne was misled and deceived by Mary as she was provided with a different cuisine, instead of what was promised. Further, the space in the boat was falsely represented. This would mean that both sections 18 and 29 were contravened by Mary. The invitation to treat and an offer are two terms which cause a lot of confusion in the daily lives of people. The confusion is due to the fact that at particular instances, the particular communication can be taken as one thing and at other instances, it could be deemed as the other one. This confusion can lead to certain liabilities for the businesses who give such adverts through the different mediums. In this discussion, the points have been put in favour of the care which needs to be undertaken by the businesses while creating the adverts to be published in hard copy and soft copy. In the first part of this discussion, Lianne reads a newspaper advertisement which was taken to be an invitation to treat based on a quoted case. The reason for holding this as an invitation to treat was because the judge in the case of Partridge v Crittenden had analysed the wordings of the advertisement and applied statutory rules of interpretation for taking out its meaning, which was ultimately deemed as an invitation to treat, instead of an offer[12]. Where a case of invitation to treat is established, there is no need for the parties to complete the sale and no liabilities are attracted on them as was seen in Pharmaceutical Society of Great Britain v Boots[13]. However, this is not the case with every advertisement. To make a demarcation between a particular advert being an invitation to treat and it being an offer, the wordings of such advert have to be considered. Unlike Partridge v Crittenden, in Carlill v Carbolic Smoke Ball Company[14] the court deemed that the advertisement was an offer. The difference between the two could be established in the context of the placed advertisement[15]. In the case of Carlill v Carbolic Smoke Ball Company, the company had given an advertisement in the newspaper where it promised to award the person who got the disease even when they had used the smoke ball produced by the company. The award money was 100. Carlill used this smoke ball and still got influenza so she went to the money and claimed the award money of 100. The company denied the claim on the basis that this was an invitation to treat. However, the court agreed with the plaintiff as they stated that the newspaper advert wordings were such where the offer could be accepted by simply acting upon it. And so, the court ordered the plaintiff to be paid the promised award money[16]. The advertisements are placed in newspapers and in this growing digital age, they are found more than often across the digital platforms. The adverts also include the one posted on billboards and on the buses. So, at every place where the businesses post their advertisements, they have to take care in printing their adverts. Whatever promises or offers they made under the advertisements, have to be drafted in a manner that they remain an invitation to treat and do no become an offer. In case an offer is made through such advertisements, liability would be attracted for the businesses as they would have to go forward with the contract when the offer is acted upon by the other party[17]. Apart from the liabilities which can be raised for the businesses for posting their advertisements under the contract law, the businesses can also be made liable for the adverts on the basis of the Australian Consumer Law. Australian Competition and Consumer Commission v TPG Internet Pty Ltd[18] is a leading example of this in which TPG had advertised a price for their product. However, this price was deemed as misleading and a breach of section 18 was established as the adverts did not disclose fully that the consumers had to pay additional sum at later stage as this additional sum was hidden from the published advertisement. To conclude the discussion which had been carried on till now, it becomes very clear that the businesses have to take special care when they place any advertisement through the different mediums. This is because these adverts can result in a contract, where this advert is an offer, instead of an invitation to treat. And in such cases, the businesses become bound by the contract and have to fulfil the obligations covered under the contract. Apart from this, the businesses also become liable under the other laws including the Australian Consumer Law. Hence, as was stated at the outset of this discussion, it is crucial that businesses take care while placing any advert, or would attract liabilities upon them. References Andrews N, Contract Law (Cambridge University Press, 2nd ed, 2015) Davies PS, JC Smith's the Law of Contract (Oxford University Press, 2016) Elliott C, and Quinn F, Contract Law (Pearson Education Limited, 9th ed, 2013) Furmston M, and Tolhurst GJ, Contract Formation: Law and Practice (Oxford University Press, 2010) Gibson A, and Fraser D, Business Law (Pearson Higher Education AU, 2013) Latimer P, Australian Business Law 2012 (CCH Australia Limited, 31st ed, 2012) Marson J, and Ferris K, Business Law Concentrate: Law Revision and Study Guide (Oxford University Press, 3rd ed, 2016) McKendrick E, Contract Law (Pearson Education Limited, 11th ed, 2015) Poole J, Casebook on Contract Law (Oxford University Press, 2016) Stone R and Devenney J, Text, Cases and Materials on Contract Law (Routledge, 3rd ed, 2014) Australian Competition and Consumer Commission v TPG Internet Pty Ltd [2013] FCAFC 37 Carlill v Carbolic Smoke Ball Company [1892] EWCA Civ 1 Harvey v Facey [1893] AC 552 Hyde v. Wrench (1840) 3 Beav 334 Partridge v Crittenden (1968) 2 All ER 421 Pharmaceutical Society of Great Britain v Boots [1953] Management. Competition and Consumer Act, 2010 (Cth) Electronic Transaction Act, 1999 (Cth)
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