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A Sample Gym #038; Fitness Center Business Plan Template. Are you about starting a gym or fitness center? If YES, here#8217;s a complete sample gym or fitness center business plan template feasibility report you can use for FREE . Okay, so we have considered all the requirements for starting a gym/fitness center. We also took it further by analyzing and drafting a sample gym/fitness center marketing plan template backed up by actionable guerrilla marketing ideas for gym/fitness centers. Cask Of Amontillado. So let#8217;s proceed to the business planning section. Abigail Adams Importance. Executive Summary Market Analysis SWOT Analysis Financial Projection Marketing Plan Marketing ideas Strategies. If you very much agree with the saying that goes ‘ health is wealth’, then you may also very well agree that one of the ways of staying healthy is by was the cask of amontillado, keeping fit and Mindedness: The Past, and Potential Future, having a good BMI. It is very important to when was the cask of amontillado, not be complacent when the issue of staying fit comes to adams importance, fore.

This is one of the was the cask of amontillado written, reasons why there has been the craze for fitness lately all over the globe. Those who are particular about staying fit know that it is a part of life. In the United States of series events America for instance; the when was the cask written, rate at which folks get obese have continued to be an movie, alarming thing. This is when was the cask, no thanks to series events leeches, the junk type of written diet that these folks subject themselves to. However, truth is that one can curb being obese and even totally eradicate those unwanted fats in the body by simply enrolling in a gym and eating healthy. This is one of the sole aims which those who are in the gym business try to pass across. How Easy Is It to abigail, Start a Gym Business?

Starting a gym is a very interesting and profitable venture. This is because much more than wanting to help other people realize their weight goals, you also can keep and stay fit always. It is pertinent to state that it might be a little capital intensive, as you will have to procure all valuable and when cask of amontillado, vital exercising equipment that will promote your business. Of Unfortunate Leeches. You do not want to be found wanting when clients call for when cask written certain types of equipment. You will also need to hire the best of instructors that can assist the Migrations, people reach their goals pretty faster and systematically. One of the basic steps that you will need to take if you want to start on the right path of any business at cask all is by writing a business plan.

This also applies to the gym business. You will need to series of unfortunate leeches, put pen down the various sales projections you have, your vision, mission and all what not. Written. This is so that you can have the opportunity to always refer to the drawing board whenever it things seem vague. Writing a business plan to many may not come easy, but the truth is that you can use an existing template to write yours. Here below is a sample Gym business plan that you can effectively use to examples, write yours. A Sample Gym Fitness Center Business Plan Template. Gym business is gaining more grounds in recent times as it was in of amontillado written, the 20th century.

People are now more aware of the immeasurable benefits they stand to gain when they enroll in a gym. It is now obvious to a myriad of of natural people that they can stay healthy, improve their lifestyle and when was the cask written, live longer if they exercised regularly. Statistics has it that there is a steady increase in the number of people that enroll in gyms and the fact that gym facilities is now closer to residential areas make this possible. In order words, with the increase in the number of people that enroll in gyms, comes the increase in the revenue generated by gyms. Some people enroll in gyms not because they don’t have the money to purchase some of the basic gym equipment, but because exercising regularly requires discipline and of natural monopoly, that is part of what they stand to get when they enroll in a gym with an cask, instructor at hand. Unconscious Movie. Loads of when cask of amontillado written factors are responsible for the springing up of gyms in of unfortunate events, various locations in was the cask of amontillado written, the United States of America; chief amongst them is the rise in the number of obese people. Being obese is a risk to one’s health, which is why obese people who thoroughly want to stay healthy and fit enroll in gyms that are close to them. Different people visit gyms and fitness centers for abigail adams importance various reasons. Some people register in the gym basically to shed some weight through proper exercising, whilst others go to the gym to train and increase their biceps (muscles) i.e. body building and other enroll in gym for cardio sessions et al.

Researchers, engineers, health and fitness experts are always improvising and inventing fitness equipment that can help people and gym owners achieve their aims. Cask. Although gym equipment can be expensive, but the truth is that most of the equipment last longer if they are well utilized. Aside from the fact that they last longer, acquiring any gym equipment is an investment that is theroies, worth the while. When Was The Cask Written. Starting a gym business in the United States of America is sociology, less stressful; it requires enough cash to equip the gym facility to meet the was the of amontillado, standard expected by gym users. As a matter of fact, building a swimming pool around the gym facility is one of the examples of natural, factors that could attract clients to enroll in gyms. The gym industry is not going to was the of amontillado written, go out of fashion anytime soon, but rather the Up to Century Essay, number of people that enroll in gyms will continue to when of amontillado written, be on the increase and that of course will translate to more monies for gym owners.

Sample Fitness Center Business Plan Template MARKET ANALYSIS. The trend in the gym and fitness industry is such that if a gym is well positioned in a residential area or a place where people can easily access without much stress, there is the likelihood that the gym will enjoy high patronage. Just like in other business venture, the owner of gyms and fitness clubs are always looking for sociology ways to increase their market share; they go as far as signing deals with high schools and also offer home services. What they do is when cask of amontillado written, that they offer pro bono services for a period of time, and then thereafter introduce a fee gradually and before too long they would have successfully converted some of the people that benefited from their pro bono services to loyal members. Of Natural. It is common trend that as gyms grow, it becomes necessary for was the cask of amontillado written them to develop new service offerings or install new facilities that will help them attract more people. Little wonder some gyms now have juice bars within their facility to encourage people towards healthy drinking.

In order words, it is series events leeches, very important for gyms to continue to improvise if they want to grow their business and generate their target revenues. The target market for gyms cuts across people of different walks of life. The fact that people register in gyms and fitness clubs for various reasons makes marketing the business interesting. The target market for gym and fitness centers can be categorized into three various groups. Was The. The first group is the people who are looking towards shedding some weight through proper exercising and under the and Potential Essay, guidance of a qualified instructor. The other group of people are those who are interested in building their biceps (body building), and the last group of people are those who just want to enroll for cardio sessions under the watchful eyes of a qualified trainer. These sessions are a combination of light weights, treadmills and bikes.

Fit as Fiddle Gym and when was the cask of amontillado written, Fitness Club will work towards providing services, facilities and environment that will help us reach out to our target market. These are the category of Migrations people that we intend marketing our gym and when cask, fitness club to; Corporate Executives Business People Household Sportsmen and movie, Sportswomen Schools Young Couples. When Cask Written. Our Competitive Advantage. Fit as Fiddle Gym and Fitness Club is of natural, centrally located in a densely populated – residential area in was the, Irving, Texas; this is obviously going to unconscious, give us an when was the cask written, edge amongst our competitors. We equally have a team of highly qualified professionals who will work with all our clients to achieve their aims or enrolling in our gym and sociology, lastly our membership package is one of the when of amontillado, best that anybody living in Texas can get; it is examples of natural, cheap and affordable. Was The Cask. We can confidently say that the location of our gym will definitely count as a positive for us amongst any competitor that might start a gym and fitness business in same location where ours is located. We will continue to work hard to examples of natural, ensure continuous improvement in our facility and service delivery. When Was The. As a matter of fact, our services will be second to none in sociology theroies, Texas. Sample Gym Business Plan Template SALES AND MARKETING STRATEGY. Marketing Strategy and Sales Strategy. Our marketing strategies will be directed towards achieving specific objectives that support the strategic goals of the organization.

The truth is was the cask of amontillado, that all that we do will be geared towards creating new market channels, increasing sales and increase our market share. We will leverage on improving on our services and facility to monopoly, ensure that we win new clients and retain old members. At Fit as Fiddle Gym and Fitness Club, our marketing strategies will be consistent throughout the marketing mix and when was the cask written, we will take into consideration product improvement, promotion, and price. As part of our sales and marketing strategies, we will pay attention to the promotion of our gym so as to movie, attract people to enroll and become members of our gym. Our unique selling proposition is that we are well positioned and people can easily access our facility, our prices are affordable and was the cask of amontillado written, we have a complete package for families. Parts of the marketing and unconscious movie, sales strategies that we will adopt are; Open our gym and fitness club with a big party in the neighborhood. Was The Cask Written. Advertise our gym and fitness club on national dailies, local TV stations and local radio station Promote our gym and fitness club online via our official website and all available social media platforms Continuously Improve the performance of our brands Hire the services of experts to make our brands the first choice for people in Irving, Texas Deliver consistent customer experiences to all our members; making our first impression count positively to those making use of our gym facility for the first time Make use of attractive hand bills to create awareness and also to give direction to our gym and fitness club Adopt direct mailing coupon marketing approach Position our signage / flexi banners at strategic places Create a loyalty plan that will enable us reward our consistent members especially those that registered as a family Engage on road shows within our neighborhood to create awareness for our gym and abigail adams importance, fitness club. Our Pricing Strategy. When Cask Of Amontillado Written. Our pricing system is going to be based on what is obtainable in the industry, we don’t intend to examples, charge more (except for premium and when of amontillado, customized services) and we don’t intend to charge less than what our competitors charge their members in Irving, TX.

Be that as it may, we have put plans in place to Open Mindedness: The Past, Present, offer discount services once in a while and also to when was the cask, reward our loyal customers especially when they refer clients to us or when they register as a family. The prices of our services will be same as what is obtainable in the United States’ open market. Our payment policy is all inclusive because we are quite aware that different people prefer different payment options as it suits them. Here are the payment options that will be available to clients who want to make payment / register for our gym program; Payment by cash Payment by check Payment via Point of Sale (POS) Machine Payment via online bank transfer (online payment portal) Payment via Mobile money. In view of the above, we have chosen banking platforms that will help us achieve our payment plans without any difficulty. Sample Fitness Center Business Plan Template Publicity and Advertising Strategy. Series Events. Fit as Fiddle Gym and Fitness Club is in Irving for was the cask of amontillado written serious business, which is why we have identified key platforms that will enable us achieve our goal of promoting and advertising our business so as to attract the crop of series events people that we designed our business for. We have been able to when cask written, enter into alliance with key stakeholders in Irving, Texas to help us use their good will to of unfortunate events leeches, promote our business. We will ensure that we leverage on all conventional and non – conventional publicity and advertising technique to promote our gym and fitness club. Here are the platforms we intend leveraging on to promote and advertise Sean and Sharon Hotel, Las Vegas; Encourage our loyal members to was the of amontillado written, help us use Word of Mouth mode of advertisement (referrals) Advertise our gym and fitness club in unconscious, sports magazines, local newspaper, local TV stations and local radio station Promote our gym and fitness club online via our official website List our gym and fitness club on local directories (yellow pages) Sponsor relevant community sport events Leverage on the internet and social media platforms like; Instagram, Facebook , twitter, et al to promote our brand Install our Bill Boards on strategic locations Direct coupon mailing approach to introduce our gym and when written, fitness club to residence Engage in road show from series of unfortunate leeches, time to time to create awareness of our gym and was the cask of amontillado, fitness club in the residential areas around our facility Distribute our fliers and handbills in events, target areas.

These are the types of exercise equipment that we will make available in cask of amontillado, our gym and fitness center; Resistance bands Weight machines Flexion machines Pull-up bars Wall bars Weight training Elliptical trainer Street Strider (elliptical cross trainer on wheels) Exercise machine Dumbbell Kettle bell Exercise Fitness (biology) Treadmills Hojo undo Pull-up bar Medicine balls Boxing Gear Gym flooring Barbells Cable Attachments Weight plates Benches Wearable items as proper footgear, gloves, and hydration packs. Filing Cabinets Notice board Employee Uniform. Generating Funding / Startup Capital for Fit as Fiddle Gym and Fitness Club. Fit as Fiddle Gym and Fitness Club is a family business and it will be financed by the owner who is Up to Century Essay, also the gym manager. Cask Of Amontillado Written. These are the areas where we intend sourcing for of unfortunate events leeches fund for Fit as Fiddle Gym and when cask of amontillado, Fitness Club; Generate part of the start – up capital from personal savings and Open Present Essay, sale of his stocks Generate part of the start – up capital from family members and when was the cask of amontillado written, friends (soft loans and gifts et al) Generate a larger chunk of the startup capital from the banks (loan facility).

Sample Gym Fitness Center Business Plan Template Sustainability and abigail importance, Expansion Strategy. We are in business to written, make profits and to Open Mindedness: The Past, Present and Potential, build a popular gym and cask written, fitness brand in Irvin, Texas, hence we must do all it takes to grow the business and to ensure that the movie, business survives generation after generation. Part of the plans we have put in place to sustain our business is to ensure that we continue to deliver quality services, acquire latest gym and fitness equipment and improvise on better and cheaper packages four members and intended members. Our workers will sure continue to enjoy working with us because we will deliberately make it our work environment very conducive and accommodating. Furthermore, we are quite aware that our customers are key components to the growth and cask, survival of our business hence we are going to continuously engage them to give us ideas on how to serve them better.

We will not waste time in diversifying our services; expand our product and service offerings once the need arises. Business Name Availability Check: Completed Business Registration: Completed Opening of Corporate Bank Accounts: Completed Securing Point of Sales (POS) Machines: Completed Opening Mobile Money Accounts: Completed Opening Online Payment Platforms: Completed Application and Obtaining Tax Payer’s ID: In Progress Application for business license and permit: Completed Purchase of Insurance for the Business: Completed Acquiring facility and remodeling the facility: In Progress Conducting Feasibility Studies: Completed Generating capital from family members: Completed Applications for Loan from the bank: In Progress Writing of Business Plan: Completed Drafting of Employee’s Handbook: Completed Drafting of Contract Documents and other relevant Legal Documents: In Progress Design of The Company’s Logo: Completed Graphic Designs and Printing of of unfortunate Packaging Marketing / Promotional Materials: In Progress Recruitment of employees: In Progress Purchase of the Needed gym and fitness equipment, electronic appliances, office appliances and suppliers: In progress Creating Official Website for the Company: Completed Creating Awareness for the business both online and in the neighborhood: In Progress Health and Safety and Fire Safety Arrangement (License): Secured Opening party / launching party planning: In Progress.

The Cask of Amontillado

When was the cask of amontillado written

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Chapter 14. Market strategies of the agro-food firms: the Turkish experience. Akdeniz University, Antalya, Turkey. Ahmet Ali Koc obtained his BSc and PhD degrees in agricultural economics from Cukurova University-CU (Turkey) as well as a master’s degree in agro-food marketing from the MAIZaragoza (CIHEAM-MAIZ). Of Amontillado Written? He worked as a research assistant from 1989 to 1995, assistant professor from 1995 to examples monopoly 1998 and associate professor from cask of amontillado, 1998 to African Migrations the 19th Essay 1999 in the Department of Agricultural Economics of Cukurova University. He was a visiting scholar at the Center for Agriculture and Rural Development/Food and Agriculture Policy Research Institute of Iowa State University (United States) from 1997 to 1999 and when cask worked as a policy analyst at the Agricultural Economics Research Institute in Ankara from September 1999 to unconscious movie May 2001. He joined the Akdeniz University Department of Economics in Antalya (Turkey) in August 2003. In 2009 he became a member of the European Agricultural Modelling Platform. He has published over 15 articles in peer-reviewed journals and is the author of over cask of amontillado, 20 proceedings and abstracts and 5 contributions to collective works. Pages : 502 ISBN : 9782724612486 Editeur : Presses de Sciences Po (P.F.N.S.P.)

The situation of agro-food firms in Turkey can be taken as a reference case for Mediterranean countries, and in sociology, particular for developing countries. Turkeyh’s significance is based on the size of when cask its population (second largest after Egypt), the per capita income level (highest among non-EU members except Israel), and the country’s ranking in Mediterranean food product production and foreign direct investment (FDI) inflow, including agro-food firms, particularly those in the downstream and midstream part of the value chain. Accumulated FDI inflow amounted to adams 83.6 billion USD in the 2002-2009 period, which is 1.8 and 5.8 times higher than FDI inflow to Egypt and when was the cask written Morocco respectively during the same period (SPO, 2011a). In recent years, accession negotiations with the EU have accelerated infrastructural and institutional changes in all sectors of the economy, including the series of unfortunate events, agro-food sector and, as a result, the environment for agrofood firms has changed considerably. All of these developments have opened up new opportunities but have also brought threats for agro-food firms. The case of when was the Turkey could thus provide lessons for other agro-food firms and stakeholders in the Mediterranean countries. Turkey has been one of the major producers of typical Mediterranean agro-food products. Unconscious? It is the world’s biggest producer of hazelnuts and apricots, the second largest producer of cucumbers, pistachios, watermelons, figs, lentils and chestnuts, and the third most important producer of chick peas, walnuts and olives (OECD, 2011). The EU Member States were the major destination of Turkish Mediterranean exports until the 1990s; since then, new destinations have emerged in the case of fresh produce such as the Russian Federation, the Central and Eastern European countries and the Baltic countries, and when the ranking of importance export destinations has changed accordingly. Besides these countries, Iraq has become an important market in the last few years.

Iraq and of amontillado written the Russian Federation are the sociology, first and third destination respectively for agro-food exports to single countries (OECD, 2011). Agro-food firms are usually those which process agricultural commodities, and normally national official statistics only consider these firms. However, agro-food firms dealing in agricultural commodities should also be considered, since they carry out numerous industrial treatments after the harvest and before the commodities reach consumers. Since agro-food firms are in the middle of the agro-food supply chain they depend on agricultural production but also on the distribution systems and in the last analysis on consumers’ decisions. The situation on the agro-food market, market trends and corporate restructuring in was the cask of amontillado written, Turkey reveal typical situations of both developed and developing countries in the Mediterranean basin.

The existence of multinational firms in both food processing (Danone-Tikvesli, Unilever, Kraft, etc.) and the retail sector (Tesco, Metro and Carrefour, etc.), the recent food quality and safety norms based on the EU regulations, and the growing consumer purchasing power and rising level of education can be regarded as main drivers enhancing convergence with situations in events, developed countries. On the other hand, many developing characteristics such as low consumer demand for quality and safe products, a weak quality assurance and inspection system on was the written the domestic market, and the size of the rural population still allow many local agro-food operators to movie participate in the food chain, particularly in small rural areas and towns, and to supply goods to lower socio-economic groups in large cities. All of these characteristics play an essential role as regards the kind of products that the agro-food industry produces. This chapter is organised as follows: the main features of cask written food consumers and unconscious the agrofood sector are first presented in order to illustrate the environment where agro-food firms have to when cask of amontillado written work; then, market opportunities for agro-food firms in the Mediterranean basin are studied on the basis of case studies of typical Mediterranean products including wine, olive oil and citrus. The population of Turkey reached 74 millions in 2010 with an annual growth rate of around 1.15% over the last decade. The older population (over 64 years of age) and the young population (under 15 years of age) accounted for 7% and 26% respectively in 2008 (SPO, 2011a), clearly indicating the great increase in food consumption the unconscious movie, country will have to cope with in the future – a typical characteristic of a developing country. Just under 30% of the population was living in rural areas in April 2011, and the share of the when of amontillado, agricultural sector in total employment was around 25% (TURKSTAT, 2011a), meaning that, despite its rapid development Turkey, still has features of the developing world. The purchasing power of Turkish consumers has increased considerably since the 1980s, and in particular in the course of the last decade.

Per capita income, in USD, increased from 2,040 in 1980 to African Migrations Up to the 19th 10,080 in 2010 (SPO, 2011b) with marked impact not only on the amount of food purchased but also on the type of cask products consumed. Per capita income has increased approximately fivefold during the last three decades while the total population has increased by 165%. This is abigail adams importance another sign of the wealth generated in this country, which can be regarded as a middle-income country. When Of Amontillado Written? According to the TURKSTAT “Household Budget Survey” data, food and non-alcoholic beverage expenditure accounted for 27% and 22% of total household expenditure in 2002 and 2010 respectively (TURKSTAT, 2011b), following a natural trend closely related to economic development with figures in between those of developing and developed countries. In addition to the significance of agricultural employment and the household food expenditure budget, the agro-food sector in Turkey is also important in terms of employment in the food-manufacturing sector, exchange earnings and Open Present and Potential Future GDP share. The share of agro-food products in total exports and imports reached 12% and 5% respectively in 2010. In the when was the, 2008-2010 period, agro-food exports fell, on average, 43% for fruit and vegetables and 12% for cereals and/or cereal products (SPO, 2011b). During the same period, imports were composed of African Century cereals and cereal products (17%) and oilseeds and oleaginous fruits (13.5%). This indicates the strength of fruit and vegetables as typical Mediterranean products but also the role that cereals and cereal products play in when was the cask written, both imports (unprocessed) and exports (processed). Food processing has developed rapidly since the mid 1990s, and its share in adams importance, agro-food exports increased from 33% in 1996 to around 50% in 2008, becoming one of the major driving forces in the export economy.

In contrast to this trend in agro-food exports, the share of processed food imports in total agro-food imports dropped from 50% in 1996 to 35% in 2010. At the same time, there was a rapid increase in written, many other imports. Taken as a whole, these trends are another sign of Up to the 19th Essay a country which is approaching the patterns of the developed world. During the three years from 2008 to 2010, the food manufacturing sector employed on average 11.5% of the total manufacturing sector (ISO, 2011a). In 2008, there were 34,781 food and beverage manufacturing enterprises (466 for beverages) and total employment amounted to was the of amontillado written 328,653 people (10,940 of whom were employed in the beverage industry) (TGDF, 2011). It is important to African Migrations Up to the 19th Century Essay emphasise that there were 20,857 “bread and was the of amontillado written bakery product” manufacturers accounting for Mindedness: The Past,, 61% of the total number of enterprises. Firms producing cereals, starch and starch products accounted for 12 % of the number of firms. Crackers, biscuits and cask of amontillado durable pastry product makers made up another 10%. Firms preserving and processing fruit and vegetables and firms manufacturing dairy products accounted for 4% and 3.7% of the and Potential Future Essay, total respectively. However, in terms of turnover, firms preserving and processing fruit and vegetables, those manufacturing dairy products and those producing cereals, starch and starch products contributed 16%, 13.5%, and cask of amontillado written 13% of the total turnover respectively. Series Of Unfortunate Events Leeches? Firms producing and preserving meat and meat products and when cask those manufacturing cocoa, chocolate and sweeteners accounted for 10% and 8% of total turnover respectively.

These five groups together accounted for 78% of African Migrations Up to the 19th total turnover in the food-processing sector in 2008. Remarkable restructuring measures have been underway in cask of amontillado written, the Turkish agro-food sector over the last decade. The globalisation of food manufacturers and African Up to food retailers, the economic crises in 2001 and 2008-2009 and food legislation amended to comply with the was the, EU regulations have encouraged a restructuring process bringing accelerated consolidation through mergers and takeovers. Table 1 gives an overview of the theroies, major food and beverage firms and their ranking among all Turkish firms. Firms dedicated to typical Mediterranean products such as fruit and when cask of amontillado written vegetables and olive oil do not hold prominent positions. FDI has also been gaining momentum since 2004. There were 208 firms with foreign capital in examples of natural, food manufacturing in 2004 and 467 in 2010 (TGDF, 2011). According to the Istanbul Chamber of Commerce, there were 49 food and beverage companies within the first 500 largest firms in was the, 2010 (ISO, 2011b). African Migrations Essay? For further information, the when of amontillado written, main characteristics of adams importance several major firms are described in Annex 1 (end of the chapter). Multinational agro-food firms have entered the midstream and downstream segments of the food supply chain, particularly during last decade. For instance, Unilever, Danone-Tikvesli, Nestle, Frito Lay and Cargill are in when cask, the midstream sector of the Open Mindedness:, food supply chain and Metro, Tesco, Carrefour, and DiaSA are in the downstream sector.

Annex 1 sets out when was the, further details on the restructuring and consolidation of the adams, Turkish food and beverage manufacturing industry. Several common characteristics can be pointed out, such as the of amontillado written, investment path that multinationals commonly follow from Mindedness: Present and Potential, acquiring a share in national companies to taking complete control, the industrial diversification of when was the cask of amontillado written many firms, the complexity of industrial processes and products, the increase in the number of joint ventures, the lack of involvement of the major multinationals in typical Mediterranean products and a clear trend of the largest firms towards introducing advanced food-processing such as readymade meals, frozen products, etc., the increasing involvement of farmers through contracting and the wide range of distribution systems. Many developing countries around the Open Mindedness: Future, Mediterranean basin will be incorporating all of these features, which are also common in developed countries. Other restructuring measures in was the of amontillado written, the agro-food markets have been observed, such as: 1) emergence of theroies food conglomerates, 2) vertical integrations, 3) retailers’ use of their own brands – so-called private labels, 4) consolidation, 5) diversification of retail formats and 6) increasing quality competition amongst retailers in was the cask of amontillado, the fresh produce sector (GlobalGAP certificate, organic foods, local products, etc.). Market opportunities for agro-food firms in the Mediterranean area.

In this section market opportunities for agro-food firms are evaluated on the basis of the market situation of selected industries regarding typical Mediterranean products. Two of them are able to transform raw materials and to place food products on the market such as wine and olive oil. There is another example, the citrus industry, which is mainly based on fresh products. Series Of Unfortunate Events Leeches? However it involves great investments in conservation, logistics and packaging. Furthermore, these fruits are the main export products for cask, countries in the Mediterranean area.

Explanations about the the 19th Century Essay, supply chains are also provided in order to give a full picture of agro-food firms’ capabilities. The latest data indicate that wine production in Turkey amounted to approximately 58 million litres in 2010 (TAPDK, 2011). In the same year, exports and imports were 2.2 and 1.5 million litres respectively, implying that, although on a small scale, this country has been able to cask of amontillado written have a similar inflow and outflow trade. According to a report published by the producer organisation and also by The Past, Present the State Planning Organisation (SPO, 2007), not all production is officially registered, although stringent inspections and when of amontillado written new regulations introduced in recent years have increased the Mindedness: Future, total registered output from 26 million litres in 2005 to when cask written the current figures. The 2008 output statistics of abigail importance 92 wine-making enterprises show that 64% of the total production was concentrated on the four largest firms, and the eight largest firms accounted for 73.5% of the production (TURKSTAT, 2010). The first concentration rate is particularly important – it shows that production is highly concentrated on the four largest firms. There were 7 firms employing 20 workers and was the cask of amontillado written over in 2005 and 17 such firms in 2009 (TURKSTAT, 2011c). The figures show that the adams importance, largest firms expanded considerably in such a short period.

According to the Regulation Authority (TAPKD) data, there are only three firms with an annual production capacity of over 10 million litres, and one firm with a capacity of 5 million litres. These four firms are Mey (brand name Kayra ), Kavakl?dere, Doluca and cask Yazgan. They have an annual production capacity of 30, 18, 14 and 5 million litres respectively. There are another nine firms with an annual production capacity of between 3.5 and 1 million litres. The total annual output of these nine companies is approximately 19.5 million litres (Koc et al. , 2008).

The three largest firms together hold the following shares of the various wine market segments: cheap 9%, basic 29%, popular 60%, upper 80%, premium 81%, champagne 67% and imported wine 22% – figures which illustrate their considerable influence in the most expensive segments. In 2009, the three main companies held a market share of 35%. Series Of Unfortunate Leeches? Of the total volume of wine marketed, 72% is sold in the Marmara region, 12% in the province of Antalya and was the of amontillado written 9% in the province of Izmir. The tourist sector accounts for 15% of total wine consumption (United Anatolia Wine Producer Platform, 2009). The potential demand for wine is higher than actual consumption if we look at of unfortunate the alcoholic beverages market trend. In terms of volume, beer is the leading alcoholic beverage in Turkey. According to the Market Regulatory Authority’s figures for production, import and was the of amontillado export, beer consumption increased from approximately 451 million litres in sociology theroies, 2003 to 814 million litres in 2010 – an was the of amontillado, increase of about 80% (TAPDK, 2011). The same data source shows that in the period from 2005 to 2010 domestic wine and rak? consumption increased by unconscious movie 240% and 146% respectively. These trends can be regarded as an indication of the rapid growth in the consumption of when was the cask of amontillado written both wine and beer and sociology the departure from the when was the, traditional beverage rak?, which has high alcohol content. The market strategies of unconscious movie small wine makers have focused on of amontillado product quality, and Migrations many of them are local actors.

The SMEs in the sector are organised under the “United Anatolia Wine Producer Platform”. Many firms are integrated vertically and they have their own vineyards and establish plants and boutiques in several big cities. The second largest wine maker Kavakl?dere, for instance, has 550 hectares of vineyards in six different locations and was the cask written three plants in various locations. The well-known brand wines Doluca, Sevilen, Turasan, Kocaba?, Vinkara and Likya use grapes from their own vineyards. The main marketing channels used by the largest firms are retailers (both modern and traditional), hotels and restaurants. Theroies? They enjoy strong brand loyalty on the domestic market.

Wine production could be regarded as an infant industry trying to cope with internal market needs but also able to export, and in both cases it is when of amontillado rapidly adapting to new circumstances as it also has to compete with imported wines with different characteristics. In the last few years the wine industry has followed an interesting course towards consolidation and market positioning. The biggest firms have recognised brands, and although they do not sell a large volume they use all distribution channels, small firms clearly specialising on events local markets. This shows that a Mediterranean developing country can have a relatively new competitive industry that can promote sales on the domestic market as well as having a presence on large international markets. The industry could well expand given the increasing numbers of tourists but also with regard to recent consumer trends, which show that they prefer to drink wine instead of typical spirits with high alcohol content. The price also plays an important role in accelerating wine consumption. Cask Written? However, in terms of table wine, the wine/beer price ratio is much higher in Turkey than in France, Spain and Italy. Of Unfortunate? Furthermore, since 2003, that ratio has developed to the advantage of beer due to changes in was the cask of amontillado written, policy concerning excise duties, (specific) tax and sociology theroies special consumption taxes (advalorem tax). Olive and olive oil production has increased rapidly in Turkey in the last decade. In 2010 there were 111.4 million fruit-bearing olive trees and when was the cask of amontillado 45.8 million non-fruit-bearing olive trees.

The area under olive trees amounted to 826,000 hectares in 2010 (TURKSTAT, 2011d). Taking the “direct payment support data” of the Farm Registry System (FRS) of Ministry of Food, Agriculture and Livestock as a basis, approximately 200,000 olive growers with an average orchard size of 2.1 hectares obtained direct payment support in the 2007-2008 marketing year (Ministry of series events leeches Industry and Commerce, 2010). According to was the cask the direct payment support data, the land under olive orchards amounted to 420,500 hectares, with a total of 657,000 parcels. Unconscious Movie? We can conclude from this data that the average parcel for a grower was composed of was the 3.3 pieces, which can be considered very fragmented in movie, addition to being small and to the lack of any reasonable possibility to produce oil independently or to enhance producers’ organisations by forming cooperatives or adopting other forms of collaboration. The annual olive output was about 1.4 million tonnes, on average, during the 2008-2010 period (TURKSTAT, 2011d). Olives used for olive oil production accounted for around 68% of output in was the written, the same period. From 2000-2001 to 2009-2010, the annual average olive oil output was around 123,000 tonnes. Unconscious? In the period from was the cask, 2005 to 2009, olive oil exports amounted to 47,200 tonnes, but the figures varied widely from one year to another. Export value was 162.6 million USD on average during the same period.

The main destinations of olive oil exports were the US, Italy, Canada, Japan and Saudi Arabia with a mixture of distant and nearby markets (Ministry of Industry and Commerce, 2010). The significance of the US market must be underlined, since it imported 26% of Turkey’s total olive exports in 2009, followed by Italy with 18%. Series Events? Annual olive oil consumption on the domestic market amounted to 93,000 tonnes on average over the last three marketing years, from 2007-2008 to 2009-2010. Although total consumption has increased in absolute terms, per capita consumption is still very low compared to major olive-oil-producing Mediterranean countries such as Italy, Spain, Greece and Tunisia. The current consumption level and recent trends show signs that per written, capita consumption will continue to increase in the future as a result of income growth and unconscious consumer health awareness. According to when cask of amontillado recent data, there were 252 olive oil processing enterprises registered with the Ministry of Food, Agriculture and Present and Potential Essay Livestock in 2008. The Ministry issued a total of 1,014 olive oil production permits the same year (Ministry of cask of amontillado written Industry and Commerce, 2010). Although there are many processors in movie, the industry, a few firms are dominant players in the packaged olive oil market. The majority of was the of amontillado written processors are small and operate on local or regional markets.

Only 15 of them had 20 or more employees in 2009, for example, producing approximately 24,000 tonnes of olive oil that year (TURKSTAT, 2011d). Ana G?da is the major player in the sector with well-known brands such as Komili , K?rlang?c and Madra . Sociology Theroies? Ana G?da has a 35% share in the domestic olive oil market and its Komili brand has a share of 28%. Apart from cooperatives, other major players in the market are Kristal, Ekiz, Verde, Keskino?lu and the new entrant Yudum. The Komili, Kristal, Tari? (cooperative union), Ekiz and Verde market shares were 28%, 19%, 17%, 16% and 11% respectively in 2009, covering practically the entire market (Ekiz, 2010). When Was The Of Amontillado? The names of the leading firms working in the packaged olive market are shown in Table 2. Tari? and Marmarabirlik are the Migrations Century, only two agricultural unions of cooperatives (unions) in the first eight undertakings: Tari? consists of 33 cooperatives gathering approximately 28,000s olive growers in the Aegean region. This organisation accounts for 17% of the domestic market and 20% of exports in 2010. It can be regarded as a main actor in the export market, and it uses its commercial brand ( Ta-ze ) on its consumer packaged goods. Ta-Ze was established in 2001 by when was the of amontillado written the Union of Tari? Olive and Olive Oil Co-operatives.

Its products include olive oil, olives, gourmet products, olive oil soaps and personal care products. The company started as an intermediary for theroies, olive oil from local producers, operating through a wide network of dealers and chain stores. It sells abroad at stores in was the, Chicago, Toronto and Singapore as well as in many food retailer departments in various cities in the world. Tari? products are produced and packed in Turkey, and its plants have been covered by of natural the International Olive Oil Council’s quality control programme since 2002. Tari? olive oil is when also unique in Turkey as it is the only Turkish brand that is accredited by unconscious movie the international authority (Tari?, 2011). Marmarabirlik is an union of agricultural sales cooperatives, which was established in 1954 by the olive growers in the Marmara region. Currently, the union consists of 8 member cooperatives with a total membership of when cask of amontillado 29,653. The union purchases and processes approximately 40%-45% of the edible black olives grown in the region and sells its products throughout the Open Mindedness: Present Future, country, with 78 intermediaries in 58 cities.

It signs contracts with retailers located in Germany, Denmark, Switzerland and Bulgaria to sell on the European market as well as in Canada and Australia. Marmarabirlik establishments have a total area of 403,000 square metres. It is a large industrial establishment, which provides added value with a olive-packing capacity of approximately 150 tonnes/day and an olive oil production and bottling capacity of 220 tonnes/day in its modern plants (Marmarabirlik, 2011). There are also local brands of small-scale producers located in olive-growing regions. In the Ayval?k region, for instance, there are 26 firms (including K?rlang?c) and 18 of them (including Yudum) were using Ayval?k GIs (PDO) in 2010 (Ayval?k Chamber of Commerce, 2011). When Was The? These local firms either sell through their own shops (boutiques) located in Century, Ayval?k or through the Internet or use both systems. Some companies supply chain stores and sell their products under private (distributor) labels. There are some small-scale ones that process olives from their own orchards. Small and medium-sized processors use distribution channels to market their products either to local boutique shops and/or on the Internet. Organic production and was the of amontillado written processing methods based on local tradition have also been emerging as a main marketing instrument in addition to price competition. Although this industry already has a high olive output, given the number of non-fruit-bearing olive trees and the low per Open Mindedness: The Past,, capita consumption rate it still has great olive oil potential.

As is typical of other Mediterranean countries, the average orchard acreage is too small to was the cask written produce olive oil independently, so cooperative arrangements or vertical integrations should be established to gain efficiency. Olive oil producers try to reach the national market through many different distribution channels, and African Up to the 19th Century with their competitive quality products they have been able to enter the markets of was the written various European countries and in many other parts of the world, particularly in examples of natural monopoly, the United States. However, output varies considerably from when cask written, one year to the next, and producers may be unable to adams provide homogeneous and regular quality. Very few firms are large, but the biggest brands have a very large market share. When Of Amontillado Written? The cooperative movement, with Tari ? and Marmarabirlik, is sociology significant and has sufficient capacity to have a good share in the domestic market and presence in cask, other countries. Consequently, this industry can be considered a promising segment of the Turkish agrofood sector as a whole and proof that great efforts have been made to transform its structure and to provide attractive products on the market. Turkey is a major citrus producer in the Mediterranean Basin, after Spain and Italy. Open Mindedness: And Potential? Turkish citrus output is when was the of amontillado about one-third of the total EU citrus output (an average of sociology theroies 10.9 million tonnes in the 2005-2009 period), which amounts to around 60% of the Spanish output and is similar to the Italian one (FAOSTAT, 2011). When Was The Cask Of Amontillado? All kinds of citrus production have been increasing in Turkey over examples of natural monopoly, the last two decades. Citrus production has increased from around 1.45 million tonnes in the late 1980s to 3.6 million tonnes in 2010.

It is the first major producer of lemons and grapefruit and the third major producer of oranges and was the easy peelers (mandarin oranges, tangerines, etc.), after Spain and Italy. Of Unfortunate Events Leeches? Oranges, mandarins, lemons and when was the of amontillado grapefruit accounted for 48%, 24%, 22% and 6% of the 2009-2010 average citrus output respectively. Non-fruit-bearing citrus plant inventory data accounted for unconscious movie, approximately 17% of the total fruit-bearing citrus inventory in 2010. These inventory data indicate that citrus production will continue to increase in the near future following the growth rate achieved in recent years (TURKSTAT, 2011d). Orange output has been increasing in was the of amontillado written, Turkey for decades, from around 680 tonnes in of unfortunate events leeches, the early 1980s to 1.7 million tonnes in 2010.

The growth in output has been similar and ever higher for other citrus. Historically, Turkey has been a net citrus exporter and oranges constitute a major part of its imports. Its citrus imports have been increasing since the mid-1990s. On average, the was the of amontillado written, country imported 44,000 tonnes of oranges, 8,100 tonnes of citrus fruit juices and 13,400 tonnes of other fresh citrus in the 2004-2008 period. Movie? During the same period, Turkey exported 182,000 tonnes of oranges per annum, achieving its highest ever export figure in 2009 with 266,000 tonnes (AKIB, 2011). While the was the cask of amontillado, annual average citrus exports amounted to examples of natural slightly over 300,000 tonnes in the 1989-1993 period, the figure was 1,219,000 tonnes in 2010. The breakdown of citrus exports in 2010 shows 424,000 t lemons, 419,000 t mandarins, 221,000 t oranges and written 155,000 t grapefruit, amounting to 35%, 34%, 18% and 13% of unconscious total citrus exports. The bulk of these citrus exports was sent to the Russian Federation (32 %), Ukraine (14%), Iraq (14%), Saudi Arabia (7%) and Romania (7%) in 2010. The Russian Federation and Ukraine together accounted for approximately 45% of the when was the cask of amontillado written, oranges, 37% of the examples monopoly, lemons, 37% of the mandarins and 57% of the grapefruit exported.

Iraq accounted for 27% and when was the 17% of the oranges and mandarins. And in of natural monopoly, the period from 2008 to when cask 2010 the EU-27 accounted for an average of 50% of examples monopoly grapefruit, 30% of lemon, 16% of mandarin and 9% of orange exports. Per capita domestic use of citrus, except for lemons and grapefruit, has considerably increased, since growth in exports has been lower than growth in production. Orange consumption increased from 849,000 tonnes in 2000-2001 to 1,351,000 tonnes in the 2009-2010 marketing year (TURKSTAT, 2011e). During the same period, the consumption of mandarins increased from 363,000 tonnes to 471,000 tonnes. Integration of the citrus supply chain is weak because there are numerous small producers, which are not organised in cooperatives or producer organisations. The actors in the midstream sector of the chain thus play an important role. There are several exporters who either export products from their own orchards, usually with GlobalGAP certification. The majority of exporters use intermediaries to was the assemble their products. Exporting firms carry their export citrus to their own packing houses and they send other types of products either to wholesale markets or to the processing industry.

No data are available on African Up to Century Essay storage and the capacities of the was the written, packing houses, but the author has observed that exporters in citrus-producing regions have been investing in new packaging houses or have been modernising existing infrastructures, and most of them have expanded their capacities over the last decade. In 2007, a new initiative to promote citrus exports in foreign countries was set up (called Citrus Promotion Group – CPG). This initiative focuses on Turkish citrus promotion and other market development activities with funds coming from exports. Events? So far, the CPG has launched promotional activities involving citrus advertising in the Russian Federation and Ukraine and is planning similar promotional activities in the Middle East and Central European countries. In the downstream part of the supply chain, since 2005, 9 producer organisations with 1,027 members (called “Producers’ Union” in Turkey) have been acting together taking advantage of the Producers’ Union Act-5200 (Ministry of Food, Agriculture and Livestock, 2011), but their role in the supply chain is very weak. The cooperatives have not been particularly successful in the citrus sector.

There has been a considerable government effort to support citrus exports through a marketing board in the past. Marketing cooperatives such as Narkobirlik (Citrus Producers Cooperatives Union) were established and storage-packaging infrastructures were supported by the government in when cask of amontillado written, the 1970s. Recently, Antbirlik (former cotton agricultural sales cooperatives union in Antalya) has been involved in events, the citrus sector since cotton production has been virtually disappearing and replaced with fruit orchards, with special emphasis on oranges. In recent years, this cooperative invested in a packaging house with cold storage and started to play a role in the Antalya regional citrus market. The small size of cask of amontillado farms, limited product diversification and quality/safety standards have been major issues on the supply side. Migrations Up To The 19th? However, based on the 2002-2006 annual average, approximately 80% of the orange quantity exported was composed of Washington Navel varieties, and 90% of the oranges were exported between November and March. Similarly, Enterdonat and was the cask of amontillado written Lemas varieties accounted for 98% of Open Present and Potential Essay lemon exports and 96% of the lemons were exported between September and March. Satsuma, Freumont, Minola and Nova varieties accounted for 46%, 20%, 13% and 7% of when cask of amontillado total mandarin exports, respectively, in the same period. Approximately 90% of the African Up to the 19th, Satsuma exports were shipped between November and December and 90% of when was the cask of amontillado other mandarin varieties were exported between December and February.

The Star Buy variety accounted for 77% of grapefruit exports in 2008 and 90% of those exports were shipped from October to March (Koc et al. , 2009). Furthermore, 40% and 60% of subsidized agricultural credit has been used for the GlobalGAP production certification or organic agriculture, in recent years (Koc et al. , 2009). At the midstream level, there are currently 34 large companies processing fruit juice from citrus, but few of them are located in citrus-growing regions. Although juice consumption is very low, its growth rate has been remarkable in the last few years. However, the total volume of fruit used for fruit juice has increased from movie, 433,000 tonnes in 2000 to 771,000 tonnes in 2008. The amount of oranges processed into juice has increased by approximately 300% – from 23,000 tonnes in was the written, 2000 to 64,000 tonnes in 2008 (Meyed, 2011). Total fruit juice and fruit juice/fruit-flavoured product consumption amounted to 776,000 tonnes in 2008, which was 164% more than in 2000. Fruit nectars constitute 66% of consumption, fruit juice 7%, and the remainder consists of of unfortunate leeches fruit-flavoured drinks (Meyed, 2011). The latest figures indicate that per capita annual fruit juice consumption is around 0.8 litres.

Important investments have been undertaken in the fruit juice processing sector during the last five years in when was the written, conjunction with economic and of unfortunate leeches export growth. Recently, Cutrale from Brazil (world giant in citrus juice), Etap Tar?m (a well-known fruit juice manufacturer) and Anadolu Group (major player in the beverage sector in was the of amontillado, Turkey) have established a joint venture under the name of African Century Essay Anadolu Etap and will expand fruit juice capacity including citrus (Anadoluetap, 2011). Other companies that have recently invested in expanding the production capacity of the fruit juice sector using the latest technology, equipment and cask of amontillado written appliances. The citrus industry in Turkey can be regarded as a good example for Mediterranean countries which are trying to meet their own growing domestic demand as well as operating on international markets. Mindedness: Essay? Reaching the national market means diversifying production, taking opportunities in a variety of distribution channels and shifting slightly from when was the of amontillado written, fresh produce to fruit juices.

Since a great deal of this development is concerned with storing, transporting and distributing products, they have to develop all of these industrial capacities in order to be successful. One of the greatest difficulties is to find new markets, but Turkey has been able to capitalise on the economic growth of the the 19th Century, Russian Federation as well as other neighbouring countries (specially East European countries). This does not mean that the Western European countries have been abandoned, but they present a more saturated market with fewer opportunities. When Cask Written? This is why most promotional efforts have been dedicated to new emerging economies as well as to new products and advanced certification. African Up To Century Essay? Given the per capita citrus and orange juice consumption in developed Mediterranean countries and the recent consumption trend from concentrated juice to fresh juice, the processing industry in Turkey will be using an increasing quantity of citrus, and when was the cask of amontillado juice imports will also increase. Turkey has great potential for producing citrus fruits either for the fresh market or for juice production. Far-reaching structural changes can come about movie, if all opportunities are used. When Cask Written? The private and the public sectors must act together if Turkey is to be a main player in the Mediterranean area. Turkey is undergoing dynamic transition and could serve as a reference for many other countries in the Mediterranean basin. Since the abigail adams, mid 1990s, its agro-food supply chains, including the agro-food industries, have been developing tremendously, and rapid globalisation, consolidation and was the cask modernisation have also been observed, particularly in the midstream and downstream segments of the value chain.

Although domestic production has increased considerably in many agro-food sectors including wine and citrus, Turkey has started to import food products and of unfortunate events will be a major market for many of the items produced in Mediterranean countries including citrus, wine and even olive oil if the country’s recent economic growth continues. At the same time, this country has also been increasing its exports, especially to neighbouring countries. It is a good example for other Mediterranean countries. The strategies of Turkish agro-food firms vary according to food product or food product category. For example, firms in the wine and olive oil industries have focused on vertical integration, product differentiation (place of origin and intrinsic attributes) and distribution – alternative marketing channels (boutiques, e-commerce and when written export market diversification). Although collective action is very weak at the upstream level of the monopoly, citrus industry, activities to promote exports including the government inspection and coordination measures have played a significant role in the export field. As a result, there has been a considerable increase in Turkish citrus exports to the Balkan States and to Eastern and Central European countries such as the was the cask, Russian Federation, Ukraine and theroies Romania since the mid 1990s.

Recently, quality and safety have become important dimensions of food production, and citrus firms are gradually adopting such production systems. The scale of production systems, the fact that their adaptation to was the of amontillado written new standards such as GlobalGAP and Mindedness: and Potential Essay organic agriculture in the fresh produce sector is very slow, and the weakness of collective action are major issues that need to be addressed. Despite these problems, the geographic situation of the country (proximity to export markets) and the diversity of its products are assets that enable agro-food firms to sustain export operations and aggressively increase their export output. Furthermore, the weak foreign competition due to was the of amontillado border measures and sociology quality policy on the domestic market concerning fruit and vegetables also allows agro-food firms to dedicate the bulk of their efforts to the domestic market potential. There are also other examples including apple, cherry and cask written tomato productions, where firms are integrated vertically from the production stage through to Up to Essay export, but they account for only small percentages of the total output of Mediterranean types of products. It can be said that further economic growth in Mediterranean countries will also create significant trade opportunities amongst the various countries for either fresh or processed agro-food products. Although the trend on both the domestic and the foreign market is cask written towards greater consumption of Open The Past, Present Future processed agro-food products, the agro-food industries are developing sophisticated systems to when cask control post-harvest operations, storage, transport and series of unfortunate distribution facilities, which are important segments of the agro-food supply chains as a whole. Characteristics of some of the most important food and beverage firms in when cask written, Turkey (2009) utilise des cookies a des fins de statistiques. Ces donnees anonymes nous permettent ainsi de vous offrir une experience de navigation optimale.

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1998 dbq essay Question : With respect to the federal Constitution, the Jeffersonian Republicans are usually characterized as strict constructionists who were opposed to the broad constructionism of the Federalists. To what extent was this characterization of the two parties accurate during the presidencies of Jefferson and Madison? In writing your answer, use the documents and your knowledge of the period 1801-1817. I believe [we] shall obtain. . .a majority in the legislature of the United States, attached to the preservation of the was the cask of amontillado written, federal Constitution, according to its obvious principles and those on unconscious movie, which it was known to be received; attached equally to the preservation to the states of those rights unquestionably remaining with them; . . .in short, a majority firm in all those principles which we have espoused, and the Federalists have opposed uniformly. . Cask. . Abigail Adams Importance. . It [our country] can never be harmonious and solid while so respectable a portion of its citizens support principles which go directly to a change of the federal Constitution, to when was the cask sink the state governments, consolidate them into one, and to monarchise that. Our country is too large to have all its affairs directed by a single government. . The 19th Century. . . The true theory of our Constitution is surely the wisest and best that the states are independent as to everything within themselves, and united as to everything respecting foreign nations. I consider the government of the United States as interdicted by was the cask written, the Constitution from intermeddling with religious institutions, their doctrines, discipline, or exercises. . . . Certainly no power to prescribe any religious exercise, or to Essay assume authority in religious discipline, has been delegated to the general [federal] government. When. It must then rest with the states, as far as it can be in any human authority. . . . I am aware that the practice of my predecessors [prescribing a day of fasting and prayer] may be quoted. . . . Be this as it may, everyone must act according to the dictates of his own reason, and mine tells me that civil powers alone have been given to the President of the U.S. and no authority to direct the religious exercises of his constituents. The [Madison] administration asserts the right to fill the ranks of the regular army by compulsion. . . . Where is it written in the Constitution, in what article or section is it contained, that you may take children from their parents, and parents from their children, and compel them to fight the battles of any war in which the folly or the wickedness of the government may engage it? . . . Who will show me any constitutional injunction which makes it the duty of the American people to surrender everything valuable in life, and abigail adams importance even life itself, . . . whenever the purposes of an when was the written, ambitious and mischievous government may require it?. . . If the of unfortunate events leeches, secretary of war has proved the right of Congress to was the cask of amontillado written enact a law enforcing a draft of men out of the militia into movie, the regular army, he will at when was the cask of amontillado any time be able to prove quite as clearly that Congress has power to create a dictator.

Resolved , That the following amendments of the constitution of the United States be recommended to the states represented as foresaid, to be proposed by them for adoption by the state legislatures, and in such cases as may be deemed expedient by a convention chosen by the people of each state. . . . Second. No new state shall be admitted into the Union by Congress, in virtue of the power granted by the constitution, without the concurrence of two thirds of both houses. Third . Congress shall not have the power to lay any embargo on Migrations Up to, the ships or vessels of the citizens of the United States, . Was The. . . for more than sixty days. Fourth . Theroies. Congress shall not have power, without concurrence of two thirds of both houses, to interdict the commercial intercourse between the United States and any foreign nation, or the dependencies thereof. [W]e have another proof that the present government have renounced the true republican principles of Jefferson's administration on which they raised themselves to power, and that they have taken up, in their stead, those of John Adams . . . . [T]heir principle now is when was the cask written, old Federalism, vamped up into something bearing the superficial appearance of republicanism . . . . Sir, I am convinced that it would be impolitic, as well as unjust, to adams aggravate the burdens of the people for when was the written the purpose of favoring the manufacturers; for this government created and gave power to Congress to regulate commerce and equalize duties [tariffs] on the whole of the United States, and not to lay a duty [tariff] but with a steady eye to revenue . . . . Some men look at constitutions with sanctimonious reverence, and abigail deem them like the arc of the covenant, too sacred to be touched. They ascribe to the men of the preceding age a wisdom more than human, and suppose what they did to be beyond amendment. . . . I am certainly not an advocate for frequent and untried changes in laws and constitutions. . . . But I know also, that laws and was the cask of amontillado institutions must go hand in unconscious, hand with the progress of the human mind.

As that becomes more developed, more enlightened, as new discoveries are made, new truths disclosed, and manners and opinions change with the change of circumstances, institutions must advance also and keep pace with the times. [I have] considered the bill this day presented to me entitled 'An act to set apart and pledge certain funds for internal improvements,' and which sets apart and when pledges funds. . . for constructing roads and examples canals, and was the written improving the sociology theroies, navigation of water courses. . . . The power to when of amontillado regulate commerce among the adams, several states cannot include a power to construct roads and canals. . . . I am not unaware of the great importance of roads and canals and the improved navigation of water courses, and that a power in the national legislature to provide for them might be exercised with signal advantage to the general prosperity. But seeing that such a power is not expressly given by the Consti-tution, and believing that it can not be deduced from when was the cask of amontillado written any part of it without an inadmissible latitude of construction and a reliance on insufficient precedents; believing also that the permanent success of the Constitution depends on a definite partition of powers between the general [federal] and the state governments. . Open The Past, Essay. . I have no option but to withhold my signature from was the cask of amontillado written it . . .

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Science, Ethics and when of amontillado, Intellectual Property Law: How Orphan Black Got It Completely Wrong. Written by: Jocelyn Bosse. Advisory: This article discusses major plot points from Season One of Orphan Black . 3 Myth One: “Patents are Forever” 4 Myth Two: “Anything can be Patented” 5 Myth Three: “Patents are Secret” 6 Patents and National Security.

7 Ownership of Humans. 8 Legality of Cloning. Many ethical and legal issues which arise from events leeches, recent technological and scientific advances are explored in the cult television show, Orphan Black . [1] The protagonist, Sarah Manning, discovers that she is one of an was the cask, unknown number of illegal clones, and in her quest for answers, grapples with questions of identity and body autonomy. The issues are brought to Migrations Century, a head in the season one finale, in which evolutionary developmental biologist (and one of the when was the of amontillado clones), Cosima Niehaus, deciphers a synthetic DNA sequence in her genome to unconscious, reveal a message: THIS ORGANISM AND DERIVATIVE GENETIC MATERIAL IS RESTRICTED INTELLECTUAL PROPERTY. [2] Cosima informs the other clones: “The synthetic sequence I told you about? It’s a patent… We’re property… Everything we are, everything we become: it belongs to [the Dyad Institute].” Despite being an excellent scientist, Cosima’s remarks demonstrate serious ignorance of current patent laws. Indeed, her interpretation of the message reflects many of the myths about intellectual property laws which are prevalent in real life, including that (a) patents are forever; (b) anything may be patented; and that, (c) patents are secret. This article will debunk the intellectual property myths which appear in the Orphan Black finale. Pursuant to some remarks by of amontillado written, Cosima’s lab partner in season two, the article will conclude with a discussion about the examples of natural prevalent use of of amontillado government secrecy orders over patents for the protection of national security, and some final notes about physical property rights and the legality of human cloning. Intellectual property – like all law – varies between countries. [3] Though filmed in Canada, the creators of Orphan Black have indicated that the show takes place in “Generica” – a hybrid of Canada and monopoly, the United States of America. [4] However, the question of jurisdiction is further complicated by the existence of was the cask of amontillado written clones across the globe, including England, Germany, Ukraine, Italy, Finland, Austria, France, and probably other nations.

Ever since the establishment of the World Intellectual Property Organization (WIPO) in 1967, [5] there has been considerable harmonisation of patents laws across the globe. Despite the ambiguity of the show’s jurisdiction, we can still make overall statements about the legal position of the clones in importance, Orphan Black by reference to was the cask of amontillado written, international law and the patent laws of importance relevant countries (especially the USA, Canada, the EU, Australia, and New Zealand). 3 Myth One: “Patents are Forever” Unlike diamonds, patents rights do not extend in perpetuity. Instead, patents give a temporary monopoly to the inventor, during which time they may recoup their research and development costs. Upon expiration of the patent, the invention enters the when cask of amontillado written public domain. [6] The first patents under the Statute of Monopolies 1624 (UK) were granted for fourteen years, but since the signing of the WTO Agreement on Trade-Related Aspects of Intellectual Property Rights 1994 (‘TRIPS’), patents have a non-renewable term of twenty years. [7] While term extensions are available under rare circumstances (e.g. delay in examples of natural, the application process in was the of amontillado, Canada, or the series events five-year pharmaceutical extensions in Australia), none of those exceptions would apply to cask written, human clones.

In Canada, the abigail adams importance 20-year term was introduced in when of amontillado, October 1989; [8] however, the Orphan Black clones were born in 1984, [9] so any patents would have been subject to importance, the previous rule that patents expired after 17 years. Given that the main Orphan Black clones are currently about 32 years old, we can safely assume that any purported patents on their genetic information would have expired more than a decade earlier. The genomic sequence tag which Cosima discovered was meaningless: any patented information would be in the public domain. 4 Myth Two: “Anything can be Patented” Under s 6 of the Statute of Monopolies 1624 (UK), patents must not be “contrary to the law, nor mischievous to the state… or generally inconvenient.” As for was the of amontillado modern patent laws, Article 27 of the TRIPS Agreement allows countries to exclude patentable subject matter in order to protect “ ordre public ” and morality; this includes, for example, protection of human, animal or plant life or health, and the environment. Countries are also allowed to of natural monopoly, exclude plants or animals (including humans) from when was the of amontillado written, patentability, and several nations have done just that. Of Unfortunate Events! The TRIPS terminology was borrowed from cask, borrowed from Open The Past, Present and Potential, Article 53(a) of the European Patent Convention (‘EPC’), and the European Board of Appeals defined the concept of ordre public as covering the when was the written protection of public security and integrity of individuals as part of society. [10] The EU Directive on Biotechnological Inventions [11] clearly prohibits patents on human clones: 1. The human body , at the various stages of its formation and development, and the simple discovery of one of its elements, including the sequence or partial sequence of a gene, cannot constitute patentable inventions… 1. Inventions shall be considered unpatentable where their commercial exploitation would be contrary to adams importance, ordre public or morality ; however, exploitation shall not be deemed to cask written, be so contrary merely because it is prohibited by of unfortunate events leeches, law or regulation. 2. On the basis of paragraph 1, the following, in when cask written, particular, shall be considered unpatentable: (a) processes for cloning human beings ; (b) processes for importance modifying the germ line genetic identity of human beings; (c) uses of human embryos for industrial or commercial purposes; … The Canadian Supreme Court has held that higher life forms (defined as multicellular organisms, including plants, mice, and when cask of amontillado, humans) are not patentable subject matter. Mindedness: The Past, And Potential Essay! [12] Meanwhile, Australian legislation bans the patenting of human life in s 18(2) of the Patents Act 1990 (Cth): “Human beings, and the biological processes for their generation, are not patentable inventions.” The Deputy Commissioner of Patents has held that s18(2) extends to was the cask of amontillado, any entity which might reasonably claim the status of a human being, so the the 19th Century genetically modified clones would still fall within that exception. [13] Likewise, human clones are excluded under s 15 of the cask New Zealand Patents Act 2013 for unconscious movie reasons of when was the ordre public and morality. [14] The position is less concrete in the United States.

The US Patent and Trademark Office has granted a patent in 2001 for a method for producing embryos from unfertilised eggs, to series, create cloned livestock. [15] Despite concerns that the was the cask of amontillado patent would extend in to human cloning, the USPTO maintained a policy of examples monopoly refusing patents for human-related cloning on the grounds of a purported violation of the 13th amendment to the US Constitution, which prohibits slavery. When Was The Written! [16] Although the sociology 13th amendment is when was the cask of amontillado written no longer invoked, patents related to Open Mindedness: The Past, and Potential, human cloning are still not granted by of amontillado, the USPTO. As such, the examples of natural Orphan Black clones would definitely not be subject to patents in the EU, Australia, New Zealand or Canada. The current USPTO policy also means that the Dyad Institute could not have obtained patents over the clones in the United States. 5 Myth Three: “Patents are Secret” The original “letters patent” were developed in the 1600s as a trade-off between inventors and the Crown: the cask of amontillado written British monarch would grant a monopoly over the invention, while the details of the invention had to be fully disclosed for the benefit of society. Sociology! [17] Indeed, the word “patent” means open to observation, evident, obvious – a patent is the antithesis of a secret invention. The full text of patents can be easily found online, using a variety of means: · Google – many patents are available through Google. For example, the patent for entertaining a cat with a laser pointer (don’t panic, it lapsed back in cask of amontillado written, 2007) is publicly available here ( ). · International – the UN World Intellectual Property Organisation (WIPO) has a database of patent applications via Patentscope ( ). Note, however, that there is no such thing as an “international patent” – WIPO merely facilitates the application process across different countries. And Potential! Inventors must register their patents in every country in which they seek protection.

· Canada – the Canadian Intellectual Property Office (CIPO) allows you to freely search their patents database here ( ). · United States of America – the US Patent and Trademark Office has a searchable register here ( ). · New Zealand – the Intellectual Property Office of New Zealand has their database here ( · Europe – the European Patent Office has a patent register called Espacenet ( Consequently, if the Dyad Institute had patented the genetic information of the Orphan Black clones, it would be freely accessible on the patent register of each country where a patent was held, and when was the, probably available on movie, Google. Cosima could have avoided many hours of scientific research into when was the cask written, her own genome by examples monopoly, simply looking up the patent numbers on when cask of amontillado written, the USPTO or CIPO Registers. Only one category of patents can be kept secret: those which are subject to secrecy orders in the interests of national defence. 6 Patents and African the 19th Century Essay, National Security. In Season Two of Orphan Black , Cosima discusses the when was the cask of amontillado patents with her lab partner, who remarks that “The Dyad was just a contractor. It could be a secret military patent.” So, the question arises, what are ‘secret military patents’ and what do they mean for the Orphan Black clones?

The tension between certain private rights and public rights – in this case, intellectual property and human security – leads to a difficult balancing act in the patent laws. Although disclosure is one of the hallmark principles of patent law, publication of the details of movie certain inventions can pose risks to when written, national security, especially if they relate to movie, chemical, biological or nuclear weapons. [18] Governments are often concerned that the information disclosed in patent documents will end up in the “wrong hands,” particularly patents on weaponry and explosives which could be used by terrorist groups. There are also issues with potential misuse of dual-use technologies (those with current or potential military and civilian applications, e.g. ammonium nitrate, which could be used to produce propellant for ballistic missiles, but is mainly used in was the, the manufacture of fertilisers). [19] As such, some patents are temporarily made secret in series events leeches, order to was the cask written, protect national security. International Secrecy Orders. Article 73 of the TRIPS Agreement sets out “Security Exceptions” and provides that Member states need not furnish information where disclosure would be contrary to its essential security interests.

Likewise, Article 4 of the Patent Law Treaty 2000 (‘PLT’) stipulates that “nothing in this Treaty and the Regulations shall limit the freedom of a Contracting Party to Mindedness: The Past, Future, take any action it deems necessary for the preservation of essential security interests.” [20] Secrecy Orders in when cask of amontillado written, the USA. During World War I, the US Congress authorised the Patent and Trademark Office to temporarily classify certain defence-related patents in the interests on national security. [21] The legislation was extended during World War II to allow the of unfortunate leeches Commissioner of Patents to prevent publication or disclosure of a patent where it might be “detrimental to the public safety or defence,” as well as to was the of amontillado written, compensate the abigail adams applicant if the subject matter of the patent is used by written, the military. The laws were eventually replaced with the Invention Secrecy Act 1951 (US), which allows the American Federal Government to issue secrecy orders via the Commissioner of Patents, which are subject to an annual renewal process, except in times of war or national emergency. The use of these orders has been on the rise: [22] 5,445 secrecy orders were in effect in 2013, and 5,579 in monopoly, 2015. Was The Written! [23] For example, Juliet Marine Systems developed a stealth boat which was unexpectedly made subject to unconscious, a secrecy order in October 2009, thereby forbidding them from filing patents overseas or disclosing anything to potential investors until the was the cask order was lifted two years later. [24]

In Canada, the Minister of National Defence may take ownership of a patent for African the 19th Essay “any invention in instruments or munitions of war,” [25] and has the power to make the invention secret under s 20(5). The inventor(s) become(s) subject to s 4 of the Security of Information Act , and of amontillado written, are thereby banned from communication of any details of the invention without the authority of the Minister of National Defence. Under s 20(9) of the Patents Act, the information may be kept secret until the expiration of the patent, or until it is waived by events leeches, the Minister. The Australian Department of when cask Defence is empowered under s 152 of the Patents Act 1990 (Cth) to prohibit the publication of the African Migrations the 19th Century details of of amontillado written a patent application, at which point it must be handled by a patent examiner with the leeches requisite security clearance. [26] The prohibition order may remain in force until the expiration of the patent, unless it is revoked by the Department of was the cask of amontillado Defence. Similar provisions can be found in ss 132-134 of the series events New Zealand Patents Act 2013 . However, while Cosima’s lab partner raised a very interesting point about the potential use of secrecy orders over patents, the fact remains that human clones are not patentable (and if they were, the patents would have expired). There can be no secrecy order if there is no valid patent to begin with. As far as tangible property rights are concerned, the message in cask of amontillado, Cosima’s genome asserted proprietary rights over her body, and any derivative material. Since the abolition of sociology theroies slavery, there has been a strict legal separation of property rights and was the of amontillado, personhood. In fact, property rights over abigail adams importance human body parts have arguably been excluded from legal protection for two millennia: the Roman jurist, Ulpian, gave the maxim dominus membrorum suorum nemo videtur (“no one is the owner of their own limbs”), which has been interpreted in the English law to when was the cask written, mean that a living human body cannot be the object of property rights. [27] In words of Justice Edelman of the Federal Court of Australia: “Whatever meaning is given to ‘property’, it is independent of personhood. The antithesis of ‘property’ is personhood.

A living person can be the holder of a property right but he or she cannot be the object of it.” [28] The Romans would also consider the deceased clones to be res extra patrimonium and res extra commercium ; a corpse is generally inviolable and examples of natural monopoly, unsaleable. [29] In modern jurisprudence, the Supreme Court of when of amontillado written California has affirmed the examples of natural Roman principles: the Court in Moore v Regents of the University of California [30] rejected a property claim over Moore’s own body parts (his spleen, blood, skin, and sperm) which had been used without consent for commercial purposes. When Was The Cask Of Amontillado! Justice Panelli, in the plurality judgment, remarked: [31] “Neither the Migrations Court of Appeal's opinion, the cask of amontillado parties' briefs, nor our research discloses a case holding that a person retains a sufficient interest in excised cells to support a cause of action for conversion. We do not find this surprising, since the laws governing such things as human tissues, transplantable organs, blood, fetuses, pituitary glands, corneal tissue, and dead bodies deal with human biological materials as objects sui generis, regulating their disposition to achieve policy goals rather than abandoning them to the general law of personal property… The ramifications of recognizing and enforcing a property interest in The Past, and Potential, body tissues are not known, but are greatly feared for the effect on human dignity of a marketplace in human body parts, the impact on research and when of amontillado written, development of competitive bidding for such materials, and African the 19th, the exposure of researchers to potentially limitless and uncharted tort liability.” As such, the when cask of amontillado Orphan Black clones (alive and whole, or otherwise) could not be subject to a proprietary claim from the Dyad Institute. The law is concerned with two main types of cloning: (i) therapeutic cloning , which is the use of clonally propagated stem cells for the purposes of scientific research and medical treatment, and (ii) reproductive cloning , in movie, which a cloned embryo is implanted into when was the of amontillado written, a womb. [32] While therapeutical cloning is legal in many states, the Orphan Black clones were created by reproductive cloning, which is examples of natural generally illegal.

In March 2005, the United Nations General Assembly adopted the was the written Declaration on Human Cloning, which called on members to adopt all measures necessary to Open and Potential Essay, prohibit human cloning inasmuch as it is incompatible with human dignity and the protection of human life. [33] The Declaration also called upon members to prohibit the application of genetic engineering techniques that may be contrary to when of amontillado written, human dignity and to prevent the the 19th Century Essay exploitation of women in the application of life sciences. Of Amontillado! However, the Declaration has no binding authority over UN members, and would have no impact upon the legality of producing the unconscious Orphan Black clones. Article 3(d) of the Charter of Fundamental Rights of the European Union explicitly prohibits reproductive human cloning. France, Germany, Austria, Italy and Russia have completely banned human cloning, to name a few. In the United Kingdom, reproductive cloning is banned, [34] while therapeutic cloning has been tightly regulated by the Human Fertilisation and Embryology Authority since 1990. [35] The Dyad Institute could not have (legally) produced the Orphan Black clones in the United Kingdom, nor any other EU member states. Cask! Furthermore, the Council of Europe has specifically banned reproductive cloning in the Convention on Human Rights with Regard to Biomedicine 1997, which held to African Migrations, apply in European countries where no legislation has been passed to address the legality of human cloning. [36] Canada has a complete ban on human cloning, both therapeutic and reproductive, pursuant to was the cask, s 5(1)(a) of the Assisted Human Reproduction Act 2004 . As such, the Orphan Black clones could not have been created there. Reproductive cloning is also banned in Australia under the Prohibition of Human Cloning for Reproduction Act 2002 (Cth). Although the desire to improve scientific research and medical treatment meant that the ban on therapeutic cloning was lifted in 2006, [37] the reproductive cloning conducted by the Dyad Institute would still be illegal in Australia. [38] The picture is more complicated in the United States, where the Congress has repeatedly failed to theroies, enact legislation to address human cloning, and there are no Federal laws with respect to human cloning. [39] Public funding for human cloning and stem cell research was restricted in 2001 under the Bush Administration, [40] but that would not be a barrier for a wealthy private institute like Dyad. [41] While fifteen states ban reproductive cloning, [42] the cask of amontillado Dyad Institute could have produced the Orphan Black clones in other parts of the country. Unconscious! Nevertheless, the Dyad Institute would have no legal control over Sarah Manning, Cosima Niehaus, or the other clones.

It is a complete myth that patents can be obtained over humans, so the clone-sisters would, in fact, be autonomous individuals who are free from any legitimate claims to tangible or intellectual property rights. The mass-production of human clones by of amontillado, a malevolent corporation might still be pure science fiction, but the legal questions raised by Orphan Black are no less important to the real world. Up To Century Essay! Many countries – particularly the United States – are still struggling to pass legislation which adequately regulates therapeutic and reproductive cloning, which has significant consequences for medical research and cask of amontillado, assisted reproduction. Mindedness: The Past, Present! Furthermore, the use of government secrecy orders illustrates the difficult balancing act between the when cask of amontillado written protection of national security, and the promotion of private innovation. While the fictional clones in Orphan Black are (incorrectly) concerned by the Dyad Institute’s intellectual property rights over The Past, Future Essay their bodies, real people across the of amontillado globe stand to benefit, or suffer, from the enforcement of poorly-understood patent laws, and the legislative control of human cloning. [1] BBC America, Orphan Black (16 June 2016) The first season aired in March-June 2013. [2] Tim Surette, Orphan Black Season 1 Finale Review: Same, Same But Different (2 June 2013) The DNA tag was based on ASCII (American Standard Code for Information Interchange) coded basepairs. [3] Article 4 bis , Paris Convention for of unfortunate events the Protection of of amontillado Industrial Property 1883 . [4] Marsha Lederman, ‘How Canada is becoming the sci-fi nation’, The Globe and Mail (online), 13 April 2013

[5] Convention Establishing the World Intellectual Property Organization , signed at of natural, Stockholm on 14 July 1967. WIPO administers the Convention for was the of amontillado the Protection of Industrial Property 1883 , which deals with patents and related rights. [6] Lionel Bently and Brad Sherman, Intellectual Property Law (Oxford University Press, 3rd ed, 2009) 335. [7] Article 33: “The term of protection available shall not end before the expiration of a period of twenty years counted from the filing date.” See also: Patents Act 1990 (Cth) s 67. [8] Patent Act , RSC 1985, c P-4, s 44. [9] Orphan Black Wiki, Sarah Manning (21 June 2016)

[10] Robin Ramcharan, ‘ Intellectual Property and Security: A Preliminary Exploration’ (2005) 26(1) Contemporary Security Policy 126, 130. [11] Council Directive 98/44/EC on abigail importance, the Legal Protection of Biotechnological Inventions [1998] OJ L 213/13, art 5-6. [12] Harvard College v Canada (Commissioner of Patents) [2002] 4 SCR 45 [155]. [13] See Re Luminis Pty Ltd Fertilitescentrum AB (2004) 62 IPR 420. [14] Relevantly, the New Zealand legislation lists the cask of amontillado written following exceptions: (i) a process for monopoly cloning human beings, (ii) a process for modifying the germ line genetic identity of human beings, and (iii) the when of amontillado use of human embryos for industrial or commercial purposes. [15] US 6211429 B1 “Complete oocyte activation using an oocyte-modifying agent and a reducing agent” (Priority Date: 18 June 1997)

[16] Andrew Pollack, ‘Debate on monopoly, Human Cloning Turns to Patents’, The New York Times (online), 17 May 2002 [17] Mark J Davison, Ann L Monotti and Leanne Wiseman, Australian Intellectual Property Law (Cambridge University Press, 2nd ed, 2012) 409. [18] Robin Ramcharan, ‘ Intellectual Property and Security: A Preliminary Exploration’ (2005) 26(1) Contemporary Security Policy 126, 127. [20] The treaty entered into was the of amontillado, force in 2005, though Canada and Germany have not yet acceded. [21] Act of unconscious movie 6 October 1917, ch 95, § 42, 40 Stat 394. [22] G W Schultz, ‘Government Secrecy Orders on Patents have Stifled more than 5000 Inventions’ There is a heavy penalty upon when cask of amontillado those who breach a secrecy order: a fine of up to $10,000 or up to 2 years imprisonment. [23] Federation of American Scientists, Invention Secrecy Activity (as reported by the Patent Trademark Office) [24] Caroline Winter, ‘This Stealth Attack Boat May Be Too Innovative for the Pentagon’ (22 August 2014) Bloomberg Businessweek [25] Patent Act , RSC 1985, c P-4, s 20(1). [26] Bill McFarlane, ‘How to Keep a Secret: Prohibition Orders on Patents’ (25 August 2012)

[27] R v Bentham [2005] UKHL 18 [14] (Lord Rodger), citing D.9.2.13pr (Ulpian). Following the Australian High Court decision of Doodeward v Spence (1908) 6 CLR 406, the principle has seen modern adaptation in leeches, cases which concern the when of amontillado posthumous use of sperm samples for in vitro fertilization (IVF), which eroded the previous hostility of the English courts towards consideration of human biological material as “property”: Jonathan Yearworth Ors v North Bristol NHS Trust [2009] 2 All ER 986; for an American example, see Hecht v. Superior Court of Los Angeles County (1993) 20 Cal. Rptr. Adams Importance! 2d 275. [28] James Edelman, ‘Property Rights to when was the written, our Bodies and their Products’ (2015) 39(2) University of Western Australia Law Review 47, 53. [29] Henk AMJ Ten Have and of natural, Jos VM Welie (eds), Ownership of the cask of amontillado Human Body: Philosophical Considerations on theroies, the Use of the when cask written Human Body and its Parts in Healthcare (Kluwer Academic Publishers, 1998) 69.

[30] (1990) 51 Cal. 3d 120. [31] The opinion from Panelli J was joined by Lucas, Eagleson and Migrations Up to the 19th Century, Kennard JJ, Arabian J concurring. [32] See Australian Stem Cell Foundation, ‘Fact Sheet 4: Therapeutic Cloning’ (July 2010) [33] General Assembly Adopts United Nations Declaration on was the, Human Cloning by Vote of 84-34-37’ (8 March 2005)

[34] Human Reproductive Cloning Act 2001 (UK), which was repealed and superseded by the Human Fertilisation and Embryology Act 2008 (UK). Of Unfortunate Leeches! Section 3 of the 2008 Act forbids reproductive cloning. [35] Ruth Deech, ‘Regulation of therapeutic cloning in the UK’ (2002) 5(1) Reproductive BioMedicine Online 7, 9. The cloning regulations under the Human Fertilisation and Embryology Act 1990 (UK) were challenged in the UK High Court by the ProLife Alliance in when written, November 2001, which triggered the adams importance enactment of emergency legislation. When Cask Of Amontillado! See David Adam, ‘Loophole Legalizes Human Cloning’ (2001) 414 Nature News 381. [36] The Convention is relevant, for example, in series of unfortunate events, The Additional Protocol to the Convention for when was the written the Protection of Human Rights and Dignity of the Human Being with regard to the Application of Biology and Medicine, on the Prohibition of Cloning Human Beings was passed in 2001, and Article 1 prohibits “any intervention seeking to create a human being genetically identical to another human being alive or dead.” [37] Prohibition of movie Human Cloning for Reproduction and when was the of amontillado, the Regulation of Human Embryo Research Amendment Act 2006 (Cth). [38] Simon Grose, ‘Australia grants license for therapeutic cloning’ (2008) 14 Nature Medicine 1134. [39] Many bills have been introduced, e.g.

HR4808 - Stem Cell Research Advancement Act of of natural monopoly 2009, but never passed. Was The Cask Of Amontillado! Issues related to abortion have been a key barrier to the successful enactment of human cloning legislation over movie the years, while the strong lobbying efforts of the when was the biotechnology industry was partially behind the failure to enact laws in the late 1990s. The Food and unconscious, Drug Administration has claimed authority over reproductive cloning, but it seems unlikely that its purported regulatory jurisdiction would stand up to legal challenge. See [40] The 2001 statement was supplemented by Executive Order 13435 of of amontillado June 20, 2007.

[41] Stem cell research funding was restored in 2009 under the Obama Administration: President Barack Obama issued Executive Order 13505 “Removing Barriers to Responsible Scientific Research Involving Human Stem Cells” on 9 March 2009. The Order made no comment on human cloning. [42] Reproductive cloning is sociology theroies banned in Arkansas, California, Connecticut, Iowa, Indiana, Massachusetts, Maryland, Michigan, North Dakota, New Jersey, Rhode Island, South Dakota, Florida, Georgia, and Virginia.