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Country spotlight Travel Guide November 7, 2019 November 7, 2019
France: culture, history and gourmet food
France, a country in Western Europe, has everything that traveler needs for exiting journey: medieval cities and castles, villages in Alps and, of course, Mediterranean Riviera, for relaxing summer holidays. Paris, France`s capital, is world known as a fashion center, filled with classical art museums including, of course, the Louvre and world`s most famous landmark – the Eiffel Tower. The country is also well known for its wines and exquisite cuisine.
Official name: French Republic
Capital: Paris
Population: 63.5 million
Area: 543,965 sq km (210,026 sq miles)
Major language: French
Major religion: Christianity
Life expectancy: 78 years (men), 85 years (women)
France is located in Europe (West) and it is neighboring with several very interesting countries you should also visit: Belgium, Luxembourg, Germany, Switzerland, Italy, Monaco, Andorra and Spain. It has access to Atlantic Ocean and Mediterranean Sea.
France also has several overseas territories: French Guiana (South America), Saint Pierre and Miquelon (Atlantic Ocean), Guadeloupe, Martinique, Saint Martin and Saint Barthélemy (Antilles), French Polynesia, the special collectivity of New Caledonia, Wallis and Futuna and Clipperton Island (Pacific Ocean), Réunion island, Mayotte, Kerguelen Islands, Crozet Islands, St. Paul and Amsterdam islands, and the Scattered Islands (Indian Ocean) and Adélie Land in the Antarctic.
Your passport must be valid for at least three months after you complete visit to France. France is part of Schengen agreement and visa for any of the countries from the Schengen group is also valid for France. List of countries requiring visa can be found here.
France is located in Europe, so getting there is not a problem: there are hundreds of flights in and out of Paris airports – Charles de Gaulle (CDG), Orly (ORY), Beauvais (BVA) and other major cities (Nice – NCE, Lyon – LYS, Marseille – MRS and many more). You can also travel by car or a bus from neighbouring countries, take a train from London or arrive by cruise lines to any of famous French Riviera destinations.
Top attractions in Paris
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More travel info about Paris and France
Paris: culture, history, fashion and food
Paris, 'city of lights`, truly deserves this romantic nickname. It is globally known not only as France's capital, but as a European and world center for art, culture, fashion and...
France, a country in Western Europe, has everything that traveler needs for exiting journey: medieval cities and castles, villages in Alps and, of course, Mediterranean Riviera, for relaxing summer holidays....
Top hotels in Paris
Cheap flights and hotels discounts for Paris
Depending on your budget, staying in France can range from hostels, AirBnB, where you can rent a room or entire apartment or a house, to regular and high end hotels, it`s up to you. For latest offers on hotels from our providers use search form below:
France has great public transport, including metro (subway) in Paris, Lyon, Marseille, Lille, Toulouse and tramways in Bordeaux, Grenoble, Lille, Lyon, Nancy, Nantes, Nice, Reims, Rouen. For moving within Paris, you can also use taxi service, which is moderately cheap for quick transfer between points of interest.
Moving outside of Paris, there is an express commuter train service, RER, which covers any destination in the area (including Euro Disney).
For traveling throughout the France, you can use national railway, SNCF, which runs between any of major cities and you can also use local bus companies to reach even most remote rural sites.
You can rent a car to travel between cities, but it`s not recommended to drive within Paris or any major city due to very chaotic driving styles and traffic jams. Learn more about moving around in France.
France has one of the best cuisines in the world and French people are very proud of that. They will be happy to recommend you their gourmet food in every restaurant and advise you about matching wines, side dishes, and desserts. Not to miss while in France are certainly these: baguette, croissant and macarons, which you probably already tried elsewhere (one of the good sides of globalization), but having them in France is something different.
From top dishes, we recommend: steak frites (classic steak and fries), Croque-monsieur (or Croque-madame, whichever of these staple sandwiches you prefer), Duck confit (deliciously cooked duck meat), crêpes (of many kinds, you can buy them from street stands as well, all great), and large selection of cheese, which will require another article for itself.
Wine and Cheese Tasting in Paris at Galeries Lafayette
And of course, having wine and cheese is a gourmet experience you should not miss while in France.
If you are home sick while in France (it can happen, especially if you stay longer, we are not judging), you can find any international food you like and if you are really desperate (besides all this lovely food listed above), any world food chain is available, especially in Paris (McDonalds, KFC, Burger King, Tacobell).
For some tips on where to eat in Paris, click here.
How safe is France for tourists? France is quite safe, but tourists are generally advised to be vigilant, especially with pickpockets, so take care of your belongings when walking around for sightseeing. Tourist areas are generally safe, both for single tourists and groups/families, but extra caution is always advised. More details about safety in France you can find here.
France can be costly for tourists, but you can always find great deals on accommodation, meals and attraction tickets. For detailed pricing information for various items, click here.
It is also a huge difference between prices in Paris (most expensive city in France, but cheaper than London or San Francisco, for an example) and some other top cities in France, such as Lyon, Nice or Strasbourg, so keep this in mind when planning your trip.
France is medium to large sized country and it is spread over different geographical areas, such as Mediterranean coast in the south with nice climate with warm summers and mild winters, central France with four distinguished seasons or Alps region with snowy periods and cold winters. Average temperatures for Paris are ranging from 4 C (40 F) in winter (December-February) to up to 20 C (69 F) in summer (June-August). Keep in mind that high temperatures in Paris can go over 31 C (87 F) during July. For more info on temperatures and weather in France click here.
You can go to France anytime of the year, really, but you might want to avoid hot summer at the end of July or winter in January/February. If you are going to Paris to visit famous attractions, any time of the year is fine and in the winter you might have less tourists, but recommended time with both less crowds and nice weather would be April-June and September-October. More info on best times for France visit here.
France is part of the European Union and Euro zone, so official currency is Euro. You should pay attention when paying bills if you are coming from non-Euro countries and mind the exchange rate. (Xe.com). You can pay almost everywhere with credit cards, but check card charges from your bank in foreign countries before the trip. It is always good to have some cash on you, especially when leaving the tip in the restaurant. There are ATMs and banks on every corner and cash withdrawals are in Euros with a small fee. More info here.
There are so many things to see in France, we will list only most famous:
Eiffel Tower, landmark 324 m (1,063 ft) 19th-century tower. Built in 1889, (Engineered by Gustave Eiffel) this iconic tower, with steps and elevators to observation decks, has become a synonym with Paris and France and worldwide recognisable attraction.
The Louvre Museum, world`s largest art museum is also a historic monument itself. Located in Paris, France, on the Right Bank of the Seine River. It is world known for famous painting of Mona Lisa, Leonardo Da Vinci`s masterpiece.
Notre-Dame de Paris, also known as Notre-Dame Cathedral or simply Notre-Dame, is a medieval Catholic cathedral, famous for Victor Hugo`s novel, The Hunchback of Notre-Dame.
Palace of Versailles, 17th-century palace with gilded apartments, chandeliered Hall of Mirrors & fountain show, used by French kings, starting with Louis XIV.
Eiffel Tower Skip-the-Line Guided Tour
French Riviera, (or Côte d`Azur) is the Mediterranean coast of south eastern France. Famous (and glamorous) beach resorts such as Saint-Tropez and Cannes are located there, together with Monaco, the independent microstate.
Champs-Élysées. Famous central site full of landmarks, dining and high end shops. Louvre, Tuileries and Arc de Triomphe are all located in this area.
Arc de Triomphe, is one of the most famous monuments in Paris, standing at the western end of the Champs-Élysées at the centre of Place Charles de Gaulle.
Disneyland Paris. World known theme park with family-friendly rides, shows and costumed characters, also includes hotels and restaurants.
Sacré-Cœur, Paris. Iconic hilltop white basilica, is a Roman Catholic, dedicated to the Sacred Heart of Jesus, built in 1914, with interior mosaics, stained-glass windows and a crypt.
2-Day Paris City Break: Arc de Triomphe – Versailles – The Louvre
Mont Saint-Michel. An island commune in Normandy, France. It is located about one kilometre off the country`s north-western coast, at the mouth of the Couesnon River near Avranches.
Montmartre. A large hill in Paris`s 18th arrondissement; it is 130 m high and shares its name with the surrounding district. It`s known for its artistic history, the white-domed Basilica of the Sacré-Cœur, and as a nightclub district.
Place de la Concorde. One of the major public squares in Paris, this 18th-century promenade is decorated with fountains, statues and a genuine Egyptian obelisk.
Musée d`Orsay. Masterpieces of 19th and 20th century art, mostly from French authors. It is housed in a former railway station.
Le Marais. A historic district in Paris, consist of many important buildings from France`s pre-revolutionary period.
Disneyland Paris: One Day, One Park with Return Transfers from Paris
Jardin du Luxembourg. Park with manicured lawns and statues, created in 1612 by Marie de` Medici.
Moulin Rouge. Famous 19th century cabaret featuring Belle Epoque decor, dinner and dancers in elaborate costumes. Immortalized in paintings of Henri de Toulouse-Lautrec and famous movie starring Nicole Kidman and Ewan McGregor.
Centre Georges Pompidou. Architecturally avant-garde complex housing National Museum of Modern Art (the largest one in France), library and music centre.
Les Invalides. Series of army museums and monuments including a church and the tombs of many famed officers, including Napoleon. Everything related to military history of France can be found there.
Château de Chambord. Expansive, 16th century, former royal palace with multiple towers and cupolas, surrounded by a moat. Recognisable by its specific French Renaissance architecture design.
Sainte-Chapelle. A 13th century, Gothic chapel with relics and notable stained-glass windows of biblical scenes. It was intended to keep precious Christian relics, including Christ`s crown of thorns, acquired by Saint Louis.
Île de la Cité. One of two remaining natural islands in the Seine within the city of Paris. An urban island with historic landmarks. It is a home to the Notre Dame cathedral.
Canal du Midi. Canal du Midi is a 240 km long canal in South of France. Originally named the Canal royal en Languedoc and renamed by French revolutionaries to Canal du Midi in 1789, it was considered one of the greatest construction works of the 17th century.
Champ de Mars. Landscaped park with extensive lawns, paths and trees, bird life, a children`s play area. And not to forget – the Eiffel Tower!
Pont du Gard. Landmark Roman aqueduct with 3 tiers. Mighty aqueduct bridge rising over 3 well-preserved arched tiers, built by 1st-century Romans. It was added to the world heritage monument of UNESCO.
Château de Chenonceau. A French château spanning the River Cher, near the small village of Chenonceaux in the Indre-et-Loire département of the Loire Valley in France. It is one of the best-known châteaux of the Loire valley, housing tapestry and Old Master paintings collection.
Catacombs of Paris. The Catacombs of Paris are underground ossuaries in Paris, France, which hold the remains of more than six million people in a small part of a tunnel network built to consolidate Paris` ancient stone mines. Illuminated labyrinth in former limestone mine with millions of ghoulishly arranged skeletons. Creepy? You bet.
Panthéon. A building in the Latin Quarter in Paris, France. It was originally built as a church dedicated to St. Genevieve and to house the reliquary châsse containing her relics but, after many changes, now functions as a secular mausoleum containing the remains of distinguished French citizens.
Paris Pantheon Admission Ticket, Priority Access
Aiguille du Midi. A mountain in the Mont Blanc massif within the French Alps. Very popular tourist destination and accessible by cable car from Chamonix.
Tour Montparnasse. Tour Maine-Montparnasse, or simply, Tour Montparnasse, is a 210 metre office skyscraper in Paris. It has with panoramic views and great for taking photos of Paris from roof terrace and 56th floor observation deck.
Place de la Bastille. A famous square in Paris where the Bastille prison stood until destroyed during French Revolution in (1789-1790).
La Défense. Paris business district (largest in Europe). Located at the westernmost side of the 10 km (6.2 mi) long Historical Axis of Paris, which starts at the Louvre in Central Paris and continues along the Champs-Élysées, beyond the Arc de Triomphe and along the Avenue de la Grande Armée. If you are into long walks, you can walk all the way from Louvre to La Défense and come back with metro or a bus.
Palais Garnier. A massive (almost 2000 seats) opera house, built from 1861 to 1875 for the Paris Opera. It`s an Italian style opera with Library Museum, with ceiling painted by Chagal.
Opera Garnier Day Tour with Official Opera de Paris Guide
The Promenade des Anglais. Also called locally, in Nice: Camin dei Anglés, a promenade along the Mediterranean Sea at Nice, France. It extends from the airport on the west to the Quai des États-Unis on the east, a distance of approximately 7 km (4.4 mi). Administratively speaking, it forms part of Route nationale 98, which runs between Toulon and Menton.
Lake Annecy. Scenic swimming and water-sports locale. Picturesque lake for nice sightseeing adventures, including 13th century Château de Menthon-Saint-Bernard and village of Menthon-Saint-Bernard. Also good for biking around the lake.
Old Port of Marseille. The Old Port ("Vieux Port") of Marseille engulfs a lively yacht marina and is famous for stylish hotels, cafes, and seafood restaurants serving fresh sea food from quayside fish market. Dominant in port is centuries old Fort Saint-Jean, standing near the Romanesque-style Saint-Laurent Church.
Musée de l`Orangerie. An art gallery of impressionist and post-impressionist paintings, mostly from 20th century. In the west corner of the Tuileries Gardens, next to the Place de la Concorde.
Place des Vosges. Originally named Place Royale, Place des Vosges is the oldest planned square in Paris. It is located in the Marais district, and it divides 3rd and 4th arrondissements of Paris. Lined with trees and red brick houses and built by Henri IV in 17th century.
Marseille, Aix-en-Provence, and Cassis Small Group Tour
Palais des Papes. A historical palace located in Avignon, in the south of France. It is regarded as one of the most important medieval Gothic buildings in Europe. It even rivalled Vatican in 14th century.
Mont Ventoux. A mountain in the Provence region of France, with an iconic bike trail, made famous in the Tour de France.
Musée Rodin. A museum opened in 1919, dedicated to the works of the French sculptor Auguste Rodin. Most famous work is world known The Thinker.
Avignon and Pont du Gard Day Trip from Paris by High Speed Rail
Luberon. A massif in central Provence in the south of France. Spectacular countryside of vineyards and orchards, fascinating hill-top villages, offering natural produce.
Pont Neuf. The oldest standing bridge across the river Seine in Paris. Built in 17th century, this stone bridge hosts statue of King Henri IV.
Interesting facts about France
There are around 40,000 châteaux (castles, palaces, manor houses, etc) in France. And many of them are for rent, so why don`t you try and have French holiday in style? You can rent your stay here.
Famous croissants were invented in Austria. That`s right, Austria, in 19th century, in Viennese bakery "Boulangerie Viennoise". But we don`t think croissant lovers will be taken away from this delicious pastry. Find your best croissant.
French was official language in England for almost 300 years (1066-1362). After the Norman Conquest in 1066, French language replaced English in the royal court, among clergy and aristocracy, although common people still used English. Find out more interesting facts about France.
We hope you enjoyed reading about France! Safe travels!
Travel Guides Editor @ gotravelyourself.comLeave a Comment on France: culture, history and gourmet food0
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Leaving home and heading to college is exciting, scary, and even mysterious. You didn't pack up everything you own, cram it into your car, and say goodbye to your family and home town because you wanted to play it safe. You've heard the statistics - dropout rates as high as 47%, average student loan debt over $44,000, 50% of students will change their major at least once - we won't even get into potluck roommates or community bathrooms!
Regardless, you are here and you are brave. College is a crash course for gaining new life skills and experiences designed to give the best odds for success in your future careers and families. Christian Challenge is here to help. Each of our staff has been transformed by Jesus through college ministry and want to ensure you graduate with that same life-changing experience!
A statistic that has startled us is how 70-80% of college students walk away from their faith by the time the graduate. By learning the "why" behind Jesus' ministry it's our mission to partner with campuses and lower that percentage! We do this through small group studies and one-on-one mentorship.
We would love to get to know you, see where you come from, and help guide where you are going. Select your campus above to join a LIFE Group and visit About Us to get to know our staff. We hope to see you around!


Around about 2002 I decided I wanted to start quilting. I grew up in a house where my mom was always sewing so I had picked up basic sewing skills, but none of my close friends or family members quilted. My mom made exactly one quilt when I was a kid, and vowed never to make another. I got myself the book Quilting for Dummies which I found to have great information on the basics for getting started.
This is actually the second quilt that I finished, but it is the first that I pieced. I didn't realize before I started piecing it that they hadn't left seam allowances for the corners of the 9-patch blocks to not get cut off when the borders were added. What a major bummer for my first project! But it taught me always to double check a pattern before using it. I used a walking foot to do some very basic quilting and the binding was done by folding over the backing fabric (the one and only time I did this, before moving to using a bias binding). I stitched a "label" on the top of the binding. It reads: My First Piecing by Sarah. It wasn't really my first quilt, since I finished a lap quilt before I actually finished this one.
My 9-patch blocks are 6" finished squares and the whole quilt finishes out at about 21" square, a perfect table topper size. These are not currently my colors... I'm not sure they ever were or how I settled on them for my first project. Mom loves them though, and I'm glad that she enjoys the quilt.
I'll be linking up to Quilty Flashback Friday.
Posted in Quilting. Tags: 9-patch on August 21, 2014 by sarah.
As always, just beautiful work, Sarah!
Very pretty Sarah...love the colors!!
I learn something from every quilt I make. So neat to see how your piecing began.


text:
Q: Interceptor for 401, Renew and Retry Angular 2 ANGULAR 2 - RC5, ADAL.js

Problem
So I'm working on authenticating with Microsoft AD using adal.js and angular 2. I've got the hang of adal.js and can login, refresh tokens, logout, get users, etc etc.
My problem right now has to deal with extending Http and creating a custom class that on a 401 will retry the request that just failed.
Here is basically what I have right now:
export class HttpInterceptor extends Http {
    constructor(backend: ConnectionBackend, defaultOptions: RequestOptions, private _router: Router, private adal: IgAdal) {
       super(backend, defaultOptions);
    }

    request(url: string | Request, options?: RequestOptionsArgs): Observable<Response> {
       return this.intercept(super.request(url, this.getRequestOptionArgs(options)));
    }

    get(url: string, options?: RequestOptionsArgs): Observable<Response> {
       return this.intercept(super.get(url, this.getRequestOptionArgs(options)));
    }

    intercept(observable: Observable<Response>): Observable<Response> {
       return observable.catch((err, source) => {
         if (err.status  == 401) {
            this.adal.acquireTokenObservable().flatMap(data=>{
                // NOT SURE WHAT TO DO HERE...
                return Observable.throw(err);
            })
         } else {
            return Observable.throw(err);
         }
      });
    }
}

This works great when its not a 401, throws the error like it should. Now when I try to call super.get() after a 401 and a new token has been acquired... It doesn't try the request again, instead I get an error like so...
Cannot read property 'subscribe' of undefined

^^^ I think this has something to do with the subscription to request after all has been returned.
I think it's also worth pointing out that I have the main.ts setup just fine as the interceptors are at least working.

My questions are:

*

*Is it correct to retry the request from within the interceptor? Or does it make more sense to retry the request in the subscription later down the line.

*Is it even good practice to be retrying the request or is it better to notify the user to try again? (I'm assuming not sense that sounds kind of jarring)

*Is there an rxjs function I can use to retry after a value has been returned? (Like the token from the "acquireToken" function)

Edit 1
    intercept(observable: Observable<Response>): Observable<Response> {
    return observable.catch((err, source) => {
        if (err.status  == 401) {
            return this.adal.acquireTokenObservable().flatMap(data=>{
               return observable.retry(3);
            })
        } else {
            return Observable.throw(err);
        }
    });
}

Just tried the "retry" rxjs operator.. seems to be doing what I'd like it to do. Now my question is... How do I send someone to the login page after the retry fails?

This is my first stackoverflow question so I appologize if its not the best layout
Thank you!!

A: For anyone looking into this... I ending up doing this.
intercept(observable: Observable<Response>): any {
    return observable.catch((err, source) => {
        if (err.status == 401) {
            return this.adal.acquireTokenObservable().flatMap(data=>{
                if (data === 'User login is required') {
                    this.adal.login();
                }
                return observable;
            })
        } else {
            return Observable.throw(err);
        }
    });
}

Returning the observable stream itself instead of .retry() seems to do the exact same thing and also just retrys 1 time. Otherwise .retry(1) will actually throw 3 seperate errors for some reason.
The

this.adal.acquireTokenObservable()

Is an observable I did using the adal.js library to return a stream with the new token. Still working on a couple other issues regarding retrying certain requests, but this is a good start.

A: *

*401 is unauthorized and hence we do not retry in interceptor and the request is rejected. If you want to retry you can call the acquiretoken API again.

*Letting the user decide would be better. Unless the server is down(http resopnses 500,503 and 504) or if there is a network timeout and you don't receive a http response.In these scenarios a retry at developers end would be preferred.

*There is no retry function in adal.js library. If you want to retry you need to call the AcquireToken API again.

redpajama_set_name: RedPajamaStackExchange


Congrats to all - seems a great outcome all round! ..and just in time for salmon season Joel!
Oh, by the way there is an unwritten rule that my name tag stays in the toilets there at the shop. Its a special thing as you could understand.
hahaha..... Yeah..... Charlie stays in the toilet.... It's a little unnerving seeing him here every time.
Just noticed this thread. Congratulations on finding a suitable new owner to whom you can pass the baton, Joel, and I wish you all the very best in your future endeavours.
Good luck with your new business, Sue and Maureen.
Thanks PLJ. Business will continue as usual in Jandakot. Only change at the moment will be different name and different pooch in the office. Hoping to build business and be able to get our regular workers back on board. Nat and Pete are very important to us.
Congrats Sue and Maureen. Joel now you will be able to go on that trip you've been working on.
Have you fired Joel yet?
You know all he does is sit in the office? He never comes out and greets customers.
All seriousness Good on you. You have a great business and some big shoes to hop into and although I've only been on this forum for a short time, I'm sure Joel will still be around when you need him.
If I was a betting man I would bet he wont be able to stay away.
Good on you Joel good luck to your next endeavour.
WARNING: I suffer from ideaphoria. This post may contain untested ideas, errors, and excessive enthusiasm.


SIOS Protection Suite Microsoft SQL Server Application Recovery Kit includes tools and utilities that allow SIOS Protection Suite to manage and control the Microsoft SQL-based database application. When installed, SIOS Protection Suite is able to monitor the health of the application and automatically recover the application if it fails. The SIOS Protection Suite Recovery Kit is non-intrusive and requires no changes within the application in order for SIOS Protection Suite to protect it.
This recovery kit provides menu-driven definition of resources for automatic switchover of a Microsoft SQL Server instance. The kit provides options that allow you to easily create a complete resource hierarchy so that the recovery operation can include all disk resources used by the SQL Server as well as the Named Pipe or IP socket resources used to access the database.
For further information, refer to the Microsoft SQL Server Recovery Kit Technical Documentation.
Note: Product Requirements and FAQ information is delivered in the OS specific Release Notes.


Red River Adventures, located in beautiful Moab, Utah is proud to offer the very best and most fun Utah rafting Day Tips, Rock Climbing, and Canyoneering adventures. If you are looking for and extended family friendly Rafting Vacation of Multi Sport Adventure we have what you are looking for! Our trips are unmatched. Come see what everyone is talking about. You will be happy you did.
Thanks Jamie and Nathan for the wonderful expirience! We had a lot of fun on the water, saw some beautiful scenes and Nathan, you cooked us a delicious meal. We had a room with a view! Everything was excellent!
Be the first to add a review to the Red River Adventures.


The most detailed proteomics study to date of the human embryonic stem cell proteome has identified 3184 proteins, including post-translationally modified proteins and known stem cell markers.
It is worthwhile to carry out deep research for less painless and time saving bone marrow transplant procedure that can help the patients as well as bone marrow donors to complete the necessary treatment without losing time.
PerkinElmer has bought the Swedish analytical instrument company Perten Instruments for $266 million.
Do Martian methane and organic compounds point to life?
A spike in the levels of methane on Mars combined with the discovery of organic compounds in Martian rocks has led some observers to speculate that there may be life on the planet after all.
Bisphenol A leaching into canned drinks increases blood pressure, or does it?
Reports that canned drinks increase the blood pressure due to the leaching of bisphenol A from the interior coatings are open to interpretation.
Agilent Technologies and Baylor College of Medicine in Houston, US, have opened the Agilent Technologies Mass Spectrometry Center of Excellence.
A rapid NMR test to detect horse meat adulteration of beef is suitable for high-throughput screening in the food supply chain.
The latest in a series of tutorials prepared under the International Proteomics Tutorial Programme has been released: Basics of mass spectrometry based metabolomics.
Unexpected borate complexes detected during the electrospray ionisation mass spectrometry of hydroxy acids were traced to trimethyl borate from borosilicate glass bottles that leached into the methanol being stored.
A simple non-destructive optical method has been developed to distinguish between human and nonhuman blood primarily for customs purposes.
Waters has inaugurated Colorado State University's Proteomics and Metabolomics Facility into its Centers of Innovation Program.


Innovation is a means, not an end per se. A firm's innovation strategy should be about how its management of innovations will help it to leverage its unique resources and adjust to changes in its environment, in line with its corporate purpose.
Innovation strategies should be based on what the firm understands are the present and future key success factors relevant in the environment it faces, including in particular new partnerships, and its present and future sources of competitive advantages, including in particular its unique datasets.
Innovation strategies should be based on a shared understanding of who are the key stakeholders, including shareholders, employees, customers and society, and what are their expectations, especially regarding the time horizon considered and level of ambition.
Strategy should drive innovation, not the other way around. A firm's innovation posture should therefore be defined based on what its strategic objectives are in terms of innovation, and not just on the latest innovation buzzwords or recipes.
(Book) Davila, T., Epstein, M., & Shelton, R. (2012). Making innovation work: How to manage it, measure it, and profit from it. FT press.
(Article) Covin J.G. & Slevin D. P. (1989) Strategic management of small firms in hostile and benign environments. Strategic Management Journal, 10 (January): 75-87.
(Article) Dobni, C.B. (2010). The relationship between an innovation orientation and competitive strategy. International Journal of Innovation Management, 14(2), 331 – 357.
(Article) Jayaram, J., Oke, A., & Prajogo, D. (2014). The antecedents and consequences of product and process innovation strategy implementation in Australian manufacturing firms. International Journal of Production Research, 52(15), 4424-4439.
(Article) Kalay, F., & Lynn, G. (2015). The Impact of Strategic Innovation Management Practices on Firm Innovation Performance. Research Journal of Business and Management, 2(3), 412-429.
(Article) Mintzberg, H. (1978). Patterns in strategy formation. Management Science, 24(9), 934-948.
(Article) Prajogo, D. I. (2016). The strategic fit between innovation strategies and business environment in delivering business performance. International Journal of Production Economics, 171, 241-249.
(Article) Rosenbusch, N., Brinckmann, J., & Bausch, A. (2011). Is innovation always beneficial? A meta-analysis of the relationship between innovation and performance in SMEs. Journal of Business Venturing, 26(4), 441-457.
(Article) Sirmon, D. G., Hitt, M. A., Ireland, R. D., & Gilbert, B. A. (2011). Resource orchestration to create competitive advantage: Breadth, depth, and life cycle effects. Journal of Management, 37(5), 1390-1412.
(Article) Zajac, E.J., Kraatz, M.S., & Bresser, R.K. (2000). Modeling the dynamics of strategic fit: A normative approach to strategic change. Strategic Management Journal, 429-453.
(Book) Helfat, C., Finkelstein, S., Mitchell, W., Peteraf, M., Singh, H., Teece and D., Winter, S. (2009). Dynamic capabilities: Understanding strategic change in organizations. John Wiley & Sons.
(Book) Shapiro, C., Carl, S., & Varian, H. R. (1998). Information rules: a strategic guide to the network economy. Harvard Business Press.
(Article) Adner, R., & Helfat, C. E. (2003). Corporate effects and dynamic managerial capabilities. Strategic Management Journal, 24(10), 1011-1025.
(Article) Barney, J. B. (1986). Strategic factor markets: Expectations, luck, and business strategy. Management Science, 32(10), 1231-1241.
(Article) Barney, J. (1991). 'Firm resources and sustained competitive advantage'. Journal of Management, 17, 99-120.
(Article) Black, J. A., & Boal, K. B. (1994). Strategic resources: Traits, configurations and paths to sustainable competitive advantage. Strategic Management Journal, 15(S2), 131-148.
(Article) Danneels, E. (2002). The dynamics of product innovation and firm competences. Strategic Management Journal, 23(12), 1095-1121.
(Article) Furr, N., & Kapoor, R. (2017). Capabilities, technologies, and firm exit during industry shakeout: Evidence from the global solar photovoltaic industry. Strategic Management Journal.
(Article) Granstrand, O., Patel, P., & Pavitt, K. (1997). Multi-technology corporations: why they have "distributed" rather than "distinctive core" competencies. California Management Review, 39(4), 8-25.
(Article) Henderson, R., & Cockburn, I. (1994). Measuring competence? Exploring firm effects in pharmaceutical research. Strategic Management Journal, 15(S1), 63-84.
(Article) Klenner, P., Hüsig, S., & Dowling, M. (2013). Ex-ante evaluation of disruptive susceptibility in established value networks—When are markets ready for disruptive innovations?. Research Policy, 42(4), 914-927.
(Article) Leavy, B. (2003). Assessing your strategic alternatives from both a market position and core competence perspective. Strategy & Leadership, 31(6), 29-35.
(Article) Liao, J. J., Kickul, J. R., & Ma, H. (2009). Organizational dynamic capability and innovation: An empirical examination of internet firms. Journal of Small Business Management, 47(3), 263-286.
(Article) Makadok, R. (2001). Toward a synthesis of the resource‐based and dynamic‐capability views of rent creation. Strategic Management Journal, 22(5), 387-401.
(Article) Markides, C. C., & Williamson, P. J. (1996). Corporate diversification and organizational structure: A resource-based view. Academy of Management Journal, 39(2), 340-367.
(Article) Oliver, Ch. (1997). Sustainable competitive advantage: Combining institutional and resource-based views. Strategic Management Journal, 697-713.
(Article) Parmar, R., Mackenzie, I., Cohn, D., & Gann, D. (2014). The new patterns of innovation. Harvard Business Review, 92(1), 2.
(Article) Patel, P., & Pavitt, K. (1997). The technological competencies of the world's largest firms: complex and path-dependent, but not much variety. Research Policy, 26(2), 141-156.
(Article) Peteraf, M. A. (1993). The cornerstones of competitive advantage: A resource‐based view. Strategic Management Journal, 14(3), 179-191.
(Article) Schreyögg, G., & Kliesch‐Eberl, M. (2007). How dynamic can organizational capabilities be? Towards a dual‐process model of capability dynamization. Strategic Management Journal, 28(9), 913-933.
(Article) Simpson, D. G. (1998). Why most strategic planning is a waste of time and what you can do about it. Long Range Planning, 31(3), 476-480.
(Article) Tripsas, M. (1997). Unraveling the process of creative destruction: Complementary assets and incumbent survival in the typesetter industry. Strategic Management Journal, 18(S1), 119-142.
(Article) Wernerfelt, B. (1984). A resource‐based view of the firm. Strategic Management Journal, 5(2), 171-180.
(Article) Winter, S. (2003). 'Understanding dynamic capabilities'. Strategic Management Journal, 24, 991-995.
(Article) Yoffie, D. B., & Kwak, M. (2006). With friends like these: The art of managing complementors. Harvard Business Review, 84(9), 88-98.
(Article) Zollo, M., & Winter, S.G. (2002). Deliberate learning and the evolution of dynamic capabilities. Organization Science, 13(3): 339-351.
(Book) Baghai, M., Coley, S., & White, D. (2000). The alchemy of growth: Practical insights for building the enduring enterprise. Da Capo Press.
(Book) Jonas, H. (1985). The imperative of responsibility: In search of an ethics for the technological age. University of Chicago press.
(Book) Pavie, X. (2012). Innovation-responsable: stratégie et levier de croissance des organisations. Editions Eyrolles.
(Article) Camillus, J. C. (2008). Strategy as a wicked problem. Harvard Business Review, 86(5), 98.
(Article) Clarke, T. (1998). The stakeholder corporation: A business philosophy for the information age. Long Range Planning, 31(2), 182-194.
(Article) Eccles, R. G., Ioannou, I., & Serafeim, G. (2014). The impact of corporate sustainability on organizational processes and performance. Management Science, 60(11), 2835-2857.
(Article) Frey, C. B., & Osborne, M. A. (2017). The future of employment: how susceptible are jobs to computerisation?. Technological Forecasting and Social Change, 114, 254-280.
(Article) Geroski, P., & Machin, S. (1992). Do innovating firms outperform non‐innovators?. Business Strategy Review, 3(2), 79-90.
(Article) Gobble, M. M. (2015). The case against disruptive innovation. Research-Technology Management, 58(1), 59-63.
(Article) Gottschalg, O., & Zollo, M. (2007). Interest alignment and competitive advantage. Academy of Management Review, 32(2), 418-437.
(Article) Greenwood, R., Raynard, M., Kodeih, F., Micelotta, E. R., & Lounsbury, M. (2011). Institutional complexity and organizational responses. Academy of Management Annals, 5(1), 317-371.
(Article) Hitt, M.A., Ireland, R.D., Sirmon, D.G., & Trahms, C.A. (2011). Strategic entrepreneurship: creating value for individuals, organizations, and society. The Academy of Management Perspectives, 25(2), 57-75.
(Article) Leiponen, A. & Helfat, C.E. (2010). Innovation objectives, knowledge sources, and the benefits of breadth. Strategic Management Journal, 31, 224–236.
(Article) Pache, A. C., & Santos, F. (2010). When worlds collide: The internal dynamics of organizational responses to conflicting institutional demands. Academy of Management Review, 35(3), 455-476.
(Article) Pache, A. C., & Santos, F. (2013). Inside the hybrid organization: Selective coupling as a response to competing institutional logics. Academy of Management Journal, 56(4), 972-1001.
(Article) Sitkin, S. B., See, K. E., Miller, C. C., Lawless, M. W., & Carton, A. M. (2011). The paradox of stretch goals: Organizations in pursuit of the seemingly impossible. Academy of Management Review, 36(3), 544-566.
(Article) Stilgoe, J., Owen, R., & Macnaghten, P (2013). Developing a framework for responsible innovation. Research Policy, 42(9), 1568-1580.
(Article) Suchman, M.C. (1995). Managing legitimacy: Strategic and institutional approaches. Academy of Management Review, 20(3), 571-610.
(Article) Weick, K.E., Sutcliffe, K.M., & Obstfeld, D. (2005). Organizing and the process of sensemaking. Organization Science, 16(4), 409-421.
(Book) Miles, R.E. and Snow, C.C. (1978). Organizational strategy, structure, and process. New York: McGraw-Hill.
(Article) Becheikh, N., Landry, R., & Amara, N. (2006). Lessons from innovation empirical studies in the manufacturing sector: A systematic review of the literature from 1993–2003. Technovation, 26(5-6), 644-664.
(Article) Damanpour, F., Szabat, K. A., & Evan, W. M. (1989). The relationship between types of innovation and organizational performance. The Journal of Management Studies, 26(6), 587.
(Article) Danneels, E. (2008). Organizational antecedents of second‐order competences. Strategic Management Journal, 29(5), 519-543.
(Article) Dibrell, C., Craig, J. B., & Neubaum, D. O. (2014). Linking the formal strategic planning process, planning flexibility, and innovativeness to firm performance. Journal of Business Research, 67(9), 2000-2007.
(Article) Eiriz, V., Faria, A., & Barbosa, N. (2013). Firm growth and innovation: Towards a typology of innovation strategy. Innovation, 15(1), 97-111.
(Article) Fiss, P. C. (2011). Building better causal theories: A fuzzy set approach to typologies in organization research. Academy of Management Journal, 54(2), 393-420.
(Article) Francis, D., & Bessant, J. (2005). Targeting innovation and implications for capability development. Technovation, 25(3), 171-183.
(Article) Gatignon, H., & Xuereb, J. M. (1997). Strategic orientation of the firm and new product performance. Journal of Marketing Research, 77-90.
(Article) Gunday, G., Ulusoy, G., Kilic, K., & Alpkan, L. (2011). Effects of innovation types on firm performance. International Journal of Production Economics, 133(2), 662-676.
(Article) Hall, L. A., & Bagchi-Sen, S. (2007). An analysis of firm-level innovation strategies in the US biotechnology industry. Technovation, 27(1-2), 4-14.
(Article) Hollenstein, H. (2003). Innovation modes in the Swiss service sector: a cluster analysis based on firm-level data. Research Policy, 32(5), 845-863.
(Article) Kanter, R. M. (2006). Innovation: The classic traps. Harvard Business Review, 84(11), 72-83.
(Article) Laosirihongthong, T., Prajogo, D. I., & Adebanjo, D. (2014). The relationships between firm's strategy, resources and innovation performance: resources-based view perspective. Production Planning & Control, 25(15), 1231-1246.
(Article) Linton, G., & Kask, J. (2017). Configurations of entrepreneurial orientation and competitive strategy for high performance. Journal of Business Research, 70, 168-176.
(Article) Loewe, P., Williamson, P., & Wood, R. C. (2001). Five styles of strategy innovation and how to use them. European Management Journal, 19(2), 115-125.
(Article) Miller, D., & Friesen, P. (1982). 'Innovation in conservative and entrepreneurial firms: two models of strategic momentum'. Strategic Management Journal, 3, 1-24.
(Article) Mintzberg, H. (1994). The fall and rise of strategic planning. Harvard Business Review, 72(1), 107-114.
(Article) Naranjo-Valencia, J., Jiménez-Jiménez, D., & Sanz-Valle, R. (2011). 'Innovation or imitation? The role of organizational culture'. Management Decision, 49, 55-72.
(Article) Olson, E.M., Slater, S.F. and Hult, G.T.M. (2005). The performance implications of fit among business strategy, marketing organization structure, and strategic behaviour. Journal of Marketing, 69(3), 49-65.
(Article) Pérez-Luño, A., Wiklund, J., & Cabrera, R.V. (2011). The dual nature of innovative activity: How entrepreneurial orientation influences innovation generation and adoption. Journal of Business Venturing, 26(5), 555-571.
(Article) Pisano, G.P. (2015). You need an innovation strategy. Harvard Business Review, 93(6), 44-54.
(Article) Prange, C., & Schlegelmilch, B. B. (2018). Managing innovation dilemmas: The cube solution. Business Horizons, 61(2), 309-322.
(Article) Reeves, M., Love, C., & Tillmanns, P. (2012). Your strategy needs a strategy. Harvard Business Review, 90(9), 76-83.
(Article) Srholec, M., & Verspagen, B. (2012). The Voyage of the Beagle into innovation: explorations on heterogeneity, selection, and sectors. Industrial and Corporate Change, 21(5), 1221-1253.
(Article) Tether, B., & Tajar, A. (2008). 'The organisational-cooperation mode of innovation and its prominence amongst European service firms'. Research Policy, 37, 720-739.


For this week's Dear Mark I thought I'd follow up on the issue of post-workout nutrition from a couple of weeks ago. I mentioned in Dear Mark: Muscle Building and Carbs that I fast once in awhile after a workout. I've gotten a lot of comments and messages about this point since that post. So, here's my take on PWO fasting as promised!
As I've mentioned before in relation to intermittent fasting (IF), fasting is known to significantly increase HGH secretion. (Grok's survival depended on the ability to hormonally kick start efficiency and preservation modes during the lean days.) Research has also consistently confirmed that intense exercise, particularly resistance training, also triggers a rise in HGH. While I can (and do) take advantage of each individual method, combining the two opportunities can maximize my body's HGH release.
And I should add that I do this without worrying about a blow to muscle mass. Fasting occasionally post-workout, provided I maintain a high protein diet the rest of the time, doesn't negatively impact nitrogen retention and protein synthesis. Just as I mentioned last week that the body won't suffer if you don't force reloading of glycogen stores with a shot of glucose after a workout, I'll go out on a limb and say that you're unlikely to waste away if you don't fuel muscles immediately with protein as well. The fact is HGH has its own protein conservation potential. And, while the post-workout period is an optimum opportunity for protein synthesis, it's not the sole time your body is able to use protein and provide for the muscles' needs.
Finally, yet another means of naturally encouraging HGH release is getting a good night's sleep. After a good fast (and a great workout), I find this part comes the easiest. Honestly, it's the best sleep I get.
Hi Mark, Great post as always.
Where I work out is between 45 min to 1.5 hours (depending on traffic… oh Los Angeles) from my house so I tend to work out and then just wait until I eat dinner (generally 2-3 hours after I finish my work out). Would it be a good idea to start bringing a protein rich snack in the car to eat while I'm on my way home?
Thank you for the post Mark. I know thhis should answer some of the questions out there. I too enjoy fasting every now and then after a workout. Only occasionally though as I also thouroughly enjoy chowing down after a good hard workout too.
Very nice blog! I was so hungry after my two hour hike yesterday! I had fish, cereal, yogurt, ravioli and a salad. Just went on and on. Plus I was really tired, had a small breakfast and stayed up late the night before. I like this idea of an IF occasionally after a workout. I slept very well last night.
I just wanted to say thanks again for the interview!
I also had a question regarding IF post workout. I tend to hit the gym sometimes pretty late at night. If there isn't enough downtime between your workout and bedtime, is it a good idea to just not eat until the morning or should you at least eat something?
And thank you for letting me write the upcoming post for Thursday! I'll make sure to let my readers know.
How long does the post-workout fast go on for? An hour? Three? Til the next day?
Loved the interview, and glad to hear you're a fan of Jack Lalanne. I was worried only us old fogies (76 years young) had heard of the original fitness guru!
I'm not sure if Mark covered it, but I think Art DeVany will work out and occasionally skip dinner. If you do this intermittently, it will not work against you as both he and mark have stated, sometimes Grok just can't get the bear no matter how hard he tries.
I'm glad this post confirms what I've been doing. On hard workouts (ie. glycolytically demanding) I'll have a post workout meal, but on Alactic or just heavy lifting days, I can go with a bit of a fast pwo.
The main idea in the post today is to confirm that it's OK not to eat after a workout once in a while. I don't do it all the time, but I also never freak out (like my body builder friends) if I skip a PWO snack or meal – or two. I can't cite any research as to an exact ideal amount of fasting time, so I'll say anything and everything will work in this case: 1.5 hours or 3 hours, overnight if you've worked out late. I just don't go for the high carb PWO meal anymore.
Remember, Grok ate intermittently, sporadically, fractally, and pluri-voluminously. His genes (and ours) were designed to respond ideally to all forms of feast/famine (provided the food choices are in alignment) and the types of exercises he did.
I've just started documenting my own experience with IF as I prepare for a physique show. So far I love the results, and will try a 2 hour post-workout fasting window to see if that accelerates fat loss. Thanks for the post!
Hi Mark, Love your blogs soo helpful! I've been low carbing for only 5 weeks, I'm having between 15-30gms carbs. I have had major blood sugar issues in the past which are improving little by little since switching to low carb. I'm wondering whether fasting after a workout for a person with blood sugar issues is a good idea?
I had a similar question. If one is already partially ketotic going into a workout, and one works out intensely, say 20-35min (ie. a long-ish crossfit WOD)would blood sugar be a bit "high" right after the workout? since the body will be converting fatty acids to ketones, how will that read on, say, a blood sugar meter for a diabetic?
Michelle, you could always go the protein route after your workout. Giving your body a substrate to use for gluconeogensis as needed (and gluconeo burns fats) should address the low glucose issue.
I try to follow alternate-day fasting as much as possible, a 36/12 hour fasting/eating cycle (often more like 40/8). I frequently train on two consecutive days: early afternoon on the fast day and a similar time on the eating day, before breaking the fast mid-afternoon. Not only is this not counter-productive, it possibly even gives me a boost. I really tear into a workout on an empty stomach.
Most people I tell about this have a fit when they realise how long I go without food before training. Some can't even believe I skip breakfast.
I think it depends a lot on the person. I can fast for ten days easily most of the time. Now ten years ago I couldn't. Not that I do fact that long more than once a year. I'm just saying going without food really bothers some people, but others not do much. I usually do 18/6 IF, but I also just started low carb at the end of last year. I haven't tried going longer than that mainly because I'm often told I don't eat enough. I'm happy with 1000 cal a day mist days. It's hard for me to eat 1,500 calories a day. So yeah some people freak out when you talk about fasting only because I think they go into starvation mode just st by hearing about it. I drink coffee for breakfast then eat my eggs and bacon at lunch. I've never been a breakfast person, but the BP coffee helps me switch back into ketosis after naturally dropping out by morning since I don't eat after 5 PM.
The best sleep I ever have is midway through my fast, sleep is so good.
I enjoyed reading your interview with Andrew.
I'm also a fan of Jack Lalanne all my life, since i was little, i'd watch him on T.V. and exercise with him, it was fun!
Fasting causes my best night sleeps, actually get better night sleeps on a day of fast.
I more than appreciate this post, you've answered alot of my questions i've always had on fasting!
Great post. As I say, muscle builds 24/7….well if you give it the correct stimulus of course. Also there might be MORE benefit to pre-workout amino acids in their role for muscle repair vs post workout. Post workout shakes are for people who like to get fatter and call it mass (not muscle) gaining….I did it for many years of my younger life.
Wow, I'm so glad you said that! I've been using BCAA's (powder) pre workout for months now and I've really seen the difference!
With all due respect, I'm a bit disappointed with the article. Where is the evidence (research) to back up these claims? I'm not convinced that fasting after a workout or before one is optimal for muscle retention/building. I mean, anything is possible, but saying that our pre-ancestors sometimes had to do it proves absolutely nothing. Give us some substance, not mere speculation.
Add me to the list of fasters, not only after a workout (intermittently) but almost always before.
90% plus of my two weekly 30-minute intense sessions are begun at a point where I've not eaten for 18-30 hours (I'm still in fat loss mode — I'll be looking to cut that to every other time). I love working out fasted, and during the time I've been doing this my bench press, as one indicator, has gone from around 100 pounds to warm up at 135, then 185, then 205.
I'm usually hungry when I begin the workout, but hunger is completely killed 5-10 minutes in. It never returns for at least two hours after completion, and I never force feed. I eat when hungry. However, about every other time, I'll extend the time time before eating to as much as 4-6 hours.
It appears that you both have very different thoughts on the matter.
As for PWO nutrition, sometimes I eat and sometimes I don't. Good reasons for both, I guess, but remember that in PB workouts, you really don't need to refill glycogen stores the way you do if you are training longer, harder and higher heart-rates. When there's no need for extar glycogen, there's no need to eat extra. meanhwile, HGH improves when you DON'T eat PWO.
Hey Mark, I'm glad I just came upon this article because I have a few theories regarding pwo nutrition and you seem have similar views.
1) Number one is the HGH double whammy. Another theory I have is that while fasting blood is supplied to the brain and muscles, blood is essential to repair of damaged tissues. Now eating a big carb heavy meal would, imo, divert the blood from those damaged muscles and into the digestive system further impairing muscle repair.
2) I have read the six part post over at iflife.com about what happens to your body when you fast, which deals extensively with tissue repair and anti inflammation. Two bonuses of IF that are a big factor in why I IF that I feel would be negated during a critical time if I break my fast immediately post workout.
3) Finally, on an adaptive level, Grok probably would have failed on a hunt fairly regularly. Especially when he was just learning how. This, IMO, would cause our adaptive mechanisms to insure that next time Grok went out hunting, he would be able to run faster and throw his spear further in order to see to it that he doesn't fail again.
Now I am by no means a scientist and it's easy to make arguments for anything if you try hard enough. But I was just wondering what your thoughts would be on some of these points.
Joey, I agree with all three points. Not being a scientist sometimes means you get to think logically and not have to back it up with some made-up science project!!
I would like to see solid information regarding the HGH production when fasting after a work out.
The occasional IF does wonders for fat loss.
One thing I wonder about regarding post work out carbs…doesn't elevated insulin suppress cortisol? How does one factor that in as a mitigator to the catabolic effects of the elevated cortisol? As of now, I still have a banana as part. I have wondered about whether to ditch it or not.
I read different approaches to preworkout nutrition while fasting. Some say your first meal after fasting should be the preworkout meal while others say the first meal should be post workout meal. What do you think ?
Post-workout nutrition is grossly over-hyped pseudoscience. Scientifically, there is no magic nutrition window for muscle growth, which actually continues 3+ days after each workout. Plus, the body has more than enough protein available to recycle for muscle needs for an hour or two (actually, much longer than that).
The notion of a "magic window" for post-workout nutrition is just based on misunderstanding a small portion of research taken grossly out of context.
I was wondering, if I were to fast PWO when I did eventually eat does it really matter too much what level of protein I eat? Should I strive for a fast digesting protein as I would PWO or just go with a high quality protein regardless of the pace of digestion? And also after that fasting period are you still a fan of hardly any carbs or none at all?
Hey, when you fast post-workout, are you being in the 'fed' state the first half of the day? Or do we fast, workout and continue fasting?
Sometimes if I skip a meal I get a bit light headed – last night I did an hours resistance intense workout class and came home at 9 and wanted something to eat – I get a bit grouchy if I don't eat! So I just had some steamed veggies and some yoghurt after, and I woke up the next morning feeling really hungry. My question is, would this have had any benefits like IF if I did eat something last night?
Whether it is ok to fast PWO or not depends on many factors.
1) How long are you working out ?
2) How many calories are you consuming daily ?
3) What is your Body Fat % ?
If your goal is to build muscle, then you want to be eating on a surplus and not on a deficit, so you will have to get proper nutrition, proper macros and supplements if necessary to assure muscle health and growth.
If you are a newbie you might get away with it,by what's called newbie gains.
providing the rest of the day you eat well, you eat enough calories, and get proper supply of proteins based on your LBM, you should preserve lean mass. Otherwise you are asking for inevitable lean muscle loss.
For optimal recovery and growth it is advised to have a PWO meal, ideally both carbs and protein, but if you don't want the carbs, at least the protein ! If by fasting you mean working out evening and fasting over night until breakfast (which is probably around 12-14 hour fast) that's not too good, hinders recovery and in the long run muscle loss.
Mark sorry bad writing, do not speak English, I have a doubt, weight only 57 pounds and I'm 1.82 meters tall, my body fat percentage is very low even then I do not eat carbs after training?
A few years back I did intermittent fasting and upper-lower body split workouts with free weights.
I cycled eating and training, so one day I would eat, the next train upper body, then eat, then lower, and so on. (I ate a *lot* on the days between workouts!) I had no trouble gaining strength (and also muscle mass). I don't know if I would have gained more without the IF, but I was not unhappy with the results. It was also very time-efficient.
I'm considering doing something similar again. These days I do full-body workouts and train three times a week M/W/F. I might just fast two days a week, and mix it up so that some eating days are on training days, and some are in between.
Hey Mark, I heard you say on the Rogan podcast you most recently did, very briefly on this, in effect "If I am trying to gain muscle I'm not eating after lifting". Googled more and found this post which is quite old! the way you said it on the podcast made it sound like you had more definitive thoughts on this than this blog suggests, you have updated your thinking here?


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We say we like weird cars around here. But how weird are you really willing to live with? If you're up for living in the strangest form of opulent Franco-Italian luxury there is, consider the Citroën SM. You have no idea how great this thing is.
Normalcy is highly overrated. This is especially true in cars.
The SM is basically what a Lexus would be if it were designed by interesting people. It is, as I've said before, the official car of those dancing blue aliens in Daft Punk's "One More Time" video. Powered by a 3.0-liter Maserati V6, it rides on a hydropneumatic self-leveling and adjustable oil suspension, which gives it the smoothest damn ride quality you're likely to find anywhere.
The combination of the sonorous Italian V6, the silky ride, the sliding lock manual gear shifter and the cigar-spaceship body make this one of the most memorable and unusual cars you'll ever experience.
Coincidentally—and I might add sadly, because I'm fond of this one in particular—the SM you see in this video is for sale. It can be had on Bring A Trailer, and as of this writing the current bid is at $5,500 with seven days to go. All service records (there are probably a lot) since 2010 are included, and the motor was rebuilt in 2014.
Are you willing to give this machine a new home? You should. I know Alex has taken great care of it, and while its combination of French and Italian parts will likely make it fit only for the most attentive of owners, it's worth it.
Is There A More Absurd Rally Car Than A Citroën SM?


The Committee on Credible Practice of Modeling & Simulation in Healthcare (https://simtk.org/home/cpms) is an initiative started under the IMAG and MSM stemming from discussions at previous years' MSM Consortium meetings, and monthly IMAG/MSM meetings. Throughout these discussions it became clear that research activities in computational medicine are growing at a significant rate and notable discoveries are being made. However, the mechanisms or processes necessary to appropriately translate these research activities and discoveries in computational methods to clinical practice are lacking. Moreover, there is substantial research diversity in the field such that subject matter experts within and across mathematical and biological disciplines tend to have their own interpretation of credible practice in M&S. Additionally, tools and good practice guidelines established by individual disciplines or research areas do not readily transfer across other disciplines or are not adopted by different fields. To help fill these critical gaps, the "Committee on Credible Practice of Modeling & Simulation in Healthcare" was established.
The goal of the Committee's involvement in MSM 2014 are to present the current progress of the Committee, and to solicit input from the MSM community on key areas that will help advance the Committee's pursuits to establish credible practice guidelines for M&S in healthcare.
Ongoing activities of the Committee can be accessed at the Committee wiki at http://wiki.simtk.org/cpms. Bi-weekly meeting minutes are available at https://simtk.org/docman/?group_id=848. The updates in this section will serve to highlight key developments.
Please provide comments, general or specific to 2014 MSM Consortium Meeting presentations below.


text:
Our Insights > All Insights | Insurance | Legal News | Litigation
Coverage Issues for Non-Coverage Counsel: A Simple Primer for Issue-Spotting Some Complex Stuff
October 21, 2018 | by Carlile Patchen & Murphy LLP
Insurance is pervasive. It exists in all that we do and everywhere we go. Without insurance, risk would often be untenable and all commerce would almost assuredly cease. Any property owner knows that they had to obtain insurance as a requirement of the lender to acquire the property. Any business owner knows that it must have liability insurance to protect it from unexpected risks that could decimate its business. Most business transactions have certain insurance requirements contained within the contract such as who must insure against risk of loss or defend and indemnify for liability arising therefrom. Health insurance, while not the topic of this presentation, is so important that the government has spent the better part of 20 years discussing how to best provide insurance for all. Yet, as we all know, insurance is simply a contract. And the protection afforded by the insurer is subject to the terms and conditions of that contract. But, unlike many contracts, insurance policies are governed by certain unique rules that are not always obvious.
Following the Great Fire of London in 1666, Britain passed several laws to protect its citizens from future potential devastation. The World's First Insurance Company, Barry Klein, available at: https://www.irmi.com/articles/expert-commentary/the-worlds-first-insurance-company. One such law was to allow for establishment of organizations to indemnify for casualty losses. Id. In 1667, the first insurance company was formed, but not exactly as we know it today. Id. The first insurance companies established their own fire departments and were tasked to extinguish fires at insured properties – but only their own insured properties. Id. Once the government assumed the role of firefighting, the insurers focused on the indemnification aspect of their business model. Id.
Fast forward a few hundred years. As insurers developed in the United States, they would draft their own policies of insurance. Policies are not mere contracts drafted on a whim. They are complex documents that are created based on risk assessment and statistical analysis for premium rating. Insurers will analyze what is a covered loss and what its risk exposure is for such loss. For example, if an insurer provides coverage for 1000 homeowners against risk of loss by fire, the insurer will need to know what is the probability that a fire will occur to one (or more) of those 1000 homes and what will be the probable cost of such loss. Based on its statistics, it will establish a premium for those 1000 homes accordingly. This analysis is applied to every risk insured by the policy. Naturally, it is a monumental task.
In 1971 the Insurance Services Office ("ISO") was formed to aide insurers in their gathering of statistical data. See, https://www.verisk.com/insurance/brands/iso/. In order to have reliable statistical models, ISO needed to have standardized policies to establish a baseline. As a result, the insurance industry relies heavily, though not exclusively, on policy forms prepared by ISO. This provides consistency in statistical data and enables insurers to have a source of policy language compliant with the laws of all 50 states.
Notwithstanding the standardization of insurance policies, lawsuits are filed every day. Courts will interpret policies, but those interpretations are heavily fact dependent. There are many "basic" principals of insurance law, which are well known. For example, if an insurance policy is subject to more than one reasonable interpretation it will generally be construed in favor of the insured's interpretation. See, e.g., Pharmacists Mut. Ins. Co. v. Advanced Speciality Pharm., LLC, 2016 Ala. LEXIS 131 (2016) ("if a provision in an insurance policy is found to be genuinely ambiguous, 'policies of insurance should be construed liberally in respect to persons insured and strictly with respect to the insurer.'"); Ameron Internat. Corp. v. Ins. Co. of State of Penn., 50 Cal. 4th 1370, 1378 ("if, after the court evaluates the policy's language and context, ambiguities still exist, the court must construe the ambiguous language against the insurer");Chandler v. Geico Indem. Co., 78 So. 3d 1293, 1300 (Fla. 2011) ("Where the policy language 'is susceptible to more than one reasonableinterpretation' … [t]he ambiguous language is then construed 'against the drafter and in favor of the insured'"); Laboy v. Grange Indem. Ins. Co., 144 Ohio St. 3d 234, 237 (2015) ("provisions in an insurance contract that are reasonably susceptible of more than one interpretation will be construed liberally in favor of the insured").
A recent ad campaign from Farmers Insurance identifies a "Hall of Claims" in which highly unusual claims occurred and were covered losses. What is clear is that crazy, unusual claims do occur every day. Those facts are analyzed within the context of the insurance policy, basic insurance law principals, and any case law that may have considered similar facts (if possible). Because of the uniqueness of the facts of many claims, coverage disputes will always exist. To this end, we will address some issues to consider in future coverage cases.
1. General Policy Analysis
Every coverage issue begins with the facts of the case. When a claim is presented, the facts will provide the basis for the analysis. As noted above, ISO has formulated standard policies forms. Those forms are prepared from a statistical risk perspective, which indicates that the insurer has an expectation of what type of claim is intended to be covered. Insurers will have relied on and analyzed those forms thousands of times over. Insureds, on the other hand, have likely only experienced the policy on that particular occasion. As a result, the parties are approaching the matter from completely different perspectives.
An insurer would find it useful to approach every coverage case from the perspective of the insured. It begins with never assuming the answer. Although the insurer may have seen something similar, an insurer should analyze every possible nuance that might alter a previous outcome. In that analysis, the insurer should read the policy. It may sound simplistic, but it is a task often overlooked. An insurer has reviewed the policy many times. They may have a strong understanding of what they intend to insure from a risk perspective. However, the insured is starting from scratch. It does not have any assumptions. It has no concern about risk perspective and premium ratings. It is concerned with one thing, and one thing only: Are they insured?
Such a nuance can be found in the form of an article placed before the word "insured" in a policy. Courts have grappled with the distinction between "an insured" and "the insured." Is "the insured" singularly focused on the particular individual? Is "an insured" inclusive off any person who claims to be insured? In Safeco Ins. Co. of Am. v. White, 122 Ohio St. 3d 562, 577 – 78 (2009), Ohio Supreme Court Justice O'Donnell writing in concurrence noted the distinction:
Courts are divided on the question whether the phrase "an insured," … means "the" insured or "any" insured. Some courts have concluded that the phrase "an insured" is ambiguous and should be construed against the insurer because it could mean either "the insured" or "any insured." See, e.g., Michigan Millers Mut.Ins. Corp. v. Benfield (C.A.11, 1998), 140 F.3d 915, 926 (Florida law); McFarland v. Utica Fire Ins. Co. (S.D.Miss.1992), 814 F.Supp.518, 525-526 (Mississippi law).
A majority of courts, however, hold that the phrase "an insured" should be interpreted as "any insured." As the Supreme Court of Michigan explained in Allstate Ins. Co. v. Freeman (1989), 432 Mich. 656, 443 N.W.2d 734, "' "[a]" or "an" is an indefinite article often used in the sense of "any" and applied to more than one individual object; whereas "the" is an article which particularizes the subject spoken of " Id. at 698, quoting Allstate Ins. Co. v. Foster (D.Nev.1988), 693 F.Supp. 886, 889. Thus, the court in Freeman stated that "if we place the word 'a' or 'an' in front of the word 'insured,' then we must conclude that 'an insured' unambiguously means 'any insured.'" Id. at 699; see also Utah Farm Bur. Ins. Co. v. Crook (Utah 1999), 1999 UT 47, 980 P.2d 685, 688; Vance v. Pekin Ins. Co. (Iowa 1990), 457 N.W.2d 589, 593; Woodhouse v. Farmers Union Mut. Ins. Co. (1990), 241 Mont. 69, 72, 785 P.2d 192; Farmers Ins. Co. v. Hembree (1989), 54 Wash.App. 195, 203-204, 773 P.2d 105; Foster, 693 F.Supp. at 889; Bryant v. Allstate Ins. Co. (E.D.Ky.1984), 592 F.Supp. 39, 41; Travelers Ins. Co. v. Blanchard (La.App.1983), 431 So.2d 913, 914-915.
The one thing that an insurer should assume is that an insured is likely to be creative in its search for coverage. As such, the insurer should be creative as well. Think like an insured desperate for coverage. For example, can a homeowners' policy provide liability coverage for an automobile accident caused by an insured? Imagine an accident caused by a person driving an automobile while texting. Liability is clear on the driver. However, an insurer should evaluate whether the person on the other end of the text might be liable as well. If that person knew the driver was texting while driving, then does that establish liability for the accident.See, e.g.,Kubert v. Best, 432 N.J. Super. 495, 503 (N.J. App., 2013) ("[w]e hold that the sender of a text message can potentially be liable if an accident is caused by texting, but only if the sender knew or had special reason to know that the recipient would view the text while driving and thus be distracted."); But See, Vega v. Crane, 55 Misc. 3d 811, 817 (N.Y. Sup. Ct., 2017) (holding that it is not reasonably foreseeable for a texting party to be the proximate cause of an accident). If so, does the homeowner sitting on their couch have coverage for their liability in causing the accident by distracting the driver? That homeowner is not operating a motor vehicle from inside the confines of their living room.
The bottom line is that an insured owes it to itself and its insured to provide a thorough and fair analysis of the facts of every case. Those facts may establish that there is coverage. Or, it may establish that there is no coverage. Either way, the insured will have provided a fair and thoughtful coverage decision, which will go a long way in warding off any bad faith claims that might be raised as well.
2. Computer/Technology Usage with Endorsements
In 1971 when ISO began providing standardized forms technology was in its infancy. One endorsement could be drafted, but it would apply to many types of policies. As a result, the endorsement would have a typical header indicating that it applies to a host of forms, coverages, or provisions regardless of whether or not those forms, coverages, or provisions were part of the policy or not. For example, a policy may reflect the following:
THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.
This endorsement modifies insurance provided under the following:
COMMERCIAL GENERAL LIABILITY COVERAGE PART
COMMERCIAL AUTOMOBILE COVERAGE PART
GARAGEKEEPERS LIABILITY COVERAGE PART
PRODUCTS/COMPLETED OPERATIONS COVERAGE PART
Obviously technology has evolved since 1971. However, insurers still use that same format. They still have headings that indicate the endorsement applies to forms, coverages, or provisions that may not be part of the actual policy. The problem is that such usage can create ambiguities.
In The Burlington Ins. Co. v. Eden Cryogenics LLC, 126 F. Supp. 3d 947 (S.D. Ohio, 2015), the Court considered whether the "coverage part" headings were ambiguous thereby resulting in coverage for the insured. The endorsement was similar to the example noted above and provided as follows:
EXCLUSION – INTELLECTUAL PROPERTY
PRODUCTS/COMPLETED OPERATIONS LIABILITY COVERAGE PART
The dispute in the case centered on whether the endorsement modified all of the CGL coverages as well as the products/completed operations coverage or if it only modified the products/completed operations coverage. Id. at 955 – 57. Because Products/Completed Operations Liability Coverage was part of Coverage A of the CGL Coverage Part, the Court concluded that it was ambiguous if the heading modified ALL of the CGL Coverage Part. Id. There was be no need to include the Products/Completed Operations reference if it was already included in the CGL coverage part. Id. The text of the Endorsement did not provide any guidance as to what section was being modified. Id. at 953.Thus, the Court held that the heading was ambiguous and the insured's interpretation was reasonable thereby affirming coverage. Id. at 955 – 57.
Although not addressed in the Court's Decision, there is a separate ISO form for Products/Completed Operations Liability Coverage. However, that form was not a part of the Eden policy. It is possible that the Endorsement in Eden was meant to apply to two different forms (the CGL form and the separate Products/Completed Operations Liability form). The insurer used a blanket form applicable to many types of coverage, which potentially created the ambiguity. Today, an insurer could use technology to specify that the endorsements clearly identify that they apply to forms, coverages, or provisions that are applicable to the policy. Insurers should remove useless references. It could create ambiguities where noe should exist. But until they do, an insurer would be wise to review the headings to see if there is something there that could alter their assessment.
3. The Stray Comma
Just like any other contract, words and punctuation matters. While typos might happen in a vacuum (and might be found in these materials notwithstanding the proof-reading efforts), such should not occur in an insurance form used in potentially hundreds of thousands of policies. ISO is useful in preparing documents, of course, but insurers often modify standard ISO forms. When they do so, and even when relying on ISO, they need to be mindful of possible typos. More to the point, they should be mindful of punctuation.
Recently, a policy was encountered that contained an odd placement for a comma. The provision containing the oddly placed comma was not pertinent to the dispute at hand. Thus, it was not litigated. The policy appeared to indicate what it meant to cover, but the placement of the comma may well have inadvertently modified the policy. The policy provided a definition of persons who would be considered insureds for purposes of coverage.Per the policy, "insured" includes:
Any person (other than your 'employee' or 'volunteer worker'), or any organization while acting as your real estate manager.
The comma at issue follows "worker')". The natural question is: why is it there? The intent appears to be that the definition of "insured" includes any person or organization while acting as the named insured's real estate manager. However, the comma could also be read as to create two classes of insureds in this one sentence: 1) any person (other than your 'employee' or 'volunteer worker'), and 2) any organization while acting as your real estate manager. Under this potential scenario, one could argue that any person is an "insured" entitled to coverage under the policy. Naturally, there would likely have to be some connection between the named insured and the person seeking "insured" status. Nevertheless, the presence of the comma seems to be unnecessary and could create an ambiguity.
While the above is purely hypothetical, grammaris often at issue in coverage disputes.
"Patent" ambiguities often involve grammatical structure, placement of commas and such. The failure to insert a comma or to restructure the sentence creates an inherent ambiguity no matter what factual situation underlies the dispute over coverage. See American Nat'l, 107 F.3d at 458. The exclusion itself is confusing. Id. In such a case, Indiana's general rules favor coverage. See Eli Lilly and Co. v. Home Ins. Co., 482 N.E.2d 467 (Ind. 1985); Asbury v. Indiana Union Mut.Ins. Co., 441 N.E.2d 232 (Ind. Ct. App. 1982). Specifically, a patent ambiguity in an insurance contract is to be interpreted so as to disregard the exclusion. Sur v. Glidden-Durkee, 681 F.2d 490 (7th Cir. 1982)(citing, Huntington Mut. Ins. Co. v. Walker, 181 Ind. App. 618, 392 N.E.2d 1182 (Ind. Ct. App. 1979)).
Scott Hoffer Chevrolet-Geo v. Federated Mut. In. Co., 1997 U.S. Dist. LEXIS 9430, fn 5 (N.D. Ind., 1997).
However, in Certain Interested Underwriters at Lloyds, London v. LeMons, 85 Mass. App. Ct. 400 (2014), the Court held that the placement of a comma did not create an ambiguity. The provision at issue excluded coverage for bodily injury and property damage "arising out of an assault or battery, provoked or unprovoked, or out of an act or omission in connection with the prevention or suppression of an assault or battery, committed by an Insured or an employee or agent of the insured." Id. at 401. The issue surrounded the phrase "committed by" and what it was intended to apply toward. The insurer claimed it applied to the section immediately preceding the comma – i.e. "an act or omission in connection the prevention or suppression of an assault or battery." Id. at 403. The insured argued the "committed by" language applied to the initial reference to "assault or battery." Id. If the insurer was correct, then all claims arising from an "assault or battery," whether caused by an insured or someone else, would be excluded. If the insured was correct, then "assaults or batteries" committed by someone other than an Insured would be covered. The Court held that the comma placed before "committed by" attached that phrase to the section immediately preceding the comma. Id. at 404. Thus, the oddly placed comma was sufficient to clarify that the exclusion contained two separate and distinct coverage exclusions.
Based on this, it is wise for the insurer to pay close attention to punctuation and grammar. The reality is that grammar does indeed serve a purpose. Commas mean something. Grammar matters. The context of the comma in the sentence provides guidance. Simply stated, do not ignore the punctuation.
4. Late Notice
The law on Late Notice is largely consistent, but not entirely so. Typically, an insurer can deny coverage for late notice if the insurer was prejudiced by the late notice. See, Ferrando v. Auto-Owners Mut. Ins. Co., 98 Ohio St. 3d 186, 208 (2002) (courts must conduct a two-step approach to determine the effect of a claim denial based on late notice: 1) was the notice late, and 2) was the insured prejudiced).Courts are split as to who has the burden of proof on the prejudice prong. Some courts place the burden on the insured to prove the insurer was not prejudiced. Ferrando, 98 Ohio St. at 208 ("[u]nreasonable notice gives rise to a presumption of prejudice to the insurer, which the insured bears the burden of presenting evidence to rebut.");Bankers Ins. Co. v. Macias, 475 So. 2d 1216, 1218 (Fla. 1985) ("If the insured breaches the notice provision, prejudice to the insurer will be presumed, but may be rebutted by a showing that the insurer has not been prejudiced by the lack of notice."); Gerrard Realty Corp. v. American States Ins. Co., 277 89 Wis. 2d 130, 146 – 47 (Wisc. 1979) ("where notice is given more than one year after the time required by the policy, there is a rebuttable presumption of prejudice and the burden of proof shifts to the claimant to prove that the insurer was not prejudiced by the untimely notice."). Other courts, however, view late notice as a defense to coverage, which places the burden on the insurer to establish that it was prejudiced. Brakeman v. Potomac Ins. Co., 472 Pa. 66, 76 – 77 (Pa. 1977) ("where an insurance company seeks to be relieved of its obligations under a liability insurance policy on the ground of late notice, the insurance company will be required to prove that the notice provision was in fact breached and that the breach resulted in prejudice to its position").
For instance, in New Jersey, the insurer bears burden of showing late notice and "appreciable prejudice." The insurer must show that substantial rights regarding defense against claim have been irretrievably lost and it would likely have had a meritorious defense had timely notice been given. Gazis v. Miller, 892 A.2d 1277 (N.J. 2006); Pfizer, Inc. v. Employers Ins. of Wausau, 712 A.2d 634 (N.J. 1998); Green v. Selective Ins. Co. of Am., 676 A.2d 1074 (N.J. 1996); TransportesFerreos de Venezuela II CA v. NKK Corp., 239 F.3d 555, 561 (3d Cir. 2001); Amentler v. 69 Main St., LLC, Case No. 08-0351, 2009 U.S. Dist. LEXIS 55475, at *24 (D.N.J. June 30, 2009).
Prejudice can come in the form of lost evidence or increased liability based on subsequent events. While there is no universal rule, courts often look to the effect of the late notice on the insurer. For example, "[a]n insurer is prejudiced by late noticewhen, for example, it cannot investigate the facts necessary to determine whether coverage should be provided and when it has been denied the opportunity to have input into the manner in which the underlying claim is being defended." Fireman's Fund Ins. Co. v. Bradley Corp., 261 Wis. 2d 4, 38 (Wisc. 2003). In Petosky Mfg. Co. v. Commercial Union Ins. Cos., 1992 U.S. Dist. LEXIS 14929, * 11 (W.D. Mich., 1992), the Court (citing Michigan law) stated "[p]rejudice will be found where the delay 'materially' impairs an insurer's ability to contest its liability to an insured or the liability of the insured to a third party." The Petosky Mfg. court further held "[l]ate notice is prejudicial where an insurer is denied the opportunity to make a prompt investigation while the facts are fresh in the minds of the witnesses before physical evidence has been obliterated." Id. at * 12.
Exceptions to the Prejudice Rule
While the majority rule across the country is that an insurer must demonstrate prejudice in order to deny coverage on the basis of late notice, there are exceptions to majority rule depending on the specific type of policy and language involved. As noted above, New Jersey law generally requires that an insurer demonstrate prejudice to rely on a late notice defense. However, a recent decision from the New Jersey Supreme Court clarified that the prejudice requirement does not apply to claims made insurance policies. In Templo Fuente De Vida Corp. v. Nat'l Union Fire Ins. Co., 224 N.J. 189, 129 A.3D 1069 (2016), the Court held that, regardless of whether the insurer suffered prejudice, the insured's six month delay did not satisfy the policy's requirement that the insured report any claims as soon as practicable, and the insured accordingly forfeited coverage under the policy.
Therefore, under New Jersey law the "appreciable prejudice" standard does not apply to "claims-made" policies. Where the parties to a "claims-made" policy are "sophisticated," the policy's notice requirement should be given strict effect, and "appreciable prejudice" need not be asserted. Zuckerman v. National Union Fire Ins. Co., 100 N.J. 304, 309-310 (1985); See Templo Fuente de Vida Corp. at 209-210 (2016).
Most corporate policies outside of general liability are claims-made, such as errors and omissions, directors and officers, and employment practices liability insurance. Given same, while a filed complaint is easily recognized as a "claim," if dealing with a claims-made policies the applicable notice provision may be triggered by an angry letter from a shareholder or a letter from a former disgruntled employee, thus triggering the notice and reporting duties within the a policy.
Late notice, like everything else, can be jurisdictionally dependent. It is important to review the law applicable to the jurisdiction in which the action is to be brought. As noted above, do not assume general insurance law principals are universally held.
5. Right to Independent Counsel
The right of an insured to have independent counsel is generally based on an attorney's ethical obligations to his client to avoid conflicts of interest and on the insurer's obligation to defend its insured. When there is a genuine concern that the insurer might not provide a vigorous defense because of its very limited indemnity exposure, a court may find that the insured has the right to assume control of its own defense. In those instances, the insurer must reimburse the reasonable and necessary costs incurred by the insured in defending the action with the counsel of his own choosing. Different states have different requirements triggering the insured's right to independent counsel and the insurer's corresponding duty to pay independent counsel's reasonable attorneys' fees.
A majority of states that have analyzed the right to independent counsel follow the analysis utilized in the New York Court of Appeals case, Pub. Serv.Mut. Ins. Co. v. Goldfarb, 53 N.Y.2d 392, 401, 425 N.E.2d 810, 815 (1981). Pursuant to Goldfarb, an insured's right to independent counsel is triggered when the attorney's duty to the insured would be to defeat liability on any ground, but his duty to the insurer would be to defeat liability on only those grounds for which the insurer might be liable. Put another way, a policyholder has a right to independent counsel paid for by the insurance company, where a conflict of interest arises because a complaint contains allegations possibly both within and outside the coverage of the insurance policy.Hartford Acc. &Indem. v. Hempstead, 48 N.Y.2d 218, 397 N.E.2d 737, 422 N.Y.S.2d 47(1979); Pub. Serv. Mut. Ins. v. Goldfarb, 53 N.Y.2d 392, 425 N.E.2d 810, 442 N.Y.S.2d 422 (1981); San Diego Navy Federal Credit Union v. Cumis Ins. Society, Inc., 162 Cal.App.3d 358, 208 Cal.Rptr.494 (1984).see also, National Cas. Co. v. Forge Indus. Staffing, Inc., 567 F.3d 871, 875 (7th Cir. 2011) (stating that conflict counsel must be appointed when the underlying complaint contains two mutually exclusive theories of liability, one which the policy covers and one which the policy excludes).
Contrast that with the so-called "Burd Rule," in New Jersey based on the holding inBurd v. Sussex Mut. Ins. Co. 56 N.J. 383, 386, 267 A.2d 7, 8 (1970). The Burd Rule holds that, where a conflict exists between an insurer and its insured by virtue of the insurer's duty to defend mutually exclusive covered and non-covered claims, the duty to defend is translated into a duty to reimburse the insured for the cost of defending the underlying action if it should ultimately be determined, based on the disposition of that action, that the insured was entitled to a defense. Thus, in New Jersey, an insurer is not required to defend or pay independent counsel fees for uncovered claims where the underlying plaintiff alleges covered and non-covered claims against the insured. However, where the insured was defended by independent counsel and the loss is found to fall within coverage, the insurer must pay reasonable and necessary costs of the insured's defense.
Furthermore, an insured can only make an informed decision about whether to accept the defense counsel selected by the insurer if the insured knows all of the options available. Therefore, the insured must be told of the right to independent counsel and the obligation of the insurer to pay for independent counsel. Otherwise, the insured may accept defense counsel selected by the insurer on the mistaken assumption that the defense costs of independent counsel would not be reimbursed. Along this line a number of jurisdictions, including New York, have found that insurance companies also have a duty to inform regarding the right to independent defense counsel.Inthe event of a conflict of interest, theinsurance company has a duty to informan insured about their right to independentcounsel. Elacqua v. Physicians' ReciprocalInsurers, 52 A.D.3d 886, 860 N.Y.S.2d 229(3d Dept. 2008) (finding a duty); Jones v. Nat'l Emblem Ins., 436 F. Supp. 1119 (E.D.Mich. 1977) (finding a duty). As a result of the imposition of the duty to inform of the right to independent counsel, the failure of an insurance company to advise as to this right may subject an insurer to a claim that they have breach their obligations under the insurance contract.
The rights and obligations of both the insurers and insureds will be guided by jurisdiction specific case law and/or statutes when the right to independent counsel is triggered. Insurers and insureds must be attentive and sensitive to the subtle distinctions which may exist in different jurisdictions. However, even if the right to independent counsel is triggered and the insured has the option to select counsel of its' own choosing, this right is not limitless. Insureds should be mindful of the fact that even if they do have the right to select counsel of their choice, case law in most states only obligates the insurer to pay reasonable and necessary attorneys' fees, which may be substantially lower than the cost of independent counsel, leaving the insured responsible for the difference. See Szelc v. Stanger, 2010 U.S. Dist. LEXIS 73600 (N.J. Dist. Jul. 10, 2010). (An "insurer is not required to pay whatever fee the insured's retained attorney happens to charge; rather, the insured is required to pay a reasonable fee for those services reasonably related to the defense of any covered claims."); Int'l Ins. Co. v. City of Chicago Heights, 643 N.E.2d 1305 (Ill. App. 1994); Behnke v. State Farm General Ins. Co., 196 Cal. App. 4th 1443 (2011).
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redpajama_set_name: RedPajamaCommonCrawl


text:
« John Kerry expands his repertoire for looking ridiculous | The most startling development coming from the Rio Olympics »
About those Republicans who are skipping the convention...
It is good to know who the real conservatives are, who in Congress, which governors, which former candidates for president are stand-up people, and which of them are sore losers. The list of the latter is shameful and depressing. We knew that a great many of the establishment Republicans are cowards interested only in preserving their own privilege and power.
We didn't know how many. Now we do. The Bush family, Romney, McCain, even Kasich, the governor in whose state the convention is taking place. They are not there. Most of Trump's former opponents are not there. The list of senators and members of the House is long and disgraceful. Very bad form all around.
They are telegraphing their support for Hillary Clinton, the most corrupt, dishonest politician to prevail for so long on the national stage in American history. Another term with a radical progressive Alinskyite in the White House will be the end of America. It will hasten our slide into Venezuela territory as the bank accounts of the Clintons and their sycophants swell like Chávez's, Fidel Castro's, and Putin's as they bankrupt their people to enrich themselves. She used her position as secretary of state to make millions selling favors and access, past and future. She will do worse if president.
Mr. Trump was last on the list of preferred candidates for a great many of us, for good reasons; he is uninformed about national security issues, foreign policy, domestic policy, the military, and more. He is hardly a true conservative. We learned this week that he "does not read books." How to describe how he speaks? To say like a fifth-grader may be an insult to fifth-graders. But he has won the primary. His simple message has resonated with millions of Americans who have been disenfranchised, disrespected, and dis-employed over the last nearly eight years. They have seen the cost of their medical care skyrocket or their access to it vanish. They have seen Obama dismiss ISIS as a jayvee team while Islamic terrorism has exploded around the globe. They have seen Obama and Clinton embrace the racist anti-police rhetoric and violence of the BlackLivesMatter crowd, which is riled up and funded by George Soros with a litany of misinformation. Millions of these Trump supporters voted Republican majorities into the House and Senate to no avail. Obama has done whatever he has wanted to do, no matter how unconstitutional, illegal, or dangerous.
How do we square the facts of Trump's seeming lack of qualification for the office with his business success (and failures) around the world? His adult children seem to be hardworking, intelligent, gracious, and successful. The same cannot be said for the children of all very wealthy people. And they behave nothing like their unruly and unpredictable father. We all have to respect that; raising children to be productive citizens is the hardest job on the planet.
So whatever so many of us did not see in Trump a year ago, millions of others did see as a potential savior of a kind, and he is the candidate. For so many Republicans to snub the convention and refuse to endorse him is a pathetic display of bad sportsmanship. It is classless and graceless. And now we know who they all are. No Republican should ever respect or vote for any one of them ever again.
Trump must win to keep the Clintons out of the White House. They turned it into a tabloid soap opera for eight years in the nineties. This time they will turn the country into their own personal cash cow while they rob the American people of their freedoms (1st Amendment, 2nd Amendment), their opportunities to rise and thrive, and further adulterate the population with refugees so that an American culture will no longer exist.


text:
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redpajama_set_name: RedPajamaGithub


Popcorn is a variety of corn that can be sprouted after soaking for 12 hours. In two to three days you will have a 1/2" sprout. Contains vitamins A, B and E. and is very sweet, kids love it! We prefer it popped. Popcorn sprouts are sweet but the hull doesn't soften much.