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Could the Next Financial Crisis Involve a Carbon Bubble?
by Tristan Bove Americas Sep 20th 202112 mins
In 2006, housing prices in the US hit an all-time high, fuelled by speculation, exuberant spending, and high demand despite a rapidly falling supply. When some homeowners were inevitably unable to pay back their mortgages or federal loans, many homes foreclosed, leading to a dramatic decline in housing prices. This caused the so-called housing bubble to burst, partly contributing to the worst financial crisis in recent US history that was felt across the world. Financial bubbles have affected everything from the housing sector to the Internet, cryptocurrencies and comic books, and as we move towards a low-carbon future, we may soon be faced with another bubble: the carbon bubble. What is a carbon bubble, and how bad could it be?
Financial bubbles occur when the price of an asset becomes warped by implausible projections of the future. Often, shareholders may speculate that their assets will continue to be valuable, maintaining high stock prices and consumer confidence. Sometimes, however, demand and market confidence will be met with real-world situations that devalue the asset. In the case of the housing bubble, a combination of federal spending and extremely generous loan policies from banks allowed demand for houses to rise, even though the actual supply of homes was dwindling.
When faced with a bubble, shareholders can either play it safe and shift investments away from the straggling asset, or they can double down and speculate that it will maintain or increase its value. More often than not, this eventually leads to a bubble bursting, and in the worst-case scenarios, a financial crisis and market crash.
In the US, the housing market crash is regarded to be one of the main causes behind the 2008 financial crisis that afflicted the entire world. In addition to the stock market crash and a global recession, the housing crisis in the US caused 8.7 million jobs to be lost, almost 500 banks to fail and over 8 million homes to be foreclosed.
The impacts of financial bubbles are always temporary, and markets tend to reset after a period of stagnation or recession. The severity of bursts are more volatile, depending on the sectors involved, how many people are affected by the crisis and whether or not the consequences cascade globally. But regardless of how long a bubble burst-induced recession lasts, people suffer because of it.
The 2008 financial crisis was bad, but the next bubble might be even worse. Investors often speculate on the continued growth of assets that have historically done well for them, not always acknowledging the pace of technological change and inevitable shifts occurring in markets. As economies and governments progressively, albeit painstakingly slowly, cut their ties to fossil fuels and transition to low-carbon technologies, could we be faced with a new financial crisis, this time involving a carbon bubble?
Are We Done With Carbon?
Much like when fossil fuel-powered cars first displaced the horse economy a century ago, the world is on the verge of a similar disruption, this time involving low-carbon technologies ranging from solar panels and wind turbines to electric vehicles and batteries with immense storage capacity. These technologies can and already are displacing the smokestacks, internal combustion engines and pipelines that have defined our modern era, and not a moment too soon.
Simply put, we desperately need these technologies. Burning fossil fuels is releasing more and more carbon into our atmosphere, warming our planet to degrees not seen in millennia. This is already causing severe weather impacts, agricultural failure and biodiversity loss across the globe, and making several parts of the world starkly uninhabitable.
Some impacts of climate change may well already be locked in, but the more carbon we avoid putting into the atmosphere now, the more liveable our future will be. 1.5°C of warming is bad, but it is much better than 2°C. And as bad as 2°C would be, 3°C would be unimaginably worse. Every particle of greenhouse gas we avoid putting into the atmosphere counts, because every fraction of a degree's worth of temperature rise counts.
This is why it is so important to shift away from fossil fuels as soon as possible through every technological tool we have at our disposal. Every time someone decides that their new car will be electric instead of oil-powered, that is just a little less carbon that could have been injected into the atmosphere. And every time a power company or government decides to commission a solar farm instead of a coal plant, that's even better.
From a humane standpoint, these are not difficult decisions to make, and it's not difficult to see where the future might go. Renewables and low-carbon alternatives are better for the planet, for our health and for that of every living thing that may exist.
From an economics standpoint, fossil fuel companies and some politicians have long entertained the notion that carbon-free technologies are too expensive to implement and would cause a financial crisis. Were this correct, then economically speaking they would be right to be skeptical about carbon-free technology. If there is a bigger profit margin to be made from a perfectly cheap pile of coal lying around, solar or wind could never break into the market.
But of course, this argument is simply untrue. A 2021 report by the International Renewable Energy Agency showed that the cost of large-scale solar power has fallen by more than 85%, while onshore wind has fallen almost 56% and offshore wind has dropped 48%. In 2020, solar and wind power's levelised cost of energy (LCOE, how much it will cost for a power plant of a specific energy source to generate electricity over the course of its lifetime) fell below that of coal and natural gas in most of the world, and the International Energy Agency also released a 2020 report that showed how cost competitive renewable energy had become with fossil fuels.
This trend is expected to continue. Two thirds of solar and wind farms built in 2020 will provide cheaper electricity than even the cheapest coal plants, especially in places like Europe, the US and India, where building a new coal plant will become much, much more costly. Given its high cost, and the promise of renewables, around three quarters of plans for new coal plants have been scrapped since the Paris Agreement to mitigate global greenhouse gas emissions was signed in 2015.
More government regulations on burning fossil fuels in recent years have made the activity less profitable, but the rapid decline in cost for renewable energy is primarily due to organic market forces.
Renewable energy sources, a new and rapidly evolving technology, follow learning curves, which means that the more renewable energy installations are built, the more costs will fall. Cost declines are aided by a number of factors that accumulate as more wind and solar farms are installed, including more research and development to improve efficiency, economies of scale creating better specialisation and simply learning by doing as companies develop incremental improvements to industrial operations, installation procedures, and sales and financing processes.
Fluctuating prices of different energy sources as installed capacity increases. The costs of solar and wind power experience a steep decline due to learning curves, while coal and nuclear stay the same or become more expensive the more plants are built/ Source: Our World in Data.
Renewables benefit from learning curves because they are new technologies with a high ceiling for improvement. The price of electricity generated from fossil fuels, meanwhile, does not. Due to learning curves, many project that the price difference between expensive fossil fuels and cheap renewable energy will only become larger as time goes on.
So from an economics standpoint, markets are telling us that a transition towards renewables is inevitable, and from a common sense standpoint, we know that we should be investing more of our resources into renewable energy to preserve our future. Good news, right?
Yes, but what happens to all the leftover fossil fuels? What will happen to the infrastructure and fossil fuel reserves that have benefited from decades' worth of capital investment, but have suddenly become stranded assets, unable to turn a profit? A carbon bubble is what happens, and it might be much larger than we think – potentially equal to the housing bubble that caused the 2008 financial crisis.
The Carbon Bubble
The notion of a carbon bubble is based on our knowledge that 2°C is the absolute maximum amount of temperature rise we can cope with. Any more than 2°C, and the future frankly becomes too nightmarish for a carbon bubble to even register as a cause for concern.
To stay under that benchmark, ideally far under it, we would only be able to burn a certain amount of fossil fuels which release carbon into the atmosphere. Any more than that, and we are basically over-budget.
If we were to extract and burn all the remaining fossil fuel reserves in the world, global temperature averages would warm well past 2°C. This has been called 'exceeding our carbon budget,' the finite amount of carbon we can release into the atmosphere. The 2°C ceiling, which has now been largely amended to target a temperature rise of less than 1.5°C, is what we have to play with during our energy transition, but if we were to burn through all the fossil fuels that we could conceivably extract, we would be vastly over-budget.
A 2021 study published in Nature proved that, to have a 50% chance of staying within a 1.5°C temperature rise scenario, 60% of remaining oil and fossil methane gas reserves and 90% of coal reserves must remain un-extracted by 2050. All these remaining reserves, the so-called 'unburnable carbon,' create a fossil fuel overhang of remaining reserves that we cannot touch.
How much 'unburnable carbon' still exists in remaining fossil fuel reserves/ Data by Welsby et al/ Graphic by Earth.Org
The carbon bubble problem arises when we consider that all those reserves – every drop of oil and eventual particle of atmospheric carbon – are currently included in the valuation of the companies that own them. Basically, unless we want to exceed our carbon budget, these companies are massively overvalued. Every major oil and gas corporation, which are all listed on the stock exchange and in which countless people are invested, are valued on the basis that we are going to burn through all of our existing reserves, because that is the economical thing to do. If you own an asset, even if it is unburnable carbon, responsibility to shareholders means that, in theory, the company that owns it has to profit from it.
This leads to two potential outcomes. On the one hand, fossil fuel companies burn through all their existing reserves, blow past our carbon budget and cook the planet beyond recognition. Alternatively, governments step in with regulations and stop companies from extracting unburnable carbon, which would make these massive fossil fuel corporations extremely overvalued, basically overnight. The fossil fuel company you are invested in becomes the house you spent your savings on, and all of a sudden, that house has no value anymore.
Who is complicit in creating this bubble and potential financial crisis? Well, it isn't only the fossil fuel companies, but also the large and respected monitoring agencies that provide updated measurements of different energy sources' LCOEs. The think tank RethinkX published a recent report that highlights how the International Energy Agency, the US Energy Information Administration, Wall Street analysts and others have routinely been overvaluing the LCOE and associated costs of conventional coal, natural gas and hydro power plants for years.
Investors, regulators and policymakers rely on these agencies' assessments to make decisions, but have been misled to think that fossil fuels and older forms of renewable energy plants produce much more electricity than they actually can, and are therefore far less expensive than they actually are, making those power plants appear as good investments when they really aren't.
The RethinkX report points out that since 2010, $2 trillion dollars have been invested in fossil fuels and nuclear power based on misleading assumptions on the value of these industries. These risky investments have only been exacerbated by even more uncertain speculation in the effectiveness of unproven technologies like carbon capture and storage. The report estimates that the LCOE of coal, gas and hydro has been overvalued by as much as 400%, and that the resulting carbon bubble could swell to be worth over $1 trillion in stranded assets by 2030.
Shrinking the Carbon Bubble
But wait, how could a carbon bubble impact me if I've never invested any money in fossil fuel companies?
Even if you have not personally invested any money in fossil fuel companies (and hopefully you haven't), it is very likely that your pension fund has. A 2020 study found that pension funds in OECD countries could collectively manage anywhere between €238–828 billion in fossil fuel assets (up to USD$978 billion). In the UK alone, despite promises to divest from fossil fuels, £10 billion are still invested in fossil fuels from local government pension funds. Even if very few of us are shareholders in fossil fuel companies, we are all, directly or indirectly, stakeholders in their fortunes and misfortunes.
The carbon bubble has investors concerned. In 2013, unreasonably prescient British investor Jeremy Grantham, who manages over USD$106 billion in assets, pulled out of all coal and unconventional fossil fuel investments, such as tar sands.
"The probability of [fossil fuel companies] running into trouble is too high for me to take that risk as an investor," Grantham said, adding that: "If we mean to burn all the coal and any appreciable percentage of the tar sands, or other unconventional oil and gas then we're cooked. [There are] terrible consequences that we will lay at the door of our grandchildren."
Much like with the housing bubble and subsequent financial crisis, there are no easy answers here. We need to eliminate fossil fuels from our energy grids, and to do this, some of the biggest and wealthiest companies in history cannot touch the vast majority of their assets.
The best-case scenario for a way out is a managed decline to shrink the bubble as much as possible before fossil fuels, and also nuclear and hydro power, become financially unviable, completely outcompeted and disrupted by modern renewables. This has to come from governments, who should ensure that the public become gradually divested from these archaic forms of energy generation. At the same time, governments need to support the expansion of renewable energy sources that will replace them.
It is uncomfortable to think of, but most people are indeed financially invested in fossil fuels, either through pension funds or even regular unassuming asset managers. In 2021, half of the world's 29 largest asset managers did not have a policy in place to exclude coal as an asset. And while many asset managers have pledged to be leaving coal behind, the world's three largest asset management groups, BlackRock, Vanguard and State Street, still managed over $300 billion worth of fossil fuel investments as recently as 2019.
Larry Fink, CEO of asset management group BlackRock, has been vocal about the need for the financial sector to make a more decisive push towards climate-aware investing/ Source: World Economic Forum.
Without decisive action to eliminate fossil fuel-related assets from their portfolios, the carbon bubble will impact these firms, within which normal people from all over the world are invested. And even if we are not directly invested in the fossil fuel companies themselves, most of us are invested in the infrastructure that supports them, from pipelines to roads and railways. To minimise the impact of this impending financial crisis and bubble, governments need to ensure that asset managers and pension funds worldwide are divesting from fossil fuels now.
There are some positive signs. In 2020, New York State's pension fund worth $226 billion, one of the world's largest and most prolific investors, announced to be dropping most of its fossil fuel stocks by 2025, and by 2040 will have sold all its shares in companies that contribute to global warming. "New York State's pension fund is at the leading edge of investors addressing climate risk, because investing for the low-carbon future is essential to protect the fund's long-term value," Thomas DiNapoli, the state comptroller, said.
New York's decision to divest its pension funds from fossil fuels follows similar action taken in Ireland and Sweden. Norway, which manages the world's largest sovereign wealth fund at $1.4 trillion, also sold the last of its stocks in fossil fuel companies in Januray 2021. The following September, the Norwegian government upped the stakes by requiring that all companies in its portfolio maintain strict 2050 net-zero targets.
On an individual level, we can all become more cognisant of where our money is going. Fossil Free Funds is a search platform that can tell users whether their pension funds, mutual funds or individual investments are tied to fossil fuels, and lists options that provide guilt- and risk-free alternatives.
Divesting from fossil fuels isn't only the morally right thing to do, it is a financially wise decision, and people still have the agency to protect themselves. Ultimately, however, government policy will be needed to ensure that the financial impact of new technologies taking over from fossil fuels be minimised. The carbon bubble has the potential to cascade into a much bigger financial crisis, but it doesn't have to, as long as governments are willing to think long-term and consign fossil fuels to history today.
Tristan Bove
Tristan is an International Studies and Chinese graduate of DePaul University. He has experience researching the impacts of humanity's relationship with the environment, and how states can successfully implement strategies for sustainable development. As Policy and Economics Editor, his current interests revolve around the developmental policies that can reconcile equitable economic growth with pathways to a net-zero future.
tristan.bove@earth.org
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In this lesson, you will learn the difference between the print on demand services, KDP Print and Createspace. Both are owned by Amazon, however, there are differences between the two that all authors should know about.
Through this episode , hope you'll be able to know which one you should use, and if you have used the other previously, is it worth switching your books over.
For more in-depth information on the current comparison of the two POD's, be sure to check out my full article on the two here.
Gundi Gabrielle, aka SassyZenGirl loves to explain complex matters in an easy to understand, fun way. As a Top 100 Business Author & Entrepreneur, she's helped hundreds of newbie authors reach #1, outranking the likes of Tim Ferris, John Grisham, Hal Elrod and Liz Gilbert.
When she is not writing books or enjoying a cat on her lap (or both), she is passionate about exploring the world as a Digital Nomad, one awesome adventure at a time.
More from Gundi in her newest book INFLUENCER FAST TRACK and this FREE Training Video.


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Q: This user seems primarily to be promoting their own blog; What should I do? I'm speaking of this user.
Many of their posts are merely links to a couple blogs, and I have flagged them as "not an answer" and left hopefully helpful comments for the user.
But while looking at their answers, I also noticed that it seems likely the blogs in question are their own; A number of their answer/links point to blog posts that were made on the same day as the answer was posted, and there are two blogs which are repeatedly linked to.
I know (suspect) that the requirement to share when you are affiliated with a product is not the same thing as requiring sharing when you are affiliated with a blog/site you are using as a reference. Of course, when sharing reference links to ones own content properly, it would seem to be beneficial to share that information.
But in this case, it seems the user in question is making blog posts almost directly targeting SO questions and then posting links as answers to them.
I suspect the "Not an answer" flags and comments left to indicate what we expect as an answer is probably sufficient here. Am I correct?

A: If you suspect they're just looking for questions to answer to promote their own blog, you can politely refer them to the relevant section of the FAQ:

May I promote products or websites I am affiliated with here?
Be careful, because the community frowns on overt self-promotion and tends to vote it down and flag it as spam. Post good, relevant answers, and if some (but not all) happen to be about your product or website, so be it. However, you must disclose your affiliation in your answers.
If a huge percentage of your posts include a mention of your product or website, you're probably here for the wrong reasons. Our advertising rates are quite reasonable; contact our ad sales team for details. We also offer free community promotion ads for open source projects and non-profit organizations.

You can also just flag a few of their posts and have a moderator notify them privately if you're not comfortable leaving a comment.

A: If the purpose of the answer is, in someway, just to post the link to the blog, then I would consider the answer spam too.
That is what I would think if somebody would keep posting answers that don't really answer the question, always adding a link to the same site (even if that site is drupal.org). It is what I would think also in the case somebody would answer to different questions about Drupal, always suggesting the use of a specific Drupal module, which could really be useful for the OP, when the OP is asking how to use a different module.
I don't think it makes a difference if the user is not affiliated with that blog, when he keeps answering with a link to that blog, and the answer doesn't really answer the question being asked.
To make an example, I am a site maintainer on drupal.org, which means I volunteered to make some tasks on drupal.org, and I have been given a rule that allows me to do things normal users cannot do (in some way, it is like being a moderator on a Stack Exchange site). I am not affiliated with the site, which means that I don't gain anything if there is an increment of visitors for drupal.org because the links I leave on other sites. Still, I think it would be inappropriate if I leave links to drupal.org in an answer that doesn't really answer the question; if, vice versa, I would leave an answer that is really an answer for the question, and I would give the link to drupal.org (or api.drupal.org, the sub-site for documentation) that is pertinent for the answer, then that would be appropriate.

A: In this case, you should flag one of the user's answers as "requiring moderator attention".  The dialog that pops up allows for you to write a custom message to the moderator.
In that box, you would outline that the user seems to be promoting their blog in their answers.
As a result, the moderator handling the flag will more than likely review the user's answers to look for astroturfing (excessive self-promotion), and take the appropriate action if it is deemed this is in fact the case.
If the flag was deemed helpful, then your flag will be marked as such, or, if not, it will be declined.

A: I think the number one rule is:

Are the answers helpful to the person that asked the question?

I find it very hard to consider a truly helpful answer to be spam,  likewise if someone sends me an unsolicited email that solve a detailed problem I have at that time.   (We are hitting the general problem of "how well targeted does spam have to be, before it is spam?")
If unsure, flag one of the answers and explain the issue – then let the moderators do their job.

A: I usualy check the post against the four bullets here How can I link to an external resource in a community-friendly way? and if they don't have all four, leave them a comment with the link. If the answer is just a link, I flag as NaA no matter who wrote the target page. If they have made some effort to paraphrase, but haven't mentioned their affiliation, I comment "this appears to be your own blog" and then carry on with the link to the answer above, so that subsequent readers understand the affiliation.
It's not bad for someone affiliated with a product to answer (case in point: Eric Lippert answering C# questions) but the less well known products might be using SO for promotion, so should say so. In the same vein, it's not bad for someone who knows a topic well enough to blog about it to link to that blog, but the link should provide a service to SO, not use SO to provide a service to the blog.
I get livid when accused of spamming for including links to my blog. I make no money from my blog, it has no ads and I host it myself. I link there for convenience and laziness, which are not particularly defendable traits, but are not the same as being a spammer. A gentle reminder not to be lazy is usually all that's required to get better behaviour from a non-spammer.

redpajama_set_name: RedPajamaStackExchange


From the magnificent slopes of Table Mountain to the fantastic majestic Grand Finale situated at Val de Vie Estate with a crazy time trial between, the Cape Epic 2018 route was designed to be bold and balanced. The overall distance covers 658km, with 13 530M of climbing that will include 4 consecutive days of 100km, and the final stage which is extremely difficult to reach the line, with a Stage 5 time-trial that may shake-up even the most elite riders. There will be highlights screened everyday on Supersport so we hope you have updated your membership and have your DSTV installation optimized for this amazing event.
This section covers over 20km with 600m of climbing. Short but extremely sharp, riders will have to ride over a vicious climb on 100m in length with certain sections that ramp up to steep and unforgiving gradients. The last punch on Table Mountain is Dead Man's Tree before they will find a mass of spectators waiting to cheer the riders on, where they will loop back onto the finish. The last challenge includes the quick descent associated with Plum Pudding, which is the Land Rover Technical Terrain section.
This section covers over 110km with 1900m of climbing. The first day of the Cape Epic is never easy that welcomes all riders that come with a smile that soon turns into a grimace associated with endurance and effort. This part of the race involves rolling around farm roads, that follow up with sharp kickers and a rock n%u2019 roll descent over rutted and rocky descent of Con's Single-track. The Takkap Climb occurs just before the halfway mark and is considered the largest challenge for this day. Then the "Hidden Cliff" of Skuilkraans forms a part of the 14km uphill battle before a small reprieve and a few more testing climbs that go through the Elandskloof Reserve.
This stage covers 110km and 2000m of climbing. This part of the race is similar to a 10-round championship boxing-match with its different climbs that throw uppercuts and jabs at the riders throughout the day. There is a bit of fun to be had with the Bosvark 10km single-track swoop after 82km, which for most riders is the highlight of their day. It is advisable to keep their reserves for the remaining 40km.
This is the transition day that is longest-stage for the Cape Epic but is not regarded as the most-challenging when it comes to terrain. This stage covers 122km and 1800m of climbing. The initial 20km will include 3 climbs, with Penn Hill the primary challenge for the day with a 3.5km brute climb which comes directly after a 12km uphill graft.
This section covers 111km and 1800m of climbing as is regarded as the toughest part of the race. This section is inclusive of the 2 hardest climbs of the Cape Epic that will leave a few riders extremely exasperated at certain times.
This stage is the flat out but very far from actually flat and covers 39km with 1430m of climbing. This is a timed trial that could shake event the most elite of the categories with the intensity associated with altitude gain and a very short day. Rondawel forms the first 5km of the race, followed by Plantation over 13km, and Seven Peaks over 22km. The fun really begins with Bobsled bridge along with the single-track descents of "Cool Runnings" and "Cool Runnings Two".
This section covers 76km along with 2000m of climbing. This is regarded as a fun-day for the Cape Epic, but riders still need to travel up in order to enjoy all the down hills.
The last leg of the Cape Epic involves 70km and 2000m of climbing, where the climb starts after just 3km on the Patatskloof, with the concrete strips which indicate the start of the Beulah climb. Once Protea Climb is completed riders are given a glimpse of the finish situated at iconic Val de Vie, yet are faced with the final challenge, known as Freedom Struggle Climb. This Bone Rattler descent will be followed up by a 3km bumpy, rocky and very loose descent where all riders need to exercise extreme caution. The last 6km is over the purpose-built singe track onto Grand Finale situated at Val de Vie Estate where riders get to celebrate wearing the Cape Epic finisher's medals.
Cape Town is known for its wine region and is a favorite destination for wine connoisseurs from all over the world. Some of the best and oldest wine farms in Cape Town are recognized internationally for the fine wines they produce. Here are some of the most popular wine farms in Cape Town.
Steenberg is the Cape Town's first farm which was established in 1682. The farm has grown into one of the finest wineries in the area over the span of 300 years even though it was not originally a wine estate. The farm produces some of the finest Sauvignon Blanc and Methode Cap Classique in South Africa, along with several other celebrated varieties like the Semillon, Cabernet Sauvignon, Merlot, Shiraz, Nebbiolo and the ICON wine Magna Carta. Steenberg's wines are primed to produce an experience that evokes the unique terroir of the estate through a process of environmentally considerate and dedicated winemaking.
Steenberg Wine Estate offers guests a selection of wine tasting experiences, with a Wine Tasting Bar, Tasting Lounge and Outdoor Terrace to choose from. Steenberg Farm boasts its 5-Star Steenberg Hotel which offers exquisite hospitality with spectacular views and plenty of history making it a complete leisure destination. Overall, the Steenberg farm is where heritage meets contemporary flair.
The Cape Point Vineyards an award-winning wine estate located in the south of the famous Constantia Valley in Noordhoek. It boasts its panoramic views of the mountainous Cape Peninsula and magnificent sunsets over the Atlantic. The winery and vineyards are located on the narrow Cape Peninsula and are perfectly situated to produce award-winning white wines. Cape Point Vineyards produces arguably the most complex and fascinating Sauvignon Blanc in the Western Cape. The farm also includes a restaurant and function venue. Its Banquet Hall is located in a unique setting with 360-degree views of mountains, fynbos, vineyards, and glorious sunsets over the Atlantic ocean. The visitors can taste their award-winning wines and enjoy a cheese and charcuterie platter at the Cape Point Vineyard's tasting room.
Groot Constantia is the oldest wine producing estate in South Africa. The word "Groot" in Dutch and Afrikaans translates as "great" (as in large) in English. It is also considered as a provincial heritage site. Groot Constantia produces an array of award-winning whites and reds that ships around the world, including Shiraz, Merlot, and blended red Gouverneurs Reserve. It is only in 2003 that Groot Constantia also began production of a Constantia dessert wine, called Grand Constance. The farm also includes two top class restaurants and a conference/events venue.
Klein Constantia is a146-hectare wine estate which was established in 1685. It sits on the upper foothills of the Constantiaberg. With its cool climate, this wine estate has been producing predominantly high-quality white wines including Sauvignon blanc and Riesling. It is also home to one of the world's leading natural sweet wines, the Vin de Constance. Klein Constantia features a tasting room which is open year-round to cater guests wanting to taste their wines.
Eagles' Nest is a 38-hectare farm cradled in a secluded valley high up on the slopes of the historic Table Mountain. The farm was originally a refreshment station for travelers on the mountain pass between Wynberg and Hout Bay harbor. In 2000, fires destroyed most of the farm. It has since been turned into an esteemed wine estate, which is now known for its award-winning red wines. The farm makes use of a unique terracing system to maximize the sunlight hours because the vineyards are planted on some of the steepest agricultural slopes in South Africa. Eagles' Nest is planted predominantly to Shiraz, Merlot, and Viognier and are maintained by hand throughout the year. Eagle's Nest is open for wine tasting and sales Mondays-Sundays from 10:00 am – 4:30 pm.
A trip to South Africa's world-renowned Cape Winelands is a treat for any wine lover. For many people this means a day trip by car or on a tour bus to enjoy some of the most scenic attractions (and some of the best wines) in the world.
However, there's another way to enjoy the sites, scents and sounds of South Africa's famous wine destinations such as the Franschhoek Valley, Paarl, and Stellenbosch – and that's on a Cape Town bike tour through the winelands.
These areas offer numerous trails and gentle meanders through the vineyards and green tree lined roads that make any wine tour a delight for the senses. These bicycle routes and tours are ideal for the nature lover and the family that is looking to spend some quality time in the fresh air of these unspoiled areas.
There are a number of different tour operators that make bicycle tours of the Cape Winelands accessible for visitors. The routes vary in intensity and range from gentle meanders suitable for all ages to more challenging and longer routes that take in a wide variety of different vineyards.
Tour operators will provide transport in an air conditioned bus to the Winelands, as well as provide a qualified and professional guide. The operator will also provide mountain bikes – suitable for the smaller gentle dirt roads that are found in many vineyards, as well as arranging entrance fees and wine tasting fees at the wine estates that are going to be the focal point of the vineyard cycling experience.
Some of the most popular tours are of the Stellenbosch region where those taking part can enjoy visits to up to four different wine estates. Included in these tours are visits to cellars, wine tasting and access to experts from the various estates who will be on hand to educate and inform riders about the wine making process and the finer points of wine tasting.
A sample itinerary for a day exploring the Winelands could consist of a gentle cycling experience suitable for the whole family. This would take in between two and three vineyards and usually take a day on a route that is up to 5 miles in length. This short excursion is suitable for all ages and is ideal for families with younger children. This sort of day out will sometimes include lunch at one of the world-class vineyard restaurants – often enjoyed under majestic Oak trees.
For a more strenuous exploration experience, there are also tours which can range up to 13 miles in length. This is adventure biking and wine tasting at its best. Many tour operators will offer three (or more) vineyards, as well as one of Stellenbosch's famous Van Ryn brandy distillery. During this route, riders will be exposed to some of the Cape's most scenic vistas – including the internationally acclaimed views over False Bay. In addition, riders will also be exposed to the culinary expertise of some of South Africa's most well-respected chefs and some of the most beautiful places to enjoy a relaxing and invigorating lunch in the beautiful surroundings of wine estates that can trace their heritage back to the 17th century.
A wine tour combined with a relaxing day of bicycling is the perfect way to enjoy some of the world's best wines and some of the best scenery in on the globe. With the wide variety of bicycling options available, this is an option that should be of interest to the whole family. If you have your heart set on the Cape Winelands this is well worth investigating.
One of the oldest Cape Dutch farms in existence, Babylonstoren is all about being the essence of diversity, capturing nature at its roots, and welcoming each and every guest to an experience of exceptional dining and beautiful surroundings.
With a rich history that dates back as far as 1692, Babylonstoren benefits not only from an exquisite location but can tell a story of historic fruit and impressive wine-making.
In recent times it has been tastefully restored in a way that, whilst retaining a passion and adoration for the riches of the past, coaxes this farm into the contemporary and modern living that makes up our world.
Whitewashed walls, grand gables, inviting fireplaces and authentic charm are all symbols of what Babylonstoren stands for. With a choice of accommodation, ranging from one-bedroom suites to three-bedroom cottages, guests have the flexibility to choose sleeping quarters which suit their personal needs and tastes.
An outdoor swimming pool, salt room, vitality pool and sauna can all be enjoyed by guests.
Even the stunning gardens of Babylonstoren are steeped in a European and Asian history. With 8 acres to explore, fruit and vegetables to admire and a stunning landscape to enjoy, the gardens really are at the heart of this incredible place.
To really appreciate what the gardens have to offer, guests can enjoy the Garden Tour, a guided tour which starts every day at ten o'clock, It's not just your eyes that will enjoy the tour, but your taste buds will have a lot to be happy about too! With guests being invited to use all of their senses, touching, smelling, tasting and of course viewing the produce under cultivation, this is certainly a walk to remember.
If you're a keen gardener, you'll also be grateful for the secret gardening tips that the guides are all too happy to share with guests, as well as details on the medicinal benefits of the plants growing in the garden.
Our predecessors surely were not exempt to the ravages of stress. That's why they created cleansing rituals that have stayed with us, right to this very day. To relieve muscle ache, tension, and stress, or simply to revive, cleanse and purify, the spa at Babylonstoren carefully treats guests to ancient cleansing rituals.
For guests who gain an appetite during the spa experience, fresh, tasty and nutritious spa food is always readily available. Making use of herbs from the garden, such as rosemary and lemon thyme, spa food is focused on being wholesome, mouthwatering, unusual and refreshing.
Set in an intriguing setting of Cape Dutch architecture and modern glass walls, the atmosphere created in the restaurant is a good gauge of the quality of food that is served there; contemporary, edgy and very local!
With a menu that constantly changes to match the season and local produce that leaves the mouth watering for hours after it has been devoured, the Babel restaurant at Babylonstoren allows your senses to truly feel at one with nature.
For an experience that promises to relax your mind, revive your body and nurture your soul, Babylonstoren is well worth considering for a welcome break away.
With an exquisite choice of accommodation, a serene spa that allows ancient rituals to take prime place and a restaurant that showcases wholesome foods, you will only experience one problem when you visit Babylonstoren; the time will fly by so quickly, that you just won't want to leave!
Favorite wines are largely a matter of individual taste, however awards and peer recognition, as well as export orders can usually be used as yardsticks to measure the success of a country's wine production.
In the case of South Africa widespread international recognition has been a mark of the success of its wine production and the excellence of its many different types of both red and white. this been the case for generations and has only accelerated since South Africa came out from under the dark cloud of Apartheid.
The South African region most often recognized for the excellence of its wines can be found in the Cape Province, South Africa's most southerly province – which is also home to what many South African's regard as the Mother City – Cape Town.
The Cape Winelands (as the area where wine production is widespread) boasts many areas of excellence, centered around the towns of Franschoek, Stellenbosch, Wellington, Robertson, Somerset West and Paarl. It is these areas where some of South Africa's best wine farms are situated.
It's a difficult choice to make, but if one were forced to identify five wine farms that should be on every international visitors the following 5 would certainly be in contention.
Rust en Vrede has been around for over 300 years and produces some of the Cape's most well respected Merlot's, Cabernet's and Shiraz (internationally know as 'Syrah') wines. Nelson Mandela has a keen appreciation for the wine produced at this estate and today it's also known for it's namesake restaurant which is consistently rated as among the best in South Africa.
Established in 1700 that wine farm consistently produces wines that score extremely highly in the top 100 wines of the world. The scenic gardens are an added attraction for visitors. The Cabernet Sauvignon V has won multiple awards across the world and is perhaps the star of the extremely attractive Vergelegen lineup. As far as white wines are concerned those in the know will always take the opportunity to stock up on the very well regarded the reserve Chardonnay and Sauvignon Blanc range available from the estate, it is however the red that has been favorably compared to the best that France has to offer.
For some the La Motte Chardonnay can stand head to head with the best in the world – and the Sauvignon Blanc's and Shiraz offerings are extremely well regarded as well. The Franschoek estate also plays host to the 'Pierneef à la Motte' restaurant – winner of multiple awards.
A well loved and regarded estate Meerlust was established in 1693 and it's Bordeaux blend Rubicon can be found in some of the finest restaurants across the globe. Other notable reds are the Pinot Noir and Merlot offerings. It also has a wide variety of very impressive white wines available. A visit to this estate will simply not disappoint lovers of red wine – while the whites are elegant and subtle.
This is one of South Africa's most venerable wine estates being established in 1694. The estate produces only red wines and that focus has enabled it to built a reputation as one of the premier red wine producers in the world. The rich and velvety Shiraz, Merlot and Cabernet Sauvignon wines are an absolute delight.
A visit to the Cape Winelands will provide a rich and varied experience for any lover of wine. As a bonus the value of South African wine due to favorable exchange rate is simply very hard to beat.


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Shofar: An Interdisciplinary Journal of Jewish Studies
Purdue University Press
Allegories of Scripture
James C. Nohrnberg
Volume 11, Number 2, Winter 1993, pp. 127-167
Editor's Introduction: Rediscovering the Hebrew Bible as Literature
Fighters Over Israel: The Story of the Israeli Airforce from the War of Independence to the Bekaa Valley (review)
Beyond Innocence and Redemption (review)
The Palestinian Uprising: A War by Other Means (review)
Hellenists and Hebrews: Reappraising Division within the Earliest Church (review)
Jesus Within Judaism: New Light from Exciting Archaeological Discoveries (review)
How Things Were Done in Odessa: Cultural and Intellectual Pursuits in a Soviet City (review)
Refugee Communities: A Comparative Field Study (review)
Organizing Rescue: Jewish National Solidarity in the Modern Period (review)
Inscribing the Other (review)
Dreyfus: A Family Affair, 1789-1945 (review)
The Economic Origins of Anti-Semitism: Poland and Its Jews in the Early Modern Period (review)
The Chief Rabbi, the Pope and the Holocaust (review)
Journey to Oblivion: The End of the East European Yiddish and German Worlds in the Mirror of Literature (review)
Conversations with Bernard Malamud (review)
Tar Beach (review)
Allegra Maud Goldman (review)
Tradition in a Rootless World: Women Turn to Orthodox Judaism (review)
The Interilluminating Bible
Miriam and Zipporah
"This Borrowed Language": Body Politic in Judges 19
Prologue at Sinai
2 Samuel 24: A Meditation on Wrath, Guilt, and the King
A Mother's Paean, A Warrior's Dirge: Reflections on the Use of Poetic Inclusions in the Books of Samuel
To an Impotent God: Images of Divine Impotence in Hebrew Scripture
The Identity of Jacob's Opponent: Wrestling with Ambiguity in Gen. 32:22-32

redpajama_set_name: RedPajamaCommonCrawl


text:
JULY 2021 - Community Associations Newsletter - Surfside Florida – Let's Focus on Reserve Studies
By Leslie Brown and Nicole Williams
The tragic, sudden collapse of the Champlain Towers South condominium building in Surfside, Florida has rocked the community association industry to its core. Architects and engineers will be analyzing the structural failure for years. Legislators may be pressed to implement stricter standards for high-rise buildings. As community association industry professionals and residents, we cannot help but wonder whether something similar can happen in the high rises we represent, manage, serve, and live.
One area that has gotten a lot of attention since the collapse are reserve studies and reserve funding. Florida has unique statutory requirements in this regard. While formal reserve studies are not required to be conducted in Florida, condominiums are statutorily obligated to set aside reserve funding for roof replacement, building painting, pavement resurfacing and any other capital expense greater than $10,000 and maintain a reserve schedule for repair and replacement of major components. The "40-year certification" requirement that is also getting a lot of attention is specific to condominiums in Miami-Dade County. In that jurisdiction, the condominium building must be inspected for the purpose of determining the general structural condition of the building and the general condition of its electrical systems every 40 years.
Our state and local jurisdictions have their own sets of requirements with respect to reserve studies and reserving funding for community associations.
Virginia. Both the Virginia Condominium and Property Owners' Association Acts require community associations to conduct a reserve study every five (5) years, unless the governing documents impose a more stringent requirement. Additionally, both Acts require Boards to review the study on an annual basis to determine if their association is funding their reserves at appropriate levels.
Due to a 2019 change in the law, Boards must also disclose information about reserve funding levels in the budget. These disclosures include:
the current estimated replacement cost and estimated remaining useful life of the Association's capital components;
the total amount of cash currently set aside for reserves (repair, replace or restore capital components) and the amount budgeted for contribution to the reserve fund for the coming fiscal year;
a statement outlining how reserves are being funded and the extent to which the Association is funding its reserve obligations consistent with the reserve study; and,
a statement of the amount of reserves recommended by the study and the amount of cash, in fact, set aside for reserves.
Both Acts require associations to provide a copy of the budget to the ownership and to include a copy of the budget in the disclosure materials for contract purchasers.
To assist Boards and managers, the Virginia General Assembly required the Common Interest Community (CIC) Board to publish guidelines for the preparation of reserve studies. These guidelines are available on the CIC Board website at www.dpor.virginia.gov/Boards/CIC-Board under "Guidelines for the Development of Reserve Studies for Capital Components". The Guidelines provide a lot of information about why reserve studies are necessary for good association governance, the basic types of reserve studies, and what should be included in the study. Please also refer back to our October 2019 Client Alert for our insights on how to present reserve budgeting information pursuant to these new requirements.
Maryland. Both the Maryland Condominium and Homeowners Association Acts require that association budgets include a line item for reserves. For condominium resales, a statement must also be included with a summary of the most current reserve study report as well as a statement of "the status and amount of any reserve or replacement fund, or a statement that there is no reserve fund." Under Maryland case law, information disclosed in the resale documents is subject to the Maryland Consumer Protection Act, and, therefore, cannot be misleading. As such, it is important to ensure that the disclosure documents regarding the current budget and condition of the building accurately depict the association's financial health and condition.
Maryland does not mandate that reserve studies be conducted for community associations, except for associations in Prince George's County as of October 1, 2020 and in Montgomery County starting on October 1, 2021. Both the Maryland Condominium and Homeowners Association Acts were amended to require associations in Prince George's County to obtain a reserve study once every five (5) years and fund reserves in accordance with that study. The reserve study must be prepared by a person who has prepared at least thirty (30) reserve studies within the last three (3) years; someone who has a bachelor's degree in construction management, architecture, engineering or equivalent experience and education; holds a license from the State Board of Architects or the State Board for Professional Engineers; or is currently designated as a reserve specialist by Community Association Institute (CAI) or the Association of Professional Reserve Analysts. Please note that community associations in Prince George's County must have a reserve study conducted before October 1, 2021 if it has not had one conducted on or after October 1, 2016.
Montgomery County will follow suit come October 1, 2021 with nearly identical legislation to take effect in both the Maryland Condominium and Homeowners Association Acts pertaining to associations in Montgomery County. Please refer to our May 2021 Maryland Legislative Update on the specific reserve study requirements for Montgomery County associations.
District of Columbia. Under the D.C. Condominium Act, community associations have the power to adopt and amend budgets for revenues, expenditures, and reserves and impose and collect assessments for common expenses from unit owners, but there is no statutory obligation to conduct a reserve study or fund reserves. However, express language in the legal documents may require such studies or funding. For condominium resales, a statement must be included with the amount in the projected budget as a reserve for repairs and replacement (or a statement that there is no amount).
Mayor Bowser recently announced enhancements to safety reviews for multifamily and commercial buildings due to the Surfside Florida and 916 Kennedy Street NW collapses. These actions include:
Reviewing all active construction projects by 10Square Development and Beck Vissat, the property owner of 916 Kennedy St NW, to ensure compliance with D.C. Code;
Drafting an administrative bulletin and/or legislation requiring all building owners and engineering firms to report and notify DCRA of unsafe structural conditions – proactively identifying buildings before they become unsafe sites;
Legally requiring multifamily residential building owners to file with DCRA structural assessment reports and remediation plans, drafted by a licensed engineer, for any repairs to unsafe structural conditions prior to permit application;
Digitizing special inspections conducted by private companies and engineers-of-record with real-time tracking of periodic and continuous inspections – ensuring potential safety issues are caught quickly;
Creating training for plan reviewers to refresh and instill knowledge on shear wall construction;
Retroactively reviewing for adequate shear wall designs in all new, multifamily, light-framed wood-construction buildings permitted within the District over the last three years starting with buildings certified by FMC & Associates; and
Researching and procuring engineering software to model, perform advanced and complex structural analysis, and standardize structural reviews in critical building design elements.
West Virginia. Like in D.C. and Maryland, there is no statutory obligation to conduct a reserve study or fund reserves in West Virginia, but such obligations may be contained within the legal documents. Under the West Virginia Uniform Common Interest Ownership Act, community associations have the power to adopt and amend budgets for revenues, expenditures, and reserves and impose and collect assessments for common expenses from owners. For resales, a statement must be included containing the amount of any reserves for capital expenditures and of any portions of those reserves designated by the association for any specified projects.
CAI Best Practices. The Community Associations Institute (CAI), the trade organization representing the interests of the community association industry, recommends that community associations conduct regular reserve studies to determine the appropriate amount of reserves needed to fund replacement costs and the most useful funding mechanism for their reserves. Associations should have their reserve studies updated on a frequency that allows for the reserve components and funding plan to be adjusted in the best interests of the association or accordance with local statutes. Associations should review the reserve study periodically to ensure the information presented is accurate and updated. Associations should also consult a qualified reserve study professional to determine the best reserve funding plan or combination of plans for the association. For communities that are more than 30 years old, Boards should consider investigating the possibility that other experts, such as a structural engineer, may be needed in addition to a reserve specialist for the long-term viability of the reserve components.
If your community has any questions about reserve studies, reserve funding, or the implications of the Champlain Towers South collapse, please do not hesitate to contact one of our community association attorneys.
210712 Reserve Requirements.pdf
LESLIE S. BROWN
NICOLE A. WILLIAMS


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Fletcher Fixed Income Alpha Fund, Ltd., et al. v. Grant Thornton LLP, et al. (Lawyers Weekly No. 11-085-16)
FLETCHER FIXED INCOME ALPHA FUND, LTD., & another[1] vs. GRANT THORNTON LLP & others.[2]
Suffolk. January 6, 2016. – July 14, 2016.
Present: Cypher, Grainger, & Meade, JJ.
Auditor. Practice, Civil, Motion to dismiss. Jurisdiction, Nonresident, Long-arm statute. Due Process of Law, Jurisdiction over nonresident. Negligence, Misrepresentation, Proximate cause. Proximate Cause.
Civil action commenced in the Superior Court Department on January 17, 2014.
Motions to dismiss were heard by Janet L. Sanders, J.
Rachel S. Fleishman, of New York (Philip Y. Brown with her) for the plaintiffs.
Grant J. Esposito, of New York, for Grant Thornton LLP.
William M. Connolly, of Pennsylvania, for EisnerAmper LLP & another.
Jonathan D. Cogan, of New York, for SS&C Technologies, Inc.
MEADE, J. The plaintiffs, Fletcher Fixed Income Alpha Fund, Ltd. (Alpha), and Massachusetts Bay Transportation Authority Retirement Fund (MBTARF), Alpha's sole shareholder, appeal from the dismissal of their claims for accounting malpractice and negligent misrepresentation against certain entities that audited and administered Alpha, for failing to discover the fund manager's fraud. The claims against the defendants, Grant Thornton LLP (Grant Thornton), and EisnerAmper LLP and EisnerAmper (Cayman) Ltd. (collectively, EisnerAmper), who served as auditors, were dismissed for lack of personal jurisdiction, a Superior Court judge ruling that the plaintiffs failed to show that their claims arose from the defendants' transaction of business in Massachusetts. The claims brought by MBTARF against SS&C Technologies, Inc. (SS&C), a former Alpha administrator, were dismissed for failure to state a claim upon which relief can be granted, the judge reasoning that Alpha was insolvent by the time SS&C was hired, thereby negating the element of proximate cause.
Pending their appeal to this court, the plaintiffs settled with EisnerAmper. As to the remaining defendants, the plaintiffs principally argue that in deciding the issue of specific jurisdiction, the judge should have taken into account a broader range of contacts between Grant Thornton and Massachusetts, and should have considered Grant Thornton's knowledge that the audit reports would be sent to a Massachusetts entity. MBTARF also maintains that the judge held it to an incorrect pleading standard in dismissing its claims against SS&C for failure to allege facts to support causation. We affirm.
Background. We summarize the undisputed facts from the judge's February 23, 2015, "Memorandum of Decision and Order on the Defendants' Motions to Dismiss Plaintiffs' Amended Complaint." MBTARF is a pension fund for public employees and retirees of Massachusetts Bay Transportation Authority. In June, 2007, MBTARF invested in Alpha. Alpha, along with FIA Leveraged Fund, Ltd. (Leveraged), and Fletcher Income Arbitrage Fund, Ltd. (Arbitrage) (collectively, the Fletcher funds), were operated in the Cayman Islands as feeder funds for Fletcher International, Ltd. (FILB), the master fund. The Fletcher funds were managed by one Alphonse Fletcher, through Fletcher Asset Management (FAM), based in New York. MBTARF invested $ 25 million in Alpha, all of which it lost the following year when Alpha became insolvent.
In December, 2007, FAM hired Grant Thornton to provide auditing services for a number of Fletcher funds, including Alpha. Grant Thornton performed the work, and Grant Thornton Cayman Islands, an entity organized under the laws of the Cayman Islands, issued the audit reports. Grant Thornton Cayman Islands issued audit reports for 2007 and 2008, addressed to the board of directors and the shareholders of the audited funds. In March, 2010, Grant Thornton notified FAM that it was withdrawing its audit opinions for Arbitrage and Leveraged for 2007 and 2008, after the Securities and Exchange Commission challenged the accounting treatment of two $ 80 million "cashless notes" exchanged between the Fletcher funds. Grant Thornton instructed FAM to notify persons likely to rely on the withdrawn audit reports. Neither FAM nor Grant Thornton notified MBTARF, which had invested only in Alpha, that the reports for Arbitrage and Leveraged had been withdrawn. FAM then replaced Grant Thornton with EisnerAmper.
SS&C was hired by FAM as Alpha's administrator in April, 2010. MBTARF previously had been informed by FAM in 2007 that the calculation of Alpha's value would be made in consultation with the fund administrator at the time. But MBTARF was not informed that when SS&C took over that role from its predecessor, SS&C would not participate in valuations. MBTARF claims that had it been so informed, it immediately would have redeemed its investment.
The amended complaint alleges that Alphonse Fletcher committed fraud by inflating the value of the Fletcher funds. The plaintiffs claim that Grant Thornton is liable for improperly auditing the Fletcher funds, and that SS&C, as fund administrator, misrepresented the nature of its services and the value of MBTARF's investment.
Personal jurisdiction under G. L. c. 223A, § 3(a). For a court to exercise personal jurisdiction over a nonresident, "there must be a statute authorizing jurisdiction and the exercise of jurisdiction must be consistent with basic due process requirements mandated by the United States Constitution." Bulldog Investors Gen. Partnership v. Secretary of the Commonwealth, 457 Mass. 210, 215 (2010) (citation omitted). If the long-arm statute does not provide a basis to confer personal jurisdiction over the defendant, we need not consider the constitutional question of due process. Roberts v. Legendary Marine Sales, 447 Mass. 860, 865 (2006). The plaintiff has the burden of production as to jurisdictional facts once jurisdiction is challenged. See Bulldog Investors Gen. Partnership v. Secretary of the Commonwealth, supra at 219. See also Cepeda v. Kass, 62 Mass. App. Ct. 732, 739-740 (2004) (describing burden of proof by preponderance of evidence applicable to motion pursuant to Mass.R.Civ.P. 12[b][2], 365 Mass. 754 [1974]).
The plaintiffs direct their arguments to specific, rather than general, jurisdiction. General jurisdiction requires that a foreign corporation have affiliations with the forum State that are so "continuous and systematic" as to render the defendant essentially at home there. Daimler v. Bauman, 134 S. Ct. 746, 754 (2014) (citation omitted). The factual allegations in the amended complaint make clear that Grant Thornton did not have continuous or systematic contact with Massachusetts to warrant the exercise of general jurisdiction.
Specific jurisdiction, by contrast, "depends on an affiliation between the forum and the underlying controversy." Walden v. Fiore, 134 S. Ct. 1115, 1121 n.6 (2014) (citation omitted). The plaintiffs contend that specific jurisdiction over Grant Thornton is proper under the Massachusetts long-arm statute, G. L. c. 223A, § 3, as amended by St. 1969, c. 623. The statute provides, in relevant part:
"A court may exercise personal jurisdiction over a person, who acts directly or by an agent, as to a cause of action in law or equity arising from the person's
"(a) transacting any business in this commonwealth;
"(b) contracting to supply services or things in this commonwealth;
"(c) causing tortious injury by an act or omission in this commonwealth;
"(d) causing tortious injury in this commonwealth by an act or omission outside this commonwealth if he regularly does or solicits business, or engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed or services rendered, in this commonwealth."
The plaintiffs rely on G. L. c. 223A, § 3(a) and (d). As to § 3(a), the judge ruled that the evidence failed to show that the plaintiffs' claims arose from Grant Thornton's transaction of business in Massachusetts. The judge observed that the audited funds were operated in the Cayman Islands and that the work involved in the Alpha audit was performed outside of Massachusetts. The judge further observed that Grant Thornton's few contacts with Massachusetts bore little or no connection to its audits of Alpha, and most took place after the audit activities outlined in the amended complaint transpired.
On appeal, the plaintiffs argue that in analyzing G. L. c. 223A, § 3(a), the judge should have considered the totality of Grant Thornton's contacts with Massachusetts, rather than only those connected to the audits. For this, the plaintiffs rely on an overly-broad reading of Tatro v. Manor Care, Inc., 416 Mass. 763 (1994). However, the tort claim in Tatro arose in the context of a contractual relationship between the parties. The issue was whether a single telephone call between the plaintiff in Massachusetts and the defendant hotel owner in California, in which the plaintiff reserved a hotel room, was sufficient contact with Massachusetts to satisfy § 3(a), when the plaintiff was subsequently injured on the defendant's premises during her stay. The Supreme Judicial Court held that "[p]articularly where a contract between the parties is associated with other forum-related activities, a defendant's relatively minor contacts with a Massachusetts plaintiff have been held sufficient to satisfy the transacting business requirement set out in § 3(a)." Id. at 768.
The court in Tatro v. Manor Care, Inc., supra, did not include in its analysis the defendant's general contacts with Massachusetts, but rather considered only those contacts that were directed at soliciting the same kind of contractual relationship, targeting Massachusetts business people who might schedule conferences at a California hotel, that the defendant ultimately procured with the plaintiff. Citing Hahn v. Vermont Law Sch., 698 F.2d 48, 50-52 (1st. Cir. 1983), the court observed that "[t]he defendant's contact with the plaintiff was part of a larger systematic effort on its part to obtain business from Massachusetts businesses and residents." Tatro v. Manor Care, Inc., supra at 769. The cases do not hold that unrelated contacts with the forum are relevant for specific jurisdiction under G. L. c. 223A, § 3(a), as the plaintiffs insist. That argument ignores the court's directive in Tatro that other forum-related activities must be associated with the challenged transaction between the parties in order to be relevant to the analysis. Ibid. We understand "associated" to mean something more than mere coexistence.
Moreover, such an expansive reading of Tatro would run afoul of due process, which provides that in order for a State to exercise specific jurisdiction, it is the defendant's suit-related contacts that must create a substantial connection with the forum State. See Walden v. Fiore, supra at 1121. In United Elec., Radio & Mach. Wkrs. of America v. 163 Pleasant St. Corp., 960 F.2d 1080, 1087 (1st Cir. 1992), the United States Court of Appeals for the First Circuit explained that the Massachusetts "long-arm statute also demands that plaintiffs' cause of action arise from the defendant's transaction of business in the commonwealth," and "[t]he statute's relatedness requirement mirrors a key constitutional requirement for the exercise of specific jurisdiction." See Cambridge Literary Properties, Ltd. v. W. Goebel Porzellanfabrik G.m.b.H & Co. Kg., 295 F.3d 59, 63 (1st Cir. 2002) (constitutional limit on specific jurisdiction under G. L. c. 223A, § 3[a], "requires a nexus between the claim and the defendant's in-state activities").
Turning to the case against Grant Thornton, the plaintiffs point to evidence that the company registered to do business in Massachusetts in 1996. The evidence also indicates that in June, 2013, Grant Thornton had more than 175 employees in its Boston office. However, those contacts were not shown to be related to the Alpha audits performed by Grant Thornton for 2007 and 2008, nor do they support the contention that the Alpha audits, which were performed outside of Massachusetts pursuant to a contract with a Cayman Islands entity, were part of a larger systematic effort to obtain business in Massachusetts.
The plaintiffs also claim that the judge failed to apply the but/for analysis, as set out in Tatro v. Manor Care, Inc., supra at 771, in determining whether their claims arose from Grant Thornton's Massachusetts contacts. In particular, they rely on an offering memorandum between FAM and MBTARF, which indicated that Grant Thornton had been hired as Alpha's independent auditors and that Alpha would send the audit report to the shareholders. According to the plaintiffs, the offering memorandum shows that Grant Thornton knew that MBTARF would receive and rely on the reports in Massachusetts. In the plaintiffs' view, Grant Thornton's knowledge that FAM would send the Alpha audit reports to its Massachusetts shareholders constituted a Massachusetts contact that was causally linked to the plaintiffs' injury when MBTARF relied on them. However, as the judge properly determined, Grant Thornton's knowledge that FAM would send the audit reports to Massachusetts does not constitute a contact with Massachusetts sufficient to support jurisdiction. See Walden v. Fiore, 134 S. Ct. at 1124-1125 (defendant's knowledge that affidavit he drafted in Georgia would affect plaintiffs in Nevada was not proper basis for specific jurisdiction in Nevada). As explained in Walden v. Fiore, supra at 1125, a defendant's actions outside the forum, in that case the State of Nevada, did not create sufficient contacts with the forum "simply because he allegedly directed his conduct at plaintiffs whom he knew had Nevada connections."
This court applied similar reasoning in Morris v. UNUM Life Ins. Co., 66 Mass. App. Ct. 716, 721-722 (2006), where telephone calls and letters sent from two Maine physicians to a Massachusetts physician, concerning an insured's ineligibility for disability coverage, were deemed insufficient in-forum contacts to confer jurisdiction in Massachusetts for the insured's claims of misrepresentation against the out-of-State physicians. That the information provided by the Maine defendants was communicated to and utilized in Massachusetts to deny coverage to the plaintiff did not supply the requisite contacts for specific jurisdiction under G. L. c. 223A, § 3(a) or (d). Id. at 722.
Personal jurisdiction under c. 223A, § 3(d). As a threshold matter, the parties debate whether c. 223A, § 3(d), may be relied upon to establish specific jurisdiction. Grant Thornton maintains that § 3(d) can support only general jurisdiction and that, since the plaintiffs have waived general jurisdiction, they have no claim under that section of the long-arm statute. See, e.g., Connecticut Natl. Bank v. Hoover Treated Wood Prod., Inc., 37 Mass. App. Ct. 231, 233 n.6 (1994) (§ 3(d) "is predicated on general jurisdiction," i.e., defendant having engaged in continuous and systematic activity in the forum, unrelated to the suit); Fern v. Immergut, 55 Mass. App. Ct. 577, 581 n.9 (2002) (referring to claim under § 3[d] as one for general jurisdiction). In any event, while the cases tend to support Grant Thornton's view, the judge properly ruled that the plaintiffs failed to satisfy their burden of showing that specific jurisdiction may be exercised over Grant Thornton under § 3(d).
Section 3(d) of G. L. c. 223A requires a showing of tortious injury in Massachusetts caused by an out-of-State act or omission, and proof that the defendant regularly does or solicits business in Massachusetts or otherwise engages in a persistent course of conduct or derives substantial revenue from Massachusetts. Even assuming that the injury to MBTARF and Alpha occurred in Massachusetts, the record, as delineated above in our discussion of G. L. c. 223A, § 3(a), fails to establish the latter requirement. Also, as the judge observed, due process considerations would not permit the exercise of specific jurisdiction over Grant Thornton on these facts, given the scant evidence of Grant Thornton's activities in relation to Massachusetts at the time of the alleged wrongdoing.[3]
We reject the plaintiffs' contention that Grant Thornton's more recent Massachusetts contacts should be considered in the G. L. c. 223A, § 3(d), analysis. In establishing specific jurisdiction, particularly in the absence of a contractual or other continuing relationship with a Massachusetts plaintiff, our focus is directed to the defendant's contacts at the time the cause of action arose, rather than when the complaint was filed. See Cambridge Literary Properties Ltd. v. Goebel Porzellanfabrik G.m.b.H & Co. Kg., 295 F.3d at 66. The factual allegations do not establish that Grant Thornton's work relative to the plaintiffs' claims was ongoing at the time of the complaint so as to render its contacts with Massachusetts in 2013 and 2014 relevant under § 3(d).[4]
As a final matter, contrary to the plaintiffs' assertion, this case bears no resemblance to Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985), which involved a long-term franchise contract between the parties and, as a result, a continuing obligation on the part of the Michigan defendant to maintain a substantial connection with Burger King Corporation in the forum State of Florida. The defendant there knowingly "entered into a carefully structured 20-year relationship that envisioned continuing and wide-reaching contacts with Burger King in Florida." Id. at 480. Here, significantly, there was no contractual relationship between Grant Thornton and a Massachusetts plaintiff, nor was there a continuous obligation or other course of contact directed at Massachusetts by Grant Thornton. As noted above, knowledge that FAM would send the audit reports to Massachusetts was not sufficient contact between Grant Thornton and the forum to establish jurisdiction for purposes of either G. L. c. 223A, § 3(a) or (d).
Claims against SS&C. MBTARF brought claims against SS&C for negligent misrepresentation, aiding and abetting fraud, and violation of G. L. c. 93A, § 11. The amended complaint alleges that MBTARF would have redeemed its investment in Alpha when SS&C took over as administrator in 2010 had MBTARF known that SS&C had disavowed its duty to take part in Alpha's asset valuation. Yet according to the amended complaint, Alpha was "hopelessly insolvent" by the end of 2008, or "likely earlier."
On appeal, MBTARF argues that the judge applied the wrong standard, at this stage of the litigation, because MBTARF was not required to demonstrate that its allegation that SS&C was the proximate cause of its loss was true or to produce evidence to that effect. However, as SS&C argues, dismissal under Mass.R.Civ.P. 12(b)(6), 365 Mass. 754 (1974), is appropriate "where the allegations in the complaint clearly demonstrate that the plaintiff's claim is legally insufficient." Harvard Crimson, Inc. v. President & Fellows of Harvard College, 445 Mass. 745, 748 (2006). Causation is a necessary element of the plaintiff's claims against SS&C. "Before liability for negligence can be imposed, there must first be a legal duty owed by the defendant to the plaintiff, and a breach of that duty proximately resulting in the injury." Davis v. Westwood Group, 420 Mass. 739, 742-743 (1995). Also contrary to MBTARF's assertion, lack of proximate cause is appropriate for determination under rule 12(b)(6), where the complaint itself demonstrates that causation, as alleged, was not proximate. See Leavitt v. Brockton Hosp., Inc., 454 Mass. 37, 44-45 (2009). Given the allegations indicating that Alpha was insolvent when SS&C took over as fund administrator, the judge properly relied on lack of proximate cause as a basis for dismissal.
MBTARF suggests that it did not have to allege that SS&C was the sole cause of the loss, but only that SS&C's conduct was a substantial factor in the loss, citing Lawrence Sav. Bank v. Levenson, 59 Mass. App. Ct. 699, 707 (2003). The distinction does not help MBTARF's position on the facts alleged, as MBTARF must still show a causal connection between SS&C's role at Alpha and MBTARF's failure to redeem prior to Alpha's insolvency. Given the timeline alleged in the amended complaint, MBTARF has not shown that SS&C was a substantial factor in MBTARF's loss.
MBTARF further posits that despite Alpha's insolvency by the time SS&C was hired, there might have been some assets at that time that could have been used to satisfy MBTARF's redemption request. Facts to support that position were not identified in the amended complaint. "The plaintiff's claim must be based on facts set forth in the complaint; all materials outside the pleadings are excluded in this review." General Motors Acceptance Corp. v. Abington Cas. Ins. Co., 413 Mass. 583, 584 (1992). We agree with SS&C that the argument is speculative and does not warrant reversal.
[1] Massachusetts Bay Transportation Authority Retirement Fund.
[2] EisnerAmper LLP, EisnerAmper (Cayman) Ltd., and SS&C Technologies, Inc.
[3] The plaintiffs maintain that Grant Thornton derived substantial revenues from Massachusetts in 2013 and 2014, but the judge emphasized that the plaintiffs provided no evidence to support the claim, even if relevant.
[4] The Federal cases cited by the plaintiffs from other jurisdictions involved manufacturers marketing their defective products to the forum State and are factually and procedurally distinct. See, e.g., Clune v. Alimak AB, 233 F.3d 538, 544 n.8 (8th Cir. 2000) (relevant contacts were manufacturer's presence in forum while crane was present there, not only when crane accident occurred); Logan Prod., Inc. v. Optibase, Inc., 103 F.3d 49, 52-53 (7th Cir. 1996) (constitutional analysis of purposeful availment, defendant manufacturer having conceded specific jurisdiction under State long-arm statute for claim brought by a distributor). The plaintiffs also cite Grupo Dataflux v. Atlas Global Group L.P., 541 U.S. 567 (2004), but that case addressed subject matter jurisdiction.
Posted by Massachusetts Legal Resources - July 18, 2016 at 2:20 pm
Categories: News Tags: 1108516, Alpha, Fixed, Fletcher, Fund, Grant, Income, Lawyers, Ltd., Thornton, Weekly


text:
Louis Jourdan, właśc. Louis Robert Gendre (ur. 19 czerwca 1921 w Marsylii, zm. 14 lutego 2015 w Beverly Hills) – francuski aktor filmowy.

8 lutego 1960 otrzymał dwie własne gwiazdy w Alei Gwiazd w Los Angeles znajdujące się przy 6153 i 6445 Hollywood Boulevard.

W 2010 otrzymał Legię Honorową.

Życiorys

Wczesne lata
Urodził się w Marsylii jako jednego z trzech synów Yvonne (z domu Jourdan) i Henriego Gendre'a, hotelarza. Ze względu na charakter pracy jego ojca, uczył się we Francji, Turcji i Anglii. Po powrocie do Francji studiował aktorstwo u René Simona w École Dramatique i przyjął panieńskie nazwisko matki - Jourdan.

Kariera
Podczas studiów grał na profesjonalnej scenie, gdzie zwrócił na niego uwagę reżyser Marc Allégret, który zatrudnił go do pracy jako asystenta operatora kamery przy realizacji Wejście dla artystów (Entrée des artistes, 1938) z Louisem Jouvetem, Bernardem Blierem i Marcelem Dalio. Wkrótce Marc Allégret i Marcel Achard zaangażowali go do roli Jonesa w filmie Korsarz (Le Corsaire, 1939) u boku Charlesa Boyera.

W nagrywanej w Rzymie Komedii szczęścia (La Comédie du bonheur, 1940) wystąpił u boku Michela Simona, Micheline Presle i Ramóna Novarro jako Fédor. Julien Duvivier powierzył mu podwójną rolę jako Pierre Froment i Félix Froment w dramacie Rodzina Froment (Untel père et fils, 1943) z Raimu i Michèle Morgan. W komedii Pierwsza randka (Premier rendez-vous, 1941) z Danielle Darrieux został obsadzony jako Pierre, bratanek Nicolasa Rougemonta.

Jego pierwszym hollywoodzkim filmem był Akt oskarżenia (1947) w reżyserii Alfreda Hitchcocka z udziałem Gregory Pecka, gdzie grał postać André Latoura, służącego Pani Maddaleny Anny Paradine (Alida Valli). W melodramacie Maxa Ophülsa List od nieznajomej (1948) wystąpił w roli słynnego pianisty, Stefana Branda. W 1959 za rolę Gastona Lachaille w filmie muzycznym Vincente'a Minnellego Gigi (1958), na podstawie powieści Colette, otrzymał nominację do Złotego Globu. Stałe miejsce w historii kina przyniosła mu jednak kreacja Kamala Khana, wyrafinowanego i bezwzględnego afgańskiego księcia, przeciwnika Jamesa Bonda w filmie Johna Glena Ośmiorniczka (1983).

Karierę aktorską zakończył w 1992.

Życie prywatne
11 marca 1946 ożenił się z Berthe Frédérique. 6 października 1951 urodził się syn Louis Henry, który zmarł w 1981 w wieku 30 lat w wyniku przedawkowania narkotyków. Od 1992 Jourdan na stałe mieszkał wraz z małżonką na południu Francji.

Zmarł 14 lutego 2015 w wieku 93 lat w swoim domu w Beverly Hills.

Wybrana filmografia

 Akt oskarżenia (1947) jako Andre Latour
 List od nieznajomej (1948) jako Stefan Brand
 Pani Bovary (1949) jako Rodolphe Boulanger
 Anna z Indii (1951) jako kapitan Pierre François LaRochelle
 Szczęśliwy czas (1952) jako Desmond Bonnard
 Trzy monety w fontannie (1954) jako książę Dino di Cessi
 Łabędź (1956) jako dr Nicholas Agi
 Gigi (1958) jako Gaston Lachaille
 Wszystko, co najlepsze (1959) jako David Savage
 Kankan (1960) jako Phillippe Forrestier
 Hrabia Monte Christo (1961) jako Edmond Dantes/hrabia Monte Christo
 Z życia VIP-ów (1963) jako Marc Champselle
 Hrabia Monte Christo (1975) jako De Villefort
 Człowiek w żelaznej masce (1977) jako D'Artagnan
 Columbo jako Paul Gerard (w odc. pt. Morderstwo pod szkłem z 1978)
 Aniołki Charliego jako dr Paul Redmont (w odc. pt. Nips and Tucks z 1980)
 Potwór z bagien (1982) jako dr Anton Arcane
 Ośmiorniczka (1983) jako Kamal Khan
 Niebezpieczne ujęcia (1984-85; serial TV) jako George LeMare
 Powrót potwora z bagien (1989) jako dr Anton Arcane
 Rok komety (1992) jako Philippe

Przypisy

Linki zewnętrzne

Francuscy aktorzy filmowi
Francuscy aktorzy teatralni
Francuscy aktorzy telewizyjni
Ludzie urodzeni w Marsylii
Odznaczeni Legią Honorową
Pochowani w Kalifornii
Urodzeni w 1921
Zmarli w 2015

redpajama_set_name: RedPajamaWikipedia


It's not a certain body type or neglecting certain food groups.
As an advocate for the Health at Every Size movement and fighting against fatphobia and eating disorders, I hear a lot of misconceptions from other people about what health is. We live in a society that glorifies losing weight and shames gaining weight, and it's easy for people to become focused to an extreme on health and fitness. Furthermore, dieting is the biggest predictor of an eating disorder, and both weight loss and body size can be affected by genetics, according to the Center of Excellence for Eating Disorders, one of the most prestigious eating disorder centers in the country. The following are truths about health.
1. Health doesn't always equal skinny.
For some, losing a bunch of weight and being "skinny" is unhealthy because it took unhealthy behaviors to get there. For some, they don't try to incorporate all nutrients into their diets, but still are able to maintain a low weight.
2. Health isn't even one particular body size or BMI number.
BMI isn't a good indicator for health -- it doesn't always accurately portray what a person is eating, how much water he or she is drinking, or account for muscle mass. Health looks differently for different people. Health at Every Size celebrates body diversity, finding enjoyment in moving your body, trusting your body's hunger and satiety signals, and accepting your size. Fatphobia is an issue that leads to unhealthy eating and even eating disorders.
3. Health isn't only eating fruits and vegetables or avoiding entire food groups. It doesn't label food.
All foods have a place in a healthy diet; we need all kinds of food and nutrients to live healthily and happily. Labeling foods as "good" or "bad" can translate into us feeling like "good" or "bad" people, and makes us sometimes avoid the foods our bodies want. Food has no moral value. Furthermore, the more you restrict your eating, the more you want (and will likely eat, or even binge on) that food.
4. Health isn't an obsession about what you eat, look like or how much you exercise.
Health is about trusting your body's signals, honoring your body's needs, and being able to live with a flexible and carefree nature. Obsessions can be unhealthy and taken too far. The following phrase annoys me too, but it's so true: everything in moderation.
5. Health isn't purely physical -- it's just as much mental.
Mental health is so important to a happy and healthy life; mental health matters just as much as physical health. Ways to maintain mental health include seeing a therapist, spending time with other people, and doing things you enjoy and that relax you. A great resource for finding a therapist is www.therapists.psychologytoday.com.
6. Health cannot be recognized instantly by looking at someone.
As stated before, health looks differently for different people and is often dependent to some degree on genetics. We can't tell what a person eats by how much space he or she takes up. This goes for all intersections of identities.
7. Health isn't always about "should" or "shouldn't."
Our bodies know what they need and will tell us and adjust to what we feed it. They work to keep us alive. If you want a piece of cake, eat a piece of cake! You're not going to gain weight from that, nor is it a bad thing.
8. Health isn't about detoxes.
Our body has learned over many years how to survive and take care of itself. It heals and adjusts in amazing ways. We have livers and kidneys that detox for us; detoxing through other methods isn't healthy and often doesn't work.
9. Health isn't about distrusting your body.
I've said it several times, and I'll say it again: trust the hunger and satiety signals your body gives you. Trust the cravings. Your body knows what it wants -- it was created to work that way. When your body distrusts you, or doesn't get food when it needs it, it know's how to survive; for example, it may make you eat, cause you to binge, or keep you awake under survival mechanisms in which your body keeps you awake so you can go "look for" food.
"Normal eating is going to the table hungry and eating until you are satisfied. It is being able to choose food you like and eat it and truly get enough of it — not just stop eating because you think you should. Normal eating is being able to give some thought to your food selection so you get nutritious food, but not being so wary and restrictive that you miss out on enjoyable food.
During Embody Carolina trainings, which were created by CEED and mentioned at the top, we talk more about healthy and unhealthy eating, we mention how we don't agree with her use of "mistakes," but that overall, we believe this is a great definition of healthy eating. Screenshot the picture below for your phone's wallpaper, if you'd like!
You get the point by now: your body is not the devil, and health is not a one-size-fits-all kind of deal. By embracing and taking care of ourselves, not being the "food police" for ourselves or others, and by listening to our body's signals, we can live a healthy and carefree life that isn't triggering to anyone, including ourselves.


text:
Boeing and Porsche unites to make a flying car
By Sarah Walker
AutomobileGlobal
US aeronautical giant Boeing and the German sports car manufacturer Porsche will unite to make flying car. They will come together to explore the urban air mobility market.
Boeing and Porsche to venture vertical take-off, landing flying car
Porsche is already reputed to have its "low flying" bodies. However, Boeing's idea is to create a vehicle that is used in everyday life and is considered an extension of urban traffic to airspace. Thus, the proposal is to manufacture a fully electric vertical take-off and landing vehicle.
The announcement did not include any details about the value of the investment or other features that the two companies plan to invest. In addition, no target date has been advanced either.
"We are combining the strengths of two leading global companies to address a key potential market segment of the future. In the long run, this could mean moving to the third dimension of travel" – Detlev von Platen, Porsche board member responsible for sales and marketing.
Porsche's parent company, Volkswagen AG (VLKAF), is the world's largest car manufacturer. It announced a major boost in electric vehicle development, setting the goal of building 22 million electric cars in its brands over the next 10 years.
Boeing suffers heavy losses on 737 Max problem
Boeing's revenue reached $100 billion for the first time in 2018. However, this year its sales are drastically lower due to the problem affecting its best-selling 737 Max commercial jet. As is well known, this aircraft has been involved in two fatal accidents that killed 346 people.
More than intended, companies have already shown a prototype of a self-driving electric flying car earlier this year.
"Porsche and Boeing (BA) combine precision engineering, style and innovation to accelerate urban air mobility around the world", said Steve Nordlund, general manager of Boeing NeXt, a company unit that works on the next generation of vehicles and aircraft.
Despite the fact that it is not yet possible to glimpse how everything will "fly over our heads", a future seems to place airplane, drone and flying car over cities.
Read also: Volkswagen Group will develop its own operating system for cars
Sarah's curiousness of technology drove her to check out and review emerging products, be it weird or appealing she loves everything there is about tech.


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Contact Team Zold to set up a private tour of 310 Red Maple PH7.


Develop your professional skills in Nevada!
Nevada is a prosperous state known for its desert landscapes and big cities. Consider training in Reno or Las Vegas and growing professionally in some of the most exciting cities in the United States. Filter and find training in Nevada below!
Nevada, gets its unique name from the mountain range that borders it - the Sierra Nevada Mountain Range. Nevada is well known for being the "Sagebrush State" because of the wild sage growing everywhere. It has a dry desert climate and gets the least rainfall compared to any other state.
The state brings in many tourists due to its large cities that offer gambling and entertainment, warm climate and beautiful scenery. The popular city of Las Vegas has not only drawn in tourists but residents. Due to Las Vegas's desirability, along with other popular cities, Nevada's population is continuing to grow faster then any other state. There are a variety of providers who offer training in Nevada due to the large amount of businesses present there and the easy accessibility of people from out of town.
Largely tied to the prosperous economy of its largest city, the state of Nevada's economy is driven by the tourism, gaming, and entertainment industries. Historically, Nevada began to flourish as a mining state, a industry that still fuels its economy today. The most valuable mineral mined in the state of Nevada is gold, closely followed by the mining of silver. Today, Nevada's gold accounts for almost 10% of all of the gold production in the world. If your interested in pursuing a career in the mining industry then training in Nevada is your ticket.
As tourism plays such a vital role in the economy of Nevada, it is no surprise that the hotel industry is positively correlated. To accommodate the large amount of tourism in the state, Nevada has more hotels per capita than any other state in America. Hotels in the state can range from cheap and quite basic to extremely lavish suites. Pop stars, magicians, and dancers round out the main attractions of the entertainment industry in Nevada. These well-known performers draw in enormous crowds and are known to be vast sources of revenue in the state. Additionally, Nevada's economy benefits from the industries of ranching, business, and education. In fact, the two largest employers in the state of Nevada are both school districts. If your looking to get involved in one of these industries then consider training in Nevada and developing your skills to match specific positions.
Training conferences and events find a comfortable home in Nevada, due to the states abundance of accommodation and entertainment. Therefore, the executive and professional education industries have flourished there. Corporations from around the world host their training events and annual conferences or conventions within the state, providing participants with a relaxed yet focused work event. Many professional training companies have located themselves in Nevada and host seminars and courses throughout the state to both residents and tourists alike. This has allowed the professional education industry to rapidly develop and mature.
Since Nevada is such a popular destination, professionals can usually find cheap flights and reasonable accommodation to participate in training in Nevada. If your company is based in Nevada then consider hiring a provider who does in-house training. In-house training can cover all the same topics as traditional style courses, the only difference is that it is delivered at your location and the content can sometimes be shaped to meet the specific needs of your organization. Consider training in Nevada and seeing what this prosperous state has to offer.


text:
Q: Stackoverflowexception error in my generic list code, c# I get the error: "Process is terminated due to StackOverFlowException" everytime I try to run my code. When I look at the warning I get it on my properies that says "make sure you do not have an infinite loop or infinite recursion". Here is my code:
class Book
{
    public string bokensTittle
    {
        get { return bokensTittle; }
        set { bokensTittle = value; }
    }
    public string forfattareFornamn
    {
        get {return forfattareFornamn;}
        set {forfattareFornamn = value;}  // on this line i get the error
    }

    public string forfattareEfternamn
    {
        get {return forfattareEfternamn;}
        set {forfattareEfternamn = value;;}
    }

    public int lanseringsDatum
    {
        get { return lanseringsDatum; }
        set { lanseringsDatum = value; }
    }

}

Could anybody help me to fix this?

A: You have a simple, endless recursion here.
Both of your properties are accessing themselves.
There are two ways of fixing it:

*

*Automatic properties:
public string ForfattareEfternamn
{
    get; set;
}

public int LanseringsDatum
{
    get; set;
}

*Backing fields:
private string _forfattareEfternamn;
private int _lanseringsDatum;

public string ForfattareEfternamn
{
    get { return _forfattareEfternamn; }
    set { _forfattareEfternamn = value; }
}

public int LanseringsDatum
{
    get { return _lanseringsDatum; }
    set { _lanseringsDatum = value; }
}

BTW: Please note how I changed the names of the properties to start with an upper case letter. That's the accepted standard for public members in C#.

A: The names of your properties matches the names you are using in the getters and setters. Declare only get;set; statements if you are not intending to use private variables.
class Book
{
    public string bokensTittle
    {
        get;set;
    }
    public string forfattareFornamn
    {
        get;set;
    }

    public string forfattareEfternamn
    {
        get;set;
    }

    public int lanseringsDatum
    {
        get;set;
    }
}

A: You are calling property from getter, which call property and so on.
public string forfattareEfternamn
{
    get {return forfattareEfternamn;} <-- here you call property getter again
    set {forfattareEfternamn = value;}
}

If you want to use back storage, then field and property should have different names (usually camelCase name for back storage, and PascalCase name for property):
private string forfattareEfternamn; // field for storing property value

public string ForfattareEfternamn // property
{
    get {return forfattareEfternamn;} // returning field value
    set {forfattareEfternamn = value;}  // setting field value
}

But in your case you can simply use auto implemented property:
public string ForfattareEfternamn { get; set; }

I strongly recommend you to read Properties (C# Programming Guide)

A:  public string forfattareEfternamn
    {
        get;
        set;
    }

    public int lanseringsDatum
    {
        get;
        set;
    }

I believe autoproperties is what you are trying to do.

A: try this :
public string forfattareEfternamn
{
    get;
    set;
}

public int lanseringsDatum
{
    get;
    set;
}

A: Both of your get statements reference themselves. Any time you try to retrieve either property it will call its own get over and over. This is the infinite loop and the cause of the stack overflow.
Instead, you can use a backing field.
private string _forfattareEfternamn;

private int _lanseringsDatum;

public string ForfattareEfternamn
{
    get {return forfattareEfternamn;}
    set {forfattareEfternamn = value;;}
}

public int LanseringsDatum
{
    get { return lanseringsDatum; }
    set { lanseringsDatum = value; }
}

Alternatively, if you need no additional code in the properties, blank get/set will be fine for you.
public string ForfattareEfternamn
{
    get;
    set;
}

public int LanseringsDatum
{
    get;
    set;
}

(Also in your setter for the first you have an extra ;)