Wednesday, December 4, 2019

Model Thesis On Globalization For Globalism -Myassignmenthelp.Com

Question: Discuss About The Model Thesis On Globalization For Globalism? Answer: Introducation The article helps in analyzing the different factors that has affected the culture. The two factors are immigration along with globalization. Globalization is defined as the system of complex connections among different countries. It happens both in cultural and economic level. It has been identified in the article that globalization has huge effect on working individuals who work for multinational companies. Globalization has profound effect on the culture in other countries (Hay and Marsh 2016). It has been seen that the individual cultures are easily threatened by the globalization factors. The advantages include broadening the minds of individuals and it helps in promoting education. It helps in improving the international relations among different nations (Rao 2015). On the other hand, there are different advantages of globalization that include there has been gap between the rich and poor in the entire competitive market. It has affected the entire global economy that has affec ted the environment. The globalization has affected the good working condition of the workers. Reflection From the article, I have understood that globalization and immigration has huge impact on the culture. I have analyzed that globalization takes place in both cultural and economic level in different countries. In the article, I have seen that the example of Starbucks has been provided wherein globalization not influences the culture by exporting goods and services, but it has effect on individuals working in the different multinational companies. I have analyzed that there are different benefits and disadvantages of globalization wherein it has profound effect of the different cultures of the different companies. I have understood that globalization has helped many organizations in hiring Indian employees with proper training and developmental programs. It has helped in broadening the mind of the individuals in different countries in an effectual manner. I have highlighted the disadvantages in the article that included that it has increased the gap between rich and poor. There have b een different cases wherein employees are complaining about the work pressure and depression. In the article, it has been shown that employees are depressed and they are quitting their jobs due to excessive pressure. References Hay, C. and Marsh, D. eds., 2016.Demystifying globalization. Springer. Rao, R.S., 2015. A University Model Thesis on Globalization for Globalism.International Journal of Emerging Trends in Science and Technology,2(04).

Thursday, November 28, 2019

Tips and Tricks on How to Focus on Homework

Being tired and annoyed after a long day in school or college is absolutely normal. In such a mood, its hard to motivate and force yourself to start working on your assignments for the next day. Many students cant cope with procrastination looking for the answer to the question â€Å"How to focus better?† and end up using study drugs which is not recommended. Fortunately, we have a few tips that will help you to stop procrastinating, increase your productivity and get to work. Keep reading our article to know more. Find a Comfortable Place Its easy to feel distracted and unfocused when your setting doesnt match the task that you have to complete. Thats why setting the right atmosphere is the first thing you should do when starting working on your assignments. Here are a few things that you need to take care of before you actually start doing your homework: Your working place has to be a desk (or a table) with a comfortable chair. Now, many of you would say â€Å"Whats wrong with doing your homework while lying in bed?† Actually, everything. When you sit or lay on the couch or bed, it relaxes you too much and makes you sleepy. A comfortable table and a chair will be the best option for sitting straight and keeping yourself toned. Open your window to get fresh air. When your brain lacks oxygen, it cant work correctly, so it makes you a slower thinker. Fresh air and deep breathing will help you to keep your mind sharp and avoid headaches. Bring some snacks to your working place. You will probably want to have a snack during this study session, so grab them beforehand. Otherwise, you will have to walk outside the room to grab something to eat, and it will negatively impact your concentration. Staying in the room where you are studying is the best tip on how to concentrate on study continuously for long hours. Find a place where the rest of your family or your mates wont bother you to study. The best option would be a separate room with a door closed. If you have someone at home, ask for privacy and silence. Try to avoid doing your homework in the living room, because it will be much harder to focus with a talk show on TV or chatting family members in the background. The atmosphere and the place you are studying at are very important for setting up the right mood for a cram session and keeping yourself focused. Eliminate Distractions This is the most important and the hardest step. When you need to focus on your assignments – which can be quite boring, lets face it – its hard to keep away from the temptation of using your phone, checking social media and watching TV shows. But you can do that, you just need to follow easy steps: Block your phone or give it to someone while you are learning. It is a simple rule for anyone who wants to succeed in studying – not using your cell phone. To make it easier for you, you can log out of your social media accounts, to turn off the Wi-Fi on your phone or to switch to the airplane mode. This way you wont receive messages, calls or annoying notifications and will be able to stay focused. If you know that you wont be able to keep yourself away from your phone, give it to a parent, a friend or use an app that blocks your screen for a preset time – Flipd, Offtime, etc. Avoid listening to music with lyrics. When you are trying to understand information that you are reading or to formulate a thought that you need to write down, the side noises can hinder. Especially when someone is talking or singing. It happens because your brain is trying to process the information it receives by hearing. If you need some background music, choose some tracks without lyrics. Classical music will do the best. Dont watch TV. It distracts you just like music. Avoid watching it; otherwise, your productivity will severely decrease. All of these tips are great for school and college students who get distracted easily. The less you interrupt your studying process, the more focused you will be while completing homework. Organize Your Time Time management is one of the most essential college skills. If you can productively organize the time you spend on doing your homework, you can change your studying routine and spend less time every day working on another assignment. What does it mean? Time management in studying means that you need to create an action plan first and then follow it without messing the time limits you established. For example, your plan for the evening might be: 3.00  PM – 4.00 PM Math assignment 4.00  PM – 4.30 PM Rest 4.30 PM – 5.30 PM Science assignment 5.30  PM – 6.00 PM Rest 6.00 PM – 7.00 PM Literature assignment 7.00  PM – 8.00 PM Dinner 8.00  PM – 9.00 PM Art assignment As you can see this plan implies an alteration of studying and small 30 minutes breaks to help your brain rest and get ready for the next assignment. You can have snacks, use your phone, listen to music or do some exercises during these breaks. Just give yourself some reward for the amount of work that you completed. You would also be surprised how easily you can manage your time in college. If you set up the schedule for studying at home, it will be easier for you to get to work faster. The mind gets used to certain actions that repeat from day to day. So, just like you are used to going to school in the morning, you will be used to getting to work when the homework time comes. Not everyone can establish such a schedule. But you surely ought to try it. Start with the most time-consuming and challenging assignments. As soon as you get to work, your concentration is much stronger than at the end of studying session. Dedicate the time when you are focused the most to the assignments that require more time and effort. Establish the priority of each assignment that you have to complete. Give the main priority to the assignments that are urgent or value more and start with these tasks. If all of your tasks are important and you don’t have enough time to finish all of them, consider turning to a professional service for help. Cross out finished assignments from the plan – you will see your progress and feel more satisfied with your productivity. Moreover, such a tactic helps boost your motivation to do homework. Dont try to be multitasking. When you try to complete a few assignments at the same time, your concentration gets worse due to the variety of information that your brain needs to process. Focus on one assignment at a time. After finishing it, you can have a break and then start a new assignment. As you can see, the time that you spend on your assignments is as important as the time you give yourself to relax between your study sessions. Such breaks not only help your brain to keep concentration for a long time but also provide you with an opportunity to avoid the temptation as you know that after completing another assignment you can enjoy the things you like – music, social networks, etc. We hope that you found our pieces of advice useful and will feel more focused the next time you have to start your homework assignment.

Sunday, November 24, 2019

Estimating lines and angles Essays

Estimating lines and angles Essays Estimating lines and angles Essay Estimating lines and angles Essay We were set a piece of coursework that involved asking people to guess the line and the angle size that were drawn on a piece of paper. We had to collect data, analyse it and then draw up a conclusion. The method- I drew a line on a blank piece of paper and on another blank sheet I drew an angle. I then asked 15 girls and 15 boys from y10 to estimate the line and angle. I didnt know the sizes at this point so that there was no way I could give people any clues. When I collected my data it was randomly stratified. This was because I asked any body in my year that I came across I didnt choose. But it was also stratified in that I made sure I asked 15 boys and 15 girls. This is the table I will use to collect all my results on: The hypotheses- I made three hypotheses and I will try to carry out two of them if I have time. Hypothesis 1: I think that more people will do better at guessing the angle because you can work out 90 degrees and then guess the last bit. Estimating a line is much harder as it is harder to imagine a centimetre or say 15 centimetres. Hypothesis 2: I think that girls will be better at estimating than boys estimate as girls are normally more careful then boys. They will probably take more time to estimate, so there estimate will be more accurate. Hypothesis 3: I think that older people will be better at estimating as they will be wiser and more familiar with estimating lines and angles. Method (continued): I gathered all my results then typed them out on the computer so it could work things out for me. Here are my results: sex age line est. true line diff. % error abs. angle est. true angle diff. % error Abs. f 15 9 8.5 0.5 5.9 5.9 105 122 17 -13.9 13.9 f 15 9 8.5 0.5 5.9 5.9 125 122 -3 2.5 2.5 f 15 10 8.5 1.5 17.6 17.6 120 122 2 -1.6 1.6 m 15 7 8.5 -2 -17.6 17.6 110 122 12 -9.8 9.8 m 15 8 8.5 -1 -5.9 5.9 140 122 -18 14.8 14.8 m 15 6 8.5 -3 -29.4 29.4 162 122 -40 32.8 32.8 m 15 6 8.5 -3 -29.4 29.4 110 122 12 -9.8 9.8 f 15 8 8.5 -1 -5.9 5.9 150 122 -28 23.0 23.0 m 15 7 8.5 -2 -17.6 17.6 160 122 -38 31.1 31.1 m 15 8 8.5 -1 -5.9 5.9 120 122 2 -1.6 1.6 m 15 10 8.5 1.5 17.6 17.6 145 122 -23 18.9 18.9 m 15 7 8.5 -2 -17.6 17.6 160 122 -38 31.1 31.1 f 15 10 8.5 1.5 17.6 17.6 167 122 -45 36.9 36.9 f 15 7 8.5 -2 -17.6 17.6 135 122 -13 10.7 10.7 f 15 7.5 8.5 -1 -11.8 11.8 150 122 -28 23.0 23.0 f 15 7 8.5 -2 -17.6 17.6 150 122 -28 23.0 23.0 m 15 8 8.5 -1 -5.9 5.9 130 122 -8 6.6 6.6 m 15 9 8.5 0.5 5.9 5.9 120 122 2 -1.6 1.6 f 15 9 8.5 0.5 5.9 5.9 115 122 7 -5.7 5.7 f 15 7 8.5 -2 -17.6 17.6 120 122 2 -1.6 1.6 f 15 10 8.5 1.5 17.6 17.6 120 122 2 -1.6 1.6 m 15 11 8.5 2.5 29.4 29.4 140 122 -18 14.8 14.8 m 15 17 8.5 8.5 100.0 100.0 93 122 29 -23.8 23.8 m 15 8.5 8.5 0 0.0 0.0 139 122 -17 13.9 13.9 m 15 6 8.5 -3 -29.4 29.4 145 122 -23 18.9 18.9 m 15 7 8.5 -2 -17.6 17.6 135 122 -13 10.7 10.7 m 15 7.5 8.5 -1 -11.8 11.8 120 122 2 -1.6 1.6 f 15 9 8.5 0.5 5.9 5.9 160 122 -38 31.1 31.1 f 15 12 8.5 3.5 41.2 41.2 125 122 -3 2.5 2.5 f 15 7 8.5 -2 -17.6 17.6 120 122 2 -1.6 1.6 I have included an absolute value of percentage column in my table so I could work out the percentage error correctly. If I just used the percentage error my results wouldnt be accurate. This is because if people guessed below then a minus sign was in the column. These minus signs would cancel out some of the positive numbers when I was working out the average. I then did two graphs for the percentage error of the line and the angle: I can see from these graphs that someone did actually estimate the angle correctly. This was a shock to me as it goes against my hypothesis that it is easier to estimate lines than angles. Many people were close to zero for both the line and the angle. But I didnt think these graphs were very useful as they had different scales so visually they werent very accurate. I worked out the range for both the line and the angle percentage error: Line: 129.4 Angle: 60.7 This supports my first hypothesis, but as it is clear from the graphs there were a few anomalies from both the line and the angle estimates. This could have made the range in accurate. I have done both the results on one graph as well so can see which ones were closer to zero with them both on the same scale: I supported my hypothesis further by calculating the average percentage error for the angle and the line. I did this by using the absolute value columns in my table, here are the results: Line: 18.2 Angle: 14.0 As you can see the average percentage error for the angle was lower than the average percentage error for the line. This does support my hypothesis further and proves people do find it easier to estimate angles than lines. I think the person who estimated the line correctly was just lucky rather than skilled because the line wasnt a whole number so it shouldnt have been easy to estimate. However, it was a simple decimal with it being 5 which is a sensible decimal to estimate. I dont think that the angle wasnt very easy to estimate either as I put it on a slant so that it would be harder to work out 90à ¯Ã‚ ¿Ã‚ ½

Thursday, November 21, 2019

MGMT455 U1 IP Theory X & Y Research Paper Example | Topics and Well Written Essays - 500 words

MGMT455 U1 IP Theory X & Y - Research Paper Example This theory tends to adopt the authoritarian style of management. Whereas, Theory Y assumes that individuals take responsibility and they do not need control and direction on each step, they are active, motivated and consider the work as the natural part of their lives, and are capable of achieving higher goals in their jobs. This theory is considered is the participative style of management. One style cannot be used in all situations. It totally depends on the circumstances and conditions of the environment and employees. The management can be authoritative in some cases and can also be practical in other cases while a mix of both the theories can result better. The practices of Theory Y can turn out with better results as this will develop confidence and courage among the employees to work in a relaxed and a comfortable environment. For-example, well and high structured call center operations can get a certain amount of benefits by allowing their employees to perform and respond to customers on their comfort and knowledge level. So, by adapting to Theory Y practices they can appreciate and encourage the overall knowledge sharing processes. The difference between Theory X and Theory Y management is quite noticeable. In my opinion, the management of Theory Y is much more effective and productive than Theory X, as the authoritarian management of Theory X is much adopted in most of the huge firms and organization and leaves less comfortable environment for the employees, whereas most of the organizations allow participative management of the employees which prefer self motivation and appreciate new ideas from the individuals. Considering Theory Y management, many of the organizations use decision making processes, in which each employee has the opportunity to share his thoughts and ideas. There are basically two major types of democratic decision making, including, persuasive democratic management and consultative

Wednesday, November 20, 2019

Medical Experiments on Incompetent Individuals in a Society Essay

Medical Experiments on Incompetent Individuals in a Society - Essay Example Many factors are important and need to be taken into consideration while a problem of this intensity is being discussed. The divisions in the society need to be taken into account. Racial differences and how intelligence in different races and societies are assessed is an important aspect of such a debate. One must also assess the question as to who possesses the right to assess the intelligence of people who are to be subjected to medical experiments. What constitutes intelligence also remains an important part of this debate that would decide the future of human society. Much of this debate can be argued to stem from the work of the great naturalist, Charles Darwin, who argued that in a world where the natural resources that is available to everybody is limited, the law of the ‘survival of the fittest’ would be the one that holds (Darwin). ... The fact that such reforms can be brought about or stalled only through the medium of legislation by the executives of nations makes the issue even more complicated. This is because the issue, like the legalization of abortion or animal rights, is an extremely sensitive issue and can create problems for political parties that usually take the decisions of the executive wing of the government of a nation state. Public perceptions are thus, an important part of this debate. An objective approach that brings people from various backgrounds together for negotiations would be the best way to seek a solution for this problem. This should be preceded by campaigns that seek to allay the fears of all sections of the society regarding this matter. This paper shall seek to look at the complexities of the issue at hand and examine the choices that are available to human society as a whole for the purpose of attaining a solution to this problem. The issue of whether people who are in states of co ma where they may not be able to inform others of their assent or dissent to be a part of a certain experiment conducted for the purpose of finding out the efficacy of a certain scientific or medical truth, is a complex one. What constitutes death for such people is a question that has not met with satisfactory answers from philosophers as of yet. People who have died may have, in their wills, decided to donate their bodies for the cause of medical research. The question of death, thus assumes importance in this matter. Also important is the assent of the person involved. In many cultures, the body of a person is considered to be important for the performance of the last

Sunday, November 17, 2019

Worst place to work(check attachment) Essay Example | Topics and Well Written Essays - 250 words

Worst place to work(check attachment) - Essay Example partment of Asian pearl Seaford restaurant to ensure that each and every worker provides solution to the customers since; it is not just how the restaurant serve the customers, but how a service is delivered to each and every customer (Murphy, 24-32). Asian Pearl Seaford Restaurant should know that when there is an increase to customer satisfaction, which comes as a result of creating an environment where teamwork is a top priority, this translates to exceed sales goals within a complete business cycle. Moreover, the leadership in the restaurant and its management especially the manager should understand that a right leader is a key to a great team and hence; he should be willing to help the employees where necessary through an essence of shoulder to shoulder as a form of morale. Some employees are new and lack experience to tackle customer’s complaints and therefore it is upon the manager to show them the best approach they can use as one way of keeping the customers as well as protecting the dignity of the restaurant at large. Creativity is one term and aspect that plays a role as far as coordination and effective communication is concerned. Effective communication is the backbone of all solution in the industry of service and when you overlook the essence many common problems starts arising. Deploying creativity helps to curb many obvious mistakes and this may be through Creating proper two-way contact policies which help you as a manager avoid staffing, scheduling, reservations, and order as well as catalog problems. Regular staff meetings should be availed to keep everyone on the same folio and review any existing operations in determination of each area where at least two people must work together by a virtue of aid. Once youve identified areas where problems could arise, you can be proactive in finding solutions which in turn translates into customer’s satisfactions and profit maximization in business too. Summarily, dynamics and teamwork must be

Friday, November 15, 2019

Interest of Stakeholders and Copyright Law

Interest of Stakeholders and Copyright Law Introduction Copyright law has been developed into major issue when it comes to the interest between the stakeholders as the technologies today are evolving in decent speed. Copying an intellectual property without the authorisation of the owner is an infringement under the law of United Kingdom and European Union. Under European copyright law, art.2 of Directive 2001/29/EC stated that authors, producers and performers will possess the exclusive right for the reproduction of their own works.[1] However, when it comes to private copying, there is an exception under the directive with certain conditions. This could be said as the balance of the interest between the copyright owner and user of the products. A private copy is defined as any copy for non-commercial purposes neither directly or indirectly by a natural person for personal use.[2] The private copy exception is provided in the art.5(2)b of the DIRECTIVE 2001/29/EC, where Member States may provide for exceptions or limitations to the reproductions on any medium made by a natural person for private use and for ends that are neither directly nor indirectly commercial, the right holders receive fair compensation which takes account of the application or non-application of technological measures referred to in Article 6 to the work or subject-matter concerned; [3] The would permit someone to format shift (i.e. shift content from one format to another); or space-shift (i.e. move content to different personal devices or media); and back-up copies that they have acquired.[4] As a mechanism for fair compensation, 22 out of 27 European Union members have chosen to meet the requirement through a levy system[5] The fair compensation or the levy system of private copying mainly to compensate the copyright owner for the potential harms to their works due to private copying.[6] In Padawan SL v Sociedad General de Autores y Editores de Espana (SGAE), the court held that held that fair compensation is an autonomous concept of EU law which had to be interpreted uniformly in all the Member States that had introduced a private copying exception: although it is open to the Member States, pursuant to Article 5(2)(b) of Directive 2001/29, to introduce a private copying exception to the authors exclusive reproduction right laid down in European Union law, those Member States which make use of that option must provide for the payment of fair compensation to authors affected by the application of that exception. An interpretation according to which Member States which have introduced an identical exception of that kind, provided for by European Union law and including, as set out in recitals 35 and 38 in the preamble thereto the concept of fair compensation as an essential element, are free to determine the limits in an inconsistent and un-harmonised manner which may vary from one Member State to another, would be incompatible with the objective of that directive[7] The exception had to satisfy a three-step-test provided in art.5 of the Directive (also in Art.9.2 of the Berne Convention, Art.10 of the WIPO Copyright Treaty and Art.13 of the TRIPS Agreement).[8] The exception can only be applied in certain special cases which do not conflict with a normal exploitation of the work or other subject-matter and do not unreasonably prejudice the legitimate interests of the right holder.[9] Legislators of Member States must take into account the criteria provided in the test when implementing the exception to the copyright in national legislation.[10] There are still uncertainties in the scope of this exception. When it comes to the second step of the test, the phrase normal exploitation remain as a broad and unclear concept. [11] To prevent most of the infringement of exploitation, the definition of the phrase need to be interpreted in clear and restrictive approach to limit certain range of exploitation of works. reference is often made to the WTO Panels report, in which the criterion of normal exploitation was deemed to involve consideration of the forms of exploitation that currently generate an income for the author as well as those which will be probably important in the future.[12] , it could impose a status quo and prevent any extension of exceptions to new situations unforeseen by the letter of the text, but which could derive from its spirit. On the other hand, reference to future exploitations runs the risk of paralyzing exceptions every time a technical evolution allows to control previously uncontrollable uses, and thus creates new possibilities for exploitation.[13] As concerns the control by right holders of the uses of their works through technical measures, this could even lead, in the long run, to the disappearance of limitations in the digital environment.[14] , a conflict with the normal exploitation can only occur if the author is deprived of a current or potential market of considerable economic and practical importance.[15] One of the issue regarding this point is that art.5(2)(b) didnt expressly state that whether the private copy exception only refer to copies from lawful sources, or involving the copies from illegal sources. Due to this uncertain area, the exception does not actual provide the copyright holders to authorise or prohibit the users from making a private copy. Nonetheless, the uncertainty could not be leading to the meaning of that the provision could demand the copyright holders to tolerate with the infringement of rights within private copy. This issue occurs in Netherland, where the Government of Netherland stated that the source of copy is irrelevant despite it is unlawful. The reason provided by the Government is that mere downloading is not a form of reproducing or making available. However, the Government held that the damages caused by illegal downloading to the copyright holder will be compensated by blank levies. The Government confirmed that only the act of uploading the unlawful content would be considered as an act of infringement, instead of mere downloading the work. The blank levies provided for illegal downloading could seen as protecting the interest of copyright holders as it would be practically impossible to enforce copyrights within the private copy area.[16] However, the legality of the sources of reproduction is matter to private copy exception. Court of Justice of European Union(CJEU) in the case of ACI Adam BV v Stichting de Thuiskopie [17]mentioned that Member States should not permitting private copy exception for any reproductions from unlawful sources as it could lead to negative impact on the functioning of the internal market[18]. In fact, tolerate to the unlawful distribution of illegal works would only legalize the act of infringement and will not minimising the act of illegal downloading. Thus, the CJEU said, art.5(2)(b) seek to ensure the proper functioning of the internal market and ensuring proper support for the dissemination of cultural works.[19] Why illegal downloading from unlawful sources shall not be legalised? First, legalising the act of illegal downloading would promote piracy, which would reduce the sales of the works from lawful sources and contravene the normal exploitation of works. Allowing illegal downloading would put the copyright holders in a position where they have to unreasonably tolerate the act of infringements, and this is clearly discriminating their legitimate interests.[20] To clearly distinguish copying from unlawful sources from private copy exception, the national legislators could achieve it by implementing a condition into the law that prohibit the acts of reproduction from the source that is obviously unlawful. [21] This approach has been taken by certain Member States to clarify the downloading act from unlawful sources not to be recognised as private copy. The German legislator expressly did in his first implementation act of the Directive (s.53(1) of the law of September 13, 2003, also called the first basket). Spain adopted a similar solution in the law of July 7, 2006, stating in Art.31.2 that the reproduction must be made from a legally accessed source to qualify as private copy. [22] Still today, it remains uncertain whether private copying is a mere defence or is actually enforceable against undue restrictions[23]. In fact, even where private copying is statutorily permitted, right holders may foreclose its exercise by relying upon technological protection measures or through licensing terms. To develop this interesting thesis more in detail, as the perspective adopted is mainly an EU one, it would have been interesting to include a discussion on the history behind the drafting of art.5 of the InfoSoc Directive (this is the relevant provision on copyright exceptions and limitations, including private copying).[24] However, the problem with the three-step test is probably to be found elsewhere: in the Directive of 2001. There, the test seems to be addressed not only to the national legislature but also to national judges.36 This gives it a broader scope than in the international conventions.37 Judges may be required to examine whether the application of a limitation in a specific case respects the conditions of Art.5.5. National courts in Europe have already analysed the application of national limitations to copyright in the light of the three-step test.38 Indeed, it is difficult to dispute judicial reliance on the test where it has been implemented in national law.39 The danger of such an approach is obvious: the private copy is at risk of being challenged by judges. Its scope risks dramatic reduction. The decision of February 28, 2006 of the French Supreme Court delivers an outstanding example.40 In this much commentated decision, the Supreme Court applied for the first time Art.5.5 of the directive in order to overcome the application of an exception in favour of a technical protection measure, arguing abstractly and generally that the private copy of a DVD conflicts with the normal exploitation of the work, without providing a definition of this term at any time.41 To avoid such misuse of the test, some guidelines *E.I.P.R. 128 for the judges of how to interpret the test in a more balanced way should urgently be worked out. The Max Planck Institute for Intellectual Property and the Queen Mary University of London jointly put in place a working group of European scholars that are currently working on this issue.42 Private Copy Exception in United Kingdom Copyright law in the United Kingdom has been evolving in recent years and the changes started to get significant since the Gowers Review of 2006 and the Hargreaves Review of 2011, gathering pace with the Enterprise and Regulatory Reform Act 2013.[25] The report in Hargreaves Review of intellectual property and the digital market in May 2011, recommend that the UK should implement the exception to ensure that the law kept up with digital copyright use.[26] For the first time, the UK legislator had implement the private copy exception into the national law. The exception was introduced by s.28B of the Copyright, Designs and Patents Act(CDPA) of 1988. This section of CDPA was enforced on October 1, 2014.[27] The new act implemented only allow copy from lawful sources for private purpose of individual concerned only. This exception does not include the passing of copy to family and friends which was allowed in the Directive. Such an exception would permit people legally to copy any work that they had access to and it would be easy to obtain copies of works without paying for them.[28] As to the narrower implementation, the Government stated that such implementation would cause no more than minimal or zero harm to the copyright holders. Based on this condition, there were no compensation provided for copyright holders in S.28B CDPA by the UK Government.[29] Problem with S.28B of CDPA The exception provided by the Directive allow the passing of copies to family or friend but the exception implemented in UK legislation prohibited such act. Professor Hargreaves suggested the Government should introduce an exception to allow individuals to make copies for their own use and that of their immediate family on different media. Importantly, Professor Hargreaves thought that the question of compensation was wrapped up in the copyright holders freedom to choose an appropriate price: Rights-holders will be free to pursue whatever compensation the market will provide by taking account of consumers freedom to act in this way and by setting prices accordingly.[30] The biggest issue in the S.28B of CDPA is that the fair compensation as provided by the directive is not implemented into the exception. Based on the directive, fair compensation to the copyright holders only could be exempt if the damage caused would be de minimis or minimal. [31]However, the UK Government commissioned a research study and impact assessment that showed the harm that would likely cause to the copyright holders due to the private copying acts permitted in S.28B of CDPA would be minimal. The main reason is that the exception only applies to rightfully acquired copies which the copyright holders would receive the sufficient remuneration at the sales of the works, which the compensation was already priced in.[32] Quashing of S.28B CDPA The exception introduced by UK Government had been challenged after it had been introduced by British Academy of Songwriters, Composers and Authors, Musicians Union and UK Music 2009 Limited. The parties had applied for judicial review on the newly introduced exception on the basis that it failed to provide fair compensation as in the Directive to the copyright holders which would be unlawful.[33] The main issue leads to the quashing of the Regulation is that whether there is evidence of the harm to the copyright holders which would be minimal to determine that compensation scheme is not required as provided by the Regulation.[34] The judge reviewed the evidence provided in Governments Updated Impact Assessment and stated that evidence to prove the harm is minimal do not meet the satisfactory level.[35] The judge also criticised the IPO Research Report provided as evidence that lack of consumer surveys, price analysis and comparative analysis with other Member States.[36] How the Exception Affect the Interest of Stakeholders When it comes to the interest of the copyright holders, we would straight pinpoint to the fair compensation issue. The reproductions of works are getting easier and wider due to advancement of technology. As downloading from unlawful sources would not be considered as private copying, CJEU in its decision in ACI Adam stated that the levy system would not be applied to illegal downloading from unlawful sources.[37] Such development had great impact on certain countries which dont distinguish between lawful and unlawful sources for private copy exception. [38] However, as large part of copies made online from unlawful sources, the levy system should be implemented to compensate such condition as only compensating copies made from lawful resources would left the copyright holders to bear the losses. Copyright holders had to prosecute the users to get remuneration for copies from unlawful sources. Such approach does not balance the interest of copyright holders if the users continue to access the unlawful sources instead of the legal online services provided.[39] Distinguishing illegal downloading from the exception would make the law serves better, but it taken away the minimum damages to be suffered by the copyright holder as online piracy and illegal downloading would not reduce merely due to removing such act from private copy exception. The decease of compensation for copyright holders would not be a reasonable solution as private copying is increasing. The interest of the copyright holders would be harmed due to such limitation instead of getting protected.[40] Recent Development In Entidad de Gestion de Derechos de los Productores Audiovisuales (EGEDA) v Administracion del Estado, the funding scheme of Spanish for private copy exception was criticised by the ECJ, where the court held that the scheme does not guarantee the cost of such compensation would solely bear by the user who made private copy.[41] In Case C-521/11 (11th July 2013) at paragraph [20], in relation to the person who has to pay, the Court confirmed that à ¢Ã¢â€š ¬Ã‚ ¦since the provisions of Directive 2001/29 do not expressly address the issue of who is to pay that compensation, the Member States enjoy broad discretion when determining who must discharge that obligation[42] However, the ECJ held that the Copyright Directive shall precludes budgetary scheme such as the scheme established in Spain to work as fair compensation to the copyright holders due to the private copy of their works as such scheme would involve a legal person who did not conduct such reproduction to bear the funding with those who make reproduction of works for private purpose. As the scheme could not guarantee the cost of that fair compensation is ultimately borne solely by the users of who make private copies, it shall not be treated as the fair compensation to the copyright holders even though Member States have the discretion to determine the legal person to bear such obligation.[43] [1] European Competition Law Review 2011 Case Comment Copying levies: moving towards harmonisation? The European Court rules on the concept of fair compensation for rightholders Bill Batchelor Tom Jenkins Matthew Butter [2] International Survey on Private Copying Law Practice 2015 [3] Art. 5(2)b of DIRECTIVE 2001/29/EC [4] Paragraph 91 R. (on the application of British Academy of Songwriters, Composers and Authors) v Secretary of State for Business, Innovation and Skills Queens Bench Division (Administrative Court) [5] [6] Entertainment Law Review 2009 Finland: copyright Mikko Manner [7] Paragraph 36 Padawan SL v Sociedad General de Autores y Editores de Espana (SGAE) (C-467/08) [8] European Intellectual Property Review 2008 The answer to the machine should not be the machine: safeguarding the private copy exception in the digital environment Christophe Geiger [9] Art. 5(5) of DIRECTIVE 2001/29/EC [10] Refer to no.8 [11]Refer to no.8 [12] THE ROLE OF THE THREE-STEP TEST IN THE ADAPTATION OF COPYRIGHT LAW TO THE INFORMATION SOCIETY Christophe Geiger [13] In this sense also M. Buydens and S. Dusollier, Les exceptions au droit dauteur : à ©volutions dangereuses: Comm. com. à ©lectr. Sept. 2001, p. 13; J. C. Ginsburg (prec. note 20), p. 48, which underlines the risk that the traditionally free uses, such as for training purposes or parody, be considered as normal exploitations, supposing that right holders manage to implement a profitable collecting system. [14] See also in this sense M. Buydens and S. Dusollier (prec. note 30), p. 12. For more developments, see C. Geiger (prec. note 8), n ° 418 and s. [15] International Review of Intellectual Property and Competition Law 2006 The private copy exception, an area of freedom (temporarily) preserved in the digital environment Christophe Geiger [16] Entertainment Law Review 2008 Case Comment Netherlands: copyright home copying Diederik Stols [17] ACI Adam BV v Stichting de Thuiskopie [18] Entertainment Law Review 2014 Case Comment Private copying levies, illegal online sources and the private use defence: Case C-435/12 ACI Adam BV v Stichting de Thuiskopie1 Kirsten Toft [19] Refer to no.18 [20] International Review of Intellectual Property and Competition Law 2015 Case Comment Private copying and downloading from unlawful sources Joao Pedro Quintais [21] Refer to no.8 [22] Refer to no.8 [23] European Intellectual Property Review 2013 Publication Review Private Copying: The Scope of User Freedom in EU Digital Copyright Stavroula Karapapa Reviewed by Eleonora Rosati* [24] [25] Entertainment Law Review 2015 Case Comment You say you want a revolution: judicial review of the UKs private copying exception James Sead Rebecca Pakenham-Walsh [26] European Intellectual Property Review 2015 Case Comment A pause in private copying: judicial review holds the UK private copying exception to be unlawful because there was no evidence to support the decision not to provide compensation to rights holders Joel Smith Heather Newton* [27] s.28B of the Copyright, Designs and Patents Act of 1988 [28] Para 71 R. (on the application of British Academy of Songwriters, Composers and Authors) v Secretary of State for Business, Innovation and Skills Queens Bench Division (Administrative Court) [29] European Intellectual Property Review 2015 Case Comment A pause in private copying: judicial review holds the UK private copying exception to be unlawful because there was no evidence to support the decision not to provide compensation to rights holders Joel Smith Heather Newton* [30] Paragraph 53 of R. (on the application of British Academy of Songwriters, Composers and Authors) v Secretary of State for Business, Innovation and Skills Queens Bench Division (Administrative Court) [31] Recital (35) of Directive 2001/29/EC [32] European Intellectual Property Review 2015 A comparative study on the reproduction by natural persons for private use exception to copyright in the UK and France Myriam Otaola Allende* [33] European Intellectual Property Review 2015 Case Comment A pause in private copying: judicial review holds the UK private copying exception to be unlawful because there was no evidence to support the decision not to provide compensation to rights holders Joel Smith Heather Newton* [34] Entertainment Law Review 2015 Case Comment You say you want a revolution: judicial review of the UKs private copying exception James Seadon* Rebecca Pakenham-Walsh [35] European Intellectual Property Review 2015 Case Comment A pause in private copying: judicial review holds the UK private copying e