Discussion of the four types of budgeting system

In Business terms if we talk about budgeting it is the ability of a manager to plan and allocate the available funds to different departments of the organization. This enables the organization to efficiently allocate the funds to more productive areas and cut back expenses from the less productive areas.This includes utilization of assets to generate income and public relationships. Normally budgeting is done by accountants, financial experts and representative of the respective department whose budget is being formed (Wisegeek, n.d, n.p)In daily life also budgeting is an effective way to determine the monthly living expenses keeping in view the bills of previous month. Say for example if an individual is earning $4,500 per month, by deducting his known bills from this amount before they even come, he can forecast his household budget, now instead of assigning fixed dollar amounts he can assign percentages to the rest of the sundries (Wisegeek, n.d, n.p).A successful budget is neithe r too strict nor too lenient but a balance between the two extremes because there are some expenses which are to be paid in full so it should be the strict side of the budget. In organizations, each and every department should know their upper limits on spending.The reason of forming a periodic budget is to have a clear cut view of the limits in term of expenditure (Wisegeek, n.d, n.p).Another view in budgeting is that not every project can be assigned a fixed dollar amount because an organization cannot forecast each and every expense and here comes the lenient side of the budget in which we are working with the percentages.Also there is always the chance of unexpected which requires immediate attention, so in that case if an organization or individual has fixed his budget he they would not be able to change or reallocate it. So what accountants and financial experts do is that they regularly adjust the figures according to their needs (Wisegeek, n.d, n.p).When the inflow of income is greater than the outflow most of the people negligent about budgeting, but those who have formed a practical budget and they follow it can survive even greater financial setbacks (Wisegeek, n.d, n.p).Traditional (Incremental) BudgetingTraditional or incremental budgeting is the most common type of budgeting used today, which includes forecasting for the whole year and no change is bought in the whole budgeting period. Because of simplicity and easy coordination traditional approach is mostly liked by the organizations (lmmattersonline, n.d, n.p).Imperative approach now a day is criticized from modern organizations. They say that this type of budgeting no longer serves the needs of organization, because mostly budget is timed incorrectly (for too long or for too short) period, depends on wrong measures (too basic or too composite), also too stiff in changing global environment and some times too political (which shows that benefits are only derived by upper management)If we look at the time period of traditional budgeting its fixed and specific, normally starting at the beginning of a fiscal year. The forecasted values of the budget also remains same during the whole cycle of the budget, the process of forecasting values is done keeping in view the values from the previous budget and the expectations are also made by looking at them.Finally the determination of goals is done by the top management, which is then communicated to lower management for implementation (lmmattersonline, n.d, n.p).The advantages of traditional or imperative budgeting approach are that it is easy to form, simple to manage and easy to evaluate. Furthermore every one’s goals are clear and accountability can easily be done (lmmattersonline, n.d, n.p).On the other hand disadvantages of traditional or imperative budgeting approach are that is unable to cater the needs of modern organizations and that the decision making during the year becomes difficult because of inflexibility in budget (lmmattersonline, n.d, n.p).Zero Based Budgeting (ZBB)Zero based budgeting (ZBB) is an alternate of traditional budgeting approach mostly used by government or not for profit organizations. Using this approach means that managers have to justify all expenditure and not only the changes from previous year. The benchmark for this approach is zero rather than last year’s budget (accountingformanagement, n.d, n.p).If we compare zero based budgeting (ZBB) with the traditional or imperative budgeting approach, in incremental approach the managers start from the last year budget and then add or subtract according to the predicted needs, taking last year’s budget for granted as baseline, while on the other hand zero based budgeting approach requires considerable documentation from the managers to justify the budget (accountingformanagement, n.d, n.p).Which not only includes the master budget document but also the decision packages showing all the activities of the part icular department ranked according to their importance and the cost of each activity should also have to be determined.Top executives then cross check the decision packages and cut back the expenses from less important areas (accountingformanagement, n.d, n.p).Zero based budgeting (ZBB) is considered to be a good approach; the only issue with it is the number of times the review is carried out. As this approach is quite time consuming and too costly to justify on an annual basis, also that annual reviews become mathematical and the purpose of budgeting is lost (accountingformanagement, n.d, n.p).For some managers zero based budgeting (ZBB) is quite helpful for others it is nothing but the wastage of resources like time and money. So it’s up to an individual what he chooses? (accountingformanagement, n.d, n.p).The advantages of zero budgeting approach (ZBB) are that the resources are utilized properly, and the identification of need and benefits become justified. ZBB also lead towards cost effective ways. It helps to identify inflated budgets and then helps the service oriented organizations to identify their output.The decentralization is also one of the benefits which increases the motivation of staff and gives them the message that they are also accountable for their actions (accountingformanagement, n.d, n.p).

Case Briefing and Problem Solving

Issue Spotters Delta Tools, Inc. , markets a product that under some circumstances is capable of seriously injuring consumers. Does Delta owe an ethical duty to remove this product from the market, even if the injuries result only from misuse? Why or why not? I think Delta Tools, Inc. doesn't owe an ethical duty to remove the product from the market unless the company doesn't warn its customers of the danger they can meet upon misuse of the product. If the company takes all the measures to warn their customers of the danger of the product once it's misused, customers have knowledge of the risk and voluntarily assume it.For example, the use of any antibiotics with the alcohol can lead to many harmful processes and activities. Nevertheless, pharmaceutical companies don't remove these products from the market because of that. It's a customer's responsibility to use the product properly. Case problems 8–1 Business Ethics. Jason Trevor owns a commercial bakery in Blakely, Georgia, that produces a variety of goods sold in grocery stores. Trevor is required by law to perform internal tests on food produced at his plant to check for contamination.Three times in 2008, the tests of food products that contained peanut butter were positive for salmonella contamination. Trevor was not required to report the results to U. S. Food and Drug Administration officials, however, so he did not. Instead, Trevor instructed his employees to simply repeat the tests until the outcome was negative. Therefore, the products that had originally tested positive for salmonella were eventually shipped out to retailers. Five people who ate Trevor's baked goods in 2008 became seriously ill, and one person died from salmonella.Even though Trevor's conduct was legal, was it unethical for him to sell goods that had once tested positive for salmonella? If Trevor had followed the six basic guidelines for making ethical business decisions, would he still have sold the contaminated goods? Why or why not? The issue in this case problem is whether Trevor's actions were unethical. In my opinion it was unethical for Jason Trevor to sell goods that had once tested positive for salmonella. Salmonella is a bacterium that can cause many illnesses.Two basic ethical approaches can be applied to this case. Firstly, Trevor should've thought about his customers from the religious position. He could've foreseen that products positive tested on salmonella would harm people inevitably. Secondly, he had to consider the outcome of this sale. He didn't think about the consequences that can follow. He acted negligent by letting his employees ship the products to the retailers. If Trevor followed the six basic guidelines for making ethical business decisions he would not have sold the contaminated goods to the public.Having five people seriously ill and one person died because of the contaminated products harms the name of the brand associated with this incident. Thus, company loses its custom ers and, as a result, part of the revenues. I think Trevor also should feel guilty about what happened to those people meaning that on the Conscience step, which is the 4th guideline, he would've reconsidered his actions and probably changed his mind. I guess he would've not been happy to be interviewed about the actions he was about to take.And the next step, which is Promises to his customers, would've made him doubt his decisions because of the trust of the customers that he held in his hands. And I am sure Trevor's hero would not have acted the way that can harm people. Thus, Trevor would not have sold the contaminated goods had he followed the basic guidelines for making ethical business decisions. Brody v. Transitional Hospitals Corporation United States Court of Appeals, Ninth Circuit, 280 F. 3d 997 (9th Cir. 2002). http://caselaw. findlaw. com/us-9th-circuit/1019105. html FACTS Jules Brody and Joyce T.Crawford filed a class action complaint against Transitional Hospitals Cor poration (THC) and its officers on August 28, 1997 accusing THC of unlawful insider trading after THC bought 800,000 shares of its stock between February 26 and February 28 without first disclosing that Vencor and other parties had expressed interest in THC. In addition, Brody and Crawford claimed that THC, in its March 19 and April 24 press releases, materially misled them about THC's intention to sell the company. The district court granted the defendant's motion to dismiss the claims. The plaintiffs appealed to the US Court of Appeal, Ninth Circuit.ISSUE Are Brody and Crawford the proper plaintiffs to sue THC for damages for violation of the statute and rule? regarding the insider trading? DECISION No. US Court of Appeal, Ninth circuit, affirmed the district court's decision to dismiss Brody and Crawford's complaint for failure to state a claim upon which relief can be granted. REASON The Court noted that plaintiffs did not meet a contemporaneous trading requirement, a judicially -created standing requirement, which specified in Section 14(e) and Rule 14e-3 that the plaintiffs must have traded in a company's stock at about the same time as the alleged insider.In addition, the Court decided that the plaintiffs' complaint must specify the reason or reasons why the statements made by THC in its press releases were misleading. Brody and Crawford argued that in order for statement not to be misleading, â€Å"once disclosure is made, there is a duty to make it complete and accurate†, for which the Court found no support in the case law. The case law? only prohibits misleading and untrue statements, not statements that are incomplete. FOOTNOTES: ? Sections 10(b), 14(e), and 20(a) of the Exchange Act, 15 U. S. C.  §Ã‚ § 78j (b), 78n (e), and 78t (a), and Rules 10b-5 and 14e 3, 17 C.F. R.  §Ã‚ § 240. 10b-5 and 240. 14e-3, promulgated thereunder by the Securities Exchange Commission (â€Å"SEC†) ? Rule 10b-5 and Section 14(e) Full case: BRODY v. TRAN SITIONAL HOSPITALS CORPORATION Jules BRODY; Joyce T. Crawford, Plaintiffs-Appellants, v. TRANSITIONAL HOSPITALS CORPORATION; Wendy L. Simpson; Richard L. Conte, Defendants-Appellees. No.? 99-15672. Argued and Submitted July 11, 2001. — February 07, 2002 Before: HALL, WARDLAW and BERZON, Circuit Judges. Jeffrey S. Abraham, New York, NY, for the plaintiffs-appellants. Mark R. McDonald, Morrison & Foerster, Los Angeles, CA, for the defendants-appellees.In this case we address several securities fraud issues, centering on whether a plaintiff must have traded at about the same time as the insider it allege violated securities laws. ? Jules Brody and Joyce T. Crawford brought suit against Transitional Hospital Corporation (â€Å"THC† or â€Å"the company†) and its officers claiming violations of the Securities and Exchange Act of 1934 (â€Å"Exchange Act†) and state law because the defendants both traded in reliance on inside information and released misleading public information. ? The district court granted the defendant's motion to dismiss for failure to state a claim. Brody and Crawford now appeal the district court's order on several grounds. BACKGROUND In determining whether the complaint states a claim upon which relief could be granted, we assume the facts alleged in the complaint to be true. ?Ronconi v. Larkin, 253 F. 3d 423, 427 (9th Cir. 2001). ? The facts alleged in the complaint are as follows: THC was a Nevada corporation that delivered long-term acute care services through hospitals and satellite facilities across the United States. ? In August 1996, the company announced its plan to buy back from time to time on the open market up to $25 million in company stock. Two months later, THC expanded the repurchase plan to $75 million. On February 24, 1997, Vencor, Inc. submitted to THC's board of directors a written offer to acquire the company for $11. 50 per share. ? THC did not disclose this offer publicly. ? Between February 26 and February 28, THC purchased 800,000 shares of its own stock at an average price of $9. 25 per share. ? This $7. 4 million buy-back was in addition to another $21. 1 million that THC had spent purchasing its stock in the three month period that ended on February 28, 1997. The plaintiffs do not allege that the total repurchase exceeded $75 million. THC issued a press release on March 19, 1997, detailing the progress and extent of its stock repurchase program. ? The press release did not mention Vencor or any other party's interest in acquiring THC. The plaintiffs argue that because of this omission, the March press release was misleading. On April 1, 1997, Vencor increased its offer to purchase THC to $13 per share. ? In the next few weeks, THC also received offers from two other competing bidders. ? On April 24, after receiving all hree offers, THC issued another press release, stating that the company had â€Å"received expressions of interest from certain parties who have i ndicated an interest in acquiring† it. ? The same document also stated that THC had hired â€Å"financial advisers to advise the company in connection with a possible sale. † ? The plaintiffs argue that this press release was also misleading; because it did not state that substantial due diligence had already taken place, that THC had received competing offers exceeding $13 per share, or that a THC board meeting would take place two days later to consider these offers.At the board meeting, the THC board voted to negotiate a merger agreement with Select Medical Corporation (â€Å"Select†). ? On May 4, THC publicly announced that it and Select had entered into a definitive merger agreement and that Select would purchase THC at $14. 55 per share. ? Vencor thereupon threatened a hostile takeover. ? To fend off that maneuver, THC ultimately agreed, on June 12, to a takeover by Vencor rather than Select, at $16 per share. Brody and Crawford sold shares at times that sa ndwich the April 24 press release. ? Two days before that press release was issued, Crawford sold 500 shares at $8. 75 per share. ? Brody sold 3,000 shares of THC stock at $10. 50 per share on April 24, just after the press release was made public. ? The plaintiffs argue that had they not been misled by THC, they would have held onto their shares, and benefitted from their subsequent increase in value. Brody and Crawford filed a class action complaint against THC and its officers on August 28, 1997. ? In addition to alleging violations of Nevada state law, Brody and Crawford alleged violations of Sections 10(b), 14(e), and 20(a) of the Exchange Act, 15 U. S. C.  §Ã‚ §? 78j(b), 78n(e), and 78t(a), and Rules 10b-5 and 14e 3, 17 C.F. R.  §Ã‚ §? 240. 10b-5 and 240. 14e-3, promulgated thereunder by the Securities Exchange Commission (â€Å"SEC†). ? These claims focus on two aspects of THC's course of action: Brody and Crawford accuse the company of illegal insider trading beca use THC repurchased 800,000 shares of its stock between February 26 and February 28 without first disclosing that Vencor and other parties had expressed interest in THC. In addition, Brody and Crawford claim that THC, in its March 19 and April 24 press releases, materially misled them about THC's progress toward its eventual merger.The district court dismissed all of Brody and Crawford's claims. ? In so doing, the district court held that Brody and Crawford are not proper parties to assert any insider trading claims, as Brody and Crawford did not trade contemporaneously with THC. In addition, the district court decided that the plaintiffs failed to state a claim under Rule 10b-5 or any other law based on materially misleading information, as the press releases were not misleading under the applicable standards. The plaintiffs appeal these aspects of the district court's dismissal. We review de novo the district court's dismissal for failure to state a claim pursuant to Federal Rule of Procedure Rule 12(b)(6). ?Zimmerman v. City of Oakland, 255 F. 3d 734, 737 (9th Cir. 2001). DISCUSSION A.? Insider Trading As they pertain to insider trading, Section 10(b), Rule 10b-5, Section 14(e) and Rule 14e-3 make it illegal in some circumstances for those possessing inside information about a company to trade in that company's securities unless they first disclose the information. See, e. g. , United States v. Smith, 155 F. 3d 1051, 1063-64 (9th Cir. 998). ? This type of prohibition is known as an â€Å"abstain or disclose† rule, because it requires insiders either to abstain from trading or to disclose the inside information that they possess. The district court dismissed the insider trading claims, holding that the named plaintiffs could not assert them because they did not trade contemporaneously with THC. On appeal, Brody and Crawford argue that nothing in the applicable securities laws requires investors to have traded contemporaneously with insiders in order t o maintain a suit for insider trading. In addition, they argue that even if such a requirement exists, they in fact did trade contemporaneously with THC. 1.? Section 10(b) and Rule 10b-5 Neither section 10(b)1 nor Rule 10b-52 contain an express right of action for private parties. ? The Supreme Court has held, however, that proper plaintiffs may sue for damages for violation of the statute and rule. ? See Superintendent of Ins. v. Bankers Life and Cas. Co. , 404 U. S. 6, 13 n. 9, 92 S. Ct. 165, 30 L. Ed. 2d 128 (1971). Because neither the statute nor the rule contains an express right of action, they also do not delineate who is a proper plaintiff. ? In the absence of explicit Congressional guidance, courts have developed various â€Å"standing† limitations, primarily on policy bases. 3 For example, in Blue Chip Stamps v. Manor Drug Stores, 421 U. S. 723, 95 S. Ct. 1917, 44 L. Ed. 2d 539 (1975), the Supreme Court held that to bring an insider trading claim under Rule 10b-5, a plaintiff must have traded in the same stock or other securities as the insider trader. The contemporaneous trading requirement, at issue in this case, is another judicially-created standing requirement, specifying that to bring an insider trading claim, the plaintiff must have traded in a company's stock at about the same time as the alleged insider. ?In Neubronner v. Milken, 6 F. 3d 666, 669 (9th Cir. 1993), the Ninth Circuit adopted a contemporaneous trading requirement for Section 10(b) and Rule 10b-5 actions. ? See also In re Worlds of Wonder Sec. Litig. , 35 F. 3d 1407, 1427 (9th Cir. 1994). Neubronner explained that two reasons animate this rule: First, â€Å"noncontemporaneous traders do not require the protection of the ‘disclose or abstain’ rule because they do not suffer the disadvantage of trading with someone who has superior access to information. † ? 6 F. 3d at 669-70 (quoting Wilson v. Comtech Telecommunications Corp. , 648 F. 2d 88, 94 95 (2d Ci r. 1981)). ? Second, the contemporaneous trading requirement puts reasonable limits on Section 10(b) and Rule 10b-5's reach; without such a limitation, an insider defendant could be liable to a very large number of parties. Id. at 670. Brody and Crawford offer two reasons why the contemporaneous trading rule adopted in Neubronner should not here apply. ? First, they argue that the rule does not make sense, as a matter of statutory interpretation. ? In other words, they request that we declare that Neubronner's interpretation of Section 10(b) and Rule 10b-5 was incorrect. ? Although the decision in Neubronner is not beyond debate, we do not consider the question further, as a Ninth Circuit panel may not overrule a prior Ninth Circuit decision. ?Hart v. Massanari, 266 F. 3d 1155, 1171 (9th Cir. 2001).Brody and Crawford attempt to avoid this precedential barrier by claiming that Neubronner's implementation of the contemporaneous rule was dictum, and therefore not binding on us. ? It wa s not. ?Neubronner explicitly described its ruling regarding the contemporaneous trading requirement as a â€Å"holding. † ? 6 F. 3d at 670. ? In addition, the determination was a necessary predicate for the case's ultimate conclusion that contemporaneous trading must be pleaded with particularity. ? Id. at 673. Brody and Crawford's second submission in avoidance of Neubronner is that United States v. O'Hagan, 521 U. S. 642, 117 S. Ct. 2199, 138 L.Ed. 2d 724 (1997), overruled Neubronner. ? That assertion is simply wrong. ? O'Hagan, which was a criminal case, addressed neither the contemporaneous trading requirement in private actions nor any other standing rule. ? Instead, by approving of an expansive concept of who qualifies as an insider under Section 10(b), the Supreme Court in O'Hagan clarified that more defendants may be liable under Section 10(b) than some courts have previously thought. ? Id. at 650, 117 S. Ct. 2199. ? In so doing, the Supreme Court did not alter pre-e xisting notions concerning whom insiders harm when they trade based on privileged information. Brody and Crawford next argue that even if the Section 10(b) and Rule 10b-5 contemporaneous trading requirements remain, the court should define contemporaneous trades as trades that take place within six months of one another. ? Under this definition, Brody and Crawford would have standing, as they sold their stock just under two months after they allege THC bought the large block of stock in February. [3]? In Neubronner, this court did not decide the length of the contemporaneous trading period for insider trading violations under Section 10(b) and Rule 10b-5, 6 F. d at 670, nor has this court decided the question since. ? Because the two-month time period presented by the facts of this case exceeds any possible delineation of a contemporaneous trading period, it is not necessary in this case either to define the exact contours of the period. ? We simply note that a contemporaneous tradi ng period of two months would gut the contemporaneous trading rule's premise-that there is a need to filter out plaintiffs who could not possibly have traded with the insider, given the manner in which public trades are transacted. 2.?Section 14(e) and Rule 14e-3 Brody and Crawford also argue that the district court erred in dismissing their claims under Section 14(e)4 and Rule 14e-35 by holding that insider trading actions brought under Section 14(e) and Rule 14e-3 must also conform to a contemporaneous trading requirement. ? In making this argument, the plaintiffs urge that we hold for them on two matters of first impression: (1) whether a private right of action exists under Rule 14e-3; and (2) if a private right of action does exist, whether it contains a contemporaneous standing requirement. We can assume, without deciding, that a private right of action exists under Rule 14e-3, for we see no reason why the same contemporaneous trading rule that applies under Rule 10b-5 would n ot apply in such an action. ?As noted, this court has definitively adopted a contemporaneous trading requirement under Rule 10b-5. ? Although Rule 14e-3 differs in some respects from Rule 10b-5, (and was adopted in order to plug some holes the SEC perceived in Rule 10b-5),6 its core, like the core of Rule 10b-5, is an â€Å"abstain or disclose† requirement. And, as is true of the â€Å"abstain or disclose† requirement of Rule 10b-5, the similar requirement of Rule 14e-3 is designed to prevent the disadvantage that inheres in trading with an insider with superior access to information. ?45 Fed. Reg. 60411-12 (1980). ? So we would have to have some excellent reason to adopt a different standing rule under Rule 14e 3 from the one we use under Rule 10b-5. ? We are convinced that there is no basis for drawing such a distinction. The best candidate appellants have advanced as a basis for differentiating the standing requirement under the two Rules is Plaine v. McCabe, 797 F. d 713 (9th Cir. 1986). ?Plaine held that a plaintiff suing under Section 14(e) need not have traded at all, let alone contemporaneously. ? Id. at 718. The fulcrum of Plaine was a distinction suggested by Piper v. Chris-Craft Indus. , Inc. , 430 U. S. 1, 38-39, 97 S. Ct. 926, 51 L. Ed. 2d 124 (1977), between the types of shareholder protections contained in Sections 10(b) and 14(e): Piper noted that while Section 10(b) was enacted to protect only individuals who actually traded in stocks, Section 14(e) can be understood as protecting not only those who buy or sell stocks but also shareholders who decide not to trade. 430 U. S. at 38-39, 97 S. Ct. 926. ? Because Rule 14e-3 was promulgated under Section 14(e), the argument that a plaintiff who alleges insider trading under Section 14(e) or Rule 14e-3 need not worry about the contemporaneous trading requirement-because he need not have traded at all-has some initial plausibility. On a closer examination, however, Plaine does not speak to the issue at hand. Rather, Plaine focused only on non-insider trading claims brought under Section 14(e), and did not consider the standing requirements for an insider trading claim brought under Rule 14e-3. Section 14(e) broadly prohibits â€Å"fraudulent, deceptive, or manipulative acts or practices, in connection with any tender offer;† it does not contain any specific reference to insider trading. ? Rule 14e-3, on the other hand, focuses on one type of behavior, insider trading, whose prohibition is thought to prevent fraudulent, deceptive, or manipulative acts. ? See O'Hagan, 521 U. S. at 672-73, 117 S. Ct. 2199. ? In accordance with its specific, prophylactic focus, Rule 14e-3 applies to a different set of behaviors than does Section 14(e): Section 14(e) centers on the actual tender offer, whereas Rule 14e-3 regulates illegal insider trading that takes place while a tender offer is under consideration. ? As appellants' brief states, â€Å"[a]ll the elements of a Sec tion 14(e)/Rule 14e-3 insider trading violation are supplied by the language of Rule 14e-3. A comparison of the facts in Plaine with the facts in this case illustrates the difference between the Section 14(e) claim considered in Plaine and the Rule 14e-3 claim considered here. ? Plaine held shares in a company subject to a tender offer. ? She complained that false information in proxy materials had induced other shareholders to tender their shares. ? Because so many other shareholders tendered their shares, the merger went through at a price Plaine viewed as inadequate. Although Plaine did not tender her shares, the court ruled that she alleged injury occurring as a result of fraudulent activity in connection with a tender offer and had standing to assert her claim. ?797 F. 2d at 717. ? Plaine did not, however, allege insider trading, and therefore could not have made out a claim under Rule 14e-3. Brody and Crawford, on the other hand, did allege insider trading but did not allege t hat THC manipulated the tender offer process through the use of false information or by any other means. ? As such, the facts in the current case present a very different situation than that presented in Plaine. The circumstances do, however, bear a much closer resemblance to those in Neubronner, a Rule 10b-5 case centering around accusations of insider trading in violation of an abstain-or-disclose requirement. ? See Neubronner, 6 F. 3d at 667. Despite the similarities of the issues here and in Neubronner and between Rules 10b-5 and 14e-3, as applied to insider trading allegations, Brody and Crawford emphasize the differences between the Rules. ? Unlike Rule 10b-5, Rule 14e-3 does not require proof that a person traded on information obtained in violation of a duty owed to the source of the inside information. Instead, Rule 14e-3(a) creates a duty for a person with inside information to abstain or disclose â€Å"without regard to whether the trader owes a pre-existing fiduciary du ty to respect the confidentiality of the information. † ? O'Hagan, 521 U. S. at 669, 117 S. Ct. 2199 (quoting United States v. Chestman, 947 F. 2d 551, 557 (2d Cir. 1991) (en banc)). ? Although Rule 14e-3 thus expands the notion of who is an insider, it does not follow that the Rule also expands the class of shareholders who may complain when an insider trades without disclosing insider information. As a result, the fact that Rule 10b-5 and Rule 14e-3 are not identical does not lead to the conclusion that one has a contemporaneous trading requirement and the other does not. More importantly, perhaps, in this case, the allegation is that THC traded in its own stock on the basis of inside information. ? Such allegations would state a â€Å"†¦Ã¢â‚¬Ëœtraditional’ or ‘classical’ theory of insider trading liability [under] Rule 10b-5 based on ‘a relationship of trust and confidence between the shareholders of a corporation and those insiders who have obtained information by reason of their position with that corporation. †¦Ã¢â‚¬  ? O'Hagan, 521 U. S. at 651-652, 117 S. Ct. 2199 (quoting Chiarella, 445 U. S. at 228, 100 S. Ct. 1108). ? As such, this case is one that could be-and indeed, was-brought under both Rule 10b-5 and Rule 14e-3, and as to which any differences between the two rules regarding the necessary relationship between the insider and the source of information is not relevant. Brody and Crawford note another reason that, they argue, suggests an expansive reading of Rule 14e-3 is appropriate. In O'Hagan, the Supreme Court ruled that the SEC is permitted to promulgate rules under Section 14(e), such as Rule 14e-3, that prohibit acts not themselves fraudulent under the common law if the rules are reasonably designed to prevent acts that are. ?521 U. S. at 671-73, 117 S. Ct. 2199. ? This authority derives from the prophylactic rule-making power granted to the SEC by Section 14(e), a power that has no parallel in S ection 10(b). ?Id.That the SEC had more power to protect investors when it promulgated Rule 14e-3 than it did when it promulgated Rule 10b-5 does not mean, however, that the SEC exercised that power so as to protect noncontemporaneous traders under Rule 14e-3. ? And, in fact, what evidence there is demonstrates that the SEC did not intend to protect investors who could not have possibly traded with the insiders. In O'Hagan, the Supreme Court quoted at length from and afforded deference to the SEC's explanation of why it promulgated Rule 14e-3. Part of the Federal Register excerpt quoted in O'Hagan stated: The Commission has previously expressed and continues to have serious concerns about trading by persons in possession of material, nonpublic information relating to a tender offer. ? This practice results in unfair disparities in market information and market disruption. ? Security holders who purchase from or sell to such persons are effectively denied the benefits of disclosure a nd the substantive protections of the [legislation that includes Section 14(e)]. 21 U. S. at 674, 117 S. Ct. 2199 (quoting 45 Fed. Reg. 60412 (1980)). This quotation evinces a particular concern for those who â€Å"purchase from or sell to† insiders, and suggests that these shareholders, and not others who trade later, are the intended beneficiaries of Rule 14e-3. ? The contemporaneous trading requirement, designed to limit the class of potential plaintiffs to only those who could have possibly traded with the insider, is therefore precisely congruent with the SEC's expressed purpose in promulgating Rule 14e-3.In sum, Rule 10b-5 and Rule 14e-3 contain similar insider trading prohibitions, triggered by similar concerns. ? While Rule 14e-3 focuses on the tender offer context, the background history and language of Rule 14e-3 indicate that the Rule does not alter the premise that a shareholder must have traded with an insider or have traded at about the same time as an insider t o be harmed by the insider's trading. ? We conclude that there is no principled distinction between Rules 10b-5 and 14e-3 as regards the need for a contemporaneous trading allegation.We therefore extend the contemporaneous trading requirement to insider trading actions brought under Section 14(e) and Rule 14e-3 actions. ? Because Brody and Crawford traded nearly two months after they allege THC traded, they did not trade contemporaneously with THC. The district court was correct in dismissing their Rule 14e-3 insider trading claims. B.? Misrepresentation We next consider a different set of concerns addressed by the securities laws: Rule 10b-5 and Section 14(e)'s explicit prohibition against the making of untrue or misleading statements. The plaintiffs do not maintain that either press release issued by THC was untrue. ? They do argue, though, that THC violated the prohibitions against making misleading statements when it issued the two press releases here at issue. ? In order to sur vive a motion to dismiss under the heightened pleading standards of the Private Securities Litigation Reform Act (â€Å"PSLRA†), the plaintiffs' complaint must specify the reason or reasons why the statements made by THC were misleading. ?15 U. S. C.  §? 78u-4(b) (1); see also Ronconi, 253 F. 3d at 429.As an initial matter, Brody and Crawford correctly assert that a statement that is literally true can be misleading and thus actionable under the securities laws. ? See In re GlenFed Sec. Litig. , 42 F. 3d 1541, 1551 (9th Cir. 1994). ? But they err when they argue that in order for a statement not to be misleading, â€Å"once a disclosure is made, there is a duty to make it complete and accurate. † This proposition has no support in the case law. ?Rule 10b-5 and Section 14(e) in terms prohibit only misleading and untrue statements, not statements that are incomplete.Similarly, the primary case upon which Brody and Crawford rely for their innovative completeness rule su pports only a rule requiring that parties not mislead. ? Virginia Bankshares, Inc. v. Sandberg, 501 U. S. 1083, 1098 n. 7, 111 S. Ct. 2749, 115 L. Ed. 2d 929 (1991). ? Often, a statement will not mislead even if it is incomplete or does not include all relevant facts. 8 ? Further, a completeness rule such as Brody and Crawford suggest could implicate nearly all public statements potentially affecting securities sales or tender offers. No matter how detailed and accurate disclosure statements are, there are likely to be additional details that could have been disclosed but were not. ? To be actionable under the securities laws, an omission must be misleading; in other words it must affirmatively create an impression of a state of affairs that differs in a material way from the one that actually exists. ? See McCormick v. The Fund American Cos. , 26 F. 3d 869, 880 (9th Cir. 1994).We conclude that neither Rule 10b-5 nor Section 14(e) contains a freestanding completeness requirement; th e requirement is that any public statements companies make that could affect security sales or tender offers not be misleading or untrue. ? Thus, in order to survive a motion to dismiss under the heightened pleading standards of the Private Securities Litigation Reform Act (â€Å"PSLRA†), the plaintiffs' complaint must specify the reason or reasons why the statements made by THC were misleading or untrue, not simply why the statements were incomplete. 15 U. S. C.  §? 78u-4(b) (1); see also Ronconi, 253 F. 3d at 429. ?Brody and Crawford's allegations do not comport with this requirement. ? They allege, first, that the press release issued on March 19 was misleading because it provided information about THC's stock repurchase program but did not contain information regarding THC's possible takeover. ? Although Brody and Crawford specify what information THC omitted, they do not indicate why the statement THC made was misleading. ? If the press elease had affirmatively intimat ed that no merger was imminent, it may well have been misleading. ? The actual press release, however, neither stated nor implied anything regarding a merger. ?Brody and Crawford also claim that THC's second press release, issued on April 24, was misleading. ? Again, the plaintiffs do not argue that the press release was untrue. ? Instead, they argue that it was misleading because it stated generally that THC had received â€Å"expressions of interest† from potential acquirers, when in fact it had received actual proposals from three different parties. Importantly, the complaint does not provide an explanation as to why this general statement was misleading, nor is it self-evident that it was. A proposal is certainly an â€Å"expression of interest. † ? Moreover, the press release did not simply state that there had been vague â€Å"expressions of interest;† it went on to state that the â€Å"expressions† were â€Å"from certain parties who have indicate d an interest in acquiring either the entire company or in acquiring the company, with the company's shareholders retaining their pro rata interests in Behavioral Healthcare Corporation [a THC subsidiary]. ? This specificity concerning the nature of the parties' proposals certainly suggests that something more than preliminary inquiries had taken place. Further, the press release additionally stated that the â€Å"Board of Directors has engaged financial advisors to advise the company in connection with a possible sale. † ? This additional information again suggested proposals that were concrete enough to be taken seriously. ? And the reference to multiple parties contained in the press release suggests an ongoing auction for THC was taking place with at least two participants.In short, the press release did not give the impression that THC had not received actual proposals from three parties or otherwise mislead readers about the stage of the negotiations. ? Instead, althoug h the press release did not provide all the information that THC possessed about its possible sale, the information THC did provide-and the reasonable inferences one could draw from that information-were entirely consistent with the more detailed explanation of the merger process that Brody and Crawford argue the press release should have included. Put another way, Brody, if he read the press release, would have been on notice, before he sold his shares, of the distinct possibility that the value of the shares would increase in the near future because of a takeover contest. 9 [11] Because Brody and Crawford have not alleged facts indicating that THC's April 24 press release was misleading, the district court properly dismissed that aspect of the plaintiffs' complaint. CONCLUSION Brody and Crawford have not met the contemporaneous trading requirements necessary to have standing in the insider trading claims they assert. Additionally, they have failed properly to allege misrepresentat ion against THC. As a result, we affirm the district court's decision to dismiss Brody and Crawford's complaint for failure to state a claim upon which relief could be granted. AFFIRMED FOOTNOTES 1. ?Section 10, in relevant part, states: It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce or of the mails, or of any facility of any national securities exchange-?..... b)? To use or employ, in connection with the purchase or sale of any security registered on a national securities exchange or any security not so registered, or any securities-based swap agreement (as defined in section 206B of the Gramm-Leach-Bliley Act), any manipulative or deceptive device or contrivance in contravention of such rules and regulations as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors. 2. Rule 10b-5 states: It shall be unlawful for any person, directly or indirec tly, by the use of any means or instrumentality of interstate commerce, or of the mails or of any facility of any national securities exchange,(a)? To employ any device, scheme, or artifice to defraud,(b)? To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or(c)?To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person, in connection with the purchase or sale of any security. 3. ?These â€Å"standing† limitations are not, of course of the constitutional variety, grounded in Article III of the Constitution, but simply delineate the scope of the implied cause of action. 4. ?Section 14(e) states: It shall be unlawful for any person to make any untrue statement of a material fact or omit to tate any material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or to engage in any fraudulent, deceptive, or manipulative acts or practices, in connection with any tender offer or request or invitation for tenders, or any solicitation of security holders in opposition to or in favor of any such offer, request, or invitation. ? The Commission shall, for the purposes of this subsection, by rules and regulations define, and prescribe means reasonably designed to prevent, such acts and practices as are fraudulent, deceptive, or manipulative. . ?Rule 14e-3(a) states:(a)? If any person has taken a substantial step or steps to commence, or has commenced, a tender offer (the â€Å"offering person†), it shall constitute a fraudulent, deceptive or manipulative act or practice within the meaning of section 14(e) of the Act for any other person who is in possession of material information relating to such tender offer which information he knows or has reason to know is non public and which he knows or has reason to know has been acquired directly or indirectly from:(1)? The offering person,(2)? The issuer of the securities sought or to be sought by such tender offer, or(3)?Any officer, director, partner or employee or any other person acting on behalf of the offering person or such issuer, to purchase or sell or cause to be purchased or sold any of such securities or any securities convertible into or exchangeable for any such securities or any option or right to obtain or to dispose of any of the foregoing securities, unless within a reasonable time prior to any purchase or sale such information and its source are publicly disclosed by press release or otherwise. 6. ?Chiarella v. United States, 445 U. S. 222, 100 S. Ct. 1108, 63 L. Ed. d 348 (1980), considered, but did not decide, the viability of a misappropriation theory of liability under Rule 10b-5. ?445 U. S. at 235-37, 100 S. Ct. 1108. ?(A misappropriation theory extends liability to some parti es who trade in a company's securities on the basis of confidential information but who have no special relationship with the company's shareholders. ) Following Chiarella, the SEC promulgated Rule 14e-3, which clearly creates liability for insiders who trade in connection with a tender offer and do not disclose the inside information, regardless of their relationship to the shareholders or the source of the information. Then in 1997, the Supreme Court decided O'Hagan, answering the question left open by Chiarella and deciding that Section 10(b) and Rule 10b-5 do create liability under a misappropriation theory. ?521 U. S. at 650, 117 S. Ct. 2199. ? The upshot is that Rules 10b-5 and 14e-3 largely overlap with regard to the scope of insider trader liability, although they differ in some respects not here pertinent. ? See p. 1004, infra. 7. As we discuss below, in O'Hagan the Supreme Court approved Rule 14e-3 as a prophylactic rule designed to prevent core violations of Section 14(e) . ? See p. 1004, infra. 8. ?For example, if a company reports that its sales have risen from one year to the next, that statement is not misleading even though it does not include a detailed breakdown of the company's region by region or month by month sales. 9. ?We note that Crawford sold his shares before the April 24 press release, so he could not have been influenced in his trading by the release. BERZON, Circuit Judge.

Analyze the debate over states' rights versus national supremacy from Research Paper

Analyze the debate over states' rights versus national supremacy from the founding of our nation up until today. how has this debate changed over time - Research Paper Example As noted, it is not all the states that regard the death penalty as legal. The federal government is permitted to enforce the death penalty for various crimes. Statistics indicate that between the years 1967 and 1997, only one execution was undertaken out of every 1,600 crimes involving murder. They also go on to indicate that, out of every 8,000 convictions, less than 120 are charged with the death sentence (Rogers, 2008). Federal crimes are used to enact the death penalty by the federal government. Federal crimes include; espionage, treason, drug trafficking, just to name but a few. Similarly to what happened in the states, the federal government did not enact the death penalty for ten years, 1967-1977. It was during a time when the Supreme Court was deliberating on the legality of the death penalty. In 1988, the death penalty was re-enacted and only 3 executions have been undertaken since then. Just like the governors have the authority to grant clemency in death penalty cases, so does the president. In spite of the uniformity in the federal death penalty, states differ in their enactment of the penalty. For example, the Supreme Court in Nebraska nullified the utilization of the electric chair as a means of execution in the year 2008. The New York Supreme Court also nullified the death penalty in the year 2004. Hence, these states in reality have no death penalty (Rogers,

Eco-Friendly Plastic Bag Research Paper Example | Topics and Well Written Essays - 1500 words

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Miss Spider's tea party Essay Example | Topics and Well Written Essays - 500 words

Miss Spider's tea party - Essay Example The ballet group itself is a non-profit entity, and its laudable programs are funded completely by donations and powered by volunteers in the main. This makes the event doubly meaningful and worthwhile, first because of the goodwill and the eminently good intentions of the group, and second because of the excellent production and the merits of the artistic show itself (Cuyahoga Valley Youth Ballet; Cuyahoga Valley Youth Ballet (b)). The story itself is straightforward, and a delight to watch on stage. Miss Spider is preceded by a reputation for eating bugs, and so has a difficult time making friends and being able to invite neighbors for tea. This is a recipe for loneliness, and the story in a way is about this loneliness and the walls that people and bugs erect among themselves, motivated by fear and impressions that may not correspond with reality. All sorts of bugs in the neighborhood resisted the charms of Miss Spider and chose to stay away, and even the ants could only stay for a short while. It took a helpless wet moth, who couldn’t escape if it wanted to, for the rest of the neighborhood to know how harmless and contrary to stereotypes Ms. Spider was. Her act of kindness towards the moth convinced them to finally stop by Miss Spider’s house and stay. There is much to the production that can be recommended for all children. The story itself is instructive with regard to how to deal with peop le in the outside world, to see without blinders and to give people a chance, and more importantly, to not be deceived by appearances. People are good and bad, and with caution and the guidance of elders, the outside world can be engaged in. On another level, the production also emphasizes the importance of friendship. This production has many hooks to the course. It is a worthwhile addition, for instance, to the library of children’s literature that can be recommended to students. That it has been staged by an organization with a

Public University Analysis Essay Example | Topics and Well Written Essays - 1000 words

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Pheromones Essay Example | Topics and Well Written Essays - 2000 words

Pheromones - Essay Example Pheromonal communication elicits physiologic and behavioural changes in the subject affected. Pheromones were initially studied in insects, where they have an established role as proven by scientific research. Limited sensory development in insects as compared to mammals necessitates the presence of some communication mechanism by which they can exchange information. Pheromones are the substances which perform this function. The complex manner in which ants, termites, honey bees, bugs and other insects organise their daily life without any verbal communication is a definite clue to the presence of pheromones. All insects have a highly organised pattern of social interaction as well as a well defined reproductive pattern which are guided by pheromones. According to an online article by Pines Maya of the Howard Hughes Medical Institute, the first pheromone ever to be identified (in 1956) was a powerful sex attractant for silkworm moths. It was isolated over a span of twenty years by a team of German researchers. After removing certain glands at the tip of the abdomen of 500,000 female moths, they extracted the compound. Miniscule amounts of this compound elicited excitement in the male moths exhibited by fluttering of their wings. This clear sign that the males had sensed the attractant enabled the scientists to purify the pheromone. The compound was purified subsequently and was named "bombykol" for the silkworm moth, Bombyx mori from which it was extracted. There are enough visibly apparent instances of evidence of the existence of pheromones in our daily life when we observe insect behaviour. Bees and wasps home in to the precise location of their hives; ants leave a trail for others to follow, and the butterflies locate members of the opposite sex during flight. Pheromones are predominantly volatile compounds detected by the sense of smell but sometimes can be liquid contact chemicals (Gullan P.J. et al). They are secreted from the exocrine glands derived from the epidermal cells. Classification of pheromones in insects is based upon five categories of behaviour associated with sex, aggregation, spacing, trail forming and alarm. Sex pheromones are usually secreted during the breeding season by the female which attracts the males. Aggregation pheromones cause insects of both sexes to crowd around the source of the pheromone. Spacing pheromones are anti aggregation and are secreted to repel further arrivals of the species when a particular spot is saturated with the species or the food source is exhausted. Trail marking pheromones are volatile and short lived chemicals that evaporate within days unless reinforced. They are used by social insects like ants to mark the trail to the nest or food source. Alarm pheromones are volatile, non persiste nt compounds that are secreted by insects during aggression by a predator or any other calamity which may affect the nest. They induce protection behaviour by collection or aggregation of the affected species such as bees. The presence and significance of pheromones in higher species in the ecological order has been well documented but the role played by them in human beings has been full of claims, counterclaims and controversies. Social as well as sexual behaviour in the quadruped mammals is strongly influenced by the sense of smell. Territory marking is a prominent feature in animals like lions, tigers and dogs. Such animals can detect the presence of another male by the

Report on the feasibility of the overseas expansion of acomb tyres in Essay

Report on the feasibility of the overseas expansion of acomb tyres in india - Essay Example The best beneficiaries in this case would rightly be India & China, with Russia just beginning to emerge to becoming a challenger to them in this are. The world has seen similar advances in other domains of trade & commerce as well. Companies today feel pride in declaring themselves as multinational corporations rather than be known more as local or regional players. The tyre industry is one such area, which has seen similar changes. Today major tyre industries like Bridgestone & Dunlop are popular & financially very strong owing to the fact that they are MNCs (Multi National Corporations). But, Yadong Luo (1997) is of the positive view that this must not deter other SMEs (Small & Medium Enterprises) from aspiring to go global as has been cited by Zoltan J Acks (2001). This report is written as an advisory statement to the Acomb Tyres of the UK (which is an SME) as to what are the pros & cons of setting up shop in other countries. In this report, the country under discussion is India. The reasons for selecting this country as the most favorable destination is discussed in the following sections of the report. As the Acomb tyre Industries' major area of production is in the area of agricultural tractor tyres, the report concentrates on analyzing a suitable market for the same type of products. The present section concentrates on what are the reasons for global expansion as also what are the best strategies to initiate such expansions. Examples in support of the argument are discussed in the section that deals with the expansion of Acomb in India. REASONS FOR OVERSEAS EXPANSION & STRATEGIES TO DO SO There is no doubt that Acomb Tyre Industries is established & considerably popular in its native market in the UK with an estimated annual turnover of around 22m. But the following points that are described below outline the prime reasons as to why Acomb should consider a major overseas expansion: Limited Home Market It is a known fact that Acomb industries has won several awards for its unique and innovative products and has earned a solid reputation among farmers and other users of agricultural vehicles in the Northeast England and its surrounding regions. But a point to note is that the tyre market in the UK has been found to become stagnant in terms of growth & the economy. The tyre industry is no longer seen as a major contributor towards the development of the economy as it used to be so previously. Siobhan A Austen (1999) says that a prime reason for this can be attributed to the fact that the amount of sales of tyres on an annual basis; especially in the agricultural sector has reached its optimum levels owing to the limited amount of land available in the UK. Acomb has also been feeling the effect of the limited market, which is one of the company's prime reasons for asking us to prepare this report. The analysis of the prevailing market conditions in the UK have led us to the conclusion that it is time for Acomb to start looking for greener pastures. Better Profit Margins History has shown that today's major companies have come to dominate the market,

Essay of media analysis Example | Topics and Well Written Essays - 750 words

Of media analysis - Essay Example The book ‘carved in bone’ by Jefferson Bass conveniently covers the subject under study by virtue of an interesting plot where Dr Bill Brockton who is a Forensic Anthropologist studied the case of a deal mummified woman discovered in a cave. Brockton this makes use of quite intriguing techniques like analyzing the graphical decomposition of the corpse and using various experiments to put together pieces of the puzzle to unveil who the woman really was. He owns a research laboratory where he experiments with the techniques which may have been used during homicides. To de-flesh the bones, he boils them and bleaches them and later tries to determine patterns from fragments on bones and also from the kind of impact he finds on the bones to gather enough evidence to challenge the strong lobbies in the county (Bass 2006). This book, written by a forensic anthropologist himself proves to be an insightful account on how far can the subject matter go in solving mysteries of the c rime world . In the article ‘When Forensic Anthropology meets DNA’, another interesting aspect of the subject is unveiled. The forensics department was able to draw DNA samples from a corpse decomposed to such an extent that extracting any evidence of identity was nearly impossible. However, Laura Fulgitini, who`s a forensic anthropologist uses her impeccable skills to jot together the pieces of skull together by adding cement to the missing sections to conveniently unveil the identity of the corpse, who turns out to be one of the people missing from San Diego, Joy Risker. Under normal circumstances, drawing DNA from the sample would have been of no use since there would have been no one to compare the sample to, however, by re-creating the shape of the skull, the forensics was able to get a fine idea of what the person would have looked like. On comparing the image of the corpse with the person missing, they were able to get a breakthrough, which was only possible due to

Organizational Training Design Assignment Example | Topics and Well Written Essays - 3750 words

Organizational Training Design - Assignment Example It is evidently clear from the discussion that the training program is conceptualized to introduce key personnel to the rudiments of the customer contact software package (SAM) chosen by the team.   The trial run, scheduled for a single day, would provide preliminary insights into crafting a better program for larger scale integration. In this manner, the trial training will help the firm realize better results while avoiding costly errors that may have been encountered without the trial program. The firm is in the midst of its regular operations. In the financial services industry, the stock market, currencies market, and securities trading are constantly moving. Prices of the traded assets are always being bidded up or sold down in any one trading session, for which reason the brokers, traders, and analysts are always focused on the market. Obviously, training is going to come into direct interference with this. Clients may be called during the course of trading to speak with the ir own traders or analysts (who may be managers), for feedback, advice, or transaction in the markets. If such person were pulled out of the firm’s operations for one day, then customers will find this disconcerting because they have established trust with their usual contact and may not want to transact with others. Prior arrangements and coordination should, therefore, be made with substitute personnel if any, or better yet, arrangements should be made to hold the training during a non-trading day, or possibly broken down to be accommodated into non-trading hours during work days. Depending upon the individual manager’s perspective, he may consider the training as either opportunity, reward or punishment. Employees who are engaged and motivated, and who feel an empathy with the market and the needs of the firm, will only look at the training program as an added opportunity. Training programs, after all, provide the individual worker with added tools by which he could more effectively address his work. In a sense, the trainee-manager may feel that the training program may be a reward. Oftentimes, being in the pilot batch of a program may be construed as an honor, because it is an acknowledgment of the above-average capabilities and skills of the trainee. After all, the best subjects are usually chosen for the trial of a new innovation, to assess the best possible chances for success of the prospective change. Seldom, if ever, will the training program be considered as punishment, but in such case, it may be due to the perceived withdrawal of the trainee from the workplace, affording him less change for output performance for the day in case there is some competitive (as against others) or evaluative (as in chances for promotion or raise) implication of such foregone output. All persons or groups who may have a strong faith in computerization and are convinced that the firm’s sales will be improved by added technology will definitely have an interest in seeing it succeed. Also, those employees who are in touch with market developments and are aware of competitive advantages of their company’s competition will praise and root for the success of the installation, training, and implementation activities with regard to SAM.  

Enders Game Essay Example for Free

Enders Game Essay I selected this book because I was thinking that it would keep me entertained and make it so that I will not fall asleep. This was one of those books that it did not matter about what happened before it you can just start reading it from the start, so before the book began I have now idea what happened I just started to read the book and I liked it. When the book begins it starts out with ender and his brother and sister and his brother is mean and is always threatening his younger brother ender and his younger sister. In this story it is the narrator that is telling it. The setting was important because it was at Enders house at first and his older brother, bulling hem, which made ender stronger and made it so that he would look out for himself. In the beginning the author held my interest because the government shipped ender off to military school at age three. Journal Entry #2 Ender go’s to military school and he gets bullied from the start and makes a name for himself right at the beginning by braking some kids arm, so after that every one starts to put together gangs and start having gang wars in the battle rooms and in the cafeteria. There where lots of twist in this story like ender would always when the war games and he was the commander of army’s and he was just smarter than the older boys. It was pretty easy to fallow the plot if I didn’t zone out but if I did zone out than it was pretty easy to know what was happening because the story would repeat its self. The language in the book was really easy to understand there was a lot of a made up words but it was all right. The mane thing emerges in the book when it comes to the battle games and ender is better then everyone else. Journal entry #3 The climax of the story was when ender meet bean, ender was hard on bean just like how the government was hard on ender and that made bean a lot stronger. But ender and bean come together and they start to when all of these battles together. There are lots of lessons I learned about this book, I learned that life isn’t always easy and the hard things in life make you stronger. If someone talked to me about this book I would tell him or her it was a good book and I would recommend it to them because there was a lot of action in it. But the book did not meet my expectations because I do not like it when three year olds are talking like they are 25 years old I think that was a little over bored and when the three year olds are going to military school that was dome I think that he should have made them 18 because that is more realistic.

Effects of the French and Indian War

Effects of the French and Indian War Why do I think the French and Indian war created America? Much of historians work on the creation of America has focused primarily upon the War of Independence and its great influence in shaping the institutions of the American state. This scholarly focus upon the War of Independence as the cradle of America has meant that the French and Indian war has rather less significance in the popular imagination than it merits. It is the aim of this essay to demonstrate that the French and Indian war was not just a mere precursor to the much more widely recognized American War of Independence but rather a seminal event in its own right that had a profound effect on the course of American history. The French and Indian war sowed the seeds for the creation of America as we know it today. The noted historian Fred Anderson believes that the importance and influence of the French and Indian war was such that he terms it â€Å"the war that made America.†[1] The argument that the French and Indian war created America shall be made with the expositio n of the following points: Firstly, the war changed the colonials’ view of their own standing within the Empire. They believed that they had proved themselves as equals but their status had not undergone a similar conversion in the eyes of the Whitehall. Secondly, the removal of the French threat from North America led some to question why they needed to continue in their relationship with the British. Thirdly, the French and Indian war led to the Royal Proclamation of 1763 which denied the expression of the colonies’ determination for further westward expansion. Finally, the cost of the French and Indian war, and the wider Seven Years War  led to increased taxes being imposed upon the colonies, taxes that were increasingly seen as an unjust imposition. All of these factors outlined converged to produce the thirst for independence from the British Crown and led ultimately to the creation of America. The French and Indian war initiated a cultural shift which led the colonials to conceive of themselves as equal partners in the [British] empire†[2], an idea that put them at odds with their British overlords and ultimately led to conflict with the British Empire and the eventual creation of a independent America. The colonists assumed that their efforts in the war had proved their status as equal members of the Empire. They were, in their own opinion now ‘partners in Empire.’ There was a sense of pride in belonging to the Empire. Benjamin Franklin celebrated â€Å"not merely as I am a colonist, but as I am a Briton.†[3] In a mood of rejoicing, New York erected statues of King George III and William Pitt. However, the British did not agree that the colonists had earned their newfound status as partners in Empire. The views of the British had not altered, the belief in the Empire’s hierarchy and the primacy of the Crown remained. These competing vision s of empire[4] were irreconcilable and meant yet further division between the two sides. The Treaty of Paris (1763) saw France lose all of its North American territory east of the Mississippi save for the two small islands of Saint Pierre and Miquelon. This routing of the French led the colonies to question quite why they should remain tied to the British. There was now no common enemy to unite them. In 1773 the royal governor of Massachusetts stated that had Canada â€Å"remained to the French none of the spirit of opposition to the Mother Country would yet have appeared.†[5] The removal of the French threat that resulted from the conflict fostered an atmosphere in which the colonials began to give birth to their own ideas of democracy and self-rule thus providing them with the intellectual and philosophical ammunition with which to attack British imperialism The British were concerned that the colonies western frontiers should not expand any further, lest it aggravate the Indian tribes and thus provoke a further spate of conflicts. Furthermore, Britain’s new North American Empire, minus the French, was vast and any efforts to enlarge it yet further risked rendering it ungovernable. As a result the Royal Proclamation of 1763 prohibited further westward expansion beyond the Appalachian Mountains. The ejection of the French from North America meant that the colonists’ desire for further westward expansion grew stronger at the very time when such expansion was denied by the Crown. In the eyes of the colonials the war had opened up the vast North American continent for further expansion and settlement. A 1763 famer’s almanac summed up the prevailing mood; â€Å"But now behold! The farmer may have land for nothing†¦Land enough for himself and all his sons, be they ever so many.†[6] Something had to give and the issue of pushing back the frontiers soon brought the colonies into conflict with the Empire and added to the clamor for independence. Ironically the imperials expansionist ambitions of the settlers brought helped turn them against the impositions of the British Empire. The huge cost of the French and Indian conflict, and the wider Seven Years War meant that British debt spiraled as a result. To help ease this financial burden a greater taxation was imposed upon the colonies. This fiscal burden, along with the philosophical objections no taxation without representation went the famous cry – made the colonies further question the wisdom of British rule. Protecting the continent had cost the British dearly and relative to British taxpayers the colonists paid less in taxes even though they were more prosperous. A prewar British debt of  £73 million had grown to  £137 million postwar[7] and the burden of administering North America was now more costly because the Empire had expanded so greatly. The colonists objected to paying what they saw as arbitrary taxes to a distant parliament where no colonist sat. Furthermore, the new taxes came at a time when the colonial economy was suffering a downturn, making them even more resented. The rebellio n over taxes, the Stamp Act in particular, also had the effect of confirming British suspicions that the colonists longed for independence and helped set the colonist on a collision course with the Mother country. In conclusion, this paper has demonstrated that the French and Indian war was a crucial contributing factor in the creation of an independent America. Whilst the American War of Independence may get much of the glory, the events of 1754–1763 clearly sowed the seeds for the colonies’ break away from the British Empire. It did so due to four key reasons. Firstly the war encouraged the colonials to view themselves as equals yet their status had has not undergone a similar conversion in the eyes of the Mother country, leading to discontent in North America. Secondly, the removal of the French threat also meant the removal of the common enemy that united the colonies and Britain, thus leading the colonists to question their ties to the Crown. Thirdly, the French and Indian war, due to the vast expansion of the North American empire, resulted in Royal Proclamation of 1763 which denied any further westward expansion, the very expansion that the settlers desired. Finally, the c ost of the French and Indian war, and the wider Seven Years War led to increased taxes being imposed upon the colonies who resented paying what they felt were arbitrary taxes to a distant parliament, especially in a time in which they were experiencing an economic downturn. All of these factors combined to stoke the fires of independence and rebellion in North America leading to the creation of an American nation free from imperialism. As Anderson argues, without the French and Indian war â€Å"American independence would surely have been long delayed†[8] Bibliography Anderson, Fred, Crucible of War: The Seven Years War and the Fate of Empire in British North America, 1754-1766 (London: Faber Faber, 2000) -, The War That Made America: A Short History of the French and Indian War (New York: Penguin, 2006) Fowler, William M, Empires at War: The French and Indian War and the Struggle for North America, 1754-1763 (New York: Walker, 2005) Jennings, Francis, Empire of Fortune: Crowns, Colonies and Tribes in the Seven Years War in America (New York: Norton, 1988) McLynn, Frank, 1759: The Year Britain Became Master of The World (London: Jonathan Cape, 2004) Taylor, Alan, American Colonies: The Settling of North America (London: Penguin, 2001) Footnotes [1] Anderson, Fred, The War That Made America: A Short History of the French and Indian War (New York: Penguin, 2006) [2] Anderson, Fred, Crucible of War: The Seven Years War and the Fate of Empire in British North America, 1754-1766 (London: Faber Faber, 2000) [3] Taylor, Alan, American Colonies: The Settling of North America (London: Penguin, 2001), 437 [4] Anderson, The War That Made America , 746 [5] Taylor (op cit) 438 [6] Ibid. 437 [7] Ibid. 439 [8] Anderson, Crucible of Wa,r xi

Research Methods Aims And Objectives In Business Business Essay

Research Methods Aims And Objectives In Business Business Essay The purpose of this Chapter is to discuss and justify the methodology used to effectively investigate the phenomenon informing the research title which is; The Impact of a company managed online community on purchase decision and brand loyalty Firstly, this chapter explains the conceptual structure of the research which will describe how the author is going to carry out the research. Then, explains research method types and methods use to retrieve the collected data by primary research. Research methodology explains the overall structure of the study. According to Croswell J (2010) methodology is the analysis of principle methods, rules and evaluation employed by a researcher. The discussion is focused on matters regarding the purpose of research, research philosophy, research approach, research strategy, data collection, data analysis, and quality standards. 3.2 Research aims and objectives The study aims seek the dimensions of an online community hosted by a company and how it affects consumers purchase decision. In addition, this study investigates how an online community can attribute to generate their brand loyalty through its own brand community. These are the objectives: To investigate a company managed online community and characteristics To identify key influencer in online purchase decision To investigate the relationship a company managed online community and consumer purchase decision To find out the relationship between a company managed online community and brand loyalty 3.3. Research Process The research process used to define the approach of the research in the study in exhaustive. In figure 3.1 research process onion describes the issue underlying the choice of data collection methods (Saunders et al. 2009). Below figure shows the overview of the researchers methodology towards this research. Figure 3.1 Research Process Onion. Source: Created by the Author, adopted from Saunders et al (2009:108) Also, figure 3.2 shows the outline of process for this research. Figure 3.2 Process of the authors research Source: Created by the Author(2010) 3.4. Purpose of research There are three different types of research, and Yin (2009) writes that these are exploratory, explanatory, and descriptive. The purpose of the research determined which one of these to use in order to be able to fulfil this purpose. Saunders et al (2009) describe exploratory research as a way to find or look for new insight or to see what is going on. They further state that it is especially good to use if the purpose of research is to increase the understanding of a problem. Gliner et al(2009) complement the characteristics of exploratory research by adding that this type of research calls for flexibility, since new information can change the direction of the research. Gliner et al(2009) conclude that descriptive research is characterized by that the problem is clear and well structured. Saunders et al (2009) writes that it is necessary to have a good picture of the problem before the data collection. The focus of an explanatory study is to find interrelations between the variables in the studied situation or problem (Saunders et al, 2009). Saunders et al (2009) also states that analysis of quantitative data can show correlations between factors which gives the researcher a picture of the relationships involved. The overall purpose of this research was to investigate the area of online communities and its influence on purchase decision and brand loyalty. The goal was to seek out if marketing in these specific media channels are more accepted among consumers, and why this is the case, in order to gain a better understanding of their effectiveness and influence. This led us to use a both exploratory and explanatory approach. In the data collection and in the analysis we explore, and in the findings and conclusions we begin to explain. 3.5 Research Philosophy The research philosophy is determined by the philosophical points of views, as there are different approaches about the way in which the knowledge is urbanized and judged as suitable. Thus, the research philosophy relates to the development of knowledge and the knowledges nature (Saunders et al, 2009). The literature suggests three main approaches in which to conduct a research process and all of them have an important part and role in business and management. These are Positivism, Realism and Phenomenology. 3.5.1 Positivism Positivism is described as the conventional way of research and it acquires a clear quantitative approach to find out phenomena as an alternative of qualitative approach (Croswell, 2009). That is also said that positivism is very important approach in natural science (Remenyi, 2002). The understanding of this idea may not be proven but the philosophy based on positivism is far more powerful than the ideas for reaching targets and achieving goals. Positivism is very important research philosophies for creating new ideas. Thus, positivistic research tries to identify the non-financial motivation techniques provided by Tesco-express. The researcher uses the idealistic approach of positivism while using a questionnaire with a group of people. 3.5.2 Realism Another approach which relates to the positivism is realism (Saunders et al, 2007). According to Kothari, (2005) Realism is the source of many ideas, belief and opinions of human. 3.5.3 Interpretive Interpretive studies presume that people produce and correlate their own subjective and inter subjective meanings as they interact with the world around them. Interpretive researchers thus attempt to understand phenomena through accessing the meanings participants assign to them (Orlikowski and Baroudi 1991). Here researcher has decided to choose a Positivism philosophy, based on the aim of the research. The reason behind choosing this approach is responses does not influence the researchers belief and the knowledge (Proctor 2006). Also Positivism is one of the strongest research philosophies for creating new ideas. In addition to this, according to Gill (2002), the importance of a highly controlled methodology facilitates replication and experimental explanation to statistical analysis. 3.6 Research Approach There are two different types of approach for research. These are deductive and inductive theories(Bryman, 08). Deductive theory represents the commonest view of the nature of the relationship between theory and social research(Bryman, 08). First, theory and the hypothesis come and drive the process of gathering data. On the other hand, inductive process involves observations first and generalise the theory after the observations. This study is a business problem, more specifically how online community hosted by a company influence its consumers. Therefore, the aim of this study is to understand of the consumers who use online communities as a tool of interaction. Therefore, this study needs deductive approach. 3.7 Research Method There are mainly two types of research strategies which we can choose: quantitative and qualitative. These approaches are depending upon the structure and the purpose of the study(Bryman, 2010). Quantitative research can be constructed as a research strategy which collect and analyse quantitative data. Quantitative research requires a deductive approach to the relationship between theory and research, also it has incorporated the practice the natural scientific model and norms of natural scientific model and positivism approach(Bryman, 2010). A quantitative research approach used numbers ask base for the analysis instead of words like a qualitative would do. Blaxter et al(2010) adds to this explanation by describing that quantitative research uses a large-scale set of data. Qualitative research is more exploratory and focuses on smaller numbers and depth data. Qualitative data is mostly collected using conversation, and unstructured and semi-structured interviews. Quantitative data, the corresponding are; structured observations, interviews and surveys, and attitude scaling. By contrast, qualitative research emphasizes words rather than quantification in the collection and analysis of data(Bryman, 2010). Qualitative research data is collected from focus groups, in-depth interviews and observations. Qualitative research can be used to understand more deeply consumers attitudes towards purchase decision. But qualitative research is hard to analyse, and evaluate. Also, small number of target audiences cannot be represented whole population. For this research, a quantitative study is better because of the need for several different views on the questions and to decrease the factor of that different people think differently. 3.8 Research Strategy The decision of which strategy to use can be guided by the form of research question, the degree of control needed of behavioural events and if the focus is on current or historical events (Yin, 2003). The different choices of strategies available are; experiment, survey, case-study, grounded theory, ethnography and action research (Saunders et al, 2000). Experiments are commonly used in natural sciences and psychology, and are characterized by for example the introduction of planned changes on the variables in the experiment, and control of the other variables (Saunders et al, 2000). Surveys allow for the gathering of large quantities of data from a population in an economically efficient way (Saunders et al, 2000). Saunders et al (2000) also describe this method as having the advantage of that the analysis of the data will allow for easy comparison between the respondents. A case study is especially useful for gaining rich and detailed data (Saunders et al, 2000). They also state that case-studies are particularly good to use when asking how, what and why questions (ibid). Grounded theory is based on that a data collection is performed without the previous construction of a theoretical framework (Saunders et al, 2000). The initially gathered data is then used to make predictions that then are tested in the later stages of the data collection (Saunders et al, 2000). Moreover, the purpose of ethnography is defined by Saunders et al (2000) in the following way; The purpose is to interpret the social world the research subjects inhabit in the same way in which they interpret it (Saunders et al, 2000, p.95). They also state that ethnography is not commonly used in business research (ibid). Action research is however dedicated to researching the management of change, and the researcher often must participate in the setting where the change occurs. (Saunders et al, 2000). At first, action research, grounded theory, ethnography and experiments were discarded from the planning because of the mismatch between these methods and the purpose of research. After this, the search for a method with a match between the purpose of research and the characteristics of the method started. In table 2 below, these different criterions for the use of a survey are presented. 3.9 Data Collection Methods Bradley stated that the term primary data can describe information which is collected for a special purpose. On the other hand, secondary data has already collected by someone else for their purposes(Bradley, 2007). 3.9.1 Primary data When executing a quantitative method of data collection, the most common way of collecting data is through the use of questionnaires as it gives greater opportunity to gather information from a large number of respondents without a great amount of resources (Johannessen Tufte, 2007; Saunders, Lewis Thornhill, 2000). For the empirical research a self-completion questionnaire was deemed appropriate. This is because the research was conceptualised around obtaining information from, or about, a defined set of people or population; namely online community users (Easterby-Smith, Thorpe Lowe, 2002). There are generally two ways of conducting a questionnaire: through a self-completion questionnaire or a type of structured interview assisted by the interviewer. A self-completion questionnaire is, as the name suggests, a questionnaire where the respondent answers the questions themselves unassisted. This is in contrast to an interviewer assisting the questionnaire process by, for example reading the questions and marking up the responses as conducted in structured interviews (Christensen et al, 2001). As the research aims to understand online users, the internet was the natural medium in order to reach the desired target group. Therefore it was clear that the questionnaire would be designed as a self-completion questionnaire given that assisting the questionnaire process through structured interviews would be difficult to execute via the internet. 3.9.2 Secondary data Secondary data is formed of paper documents such as books, special reports, government produced records, and internet sources. Secondary data can help to combine it with other facts. Therefore, secondary data it good for enhance understanding of results and to confirm results(Bradley, 2007). Secondary data called as desk research, these can be searched from various sources any time. Therefore, this research can give time and cost beneficial to researchers. On the other hand, secondary research has limitations such as irrelevant to the research. But secondary research can gives general ideas of the research theories and can help save the time. In this research, following secondary data can be used to understand and enhance research. 3.9.1. Books My research is involved consumer behaviour, brand loyalty and online communities. Therefore, theories from literatures those books will be relevant to my study. Also those theories can gives general ideas about this research. Moreover, theories about culture also can be used to understand Korean culture. Books have many advantages, for example, books are easy to access, and easy to get information which is relevant to my study. Meanwhile, printed books are heavy and sometimes only can access old ones. But, nowadays, online books are widely disseminated. Internet technology helped to access those resources without any restriction of place. Internet books are very useful to get information easily. For my research books are important to understand the theories. Books can be found in the libraries and internet. 3.9.2. Journals Previous researches such as online communities, consumer behaviour, cosmetics, and decision making processes can be used as a literature review and as a guideline for my research. These previous researches can be found in the internet journal web sites such as ebsco host. Also, written journals can be found from the libraries. Journals have many advantages; journals include recent researches and recent information. Therefore, journals can give new ideas and new information for my research. On the other hand, some journals are not be accessed easily. Thus, there is a limitation for access. But, journals are useful for research to get recent research finding and applied theories to wide my research. 3.9.3. Online database Internet sources can be categorised as online database. Information search engines such as google, yahoo, or blogs and company web sites will be used for gathering secondary data. These secondary data will help guide my study and enhance understand the research areas. 3.9.4. Statistical database Published government database, government web sites, and the companies figures will be used for secondary data. These data will give a real figures about the industry which I will study and support my research as an evidence. 3.10 Sampling and Questionnaire design 3.10.1 Sampling Sampling is the process of taking parts form a defined population in order to examine these parts, usually with the aim of making judgements about the parts of the population that have not been investigated(Bradley, 2010). Also, it has a major advantages compare with other methods which is that it usually cost saving and time saving because, it investigate small portion of the whole population. On the other hand, the major disadvantage is that the process cannot summarise every characteristic in that given population(Bradley, 2010). This study identifies the target group of respondent which are Beautynet users. Data collected from the designed questionnaires and these questionnaires is sent to the online community users through the internet. However, the sample size of this study is limited 300 users from the online community, because of limited research time and limited analysis time. Returned questionnaire is analysed using statistical methods. Statistical methods are useful to understand the relationship and the users behaviour patterns. Therefore, this method can explain the relationship between the online community and its influence purchase decision, and the relationship between the online community and brand loyalty. 3.10.2 Questionnaire design The questionnaire was designed to collect the demographic information of the respondents covering age. Social class information includes education, occupation and income, (questions number 1, 2, 3, and 4) using multiple choice questions. According to Fisher (2007) this type of questions provides respondents with a choice of three to five options and asks them to choose one. This type of questions giving unambiguous options that is mutually exclusive. Authors also applied multiple choice questions to study the respondents purchasing behavior in questions number 5 to see the frequency of purchasing makeup products, question number 6 to see how much money they spend on buying makeup and question number 7 asking respondents about type of makeup product they buy mostly of. Lastly, Likert scales was applied to ask respondents about their opinions and attitudes and to ask them to choose a position on a five-point scale between strongly agree and strongly disagree (Fisher, 2007, pp.195-196). A Likert scale was applied to question number 8-26 to study the respondents attitude toward brands and their purchase decision. 3.11 Analysis of Data In order to analyze the data collected through the survey, the numbers were first statistically sorted to facilitate the surveys different ways of thinking, and then further analyzed to find possible significant patterns. This process of making sense of the raw data was made with the help of the statistical computer software Excel, from which we could generate different tables and diagrams. The raw data, together with an overview of the results can be found in chapter four. The analysis found in this chapter had two purposes; initially t to help the readers to understand, and secondly help us as researchers. In order to make the gathered data more clear, it was coded with the help of Excel and made fit in a spreadsheet, as suggested by Saunders et al (2009). 3.12 Quality Standards Validity and reliability are the two most important quality standards in research studies which this research aims to uphold a high standard of. Validity is concerned with how accurately a variable fits a concept, that is, through determining how accurately the instrument chosen measures the features intended to be measured (Bouma Atkinson, 1999). According to Easterby-Smith, Thorpe Lowe (2002) there are three ways of estimating validity namely (1) face validity: whether the instrument or its items are plausible; (2) convergent validity: the confirmation from comparing the instrument with other independent measurement procedures; and (3) validation by known groups: which is as suggested, comparing groups otherwise known to differ on the factor in question. The questionnaire was carefully constructed based on the models used in the research in order to achieve, as certain as possible, the intended results from the questions probed. Easterby-Smith, Thorpe Lowe (2002) recommend that tests for validity and reliability should be made at the pilot stage of an investigation, before the main phase of data collection. As such a pilot study has been conducted to ensure that the web-questionnaire is constructed to examine, as closely as possible, what it should examine. This was also initiated in order to secure that the questions would be interpreted correctly by the respondents thereby testing the validity of the questionnaire. In reality, it is not known whether all the questions were interpreted as intended, although a pilot study provides useful indications of problems in advance so that miss-interpretation can be minimised. Reliability is concerned with the stability of the research (Easterby-Smith, Thorpe Lowe, 2002). As stated by Christensen et al (2001) a study should be able to be conducted a second time by other researchers and yield the same results if it has a high reliability. Since this research had been conducted with a social constructionist approach reliability is not particularly relevant to the quality standards. This is because a social constructionist approach is interpreted by the researchers knowledge during the analysis process of the research. The personality of the researcher is also an influencing factor within the results. Therefore the research is limited in its ability to yield the same results if conducted a second time. 3.11 Research Limitations The study is conducted within the limited time. Thus, the population of the target audience is limited to a certain number. Therefore there is a limitation to understand all online community members and their attitudes. Also, this study aims to find out the online community and its impact on purchase decision and brand loyalty. Therefore, this study only focused small parts of consumer behaviour. Thus, future research should be considers include some other areas of consumer behaviour and large numbers of target audience to get more reliable data. 3.12 Conclusion The researcher has chosen the positivism philosophy for the research after given explanation of different kind of philosophy. While this research is about business problem, therefore, deductive theory has chosen to explain previous theories about business matter. Researcher has used quantitative method for the analysis of the data and the reason behind choosing is the population of Beautynet is too big to do qualitative method and quantitative method can be used to understand the target audiences behaviour patterns. Primary data has collected by survey from Beautynet users, and secondary data was collected by using the relevant books, journals, Most appropriate option for conducting the research is the descriptive type of research approach. The data collected for this research is using both questionnaire and the secondary data from the books, journals, online database, and statistical database.