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Facebook's Multi-Billion Dollar Tax Break: Executive-Pay Tax Break Slashes Income Taxes on Facebook– and Other Fortune 500 Companies
February 14, 2013 09:52 AM | Permalink |
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Earlier this month, the Facebook Inc. released its first "10-K" annual financial report since going public last year. Hidden in the report's footnotes is an amazing admission: despite $1.1 billion in U.S. profits in 2012, Facebook did not pay even a dime in federal and state income taxes.
Instead, Facebook says it will receive net tax refunds totaling $429 million.
Facebook's income tax refunds stem from the company's use of a single tax break, the tax deductibility of executive stock options. That tax break reduced Facebook's federal and state income taxes by $1,033 million in 2012, including refunds of earlier years' taxes of $451 million.[1]
But that's not all of the stock-option tax breaks that Facebook generated from its initial public offering of stock (IPO). Facebook is also carrying forward another $2.17 billion in additional tax-option tax breaks for use in future years.[2]
So in total Facebook's current and future tax reductions from the stock options exercised in connection with its IPO will total $3.2 billion. That's almost exactly what CTJ predicted last year, when Facebook first announced its IPO.[3]
Of course, Facebook is not the only corporation that benefits from stock option tax breaks.
Many big corporations give their executives (and sometimes other employees) options to buy the company's stock at a favorable price in the future. When those options are exercised, corporations can take a tax deduction for the difference between what the employees pay for the stock and what it's worth (while employees report this difference as taxable wages). Before 2006, companies could not only deduct the "cost" of the stock options on their tax returns, reducing their taxable profits as reported to the IRS, but they also didn't have to reduce the profits they reported to their shareholders in the same way, creating a big gap between "book" and "tax" income.
Some observers, including CTJ, have argued that the most sensible way to resolve this incongruity would be to deny companies any tax or "book" deduction for an alleged "cost" that doesn't require a dime of cash outlay.[4] But instead, rules in place since 2006 now require companies to lower their "book" profits to take some account of options. But the book write-offs are still usually considerably less than what the companies take as tax deductions. That's because the oddly-designed rules require the value of the stock options for book purposes to be calculated — or guessed at — when the options are issued, while the tax deductions reflect the actual value when the options are exercised. Because companies typically low-ball the estimated values, they usually end up with bigger tax deductions than they deduct from the profits they report to shareholders.
A November 2011 CTJ report assessing the taxes paid by the Fortune 500 corporations that were consistently profitable from 2008 through 2010 identified this stock option tax break as a major factor explaining the low effective tax rates paid by many of the biggest Fortune 500 companies.[5]
Some members of Congress have recently taken aim at this remaining tax break. In July of 2011, Senator Carl Levin (D-MI) introduced the "Ending Excess Executive Corporate Deductions for Stock Options Act," to require companies to treat stock options the same for both book and tax purposes. Levin has signaled his intention to introduce similar legislation in early 2013. According to calculations made by Levin's staff using IRS data, in the past five years U.S. companies have consistently deducted far more stock options for tax purposes than they recorded as a book expense. This "excess" deduction, according to Levin's calculations, has ranged between $12 billion and $61 billion a year.
[1] "The tax benefits realized from share-based award activity of $1.03 billion related to both the reduction of current year income tax liabilities and the expected refund of $451 million from income tax loss carrrybacks to 2010 and 2011." Facebook Inc. 10-K for 2012, p. 84.
[2] Facebook's disclosure of this huge carryforward of stock option tax breaks is cryptic, but clear to those of us who are familiar with corporate annual reports: "As of December 31, 2012, the U.S. federal and state net operating loss carryforwards were approximately $5.83 billion and $7.62 billion, which will expire in 2027 and 2021, respectively, if not utilized. If realized, $2.17 billion of net operating loss carryforwards will be recognized as a benefit through additional paid in capital." (emphasis added.) Facebook Inc. 10-K for 2012, p. 85.
[3]"Putting a Face(book) on the Corporate Stock Option Tax Loophole," by Robert S. McIntyre, Citizens for Tax Justice, Feb. 2012, www.ctj.org/pdf/FacebookReport.pdf.
[4] For a fuller explanation of CTJ's position, see "Putting a Face(book) on the Corporate Stock Option Tax Loophole," by Robert S. McIntyre, Citizens for Tax Justice, Feb. 2012, www.ctj.org/pdf/FacebookReport.pdf.
[5] Citizens for Tax Justice, "Corporate Taxpayers & Corporate Tax Dodgers, 2008-2010," November 3, 2011, page 10. http://ctj.org/corporatetaxdodgers/.


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No Comments on What Squid Game Can Tell You About Gaming and Life
According to Netflix's co-CEO Ted Sarandos, "There's a show on Netflix right now that is the number one in the world. Like, everywhere in the world. It's called 'Squid Game,'".
Sarandos is not exaggerating. Squid Game is Netflix's most-watched series to date. At this point, to call it a viral sensation is actually an understatement. Unsurprisingly, this series about a deadly game has resonated with viewers because of exaggerated and fantastic metaphors for particular life experiences. Additionally, the fact that it exploded in popularity despite very little marketing also gives us a little insight into how things really work in the real world.
So what does this show about a game (that we hope no one ever has to play) tell us about gaming and life?
Lesson 1: If people like something enough, you won't have to spend on marketing
When compared with other popular shows, Squid Game has virtually no real marketing support beyond Asia before appearing on Netflix. And yet, it has become an entertainment icon. Word of mouth was more than enough to make it a wild success.
When designing your product, be it an app, website or even a consumable product, keep this in mind. Focus on making the customer happy, and the marketing will take care of itself. A large part of Squid Game's popularity was generated by the memes that cropped up after it appeared on the platform. People loved it so much they just had to spread the love. And said love spread all the way until it turned the show into a household name.
Turns out, an easy way to get people to like your app/website/campaign is to gamify it. Make it fun for them to engage with what you're offering, and they will like it enough to spread the word and boost your product's popularity.
Lesson 2: Think Outside the Box
In the Honeycomb game, players licked the honeycomb so that it became easier to cut with a needle. Sounds like a creative solution? That's because it is.
In life and especially in gaming, innovation pays off. With users bombarded with content every time they look at their smart device, your product needs to find ways to stand out, distract, enchant and engage. Gamification of apps and websites can contribute to this significantly, given that game elements are designed to provide users with excitement, anticipation, escapism and good ol' fun.
Lesson 3: Your weakness can help you winn
In the tug-of-war contest, each competitor was assigned a role based on their strength. The losing team had 10 strong men while the winning team hada, among others, three women and an elderly man. So how did they win?
They took advantage of their opponents' underestimation of them. The 10 strong men did not expect that the other team would be a challenge, and this notion is what caused their defeat.
In life, do exactly the same. If someone underestimates you, use it to up your games and achieve a surprising victory. Winning is always easier and more satisfactory when no one expects you to win.
Lesson 4: You can finish last and still win
Think of the Glass Bridge game. It was only possible to win it after watching how everyone else played, and avoiding their mistakes. This is a valuable lesson for life.
When it comes to life and gaming, watch those who come before you. They might be racing ahead at the moment, but if they make mistakes and endure failures, you will have the advantage of knowing what went wrong, and avoiding those mistakes.
For example, during a gamification project, do the research. Study what your predecessors did, what your competitors are doing and where they may have previously failed. Don't offer discounts if a certain target audience has been shown to not care about it (such as people in very high income groups), even though gamification manuals use discounts as a major reward.
By not repeating mistakes made by others, you will be saving yourself time, effort, money and other resources. Once you know what doesn't work, you can focus on what works.
Lesson 5: Slow Down
In the show, whenever anyone is in a hurry to get through the ordeal, they lose or at least, end up regretting that decision. This is just as true of real life.
Don't rush through anything, especially important decisions and tasks. You'll end up making mistakes, overlooking significant requirements and providing shoddy results. Real life isn't fun and games (and neither is the show) which means you'll have to approach it with a calm, turbulent-free and analytical mind. If you don't, things don't usually turn out too well.
Squid Game's popularity is not just the result of a great script and excellent cinematography. It reflects important issues plaguing human life today (debt, capitalism, economic divide). The struggles of the characters and especially the protagonist ring true for millions of viewers, mainly because Squid Game is quite a treasure house of lessons about the complicated games we must play to live.
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Int J Med Sci 2020; 17(2):161-169. doi:10.7150/ijms.39444 This issue
Screening and surveillance of multiple solid tumours using plasma placental-like chondroitin sulfate A (pl-CSA)
Juzuo Zhang1,3*, Beini Sun1,8*, Kang Zhang6*, Zhilong Chen1,9*, Wenhan Yang2, Guodong Wu7, Li Tian2, Zhonglin Xiao1, Baozhen Zhang1, Shiling Chen5, Aiwen Le4, Youhui Qian7, Shaowu Ye6, Rihong Zhai2 , Xiujun Fan1
1. Center for Reproduction and Health Development, Shenzhen Institutes of Advanced Technology, Chinese Academy of Science, Shenzhen, 518055, China.
2. Carson Cancer Center, Guangdong Key Laboratory for Genome Stability & Disease Prevention, Shenzhen University School of Medicine, Shenzhen, 518055, China.
3. College of Biological and Food Engineering, Huaihua University, "Double First-Class" Applied Characteristic Discipline of Bioengineering in Hunan High Educational Institution, Huaihua, 418000, China.
4. Department of Obstetrics and Gynaecology, the Sixth Affiliated Hospital of Shenzhen University School of Medicine, Shenzhen, 518052, China.
5. Department of Gynecology and Obstetrics, Nanfang Hospital, Southern Medical University, Guangzhou, 510515, China.
6. Department of Oncology, Wuzhou People's Hospital, Wuzhou, 54300, China.
7. Department of Thoracic Surgery, the First Affiliated Hospital of Shenzhen University School of Medicine, Shenzhen, 518055, China.
8. School of Life Science, Heilongjiang University, Harbin, 150080, China.
9. College of Veterinary Medicine, Hunan Agricultural University, Changsha, 410128, China.
*These authors contributed equally to this work.
✉ Corresponding authors: Xiujun Fan (xiujun.fancom) and Rihong Zhai (rzhaiedu.cn). Address: 1068 Xueyuan Avenue, Shenzhen University Town, Shenzhen, China. Tel.: +86-755-86392360.
Zhang J, Sun B, Zhang K, Chen Z, Yang W, Wu G, Tian L, Xiao Z, Zhang B, Chen S, Le A, Qian Y, Ye S, Zhai R, Fan X. Screening and surveillance of multiple solid tumours using plasma placental-like chondroitin sulfate A (pl-CSA). Int J Med Sci 2020; 17(2):161-169. doi:10.7150/ijms.39444. Available from https://www.medsci.org/v17p0161.htm
Rationale: Placental-like chondroitin sulfate A (pl-CSA) is known to be exclusively synthesized in multiple cancer tissues and associated with disease severity. Here, we aimed to assess whether pl-CSA is released into bio-fluids and can serve as a cancer biomarker.
Methods: A novel ELISA was developed to analyse pl-CSA content in bio-fluids using pl-CSA binding protein and an anti-pl-CSA antibody. Immunohistochemical staining of tissue chips was used as the gold standard control.
Results: The developed ELISA method was specific and sensitive (1.22 μg/ml). The pl-CSA content was significantly higher in lysates and supernatants of cancer cell lines than in those of normal cell lines, in plasma from mouse cancer models than in that from control mice, and in plasma from patients with oesophageal, cervical, ovarian, or lung cancer than in that from healthy controls. Similar to the tissue chip analysis, which showed a significant difference in pl-CSA positivity between cancer tissues and normal adjacent tissues, the plasma pl-CSA analysis had 100% sensitivity and specificity for differentiating oesophageal and lung cancer patients from healthy controls. Importantly, in oesophageal and lung cancer patients, the pl-CSA content was significantly higher in late-stage disease than in early-stage disease, and it dramatically decreased after surgical resection of the tumour.
Conclusion: These data indicate a direct link between plasma pl-CSA content and tumour presence, indicating that plasma pl-CSA may be a non-invasive biomarker with clinical applicability for the screening and surveillance of patients with multiple types of solid tumours.
Keywords: circulating pl-CSA, biomarker, cancer screening
Cancer remains a serious public health problem worldwide. According to reports from the International Agency for Research on Cancer (IARC), approximately 18.1 million new cancer cases and 9.6 million cancer deaths are detected annually worldwide [1]. In China, approximately 4.3 million new cancer cases and 2.81 million cancer deaths occur every year [2]. In clinical practice, the prognosis of cancer patients is associated with the pathological stage at the time of diagnosis. However, in over 70% of patients, cancer is detected and diagnosed at an advanced stage. Therefore, early screening and diagnosis are very important for prompt treatment and a good prognosis.
In the process of tumourigenesis, circulating tumour cells (CTCs), debris and secreted substances are shed from the primary tumour into peripheral blood and have potential for use in the early detection of cancer. Current cancer biomarkers in clinical use are primarily DNA [3], RNA [4], and protein [5]. These types of biomarkers are useful as complementary tools for traditional pathological staging in cancer diagnostics and prognostics. However, their application in the early detection of a malignancy is limited by the relatively low sensitivity and specificity [6]. Therefore, there is a need to discover new cancer biomarkers to improve screening and diagnostic efficiency.
It has been reported that glycosaminoglycans (GAGs), a type of polysaccharide, play a key role in tumourigenesis [7]. Placental-like chondroitin sulfate (CS) A (pl-CSA) belongs to the GAGs family and serves as a receptor for Plasmodium falciparum-infected erythrocytes through the anchor protein VAR2CSA [8]. Pl-CSA contains a typical GlcA-GalNAc (4S) disaccharide unit and shows relatively less variation than DNA, RNA and protein [9]; it is exclusively synthesized in cancer and placental tissues and is associated with cancer progression [10]. Studies have also confirmed that recombinant VAR2CSA (rVAR2) can specifically bind to pl-CSA in multiple cancer types [10] and can serve as a target to isolate CTCs [11]. These properties of pl-CSA suggest that its content in tumour tissue and bio-fluids may be a promising biomarker for cancer screening and diagnosis. However, whether pl-CSA is released in bio-fluids as a cancer biomarker remains unclear.
In this study, circulating pl-CSA content was analysed through a new ELISA method using a pl-CSA binding peptide derived from VAR2CSA and an anti-pl-CSA antibody [12, 13]. The pl-CSA content was measured in plasma from patients with different types of cancer. The results revealed that deregulated circulating pl-CSA content is a promising cancer biomarker with high specificity and sensitivity in distinguishing cancer patients from healthy controls.
Development of a novel ELISA kit for pl-CSA analysis
As specified in the supplementary methods, purified pl-CSA was obtained from HTR8 cells, and pl-CSA anti-serum was also collected from immunized mice. The pl-CSA binding peptide (pl-CSA-BP), a mini-peptide derived from VAR2CSA [14, 15], was synthesized (China Peptides Co., Ltd., Shanghai, China). The concentrations of capture protein (supplementary Table S1) and anti-pl-CSA antibody (supplementary Table S2) were optimized, and the specificity (supplementary Table S3), sensitivity and repeatability of the ELISA were determined.
The general ELISA protocol was as follows (schematic illustration, Figure 1A). First, pl-CSA-BP was dissolved in 50.00 mM carbonate buffer (pH 9.6) and coated on 96-microwell plates (200 μl/well) overnight at 4 °C. Second, the plate was incubated with 1% BSA (200 μl/well) for 2 h to block nonspecific reactions, with no washing steps. Third, the pl-CSA samples and standard samples (100 μl/well) were incubated in the plates for 2 h. Fourth, the anti-pl-CSA antibody was added, and the plates were incubated for 2 h. Fifth, horseradish peroxidase (HRP)-labelled goat anti-mouse IgG antibody (100 μl/well, 1:10,000 dilution) was added for 1 h, and peroxidase activity in the wells was detected by adding 100 μl of substrate solution (3,3',5,5'-tetramethylbenzidine (TMB)). After 15 min, the reaction was stopped with 2 M H2SO4 (50 μl/well), and the absorbance was recorded at 450 nm (OD450). The plate was placed at 37 °C for all incubation steps and washed three times (for 5 min each) with 0.1 M PBST (pH 7.2) after each incubation step. The same protocol was applied for all ELISAs. The reliability of the values was confirmed by P/N≥2.1.
Quantitative determination of pl-CSA in bio-fluids from in vitro and in vivo samples
To explore whether pl-CSA is released into bio-fluids by cancer cells in vitro, cell culture supernatants (36 samples) and cell lysates (36 samples) were collected (supplementary methods). A total of 17 cell lines (supplementary Table S4) were obtained from American Type Tissue Collection (ATCC, Manassas, VA) from June 2010 to April 2016 and stored in liquid nitrogen in our laboratory. The human trophoblast cell line HTR8 (a kind gift from Professor Charles Graham, Department of Anatomy and Cell Biology, Queen's University, Kingston, ON, Canada) was maintained in our laboratory. All cell lines were authenticated using short tandem repeat (STR) analysis according to the ANSI standard (ANSI/ATCC ASN-0002-2011 Authentication of Cell Lines: Standardization of STR Profiling) by the ATCC Standards Development Organization (SDO) and tested negative for mycoplasma contamination. All authentications were carried out by Guangdong Hybribio Biotech Ltd. in July 2016.
To explore whether pl-CSA is released into the circulatory system in vivo, plasma samples were collected from mouse cancer models, including from choriocarcinoma BALB/c nude mouse models (10 samples), ovarian cancer models (10 samples) and negative controls (10 samples) used in previous studies [15,16]. The pl-CSA content in cell samples and mouse plasma samples was quantified using the developed ELISA method.
Measurement of circulating pl-CSA in patients with different types of cancer
For all patients, the diagnosis was pathologically confirmed by two independent pathologists. No patients received radiotherapy or chemotherapy prior to surgery. For case-control subjects, blood samples were taken once before operation from cancer patients and upon recruitment from controls. For pre- and post-surgery or pre- and post-chemotherapy plasma samples, venous blood samples were collected twice from cancer patients: one day before the operation and 3-7 days after surgery. For each sample, ~10 ml of whole blood was collected in an EDTA-containing tube and centrifuged at 5,000 rpm and 4 °C for 10 min. The supernatants were stored at -80 °C until ELISA analysis.
To validate the clinical significance of circulating pl-CSA, the pl-CSA concentration in plasma samples from patients with different types of cancer was quantified using the developed ELISA method; the samples were from 48 patients with oesophageal squamous cell carcinoma (ESCC) (66 samples), 7 with ovarian cancer (7 samples), 7 with cervical cancer (7 samples), 32 with non-small-cell lung cancer (NSCLC) (52 samples), and 44 healthy controls (44 samples) (supplementary Table S5).
Immunohistochemical analysis of tissue chips
The pl-CSA content in oesophageal (cat No. ES1202; 10 × 12 1-mm holes/chip; 60 cases) and lung cancer (cat No. BC04118a; 10 × 10 1-mm holes/chip; 50 cases) tissues, as well as in normal adjacent tissues, was analysed through tissue chip immunohistochemistry by Suzhou Cancer Cell Biotechnology Co., Ltd. (supplementary Table S6). Briefly, the tissue chip sections were baked, deparaffinised and rehydrated; then, antigen retrieval was performed, and endogenous HRP was inactivated. The sections were incubated consecutively with biotinylated pl-CSA-BP, HRP-conjugated streptavidin, and diaminobenzidine (DAB, chromogen substrate) and counterstained with haematoxylin. Then, the sections were visualized using a microscope (BX53, Olympus Corporation, Tokyo, Japan), and the microphotographs were analysed using Image-Pro Plus 6.0 software. The percentage of positive cells with different staining intensities dictated the staining score: no positive cells, 0; ≤ 10% positive cells, 1; 10% < positive cells ≤ 50%, 2; 50% < positive cells ≤ 80%, 3; and ≥ 80% positive cells, 4.
All statistical analyses were performed using the SAS statistical software package (version 9.4, SAS, Cary, NC). Continuous variables are presented as the mean ± SD. Differences between groups were compared using chi-square tests for categorical variables and Student's t test or the median test for continuous variables, where appropriate. The receiving operating characteristics (ROC) curve was used to investigate the discriminatory potential of plasma pl-CSA content. P values of <0.05 were considered to indicate statistical significance.
The newly developed ELISA method showed high specificity and sensitivity
The optimized concentration of pl-CSA-BP for ELISA was determined to be 25.00 μg/ml. Purified pl-CSA at concentrations greater than 5.00 mg/ml was obtained through rVAR2 [16] affinity chromategraphy, dialysis and vacuum drying. Approximately 5 ml of anti-pl-CSA serum was collected from BALB/c mice immunized with purified pl-CSA (25.00 mg/kg body weight) at total of five times at an interval of one week. The optimum dilution ratio of 1:1,000 for anti-pl-CSA serum was confirmed (supplementary Table S2).
The specificity of the ELISA was confirmed using the GAG similarity of CSB and CSC, which had OD450 values similar to that of the negative control, P/N= ~1.00 (supplementary Table S3), suggesting that the ELISA had relatively high specificity. The log2-transformed pl-CSA concentration (ranging from 1.22 μg/ml to 625.00 μg/ml) showed a linear relationship with OD450. When the pl-CSA concentration was below 1.22 μg/ml or above 625.00 μg/ml, a colour change was observed, but the relationship was not linear (Figure 1B). Under the specified conditions, the sensitivity of this ELISA kit for detecting pl-CSA was 1.22 μg/ml. The regression coefficients and correlation coefficients were similar in five experiments, with a variable coefficient of less than 1% between the pl-CSA concentration (ranging from 3.91 μg/ml to 500.00 μg/ml) and the OD450 value (Figure 1C), indicating good repeatability of the ELISA kit.
Specificity and repeatability of the double-antibody sandwich ELISA. (A) Assay sensitivity: the pl-CSA concentrations were 0.31 μg/ml, 0.61 μg/ml, 1.22 μg/ml, 2.44 μg/ml, 4.88 μg/ml, 9.77 μg/ml, 19.53 μg/ml, 39.06 μg/ml, 78.13 μg/ml, 156.25 μg/ml, 312.50 μg/ml, 625.00 μg/ml, 1250.00 μg/ml, 2500.00 μg/ml, and 5000.00 μg/ml. The lowest detectable concentration was 0.31 μg/ml. (B) Assay repeatability: The pl-CSA concentrations were 3.91 μg/ml, 7.81 μg/ml, 15.63 μg/ml, 31.25 μg/ml, 62.50 μg/ml, 125.00 μg/ml, 250.00 μg/ml, and 500.00 μg/ml. The content in each sample was measured 5 times.
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Pl-CSA was detected in bio-fluids of cancer cells but not of normal cells
The pl-CSA content in the culture supernatants and lysates of 18 cell lines was determined using the developed ELISA method. The pl-CSA concentration was above 50.00 μg/ml in the lysates of 11 cell lines of different cancer types, including A2780, KYSE-150, SKO3, SW872, A549, Hep-G2, MCF7, Sp2/0, MLTC-1, RM-1, and αTC1-9 cells; the HTR8 trophoblast cell line served as a positive control. After 5-fold concentration, the pl-CSA concentration in the cell culture supernatants was above 50.00 μg/ml. However, the pl-CSA content in the lysates and supernatants of the normal cell lines, including Het-1A, BEAS-2B, LO2, CHO, 3T3-L1 and NCTC-1469 cells, was under the detectable limit (Figure 2A). These results suggest that pl-CSA is released into bio-fluids by cancer cells.
The plasma pl-CSA content was higher in mouse cancer models than in normal control mice
The pl-CSA concentration in plasma samples from mouse choriocarcinoma and ovarian cancer models was analysed. The results showed that the pl-CSA concentration was above 100.00 μg/ml in all plasma samples from both mouse cancer models and was significantly higher in the mouse cancer models than in the normal control mice (all below 10.00 μg/ml) (Figure 2B). These results suggest that pl-CSA is released into the circulatory system in vivo.
The plasma pl-CSA content was higher in patients with ovarian, cervical, oesophageal or lung cancer than in healthy controls
To investigate whether the circulating pl-CSA content can distinguish cancer patients from healthy controls, the pl-CSA concentration was determined in plasma samples from patients with ovarian, cervical, oesophageal or lung cancer and in those from healthy controls. The plasma pl-CSA concentration was above 100.00 μg/ml in samples from the patients with cancer and was significantly higher in cancer patients than in healthy controls, who had a concentration below 60.00 μg/ml (Figure 3A). The discriminatory capability of plasma pl-CSA content was evaluated through receiver operating characteristic (ROC) curve analysis, which revealed 100% sensitivity and specificity for ESCC and NSCLC (Figure 3B and C). These results indicate that higher plasma pl-CSA levels might be a sensitive biomarker of solid tumours.
Pl-CSA content was increased in the supernatants and lysates of cancer cells and in the plasma from mouse cancer models. (A) The cell lysates and cell culture supernatants from fifteen cell lines were collected and analysed using the double-antibody sandwich ELISA. The evaluated cell lines included six human cancer cell lines and four mouse cancer cell lines, as well as two normal human cell lines and two normal mouse cell lines as negative controls and the HTR8 cell line as a positive control. (B) The plasma concentration of pl-CSA was significantly higher in mouse cancer models than in control mice.
Plasma Pl-CSA content was higher in cancer patients than in healthy controls. (A) The plasma pl-CSA content was significantly higher in patients with oesophageal cancer, ovarian cancer, cervical cancer or lung cancer than in healthy controls. (B) ROC curve analysis of plasma pl-CSA for differentiating oesophageal cancer patients from healthy controls. (C) Sensitivity and specificity of plasma pl-CSA content for distinguishing lung cancer patients from healthy controls.
Plasma pl-CSA context was higher in late-stage patients and was significantly decreased after surgical tumour removal in patients with oesophageal or lung cancer. (A) The plasma concentration of pl-CSA was significantly higher in late-stage patients with oesophageal cancer than in early-stage patients. (B) The plasma content of pl-CSA in oesophageal cancer patients was lower after surgery than before surgery. (C) The plasma concentration of pl-CSA in late-stage patients with lung cancer was significantly higher than that in early-stage patients. (D) The plasma content of pl-CSA in patients with lung cancer was lower after surgery than before surgery.
Plasma pl-CSA content was significantly increased after chemotherapy in patients with oesophageal cancer. The plasma concentration of pl-CSA in pre-chemotherapy patients with oesophageal cancer was significantly lower than that in post-chemotherapy patients.
To assess whether the plasma pl-CSA content is correlated with the clinical stage of cancer, we compared pl-CSA levels in patients with early-stage or late-stage ESCC or NSCLC. The results showed that the mean pl-CSA content was significantly higher in patients with late-stage oesophageal cancer (230.40 ± 89.13 μg/ml) than in those with early-stage disease (175.00 ± 21.67 μg/ml) (Figure 4A) and was significantly higher in patients with late-stage NSCLC (476.6 ± 110.00 μg/ml) than in those with early-stage disease (366.40 ± 40.27 μg/ml) (Figure 4C). Taken together, these data provide evidence that pl-CSA levels are positively correlated with cancer progression.
To evaluate whether changes in plasma pl-CSA are associated with clinical treatments, the plasma pl-CSA content in patients with oesophageal and NSCLC was compared before and after surgical resection. The plasma pl-CSA content was significantly lower after the surgical resection of an oesophageal tumour (157.10 ± 20.31 μg/ml) than before surgery (216.10 ± 58.94 μg/ml) (Figure 4B). Likewise, the surgical removal of lung cancer tissue significantly decreased the pl-CSA content, as evidenced by the comparison between post-operative plasma samples (318.20 ±33.28 μg/ml) and pre-operative plasma samples (410 ± 91.90 μg/ml) (Figure 4D). Interestingly, in the oesophageal patients, the plasma pl-CSA content was significantly higher after chemotherapy than before chemotherapy (Figure 5). These results suggest that a high pl-CSA content might be associated with the number of cancer cells. However, the significant increase in plasma pl-CSA content in patients with ESCC after chemotherapy suggests that pl-CSA may be a real-time marker for monitoring the effect of chemotherapy.
Pl-CSA was synthesized in cancer tissue and cancer cell lines and released in bio-fluids. (A) Pl-CSA was detectable by immunohistochemistry in oesophageal and lung cancer tissue but not in normal adjacent tissue (scale bar: 50 μm). (B) The analysis of pl-CSA-positive cases indicated 72% and 100% positivity in oesophageal and lung cancer tissues, respectively, compared with normal adjacent tissue. (C) A small amount of pl-CSA was released into the supernatant by the lung cancer cell lines, and the pl-CSA content was significantly higher in the lysates than in the supernatants. (D) A small amount of pl-CSA was released into the supernatant by the oesophageal cancer cell lines, and the pl-CSA content in the lysates was significantly higher than that in the supernatants.
Pl-CSA was detectable in cancer tissues but not in normal adjacent tissues
Through immunohistochemistry analysis of tissue chips, pl-CSA was detected in cancer tissues, primarily in the cytoplasm, but not in normal adjacent tissues (Figure 6A). Compared with the normal adjacent tissues, approximately 72% and 100% of the oesophageal and lung cancer tissues, respectively, were positive for pl-CSA (Figure 6B). This marker was also detected in lysates and supernatants of cultured oesophageal and lung cancer cells, and the pl-CSA content was significantly higher in lysates than in supernatants (Figure 6C and D).
To the best of our knowledge, this study is the first to investigate the role of circulating pl-CSA as a cancer biomarker. We found that the pl-CSA content was increased in supernatants of multiple cancer cells, plasma from mouse cancer models, and plasma from patients with cancer. A higher plasma pl-CSA content was correlated with cancer TNM stage. In addition, surgical removal of the tumour significantly reduced the plasma pl-CSA content. These findings suggest that circulating pl-CSA may be a promising biomarker for cancer screening and diagnosis.
GAGs are one of the most important components of the extracellular matrix (ECM). As a subunit of GAGs, CS is covalently bound to CS proteoglycans (CSPGs) in many tissues and cancer cells [17, 18]. CSPGs can regulate key cellular processes, including proliferation, apoptosis, migration, adhesion, angiogenesis, and invasion, as well as ECM assembly via their highly negatively charged CS side chain [19]. Many cancer cells express a distinct CS subtype that is normally restricted to trophoblastic cells in the placenta, indicating their functional importance in cancer pathology [10]. These placental-type CSs are synthesized by tumour cells and tumour-infiltrating stromal cells across multiple types of cancer, again suggesting their functional importance in cancer pathology. In support of this hypothesis, a recent study showed that placental-type CS is required for cancer cellular processes in vitro and in vivo by modifying the integrin signalling pathway, suggesting that placental CS may be a candidate therapeutic target [20]. Indeed, the quantitative analysis of GAG subunits in circulation has been proposed as a new method for identifying biomarkers that facilitate diagnosis, predict clinical severity and prognosis, and enable treatment monitoring and disease screening [21, 22].
Pl-CSA is expressed in many cancer tissues and associated with disease severity [10]. However, whether the pl-CSA content in bio-fluids can be used as a biomarker for cancer screening and diagnosis has not been validated. In this study, the pl-CSA content was significantly higher in the supernatants of cancer cells than in the supernatants of normal cells and in sera from animal cancer models or patients with various types of cancer than in healthy controls. Our data indicate that pl-CSA can be released into bio-fluids, and the pl-CSA content in bio-fluids may be a target for the development of a new biomarker for cancer diagnosis or prognosis. In addition, circulating pl-CSA content was higher in late-stage patients than in early-stage patients, suggesting that circulating pl-CSA concentration is associated with disease severity and may be used for cancer grading and staging. Moreover, our data show that the surgical removal of tumours can significantly reduce plasma pl-CSA concentrations, as shown by comparisons with pre-operative plasma samples, indicating that tumour tissue is the specific origin of the elevated plasma pl-CSA. In contrast, we observed a significant increase in plasma pl-CSA content in patients with ESCC after chemotherapy, suggesting that pl-CSA may be a real-time indicator of the effect of chemotherapy. The mechanisms by which chemotherapy increases pl-CSA content are unclear. Elevated pl-CSA content may be partly due to the damaging effect of chemotherapeutic agents on cancer cells since pl-CSA was abundant on cancer cells and killing cancer cells may prompt the release of more pl-CSA into circulation. Further clinical validation in larger prospective trials is needed to determine the changes in plasma pl-CSA content in response to chemotherapy.
No specific assays for the quantification of circulating pl-CSA had been developed. In the present study, we developed a novel ELISA to quantify pl-CSA content in bio-fluids. To increase the detection rate, we designed and generated a polyclonal antibody kit targeting multiple epitopes of pl-CSA; in this kit, pl-CSA is the antigen, pl-CSA-BP (VAR2CSA) is the capture protein, and the anti-pl-CSA antibody is the detection antibody. An ELISA is preferentially used to map epitopes of different monoclonal antibodies that have been generated against a single antigen [23]. Antigen detection by capture proteins and the detection of polyclonal antibodies improve the binding specificity and sensitivity of the assay [24]. In the present study, both pl-CSA-BP and pl-CSA antibodies selectively bound pl-CSA to improve the binding specificity. As the detection antibody is a polyclonal antibody, it can bind to multiple epitopes of the antigen, thus reducing the missed detection rate. This method increases the sensitivity of the assay, and the antigen-antibody reaction and enzyme-catalysed reaction ensure the specificity, which was verified with the homologous compounds CSB and CSC in our experiments. In the present study, we used the optimized ELISA to detect the plasma pl-CSA concentration in patients with ESCC and NSCLC. The results showed that this ELISA had 100% specificity and 100% specificity in distinguishing ESCC and NSCLC patients from healthy controls.
In summary, our findings suggest that a higher plasma pl-CSA content might be a novel, sensitive diagnostic biomarker of cancer. Our study provides evidence that a higher plasma pl-CSA content may also by a biomarker of cancer severity and the response to chemotherapy. Further studies are required to validate our findings in a large number of samples.
CS: chondroitin sulfate; pl-CSA: placental-like chondroitin sulfate A; pl-CSA-BP: pl-CSA binding peptide; GAGs: glycosaminoglycans; ESCC: oesophageal squamous cell carcinoma; NSCLC: non-small-cell lung carcinoma; CTCs: circulating tumour cells; IHC: immunohistochemistry; ELISA: enzyme-linked immunosorbent assay.
Supplementary tables.
The authors thank all the study subjects and their families for their participation and contributions to this study.
This work was supported by grants from the National Key Research and Development Program of China (2018YFC1004103), the Natural Sciences Foundation of China (81830041, 81771617 and 81572908), the Shenzhen Overseas High Level Talents Innovation Plan of Technical Innovation Project (KQJSCX2017033116131058 and 827-000157; KQCX2015032416521307), the Shenzhen Basic Research Subject Project (JCYJ20180305164706355, JCYJ20170413165233512, JCYJ20170817143406822, and JCYJ20180305163428950), the China Postdoctoral Science Foundation (2017M622806), and the Science and Technology Program of Guangdong Province (2017B-030301016).
J.Z.: study conceptualization, experiments, data visualization and original draft writing. B.S., K.Z. and Z.C.: experiments and manuscript writing, reviewing and editing. X.F. and R.Z.: study conceptualization; data visualization; manuscript writing, reviewing and editing; study supervision; and project administration. W.Y., G.W., L.T., S.C., A.L., Y.Q. and S.Y.: clinical sample collection, storage, and analysis; and manuscript writing, reviewing and editing. Z.X. and B.Z.: animal cancer model preparation, sample collection and analysis, and manuscript writing, reviewing and editing.
Animal experiments were approved by the Animal Ethics and Welfare Committee of Shenzhen Institutes of Advanced Technology (Shenzhen: SIAT-IRB-170223-YYS- ZJZ-A0253-01).
All experiments using human cell lines and plasma were approved by the Human Ethics Committee of Shenzhen Institutes of Advanced Technology (Shenzhen: SIAT-IRB- 180215-H0212) and the Institutional Review Board of Shenzhen University School of Medicine (protocol # 2016001 and 2016002). Subject recruitment was carried out in accordance with the guidelines approved by the institution, and informed consent was obtained from all patients and healthy controls as specified by the approved guidelines.
1. Ferlay J, Colombet M, Soerjomataram I. et al. Estimating the global cancer incidence and mortality in 2018: GLOBOCAN sources and methods. Int J Cancer. 2019;144(8):1941-53
2. Chen W, Zheng R, Baade PD. et al. Cancer statistics in China, 2015. CA Cancer J Clin. 2016;66(2):115-32
3. Dawson SJ, Tsui DW, Murtaza M. et al. Analysis of circulating tumor DNA to monitor metastatic breast cancer. N Engl J Med. 2013;368:1199-209
4. Tan S, Gou Q, Pu W. et al. Circular RNA F-circEA produced from EML4-ALK fusion gene as a novel liquid biopsy biomarker for non-small cell lung cancer. Cell Res. 2018;28:693-5
5. Houessinon A, Gicquel A, Bochereau F. et al. Alpha-fetoprotein is a biomarker of unfolded protein response and altered proteostasis in hepatocellular carcinoma cells exposed to sorafenib. Cancer Lett. 2016;370:242-9
6. Duffy MJ. Use of Biomarkers in Screening for Cancer. Adv Exp Med Biol. 2015;867:27-39
7. Gama CI, Tully SE, Sotogaku N. et al. Sulfation patterns of glycosaminoglycans encode molecular recognition and activity. Nat Chem Biol. 2006;2:467-73
8. Fried M, Duffy PE. Adherence of Plasmodium falciparum to chondroitin sulfate A in the human placenta. Science. 1996;272:1502-4
9. Mikami T, Kitagawa H. Biosynthesis and function of chondroitin sulfate. Biochim Biophys Acta. 2013;1830:4719-33
10. Salanti A, Clausen TM, Agerbaek MO. et al. Targeting Human Cancer by a Glycosaminoglycan Binding Malaria Protein. Cancer Cell. 2015;28:500-514
11. Agerbæk MØ, Bang-Christensen SR, Yang M-H. et al. The VAR2CSA malaria protein efficiently retrieves circulating tumor cells in an EpCAM-independent manner. Nat Commun. 2018;9:3279
12. Clausen TM, Christoffersen S, Dahlback M. et al. Structural and functional insight into how the Plasmodium falciparum VAR2CSA protein mediates binding to chondroitin sulfate A in placental malaria. J Biol Chem. 2012;287:23332-45
13. Ruitenberg EJ, Ljungstrom I, Steerenberg PA. et al. Application of immunofluorescence and immunoenzyme methods in the serodiagnosis of Trichinella spiralis infection. Ann N Y Acad Sci. 1975;254:296-303
14. Zhang B, Tan L, Yu Y. et al. Placenta-specific drug delivery by trophoblast-targeted nanoparticles in mice. Theranostics. 2018;8:2765-81
15. Zhang B, Cheng G, Zheng M. et al. Targeted delivery of doxorubicin by CSA-binding nanoparticles for choriocarcinoma treatment. Drug Deliv. 2018;25:461-71
16. Zhang J, Chen Z, Ren L. et al. Alteration of placental-like chondroitin sulfate A affects tumorigenesis of choriocarcinoma. Front Oncol. 2019 Revised
17. Afratis N, Gialeli C, Nikitovic D. et al. Glycosaminoglycans: key players in cancer cell biology and treatment. FEBS J. 2012;279:1177-97
18. Wang X, Wang Y, Yu L. et al. CSPG4 in cancer: multiple roles. Curr Mol Med. 2010;10:419-29
19. Kubaski F, Osago H, Mason RW. et al. Glycosaminoglycans detection methods: Applications of mass spectrometry. Mol Genet Metab. 2017;120:67-77
20. Clausen TM, Pereira MA, Al Nakouzi N. et al. Oncofetal Chondroitin Sulfate Glycosaminoglycans Are Key Players in Integrin Signaling and Tumor Cell Motility. Mol Cancer Res. 2016;14:1288-99
21. Tomatsu S, Shimada T, Mason RW. et al. Establishment of glycosaminoglycan assays for mucopolysaccharidoses. Metabolites. 2014;4:655-79
22. Peng C, Wallwiener M, Rudolph A. et al. Plasma hyaluronic acid level as a prognostic and monitoring marker of metastatic breast cancer. Int J Cancer. 2016;138:2499-509
23. Kohl TO, Ascoli CA. Immunometric Double-Antibody Sandwich Enzyme-Linked Immunosorbent Assay. Cold Spring Harb Protoc. 2017;2017(6):pdb prot093724
24. Wang J, Zhang S, Ni W. et al. Development and application of a double- antibody sandwich ELISA kit for the detection of serum MUC1 in lung cancer patients. Cancer Biomark. 2016;17:369-76
Corresponding authors: Xiujun Fan (xiujun.fancom) and Rihong Zhai (rzhaiedu.cn). Address: 1068 Xueyuan Avenue, Shenzhen University Town, Shenzhen, China. Tel.: +86-755-86392360.
Accepted 2019-11-18
Published 2020-1-1


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A 2568 Maksutov (ideiglenes jelöléssel 1980 GH) a Naprendszer kisbolygóövében található aszteroida. Zdenka Vávrová fedezte fel 1980. április 13-án.

Kapcsolódó szócikkek
 Kisbolygók listája (2501–3000)

Jegyzetek

A Naprendszer kisbolygói

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Shouse Law Group represents victims throughout the U.S. who suffered serious complications and injuries from dangerous drugs and failed medical devices.
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If you've been injured in an accident, our personal injury lawyers will fight to get you compensation for medical bills, lost wages, pain and suffering, and even punitive damages.
California Personal Injury Laws A to Z
Private Nuisance
Shouse Law Group
A private nuisance occurs when the plaintiff's use and enjoyment of his or her property are obstructed or interfered with and caused by the actions of another. Private nuisance cases generally involve a neighbor or nearby occupant doing something that interferes with the plaintiff's use of their own property.
Examples of a public nuisance may involve
a neighbor polluting the soil,
selling drugs next door, or
hoarding animals causing foul odors and health hazards.
In California, a private nuisance provides for a cause of action for the injured party. A plaintiff can file a lawsuit against the individual or group responsible for the nuisance. A lawsuit can seek an injunction to prohibit the defendant from continuing the nuisance activity. The plaintiff can also seek damages for a loss of property value or damages caused by the nuisance.
If the nuisance actions cause a physical injury to the plaintiff or the plaintiff's family, he or she may also be able to file a personal injury lawsuit for damages caused by the defendant's negligence. The person could also be prosecuted for "public nuisance" under Penal Code 372 and 373a, which is a misdemeanor and carries up to 6 months in jail.
To help you better understand the laws on public nuisance lawsuits, our California personal injury lawyers discuss the following frequently asked questions:
1. What is a private nuisance in California?
1.1. How is a private nuisance different from a public nuisance?
2. What are the elements of a private nuisance claim?
3. What are examples of a private nuisance in California?
3.1. Injurious to the Health
3.2. Illegal Sale of Controlled Substances
3.3. Indecent or Offensive to the Senses
3.4. Obstruction to the Free Use of Property
3.5. Blocking Sunlight
4. What damages are available in a private nuisance lawsuit?
5. What are defenses to private nuisance claims?
Private nuisance cases generally involve a neighbor or nearby occupant doing something that interferes with the plaintiff's use of their own property.
Property owners are generally entitled to the reasonable use and enjoyment of their own property. However, when others do something that interferes with an individual's use or enjoyment of the property, that interference may be considered a private nuisance.
California law provides a cause of action for a private nuisance. Under California Civil Code Section 3479:
"Anything which is injurious to health, including, but not limited to, the illegal sale of controlled substances, or is indecent or offensive to the senses, or an obstruction to the free use of property, so as to interfere with the comfortable enjoyment of life or property, or unlawfully obstructs the free passage or use, in the customary manner, of any navigable lake, or river, bay, stream, canal, or basin, or any public park, square, street, or highway, is a nuisance."1
A private nuisance is a type of "tort" in California. A tort is a civil wrong where the actions or inactions of one party cause damage or loss to another. Torts include intentional torts (like assault), negligence, or strict liability torts (like products liability).
A private nuisance is generally categorized as nuisances per se and nuisances per accidens. A per se nuisance generally involves an activity that is prohibited or regulated by statute. For example, when a junkyard is not operated according to state and local laws which interfere with a neighbor's use of the land, that may be considered a per se nuisance.2
Nuisance per accidens, sometimes called a nuisance, in fact, is an unreasonable use or interference, based on the surrounding circumstances.3
When a nuisance affects multiple people, a community, or neighborhood, it may be considered a public nuisance. It may still be a public nuisance even if it affects different people in different ways.4
Example: Alan lived at the end of a cul-de-sac. Alan decided he wanted to make his own hot sauce. As demand grew, Alan made large batches of the sauce in his garage. The spicy sauce and vinegar could be smelled up and down the street. Anyone who got close to Alan's house complained of coughing and burning eyes.
Alan's closest neighbors may have suffered from the noxious odor more severely than neighbors at the top of the street. However, because the nuisance affected the larger group of neighbors, it may be considered a public nuisance.
In some cases, a nuisance could be considered both public and private. However, California law also provides that any nuisance that is not a public nuisance is private.5
In order to recover damages in a private nuisance claim, the plaintiff has to prove the defendant interfered with the plaintiff's use and enjoyment of his or her land. This includes proving the following:
The plaintiff owned, leased, occupied or controlled the property;
The defendant, by acting or failing to act, created a condition or permitted a condition to exist that involved one of the following:
Was harmful to health; or
Was indecent or offensive to the senses; or
Was an obstruction to the free use of property, so as to cause loss of enjoyment of life or property; or
Unlawfully obstructed the free passage or use, in the customary manner, of any navigable lake, or river, bay, stream, canal, or basin, or any public park, square, street, or highway; or
Was a danger or fire hazard to the plaintiff's property;
That this condition interfered with the plaintiff's use or enjoyment of his or her land;
That the plaintiff did not consent to the defendant's conduct;
That an ordinary person would be reasonably annoyed or disturbed by the defendant's conduct;
That the plaintiff was harmed;
That the defendant's conduct was a substantial factor in causing the plaintiff's harm; and
That the seriousness of the harm outweighs the public benefit of the defendant's conduct.6
Minor annoyances may not rise to the level of a nuisance. The defendant's action or failure to act must be both harmful to the plaintiff and something that an ordinary person would find annoying or disturbing.
A private nuisance case must also generally consider the balancing-test factors that weigh the seriousness of harm against the public benefit. Factors involved in determining the seriousness of the harm include:
The extent of the harm and how long that interference lasted;
The character of the harm in causing impairment of property, personal discomfort, or annoyance;
The value that society places on the type of use or enjoyment invaded;
The suitability of the type of use or enjoyment invaded to the nature of the locality; and
The extent of the burden (such as expense and inconvenience) placed on the plaintiff to avoid the harm.
Factors involved in determining the benefit of the defendant's conduct include:
The value that society places on the primary purpose of the conduct that caused the interference;
The suitability of the conduct to the nature of the location; and
The practicability or impracticality of preventing or avoiding the invasion.7
Example: Brita owned a home in a suburban neighborhood on a half acre of land. Brita enjoyed tending her backyard garden in order to attract a number of songbird species. The songbirds would visit regularly but more often in the spring. When visiting, the birds would sing and chirp throughout the day. Occasionally, a local teacher would bring her class by so the children could practice identifying birds visually and from their songs.
Brita's neighbor Clive, hated the sound of the songbirds. Clive claimed the birds were too loud and interfered with his leisure activity of talking to other ham radio enthusiasts. Clive files a private nuisance complaint against Brita.
Clive may have been annoyed or disturbed; however, the jury would have to determine whether an ordinary person would be reasonably annoyed or disturbed by Brita's tending to the garden. In a balancing test, the jury would also weigh the seriousness of the harm to Clive against the public benefit. In this case, Clive would likely lose a private nuisance claim against Brita.
Private nuisance cases in California most often involve disputes between neighbors or against prior property owners. Examples of private nuisance claims in California may include the following:
A nuisance that is considered injurious to health may include waste, garbage, or dangerous material. If a property owner keeps or allows unsanitary conditions to exist on the property that is harmful or offensive to the neighbor, that may be considered a private nuisance. This could include:
Untreated human waste or garbage,
Diseased or dead animals,
Dangerous waste from manufacturing, or
Any other condition which could cause disease or illness.
The illegal sale of a controlled substance is explicitly included as a private nuisance under California law. A property that is used to sell drugs or other illegally sold substances can present a hazard to neighboring property. This may include fire hazards and dangerous substance dangers involved in drug manufacturing.
The illegal sale of a controlled substance is also a violation of other California Health and Safety codes and may be considered a nuisance per se.
An indecent or offensive nuisance may include offensive sights, smells, or sounds. The nuisance does not have to be harmful or dangerous. For example, even if a smell is not a danger to health, noxious of offensive smells may prevent a property owner from enjoying the use of their property.
Other offensive nuisances may be caused by loud music, smoke, or vibrations that can be felt in another's home.
Obstructing the free use of property generally involves a physical barrier or other way to prevent the property owner's use of their own property.
Example: Gary and Henry are next door neighbors. Both homes share access to a walkway at the rear of the property. When Gary exits the rear of his property, he must walk passed Henry's house to get to the street.
Henry is tired of people walking down the walkway late at night making noise. Henry plants a large hedge at the rear of his property. The hedge grows over the walkway, preventing people from passing by. Gary can no longer freely use the rear of his property to get to the street using the public easement.
Henry's actions may constitute both a private and public nuisance. However, Gary may be able to file a private nuisance claim against Henry is obstructing the free use of Gary's property.
3.5. Blocking Sunlight May NOT be a Nuisance
In one case, homeowners filed a private nuisance lawsuit against a neighboring property for planting trees that shaded their home. The court determined that planting trees on neighboring property that blocked the sun was not a private nuisance. A landowner generally has no easement for light and air over adjoining land.8
The damages available in a private nuisance lawsuit depend on the type of harm caused and whether the nuisance is continuing. The relief available generally includes:
Money damages for loss of value,
Money damages based on discomfort, annoyance, or emotional distress, or
Injunctive relief.
Injunctive relief may be sought for a continuing nuisance where the court orders the defendant to take action or refrain from doing something.
If the private nuisance causes physical injury or harm to the plaintiff, the injury victims may be able to file a personal injury lawsuit (in addition to the private nuisance claim). Compensatory damages in a California personal injury claim can include an award for:
Lost wages, and
Pain and suffering.
There may be a number of defenses available to the defendant in private nuisance claims. Consent is generally a defense to private nuisance lawsuits. When the plaintiff consented to the defendant's actions, the plaintiff cannot generally complain of that nuisance.
Example: On a hot summer day, Michael asked his neighbor, Janice, what she thought of Michael planting a maple tree along their property line to provide shade for their homes. Janice said it was a great idea.
Michael planted a maple tree along the property line. Years later, the tree had almost doubled in size. Janice complained that the tree was shading too much of her tomato garden and she wasn't getting enough tomatoes. Janice told Michael she wanted him to cut the tree down.
Michael refused to cut the tree down and Janice filed a private nuisance lawsuit. Janice may lose the lawsuit because she had consented to planting the tree and now was complaining that the tree was the cause of her loss of use of her property.
Another possible defense involves the plaintiff's comparative fault. Under California's comparative negligence laws, the plaintiff's damages can be reduced if the plaintiff was partially to blame for the harm. For example, if the plaintiff suffers $10,000 in property damage and the jury determines the plaintiff was 20% responsible for that damage, the plaintiff may only be able to recover $8,000 from the plaintiff.
Need Help Filing a Private Nuisance Claim in California? Call us for help...
For questions about when private nuisance claims, damages in a nuisance case, or to discuss your case confidentially with one of our skilled attorneys, do not hesitate to contact us at Shouse Law Group.
We have local law offices in and around Los Angeles, San Diego, Orange County, Riverside, San Bernardino, Ventura, San Jose, Oakland, the San Francisco Bay area, and several nearby cities.
Legal References:
California Civil Code 3479.
Sher v. Leiderman (1986) 181 Cal.App.3d 867.
California Civil Code 3480 ("A public nuisance is one which affects at the same time an entire community or neighborhood, or any considerable number of persons, although the extent of the annoyance or damage inflicted upon individuals may be unequal.")
California Civil Code 3481 ("Every nuisance not included in the definition of the last section is private.")
California Civil Jury Instructions (CACI) 2021-- Private Nuisance -- Essential Factual Elements.
California Civil Jury Instructions (CACI) 2022-- Private Nuisance -- Balancing-Test Factors -- Seriousness and Public Benefit.
Sher v. Leiderman, at footnote 2 above.
5 Shouse Law Group has wonderful customer service. They were so pleasant and knowledgeable when I contacted them. Very helpful with any questions and concerns and I can't thank them enough for the experience I had. Definitely recommend! Dee M.


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Q: Передача выборки из SQL в ORM Я делаю выборку нативным sql(так как там вложенный запрос на сумму полей),но надо передать полученные данные в "формат" ORM.как это осуществить?

A: описание работы ORM в Kohana на русском

http://kohana3.ru/orm/

в данный момент не лучший выбор из существующих вариантов, если есть возможность я бы выбрал что-то другое

redpajama_set_name: RedPajamaStackExchange


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Singapore 330mL (normal sized) Coke promotional can. Consumer information on the can states that it was canned in Singapore for sale in Singapore and Brunei.
This design was used in conjuction with Singapore's WOMAD music festival, of which Coke was a sponsor. This is the first promo can to use the yellow ribbon design.


Saban reloads defense with lots of newcomers by The Associated Press | April 14, 2019 at 2:14 a.m.
Alabama quarterback Mac Jones throws during the second half of Saturday's spring game in Tuscaloosa, Ala. Jones, a third-teamer last season, went 19 of 23 for 271 yards with 2 touchdowns and an interception Saturday.
"We have a very young team," Saban said this week. "We don't have a lot of depth. We'll welcome the new players that we have coming in the fall. I think there's a dozen more and maybe some of those guys can contribute to some of the issues that we have from a depth standpoint."
OK, it's hardly a sob story with 15 members of the nation's No. 1 recruiting class already on campus. Alabama wrapped up spring with Saturday's annual A-Day spring game pitting the first-team offense versus the first-team defense in yet another part of that development.
Alabama, as usual, has opportunities in some spots for newcomers to play early roles. The candidates include a pair of top-10 prospects, defensive end Antonio Alfano and offensive tackle Evan Neal -- along with two four-star quarterbacks with crimson bloodlines. The Tide is looking for a starting tackle with the early departure of projected first-round pick Jonah Williams, and Raekwon Davis is the only returning starter along the defensive front.
Some of those departures were practically foregone conclusions, with Jonah Williams and defensive tackle Quinnen Williams regarded as likely high first-round picks.
It wasn't the typical Alabama defense even before four defenders left early, a fact painfully reinforced in a 44-16 national championship game loss to Clemson. Alabama allowed an average of 345 passing yards to a trio of star quarterbacks -- Georgia's Jake Fromm, Oklahoma Heisman Trophy winner Kyler Murray and Clemson freshman Trevor Lawrence -- in the final three games.
• Jalen Hurts gave Alabama the luxury of a backup quarterback who was also a two-year starter. Hurts is now at Oklahoma as a graduate transfer.
Mac Jones was a third-teamer last season but only completed five passes while playing a mop-up role. He put up the biggest numbers in the spring game among the backups, going 19 of 23 for 271 yards with 2 touchdowns and an interception, mostly in the first half.
Freshmen Taulia Tagovailoa, Tua's younger brother, and Paul Tyson tried to take advantage of a chance to perform in front of Tide fans at the spring game.
Tyson is the great grandson of iconic former Alabama coach Bear Bryant. Taulia Tagovailoa was 6-of-9 passing for 93 yards with 1 touchdown and an interception. Tyson attempted five passes, completing one for 8 yards while also getting picked off.
• Alabama had depth issues at inside linebacker even before Mack Wilson opted to skip his senior season. Fifth-year senior Joshua McMillon has drawn praise from Saban.
• Defensive tackle DJ Dale wasn't among the highest rated recruits but has gotten strong enough reviews to think he might have a chance at playing time as a freshman. Saban said Dale has shown some physical skills but also "a little maturity about being able to go out there and do his job."
• Tailbacks Najee Harris and Brian Robinson appear good enough to maintain Alabama's tradition of star runners. But Alabama is replacing senior Damien Harris and potential first-round pick Josh Jacobs. Five-star freshman Trey Sanders arrives this summer.


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LIVE SCORES & SCHEDULE: Australian Open day three
Warner hints he'll put family before country in 2021
By Brett Graham
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David Warner has flagged the possibility of skipping some overseas tours in 2021, should COVID-19 quarantine restrictions continue into the new year.
It's been three months since Warner saw his wife and their three children, having been to England for a one-day series, followed immediately by the IPL, with both those tournaments played in bio-secure bubbles.
He's now nearing the end of his two weeks in quarantine in Sydney, ahead of the limited overs series against India which starts on Friday.
Australia has a number of overseas engagements in 2021, including a Test series in South Africa and possibly the final of the World Test championship in England in June.
"Honestly, it's going to be very difficult to be able to do that, this last six months have been quite challenging, getting used to these bubbles, and trying to get used to not having the family with me," Warner said.
"Each player has different circumstances, we're just not going to get time to see our families.
"At the back end of nearly 14 days in a hotel, with three kids and a wife, I wouldn't ever put them in that situation where they have to do 14 days quarantine at home."
Warner explained that it's likely there will be players that choose to sit out tours in 2021, unless a vaccine can be rolled out and travel can return to normal.
"The next 12 months is very difficult when you look at the calendar, there's going to be times when you can come home and have time with your family, but yet again you've got that 14 days that's in place that you're going to have to do beforehand," he said.
"It's going to be very difficult and something we're going to have to speak to the coaches and selectors (about).
"Each individual is going to have to put their hand up and be brave and just say it's difficult to do it."
David Warner. (AAP)
The T20 World Cup is scheduled for both 2021 (in India) and 2022 (in Australia), while the next 50-over World Cup isn't due to be played until 2023, in India.
That makes it more likely Warner will skip the 50-over format in 2021, should he choose to stay home.
"That's something we have identified as players and coaching staff," Warner said.
"The preference will be the T20 stuff over the next two years. And then gearing up for the 50-over World Cup in India in 2023."
Warner's comments were echoed by teammate Steve Smith, who is also currently in quarantine after arriving home from the IPL.
"It's obviously very different living in a bubble life. I don't think it's sustainable for a long period of time," Smith said.
More Cricket news and highlights
India to lose Test series 4-0 if Virat Kohli can't inspire early, Michael Clarke says
Steve Smith 'extremely excited' by batting discovery ahead of one-day series against India


If there's one thing I've learned as a parent..it's to expect the unexpected. I knew going into this parenting thing that we would hit milestones. That between learning to roll over and learning to crawl, milestones would be part of our lives from here on out.
What I didn't realize is that it wasn't just child milestones that we would be experiencing. Turns out we parents hit our own milestones. They may not be as easy to identify as the first time a child crawls or walks but they are there and they start early.
I've talked about them here, I didn't call them milestones but maybe realizations. Take, for example, the time I realized motherhood isn't so bad. My entire pregnancy with E, I struggled with the idea that I was going to be a mom. I worried and stressed about how I would manage…then E came and at some point very quickly after that I realized you just do. It might seem like an easy enough lesson to learn but for me, it was an awakening of sorts.
Then when we found out MiniE was coming, I worried about what life would be like with two…would E be ok with having a sibling? How were we going to manage two?! More worry, more fear but then she showed up and all the worry melted away, and I realized that my heart was capable of loving so much more than I thought. There was room for more! Another milestone.
I'm getting all deep here and I really didn't intend to but this weekend something happened and I realized that while it was a change, a milestone for E, it ended up being as much of a milestone for me.
"Huh?" you say. I'm talking about clothes shopping at Target. I went to get E some new shorts and I immediately went to the baby/toddler section only to find nothing in his size. All too small. So I looked around kind of lost..Now what? Where do I go?
Then I saw it, across the aisle was an entire new part of the store, I had never really ever paid attention to…the "Kids" section. I resisted crossing the aisle at first. That was uncharted territory that I wasn't sure I wanted to explore yet. But I had no choice, E needed clothes.
Slowly, I crossed the aisle and I started to tear up. What the heck is wrong with me?! Seriously?! Then I realized what I was feeling..was I losing my toddler? Was he becoming a kid? Where has the time gone?
I looked around and found what I was looking for. I looked at the sizes and there it was…XS, E's size, as if to validate the fact that, yep, I'm losing a toddler and gaining a kid.
Ready or not, it's here. Luckily for me, I can still wonder the aisles of Carters and find clothes his size but not much longer. Luckily for me, MiniE is still deeply rooted in the baby section or I might lose my ALL my marbles on my next shopping trip.
Either way, it just reminded me that this journey is as much about us as it is them. Take it day by day, embrace it, savor it, and most of all, roll with the punches.
What milestones have you hit as a parent?
We are both at the same point. While my little guy is still in the "toddler" sizes, he's growing fast and will be across the aisle before I know it. Sigh….another milestone that comes along way too quickly.
Oh my gosh Katie, I have been struggling with a very similar realization. My son has been teetering for a while on the clothes thing. It wasn't so sudden for me since he has been in a larger shirt for a while (he is a relatively tall kid) and still in the Toddler pants (which are now too short). It sort of came slowly. However, this is his last year of Pre-school and I am a mess just thinking that next year he will go to Kindergarten. I can't quite go into the details of my feelings, it would just take too long, but I am just not ready. It is a really hard thing for me and I never thought I would be like that but I know when next year rolls around I am going to be a total disaster. But I just keep thinking about the here and now, he is still my little boy and I will always love him no matter how big he gets.
Both of my kids will be in HS tomorrow! How did this happen? I am way too young for this!
AWE love this!! I may have teared up a little. You are such an awesome mama!!
My second child started her very first day of school today. I thought it would be easier because my son went to preschool last year but it was just as hard. She did fantastic but I felt that emotional tug when I left her there. Milestones are tricky because they are great and exciting but still hard to go through sometimes!


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Jesse Malin & The St Marks Social
After three critically acclaimed solo records, dozens of world tours and TV appearances, Jesse Malin found himself back in New York City questioning his next move. From his days fronting seminal hardcore trio Heart Attack and infamous glam punks D Generation, then seven years on the road as a solo artist, Malin had cultivated a devout fan base. He'd shared stages with everyone from The White Stripes to Counting Crows, The Hold Steady to Lucinda Williams, but felt like he was losing the plot. Malin contemplated going back to school, becoming a standup comedian or a Las Vegas wedding DJ, and even started work on a documentary film about DC hardcore Rastafarians The Bad Brains. For over a year he didnít play or record. When asked by a Hollywood screenwriter to pen songs for a film about author J.D. Salinger, Malin ó a fan of Catcher in the Rye and other Salinger works ó traveled to Cornish, NH hoping to speak to the famous recluse. In typical punk-rock fashion, instead of getting the interview, Malin landed at the local precinct for trespassing and was released only after the cops watched his video duet with Bruce Springsteen for "Broken Radio" on YouTube and were convinced he was just a writer doing research. Though he never met Salinger (who passed away this past January), Malin made the most of the experience by writing "The Archer" and "Lonely at Heart"ótwo songs that would make him want to work again and become the basis for his new album. Over the summer of 2009, in the basement of Avenue A watering hole Hi- Fi, the songs came forth. Malin, with impresario Don DiLego, drummer Randy Schrager, guitarist Matt Hogan, and bassist/DJ Tommy USA, worked with his newly formed band to bash out an album's worth of gritty anthems, and The St. Marks Social was born. A solid band, but one with an open door to Malin's community of musician friends - longtime partner in crime Ryan Adams, pop singer Mandy Moore, fellow label mate Brian Fallon, and former bandmates from D Generation Howie Pyro and Danny Sage - the Social is a group effort to keep the P.M.A. Says Malin, "To me, rock 'n' roll is an exorcism that begins every night when the sun goes down, the music starts playing, and the spirits start flowing. It helps to say things in public over dirty microphones. It's a way to spit out the poison." When Jesse met producer Ted Hutt (Lucero, Flogging Molly, The Gaslight Anthem) one drunken night at a local bar, their talk of making a record fast, loose, and raw, was the beginning of Huttís quest to create a record that would encompass Malin's roots and evolutionófrom hardcore thrasher to punk/folk singer-songwriter. The album's basic tracks were laid in three days at Greenpoint, Brooklynís Mission Studios, and the rest at Sonic Youth's Think Tank Studios in Hoboken, NJ. Filled with the characters Malin does bestómessengers and misanthropes, hipsters and hypocritesóand as always, his constant themes of redemption, nightlife, heartbreak, and survival, LOVE IT TO LIFEóa sentiment taken from a ticket stub Joe Strummer autographed for Jesseówas built with desperate optimism that shouts in gang vocals that no matter how bad it gets, youíre never alone. LOVE IT TO LIFE will be in stores on April 27, 2010. Jesse Malin and The St. Marks Social will start a residency this month at the Bowery Electric in New York to get warmed up for a run of dates with label mates Gogol Bordello in April.
After three critically acclaimed solo records, dozens of world tours and TV appearances, Jesse Malin found himself back in New York City questioning his next move. From his days fronting seminal hardcore trio Heart Attack and infamous glam punks D Generation, then seven years on the... Read More →
Maggie Mae's Gibson Room 512 Trinity St


Cushions SteamPunk There are 3 products.
Cushion Design Steam Punk available in various sizes. Printed on 2 sides. Manufactured in polyester. Includes fill.Cover removable, suitable for washing machine.Maximum washing temperature 30 ° C.Ironing in low temperature.Suitable for dryer.Dry at a low temperature.Do not use chlorine.
Cushion with Designs of Steam Punk available in various sizes. Printed on 2 sides. Manufactured in polyester. Includes fill.Cover removable, suitable for washing machine.Maximum washing temperature 30 ° C.Ironing in low temperature.Suitable for dryer.Dry at a low temperature.Do not use chlorine.
Cushion with a Design of Music SteamPunk available in various sizes. Printed on 2 sides. Manufactured in polyester. Includes fill.Cover removable, suitable for washing machine.Maximum washing temperature 30 ° C.Ironing in low temperature.Suitable for dryer.Dry at a low temperature.Do not use chlorine.


In 2015 I was commissioned to paint a series of artworks for the Parkes Shire Council for the Vibrancy Project. The artworks all have special meanings relevant to our town. This was such a fun project to be part of from start to the installation of the works in mid May 2016.
The public art concept brings the basic principles to life through a range of art murals and a community art panel installation piece, which incorporate the new Parkes "It all adds up" brand.
The focus is to encourage people into and around the Central Business District using versatile and dynamic art to create visual interest. The idea is stroll the streets, stopping in at local shops and eateries, whilst taking in the vibrant art – making Parkes CBD a place where the locals want to be and the visitors want to return to.


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Home > Faculty Publications and Other Works by Department > Education: School of Education Faculty Publications and Other Works > 93
Education: School of Education Faculty Publications and Other Works
A Standards-based Approach to Catholic Principal Preparation: A Case Study
Sandria Morten, Loyola University Chicago
Geralyn A. Lawler, Loyola University Chicago
Journal of Catholic Education
Illinois' recent redesign of the principal certification program requires the integration of the Interstate School Leaders Licensure (ISLLC) standards as well as the Southern Regional Education Board Critical Success Factors standards into the coursework and internship, establishing a focus on preparation for instructional leadership. The alignment to secular standards poses a challenge for Catholic institutes of higher education who seek to prepare aspiring Catholic school principals to be instructional, managerial, and faith leaders (Ciriello, 1994). During their own redesign, Loyola University Chicago utilized the National Standards and Benchmarks of Effective Catholic Schools to create Catholic School Principal Competencies, a list of skills that principals will need in order to effectively lead a Catholic school. The Catholic School Principal Competencies are embedded in course work, field experiences, and the internship. Other program features including coaching from veteran principals and frequent reflection allow the candidates to gain confidence as well-rounded Catholic school leader. Collaboration with other Catholic universities will help to solidify the Catholic School Principal Competencies and further streamline their integration into the program.
Author Posting © Morten, S. D., Lawler, G. A, 2016. This article is posted here by permission of the Journal of Catholic Education for personal use, not for redistribution. The article was published in Journal of Catholic Education, Vol. 19, Iss. 3, May 2016, http://dx.doi.org/10.15365/joce.1903172016
Morten, Sandria and Lawler, Geralyn A.. A Standards-based Approach to Catholic Principal Preparation: A Case Study. Journal of Catholic Education, 19, 3: 332-349, 2016. Retrieved from Loyola eCommons, Education: School of Education Faculty Publications and Other Works, http://dx.doi.org/10.15365/joce.1903172016
© Morten, S. D., Lawler, G. A, 2016.


Encourage those individuals to widely share their ideas and practices for the benefit of U.S. Manufacturing facilities nationwide.
Each winner will be awarded a cash prize of $5,000. DOE will select up to 5 winners in each category of small, medium, and large manufacturers, for a total of up to 15 winners. In addition to the cash prize, the winners will be recognized at the annual Better Buildings Summit and will have their winning ideas and practices highlighted on the Better Buildings Solutions Center. Applicants will have the option to decline the cash prize if selected and still be recognized as a winner and participate in the events and activities described in the prize rules.
Through the prize, DOE is seeking to recognize and bring attention to employees on the plant floor all around the country who not only recognize the importance of saving energy, but are making it happen, strengthening their company's competitiveness and driving cost savings in the process. By sharing successful strategies and examples of leadership, manufacturers can drive energy productivity improvements and accelerate the adoption of energy efficient technologies. Through this prize competition, DOE is seeking to recognize leaders who are responsible for creative, specific, and innovative projects to drive measureable energy savings in their manufacturing plants. Applications will be evaluated on demonstrated energy savings, with additional credit being given for successful strategies to engage other workers on the manufacturing floor. Energy efficiency is contagious; through this prize, DOE will recognize their leadership and amplify the success of their projects.
Visit Challenge.gov for the official rules of the ITEAM prize competition and application details. Click here to view or download the official prize rules.
Engineering-based results are acceptable, but true metered data is preferred. The submission will be evaluated, in part, on the magnitude of the energy and energy cost savings. Please detail any impacts beyond the direct energy savings from the projects (increased awareness and engagement, replicability for other plants, auxiliary benefits beyond energy savings).
Participants should show how their actions made the process or facility more energy efficient or increased productivity since when the project was completed (no earlier than October 5, 2018). Participants are encouraged to add in personal anecdotes such as how working with and engaging other plant manufacturing staff increased energy savings were realized and how the action will continue to lead to savings. In addition, please share content about the facility and the energy-related components of the project (e.g., why it was selected/implemented? How does it fit into a broader sustainability strategy?), what was the process for identifying the opportunity, defining the project, and deciding to proceed? Also, describe what your organization's goal or desired outcomes for the project, barrier(s) to implementation and what were your solution(s) to implementing the project? Please detail the extent to which the individual had to overcome significant obstacles (e.g., economic, technological, management support, etc.) to implement the project. Please explain, to the extent possible, how the project or practice described in the submission catalyzed greater engagement amongst other employees at the company.
Please articulate how this represents a new way of doing business for the individual, plant or the manufacturer. Where applicable, please describe the new technology and the impact it is having. How imaginative or creative is the practice or project? How replicable is the project?
The degree to which the project and/or the individual's efforts have the potential to attract widespread attention and to encourage third parties to further develop the ideas or practices.
Participants must have complied with all requirements set forth in the Official Rules for ITEAM.
Individuals must be a United States citizen or a U.S. permanent resident, and be 18 years or older.
The manufacturing facility where the idea or practice is being implemented must be located in the U.S. This includes the 50 U.S. states and 6 territories.
The manufacturer/entity must be incorporated in and maintain a primary place of business in the United States.
DOE employees and DOE support service contractors, individuals who have been employed by DOE, or working for DOE as a support service contractor within six months prior to the submission entry deadline are not eligible to participate.
Non-DOE Federal entities and Federal employees are also not eligible to participate.
Employees of any co-sponsor organization for the ITEAM Prize competition are not eligible to participate.
Participants may not be a Federal grantee using Federal funds to participate.
Federal contractor Participants may not use Federal funds from a contract to participate in the ITEAM Prize competition or to fund efforts in support of an ITEAM Participant.
Prize Administrator employees directly involved in the administration of this prize competition are not eligible to participate.
A Participant will not be disqualified for using Federal facilities or consulting with Federal employees during a competition if the facilities and employees are made available to all entities participating in the competition on an equitable basis.
Eligibility is not limited to individuals employed by manufacturers participating in DOE technical assistance programs like Better Plants, 50001 Ready, Industrial Assessment Centers, etc.
By uploading an entry, a Participant certifies that it complies with the eligibility requirements described above. As soon as DOE becomes aware that a Participant is not eligible to win the ITEAM Prize, the Participant may be disqualified.
Entries must be submitted to Challenge.gov by 11:59 PM Eastern time May 15, 2020.
All dates are subject to change including prize competition openings, deadlines, and announcements.
For questions about the prize competition, contact: iteamprize@ee.doe.gov.


In florid embrace wings within sublime.
White Orchid, Photograph, RMR, Collectible Clicks,©Rose Marie Raccioppi, 2009.
To the will of beauty my soul surrender.
And poetry is the voice of music.
Portrait of a Woman, Oil on Canvas, 1800, Jozef Grassi, Italian/Austrian, 1758-1838.
This moment of summer love.
Dispel the darkness and light be The Word.
From beauty's call I shan't depart.
And known be the Great Mind in which I believe.
Libation and banished be fear.
The resplendent perfection of a summer day.
St Peter's Church, Old Woking, 1200-1500, Surrey, England, The Ryde Window of St Peter's Church, Restoration, 2005.
A jeweled dawning held this summer night.
Sweet Summer musings I enfold.
Sweet Summer, Oil on canvas, 1912, John William Waterhouse, 1849-1917.
Liebestod, Richard Wagner , 1813-1883, Franz Liszt, 1811-1886.
Study of Guinevere for Sir Lancelot in the Queen's Chamber, 1857, Dante Gabriel Rossetti, British, 1828 - 1882.
Claude Lorrain, 1600-1682, British Museum.
The Harvester, 1880-81, oil on canvas, Julien Dupre, 1851-1910, Huntington Museum of Art, Huntington, WV.
Sitting upon a tree that once was.
Summer Bamboo, Ink on paper, 1350, Wu Chen, 1280-1354.
And hear I the whispers of THE WORD.
Secret Tree, Photograph, Karen Krinitz, Collectible Clicks, ©Rose Marie Raccioppi, 2009.
And newly decreed be joy, the knowing and doing sublime.
Melencolia I, 1514, Engraving, Albrecht Dürer, German, 1471–1528.
The Spirit of '76, 1875, Archibald McNeal Willard, American, 1836-1918.
Healed be this heart, I longingly proclaim.
Mariana in the South,1897, Oil on canvas, John William Waterhouse, British Painter, 1849-1917.
This, God's destiny willed to you.
Pygmalion and Galatea, Ca. 1890, Oil on Canvas, Jean-Léon Gérôme, 1824 –1904, French painter and sculptor in the style now known as Academicism.


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Q: How to create modal on click the button Here I have one button , if I click the button I want to take the property id and passed the API means they will give the property details and I want to display the results in my modal, here if I click means that moal is not showig how can do this, for me no need to show and hide I want to use this method

// Property View
$(document).on('click', '.prlstbtn_view_btn', function() {
  id = $(this).closest('tr').find('.myHidden').val();
  console.log(id);
  viewproperty_modal(id);
});

function viewproperty_modal(property_id) {
  htmlString = "";

  $.ajax({
    url: 'http://www.example.com/properties/' + property_id,
    type: 'GET',
    contentType: 'application/json; charset=utf-8',
    success: function(viewresult) {
      console.log(viewresult);
      $.each(result, function(key, p_typevalue) {
        htmlString += '

<button type="button" class="close" data-dismiss="modal">×</button>
View Property Details

 Name: Rashmita Das

Email Address: das76rashmita.gmail.com

Mobile Number: 77751068862

 Property Type: Apartment

 Listed For: SALE

 Country Name: India

 State Name: Karnataka

 City Name: Bengalore

 Property Name: 3 BHK Apartment In Marathahalli

 Address Line1: Marathahalli

 Address Line2: Marathahalli

 Pincode: 560037

 Block No: 8TH Block

 House No: 10

 Built Up Area: 200 sqft

 No of Bedrooms: 3

 No of Bathrooms: 1

 No of Balconies/Sitouts: 1

 No of other Rooms: 1

 Monthly rent: 1000000

 Security deposit amount : 100000

 Maintenance Charges: 10000

 Property Ready for Possession: 02/01/2017

 Construction of Your Property: 1009

 Type of Ownership: Freehold

 Total Floors: 3

 Property Face Type: North

 Bachelor Allowed: yes

 Non-Vegetarians Allowed: NO

 Pets Allowed: 4

 Carpet Area: 2400 sqft

 Property Status: Ready to move in

 separate dining space: yes

 Servant Accommodation: NO

 Furnishing: Fully Furnished

 Parking Type : 4 Wheeler

 Parking Count: NO

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 Floor Plan :

 Specifications : NO

 Housing Loans : NO

 Properties Images :

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<button type="button" class="btn btn-default" data-dismiss="modal" style="background-color: #f47c3c;">Close</button>

';
        //$('#modal_property').empty().append(htmlString);
      });
    },
    error: function(errMsg) {
      console.log(errMsg);
    }
  });
}

A: It seems you forgot to add modal to DOM and open it.
Please try this:
success: function (viewresult) {
    console.log(viewresult);
     $.each( result, function( key, p_typevalue ) {

     htmlString+='

<button type="button" class="close" data-dismiss="modal">×</button>
View Property Details

 Name: Rashmita Das

Email Address: das76rashmita.gmail.com

Mobile Number: 77751068862

 Property Type: Apartment

 Listed For: SALE

 Country Name: India

 State Name: Karnataka

 City Name: Bengalore

 Property Name: 3 BHK Apartment In Marathahalli

 Address Line1: Marathahalli

 Address Line2: Marathahalli

 Pincode: 560037

 Block No: 8TH Block

 House No: 10

 Built Up Area: 200 sqft

 No of Bedrooms: 3

 No of Bathrooms: 1

 No of Balconies/Sitouts: 1

 No of other Rooms: 1

 Monthly rent: 1000000

 Security deposit amount : 100000

 Maintenance Charges: 10000

 Property Ready for Possession: 02/01/2017

 Construction of Your Property: 1009

 Type of Ownership: Freehold

 Total Floors: 3

 Property Face Type: North

 Bachelor Allowed: yes

 Non-Vegetarians Allowed: NO

 Pets Allowed: 4

 Carpet Area: 2400 sqft

 Property Status: Ready to move in

 separate dining space: yes

 Servant Accommodation: NO

 Furnishing: Fully Furnished

 Parking Type : 4 Wheeler

 Parking Count: NO

 Parking Count: NO

 Floor Plan :

 Specifications : NO

 Housing Loans : NO

 Properties Images :

 Property Map  : NO

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<button type="button" class="close" data-dismiss="modal">×</button>
View Property Details

 Name: Rashmita Das

Email Address: das76rashmita.gmail.com

Mobile Number: 77751068862

 Property Type: Apartment

 Listed For: SALE

 Country Name: India

 State Name: Karnataka

 City Name: Bengalore

 Property Name: 3 BHK Apartment In Marathahalli

 Address Line1: Marathahalli

 Address Line2: Marathahalli

 Pincode: 560037

 Block No: 8TH Block

 House No: 10

 Built Up Area: 200 sqft

 No of Bedrooms: 3

 No of Bathrooms: 1

 No of Balconies/Sitouts: 1

 No of other Rooms: 1

 Monthly rent: 1000000

 Security deposit amount : 100000

 Maintenance Charges: 10000

 Property Ready for Possession: 02/01/2017

 Construction of Your Property: 1009

 Type of Ownership: Freehold

 Total Floors: 3

 Property Face Type: North

 Bachelor Allowed: yes

 Non-Vegetarians Allowed: NO

 Pets Allowed: 4

 Carpet Area: 2400 sqft

 Property Status: Ready to move in

 separate dining space: yes

 Servant Accommodation: NO

 Furnishing: Fully Furnished

 Parking Type : 4 Wheeler

 Parking Count: NO

 Parking Count: NO

 Floor Plan :

 Specifications : NO

 Housing Loans : NO

 Properties Images :

 Property Map  : NO

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