text:
The European Union is Harmed by EPO Abuses
Posted in Europe, Patents at 2:08 am by Dr. Roy Schestowitz
…and Elżbieta Bieńkowska (European Commission) Should Tackle Rather Than Ignore This
A new low: blocking EPO employees.
Summary: When EU officials openly reaffirm the widespread perception that they're disinterested/apathetic about EPO abuses they merely inherit the burden of EPO corruption, eroding trust in the EU as well
THE TIME is 4AM on a Sunday. I am frustrated. I'm unable to not think about this. Why are our elected politicians still ignoring the situation at the European Patent Office (EPO)? And yes, I do vote in European elections. I am in favour of the EU and always have been. This is a matter of public record; I've never hidden this. In order for the EU — and for Europe as a whole — to remain strong it needs to demonstrate a certain resistance and perseverance in the face of lobbying, bribery, and blackmail. It needs to tackle issues such as tax evasion, air pollution, privacy abuses and so on. This year's copyright directive did major damage to the EU's reputation and last year's appointment of António Campinos (former EU person) as Battistelli's successor does not inspire confidence. He had been elected a year before that after a rigged (by Battistelli) process and a Council of unelected officials — mostly heads of national patent offices (NPOs) — just rubberstamped Battistelli's choice (of a friend, a compatriot from elite French schools).
"Some time in 2017 or 2018 it already seemed like software patents were 'finished' in the US, but Trump proved us wrong by putting a litigation 'mole' (and his former business partner) in charge of the world's most important patent office."At the start of the year we stopped covering 35 U.S.C. § 101 affairs in order to better (or more often) focus on EPO abuses. It had become clear to me — more so after the visit to Berlin — that the EPO issues were "close to home" and a lot more urgent than anything that went on in the US. That was weeks before Iancu circulated a memo about gutting (or ignoring) 35 U.S.C. § 101. Some time in 2017 or 2018 it already seemed like software patents were 'finished' in the US, but Trump proved us wrong by putting a litigation 'mole' (and his former business partner) in charge of the world's most important patent office. We didn't stop covering this scandal; it's just that we typically 'shelve' articles on this topic in Daily Links (we have a relatively new section, "Patents and Software Patents," which can be found further down among the headings).
The European patent crisis and its full impact may take time to materialise because patents last a couple of decades and any European Patent wrongly granted today can have a negative effect for as long as a generation if not longer. The word "crisis" as in "European patent crisis" isn't an overstatement but an understatement. The word was used even by the Council a few years ago; it had finally realised it could not just sweep the problems under a rug somewhere. But its response was weak and they wanted us to believe that a presidential shuffle alone would magically resolve things; their eventual 'choice' of President (actually Battistelli's choice) undermined that very premise as less than a year after he began the work at the Office staff was already organising to go on strike and indeed, the following year staff started protesting (that was last month). Nothing is improving. From what I can gather, having covered the subject on a daily basis for more than five years, things 'quietly' get worse. It all gets worse over time, under the veneer of attitudinal change. Sure, Campinos may not come across as overly temperamental like Battistelli; but is temperament the most important thing? Many people out there have fallen for 'charm' and lost sight of policies; they'd use Macron, Obama, Trudeau and even Merkel as examples of "left-leaning" leaders; but their underlying policies are often characterised as "neo-liberal" — a widely misunderstood if not distorted term — meaning unfavourable to workers and favourable to 'owners' of these workers. We're seeing much of the same at the EPO these days. Examiners can feel it. They can really feel it. They hardly feel valued; some feel dispensable. This might be normal in some gift shop or something, where training new workers would not take long so staff turnover isn't a massive business risk. But patent offices are different and talent retention (or experience) is vital to all.
"The European patent crisis and its full impact may take time to materialise because patents last a couple of decades and any European Patent wrongly granted today can have a negative effect for as long as a generation if not longer."At the end of last week the EPO posted several dozen tweets from EPOPIC that spoke of replacing workers (such as searchers) with the "magic" of "hey hi" (AI). I responded to the EPO in Twitter about half a dozen times; it's troubling that they'd have us believe all jobs can be replaced with machines while maintaining the same level of service; to managers this may make economic sense (to them alone), but at what cost? They're passing all the cost and the risk to other people, e.g. by granting invalid patents or carrying out sloppy searches that won't yield relevant documents (pertaining to prior art). Where does that leave the European public, let alone examiners? We have, over the past year, published numerous documents that show examiners' concern. They're very well aware of the decline in patent quality, knowing the possible ramifications for everyone's jobs — not only at the EPO but also outside the EPO. Each monopoly granted does not necessarily make society (or "the economy") better off. Monopolies are limitation factors, not enablement factors. Similarly, each time a new law gets passed, that's an additional thing being banned or being criminalised. New laws — unless they're actually the undoing of some existing laws — merely provide more 'tools' by which to frame/render a business or a person "criminal"; hence, not each law being passed represents progress. And again, going back to patents, not every patent being granted implies more innovation; not every patent represents invention (evergreening being a good example of this point).
Trying to 'lecture' the general public about patent law isn't easy; when I explain this to my mother, for example, she fails to even grasp what patents actually are. She thinks that the word is a synonym of "invention"; "When you invent something," she told me, "that's a patent…"
"Monopolies are limitation factors, not enablement factors."As if it just 'happens'. You come up with something and magically a patent comes into existence.
A lot of people don't know how patent laws and principles work, why patent law exists, since when it has existed, who benefits from it, and the range of industries it covers.
It is, however, easier to explain to the general public — colloquially speaking — EPO scandals pertaining to finances, nepotism, and an assault on the separation of powers (the notion that when you're dissatisfied with an illegal outcome you can resort/turn to an independent branch to reassess this outcome).
Occasionally people write to me either to ask me to contact the "big media" (corporate publishers) or to ask me why I don't contact it. The latter is a loaded question as I constantly try to get media to pay attention to newer/latest scandals. 5+ years down the line, based on many experiences, I had to reach the conclusion that some writers are eager to cover the matter; but their bosses (publishes/editors/site owners) actively prevent that. Over time I also learned about threatening letters from the EPO and bribes from the EPO. This is how the rogue EPO mastered media control. They 'sell' Campinos as some kind of very kind saviour; This 'charm offensive' targets not only media but also politicians, some of whom are of course keeping themselves (mis)informed by the media.
"5+ years down the line, based on many experiences, I had to reach the conclusion that some writers are eager to cover the matter; but their bosses (publishes/editors/site owners) actively prevent that."Days ago I learned that the European Commission's Elżbieta Bieńkowska [1, 2] is now blocking people who raise concerns about corruption in Europe's patent system. Yes, actually blocking!
What does that say about her and — by extension — EU officials? Not good, Miss Bieńkowska, not good…
This is the kind of attitude that causes people to vote for leaving the EU and choose rather obscene parties instead (like that ridiculous "Brexit Party" with only one single policy!), based perhaps on the misguided assumption that they're the "lesser evil".
An EPO insider has just shared a screenshot to that effect and wrote [1, 2, 3]: "It seems that Mrs Elżbieta Bieńkowska is no longer interested in the ongoing unrests, the deteriorating working conditions and deplorable social situation at the EPO. She is now blocking concerned citizens without ever having had a conversation! #patents #deception #Europe [...] To turn a blind eye to the rule of law, remarkable behaviour for an EU representative, to say the least! #patents #deception #Europe [...] Perhaps she should ask herself who is paying her generous salary, right? Ahhh the #EuropeanCommission , alright then…"
"This is the kind of attitude that causes people to vote for leaving the EU and choose rather obscene parties instead (like that ridiculous "Brexit Party" with only one single policy!), based perhaps on the misguided assumption that they're the "lesser evil"."Will (or would) those same European officials let the EPO control the legal system and enforce it at a higher level, EU-wide, without national courts having a say? That would be madness. It would also be illegal and unconstitutional (which is likely worse than the more ordinary "illegal" because laws change over time; constitutions are more stringent). Imagine giving the EPO — a notoriously corrupt institution — more power to decide on patent scope in a couple dozen countries! Watch this new tweet from proponents of software patents in Europe; they continue to rely on the EPO (an office that violates its own law, or the EPC) rather than actual, outside, independent courts.
Incidentally, and perhaps in a somewhat timely fashion, people posted a lot of comments about the EPO and the EPC at IP Kat yesterday and the day before that. "Proof of the pudding" (a regular commenter who has not said much since IP Kat started censoring many comments critical of the EPO) wrote:
So, the Board is of the view that "the EPC provides a complete system for determining whether a priority right has been correctly claimed, and that the issue may be resolved by the EPO without reference to national law".
I would have thought that it was, in fact, the Paris Convention that "provides a complete system for determining whether a priority right has been correctly claimed". If the EPC contains any different or additional requirements, then that surely means that the EPC Contracting States are contravening their obligations under the Paris Convention.
From that point onwards the Paris Convention started to be debated yet more. "The Convention Watchdog" wrote:
Looking into the Board's communication reveals that the relevant paragraphs 27 and 28 are entitled "The EPC and the Paris Convention are a complete System". In fact the provisions of the EPC and the Paris Convention are identical as far as they are relevant for the contested legal issues in this case.
Let's start with some basic facts; the EPO violates the EPC all the time (EPO staff can attest to that; the union and representatives routinely spoke about this). The Boards themselves likely operate in violation of the EPC (not their fault but Battistelli's) while he's trucking millions of EPO euros to his friends in Paris (no connection to the Paris Convention).
"The Boards themselves likely operate in violation of the EPC (not their fault but Battistelli's) while he's trucking millions of EPO euros to his friends in Paris (no connection to the Paris Convention)."So whatever the context of the above comments (we mentioned that post some days ago), they might be inadvertently overlooking the fact that these Boards lack independence — by their very own admission — and are thus unable to rule properly. Again — it is not their fault! They're the victims here. They have the courage and the sincerity to state out in public that Battistelli robbed their autonomy. It's an extremely risky thing to do; they did that several times in the past. Similarly, as the next commenter's name put it, "EPO is not to blame but the applicant". Here's what that comment said:
The annex to the summons is published by now [it wasn't before]
https://register.epo.org/application?documentId=E3Z2HAR19821DSU&number=EP13818570&lng=en&npl=false
Anybody thinking that the EPC is a complete system and the Paris convention another and different complete system is playing with words and at the brink of bad faith.
As the provisions of the Paris convention and of the EPC are identical as far as they are relevant for the contested legal issues in this case, it should lead to the conclusion that the long standing line of case law at the EPO should be kept.
The question raised by the Board of Appeal is remarkable in its simplicity and the answer is obvious.
If A and B are the original applicants of the priority application, in order to benefit of the priority, both have to be the applicants of the subsequent applications, unless one of the original applicants transfers his right of priority to the second one, or both transfer their right of priority to a third party. The only aspect which touches the EPO when determining who the successor in title is legal regime under which those transfer of rights have been validated.
Disputing the ownership of an application once filed is different from deciding upon the right of priority, although in both cases the EPC speaks about the successor in title. When a first application is filed, or when an application claims priority and the applicant is the same as the one of the priority application, the EPO has no reasons to check whether the applicant in name is the true owner of the invention and hence of the application. The situation is different when an application is filed claiming a priority, and there is a difference in the name of the applicant of the priority application. Then the EPO has the duty to verify who the successor in title is.
One should however not forget that the problem we are faced in the present case stems from the "oddities" of US patent law.
Loss of the patent may only be the result of a document published in the priority interval becomes then prior art under Art 54(2), even if it is the own publication of all the applicants of the priority application.
In the US we have a grace period which is unknown in the rest of the world. Should the publication of an invention before filing not be sanctioned in the rest of world just because the applicant has published his invention in the US?
Translated into the priority system, it is in other words, what the appellants want.
If the right to priority cannot be transferred before the end of the priority period, why should it not be possible that the subsequent application is filed by the holder of the priority right, and the ownership of the subsequent application is then transferred? This would avoid a whole series of problems, not just before the EPO.
It might a priori look unfair that opponents can obtain revocation of a patent for, at a glance, reasons other than of substance, but here it is the applicant of the subsequent application which takes a great risk when the question of ownership of the priority right has not been properly cleared before the subsequent filing.
Put in very simple terms, the monopoly (patent) may in fact be assigned to the wrong person; yesterday someone sent me this pointer which said: "Something discovered today: apparently it is possible to "steal" someone's patent at the USPTO.
"They have the courage and the sincerity to state out in public that Battistelli robbed their autonomy.""Someone (a Swedish law firm, of all things!) declared themselves as the registered owners of one of my patents at the USPTO without my knowledge or approval (or the co-author's) and the USPTO accepted it?!?!? [...] I have sadly had to get myself a lawyer "because IANAL". Fortunately I happen to know a patent lawyer (friend from Uni)."
So at least it seems like the EPO isn't the worst patent office in every way/aspect (China is a good contender for it). "Suleman Ali" then commented:
I agree with the philosophy of the EPO's present position that it must be established that both applicants have given consent for the priority right to be established for a convention filing. However I disagree with the strict conditions that this means assignments etc must be in place by convention filing. This is completely arbitrary, and does not recognise the time frame for business negotiations and transactions. As always the EPO is applying rules in a mathematical way that serves no greater purpose. More leniency and kindness please
Well, "leniency and kindness" in whose favour? As we've been showing her for many years, the EPO tends to favour very rich people — not inventors — and then the Boards are compelled to rubber-stamp such policies. See last night's Daily Links about patents as well as [1-3] below (Shanks v Unilever) to understand how imbalanced things have become in that regard.
"Proof of the pudding" then wrote again:
A positive aspect of the arguably harsh consequence of mucking up entitlement to priority is that it has made (more) attorneys in the US sit up and take notice … and to realise that they cannot always assume that what works just fine in the US might not be good for elsewhere.
In other words, it seems to me to be a good thing that a consequence of this high-profile case could well be that US attorneys will start to ensure that they have a better understanding of an international treaty that is of fundamental importance to intellectual property rights … and to which the US is a signatory.
Now if we could only find a way of getting patent examiners in the US to start looking at, and understanding the implications of, those pesky international treaties…
No, patent examiners are pretty powerless; we've already explained, perhaps a dozen times, that US patent examiners are forced to follow some guidelines that are derived from a complete distortion (gross omissions) of caselaw. The same is likely true for EPO patent examiners; they can cite the law and name precedents, but that comes at risk of enraging the line managers, who are themselves vassals of high-level management, i.e. patent maximalists. They view patent quality as an obstruction to so-called 'productivity'; they view good examiners as nuisance who engage in gross professional misconduct/incompetence. They literally insult those who do their job properly.
"They view patent quality as an obstruction to so-called 'productivity'; they view good examiners as nuisance who engage in gross professional misconduct/incompetence."MaxDrei (patent attorney) then wrote: "If the EPO is going to continue to impose its own EBA-made law on the rest of the world, even though this EBA-made law is said to be less than fully in line with "the aim" of the Paris Convention, the EBA really ought to try very hard this time, to come up with persuasive reasoning. Otherwise it is going to be criticised."
Here's the full comment:
Thanks for that last contribution, which reminds me of the very popular fob-off that, when you come to Europe with your patent applications, "Ignorance of the law is no excuse".
It is said that you, dear Applicant, should have known that, unlike everywhere else in the world, here in Europe i) there is no grace period ii) under Art 54(3), your own earlier filings, unpublished at the date of your claim, nevertheless destroy the novelty of that claim and iii) you need to dot the i's and cross the t's, and memorialize post-filing ownership transfers BEFORE you file PCT.
If the EPO is going to continue to impose its own EBA-made law on the rest of the world, even though this EBA-made law is said to be less than fully in line with "the aim" of the Paris Convention, the EBA really ought to try very hard this time, to come up with persuasive reasoning. Otherwise it is going to be criticised.
There are good reasons for the absence of a grace period and very good reasons for the Art 54(3) self-collision. They persuade me. But as to the TBA question here, having read the Straus Amicus Brief, and now the Annexe to the TBA Communication, I personally am not seeing reasons persuasive enough to justify upholding current practice. Readers, in the enormous EPO file, which is the single doc I should read, that makes the most persuasive case for continuing with present practice? Perhaps that will persuade me.
Earlier this year we published a number of articles critiquing the composition of EBA; but again, this is very much the fault of the political managers of the Office, who also get to choose chief judges. There's no true independence; not even remotely!
"The EPO is not to blame but the applicant" responded again (to some of the above comments):
Dear Max Drei,
The whole discussion turns about the interpretation given to the word "any" or in French "celui qui". For some scholars, e.g. Prof. Strauss, it means not all of those having filed the provisional application, have to be named in the subsequent application.
According to Prof. Strauss, if A and B have filed a provisional application, A could decide to file in certain countries, and B in others. I am anything but sure of that is what the drafter of the Paris Convention had in mind. By the way what the drafters of the Paris Convention had in mind is
For other scholars, e.g. Prof. Forteau, the word "any" or in French "celui qui" should be interpreted broadly, encompassing one of several co-applicants of the original application acting individually when filing the subsequent application.
Should we follow the views expressed in the name of the proprietor, we would be bang in the question raised by the Board.
To me, "celui qui" has as plural "ceux qui". This means clearly that in case of one original applicant it must be the same applicant or its successor in title of the subsequent application. If there is a plurality of co-applicants all those co-applicants have to be those filing the subsequent application. It is a question of mere logic.
I am thus not convinced by Prof. Strauss' statement or by the one of Prof. Forteau.
After all, the purpose of the Paris Convention was to avoid self-collision, and the applicant of the subsequent application should not be penalised if its application was published before 12 months. Avoiding self-collision can only be between two applications having the same applicant or co-applicants. There again it is question of mere logic.
Dear Suleman Ali,
When the assignments are not ready and in place by the convention filing, why then not have the convention filing carried out by the original applicants and the transfer of ownership afterwards. This would obviate any problems of timing.
Why are we citing all this stuff and quoting it in full? Two reasons: 1) IP Kat has a tendency to nuke comments — especially good and important comments — even after their publication (we've covered and archived many examples of that); 2) IP Kat comments are nowadays a lot better and far more informative than posts — a paradox for most blogs. When one considers who employs these bloggers and examines who (micro)manages them, the reasons become clearer.
"If the EPC is so shamelessly being violated and if the EPO continues to demonstrate disregard for the independence of judges (their appointment process and more), how can a system like the UPC ever be tolerated?"So, in summary, there are growing concerns about EBA and about the EPC. There are, accordingly, also concerns about the Unitary Patent (UPC), or the European Union-centric Unified Patent Court Agreement (UPCA). If the EPC is so shamelessly being violated and if the EPO continues to demonstrate disregard for the independence of judges (their appointment process and more), how can a system like the UPC ever be tolerated? Ever?
Incidentally, only two days ago a Team UPC-owned blog (author unnamed, posted under "European Patent Litigation" — their 'bread and butter') published "Ingve Stjerna: Examination compatibility UPCA with German and EU law was deficient." Whoever the author is, he or she writes about UPC opponent Dr. Ingve Stjerna with his latest analysis. Here are some portions:
The compatibility of the Unified Patent Court Agreement (UPCA) and two pieces of draft legislation submitted for its ratification in Germany with the German Constitution was examined only very selectively, whereas the compatibility with EU law was apparently not examined at all. This is the conclusion of the Düsseldorf based patent lawyer Ingve Björn Stjerna, who meticulously investigated the procedure leading to the German ratification of the UPCA.
Stjerna, the lawyer behind the constitutional complaint against the UPCA which led to a stay of ratification proceedings in Germany, published an article on the issue last month. The timing is not coincidential: a decision of the German Federal Constitutional Court (BVerfG) about the case (2 BvR 739/17) is expected in the upcoming months. At the end of his article, Stjerna implicitly says the BVerfG should take into account his findings:
'The documents provided suggest that the BMJV [the Federal Ministry of Justice and Consumer Protection] having the overall responsibility for the implementation of the European patent reform in Germany and the ratification of the UPCA, did not comprehensively examine the Agreement for its compatibility with the Grundgesetz nor or [of?] that with Union law, in particular with CJEU Opinion 1/09. The BVerfG may take note of this with interest.'
In the second chapter of his article, using among others information he gathered with three requests (in October 2017, August 2018 and February 2019) based on the Freedom of Information Act, he writes what happened in practice. 'The answer is sobering. According to the official information provided by the BMJV, individual aspects were examined for compatibility with the Grundgesetz, but relevant constitutional issues remained unexamined, as did compatibility with Union law'. Then he proceeds with all the details sustaining his conclusion. A few exemples are given below.
Basically, as we said a day after he had published his paper, the government did not at all consider the impact on small businesses; it's hardly surprising considering the fact that the driving force behind UPC was a cabal of law firms and their biggest clients (usually not even European firms!).
"For Europe to remain united (unity, unitary, unified, whatever) we need the perception of functioning accountability mechanisms. We don't have that at the moment, certainly not in EPOnia."Going back to where we started, the EU (or EC) ignores all this at its own peril. The most controversial parties, including AfD, were quick to exploit these UPC scandals, leveraging them to bolster their anti-EU agenda. Unless the EU takes control of the situation at the EPO, at the very least by stripping its immunity and launching an investigation, nothing will improve. Things will get yet worse (faster than anything can ever improve).
When I look at EPO abuses I don't bash the EU. Rather, I am becoming increasingly concerned about the self-harming (in)action of the EU. For Europe to remain united (unity, unitary, unified, whatever) we need the perception of functioning accountability mechanisms. We don't have that at the moment, certainly not in EPOnia. Sweet-talking and fairy tales aren't substitutes as more people become disillusioned over time. █
Related/contextual items from the news:
In-house predict 'university-style model' after inventor compensation ruling
Lawyers say that the UK Supreme Court's judgment in Shanks v Unilever is likely to result in changes to business practice and an uptick in compensation claims
What was the relevant undertaking? Further comments on Unilever v Shanks [2019] UKSC 45
Section 40(1) UKPA states that, when considering if an employee should be awarded compensation for his invention, the court should have "regard among other things to the size and nature of the employer's undertaking". In the UKSC decision, Lord Kitchin reasoned that the Hearing Officer and lower courts had erred in their interpretation of the appropriate "undertaking" of Professor Shanks employer. The "undertaking" to be considered, according to the UKSC, was not that of Unilever as a whole. The relevant undertaking was instead that of the Unilever subsidiary by which Professor Shanks was directly employed (CRL), whilst also taking account of the commercial relationship between CRL and Unilever as a whole.
In order to establish the correct "employer undertaking" in the case in question, Lord Kitchin observed that in many situations relating to employee compensation, identification of the appropriate undertaking "will be comparatively straightforward. It will be the whole or, if it is divided into economic units, the relevant unit of the employer's business" (para. 41). However, the case in question was a different and more difficult case.
Unilever argued that the relevant undertaking was Unilever as a whole. In particular it was argued that it was "unreal to treat CRL as the relevant undertaking because it never generated any material revenues, was not the beneficiary of the royalties in question and is and was simply a service company for the Unilever group" (para. 45). Furthermore, the £24.3m benefit from the Shanks Patents went to the Unilever group as a whole. By contrast, Professor Shanks argued that the relevant undertaking was that of CRL. Particularly, CRL was Professor Shanks' direct employer and the entire Unilever group could not sensibly be described as CRL's undertaking (para. 45).
Lord Kitchin opted for an approach that lay between these two extremes. The analysis, according to Lord Kitchin, should have a more practical and commercial focus. In particular, the question to ask was what would have been the expected benefit of a patent originating from a research facility such as CRL, operating as part of the larger Unilever group, to Unilever as a whole?
£2m compensation is the largest amount of compensation that has been awarded to an employee-inventor under Section 40. Lord Kitchin agreed with the Hearing Officer that a "fair share" of the benefit derived by Unilever from the patents was 5%. Lord Kitchin disagreed with Professor Shanks' argument that a fair share would have been between 10-20%, given that, amongst other factors, the patent had been exploited at no risk to Unilever. Lord Kitchin agreed with the Hearing Officer at first instance that 5% was fair given that 1) Professor Shanks was employed to invent and, in making the invention, did what he was employed to do. Furthermore, the benefit of the patents was brought to fruition by Unilever's negotiation of the licences (something in which Professor Shanks played no part) (para. 91).
Shanks v Unilever – A Fair Share At Last
The Supreme Court handed down its judgment on 23 October 2019, marking the end of a 13-year struggle between the inventor, Prof Ian Shanks, and Unilever for compensation in relation to an invention relating to disposable glucose monitoring equipment.
The judgment of the Supreme Court provides valuable guidance on the matters to be taken into account when assessing the benefit of an invention, and the amount of compensation to be awarded to the inventor. However, it may encourage conglomerates who currently employ inventors in a small subsidiary within the larger group of companies to re-structure so that inventors are directly employed by a larger manufacturing company in the group, so that the "employer's undertaking" is a larger entity and thus a higher threshold is set when assessing whether the invention has provided an "outstanding benefit".
The Supreme Court did however decide to apply to the 5% share an uplift to reflect the impact of time on the value of money. The original 5% of £24 million (£1.2 million) was thus uplifted to an award of £2 million to Prof Shanks.
The persistence of Prof Shanks has provided, in the decision of the Supreme Court, important guidance as to the manner in which a claim for compensation under Section 40 is to be dealt with in future.
Koch's Reply to EPO Through ILO and Techrights' Interpretation of Koch v EPO Documents Help Show That ILO-AT is Played by EPO Management
EPO and EU: People Behind the Faces
SUEPO Protests Against Management of the European Patent Office Brought Back Discussions About Corruption
Think Tanks, Bristows, 'Simmons' and 'Birds' Can Only Ever Lie to Us About the Dead Unified Patent Court (UPC)
SUEPO Organises Hague Protest — Second EPO Protest in a Fortnight, Targeting the Portuguese Embassy in The Hague
The EPO Instructs European Examiners to Grant Junk Patents on Algorithms (Maths and Stats)


The varsity hockey team hosted Thomas Worthington High School on Friday at South Metro as they celebrated Staff Appreciation Night. Prior to the game, the players welcomed the teacher or staff member who they felt had had the greatest impact on them towards their education.
Once the game got underway, the visiting Cardinals struck first with a late first period goal to take a 1-0 lead after the first fifteen minutes of action. In the second period, Riley Hrin tied the game at a goal apiece, but the Cardinals retook the lead late in the second period to take a 2-1 lead heading to the third period. In the third period, the Elks had a chance to tie the game with an early power play, but were unable to do so. The Cardinals, however, did strike on the power play later in the period and then added an insurance goal to claim a 4-1 victory.
Now 10-11 overall and 5-4 in league play, the Elks are back in action this weekend as they host their annual MLK tournament at South Metro. They will play once on Friday, twice on Saturday and once on Sunday. Those times and opponents have not yet been announced.


The City Assembly is an institution that determines the important matters concerning the everyday lives of city residents. Shinjuku City Assembly meetings include scheduled meetings held four times a year and extra meetings as necessary. In addition, committees are established to investigate topics that are discussed at the meetings in a more specialized and efficient manner.
City Assembly meetings and committee meetings are open to the public. Please apply for reservations with the Secretariat to the City Assembly, Shinjuku City Office 5F.
Those who have something they would like to request or report to the city administration may do so. A letter of introduction from a City Assembly member is required.
The City Administration Information Center collects and stores government reference materials, such as publications of the city, metropolitan, and national governments. The center offers reading space and rental services and also sells city publications. In addition, consultation services are available for all residents. The center also has computers that can be used to search for information.
Materials: Publications of the city, metropolitan, and national governments; general-interest books; gazettes; metropolitan public relations materials; newspapers; magazines; and public relations videos.
Photocopying service is also available (fees charged).
"Postcards to the Mayor" and letters expressing requests and opinions are accepted by the City Office.
"Postcards to the Mayor" are available at municipal facilities such as Branch Offices.
Requests and opinions are also accepted via Internet. Please access the Shinjuku City website.
One thousand persons are randomly selected and asked to complete questionnaires in surveys conducted by mail four times a year. The results of these surveys are reflected in the administration of the city. The term of duty is one year.
A session called "Let's Talk with the Mayor about Shinjuku" is conducted at Chiiki Centers and other locations. When the dates and times are determined, they will be announced in Koho Shinjuku (Shinjuku bulletin), on the Shinjuku City website, and through other means.
Shinjuku will conduct youth meetings and youth awareness surveys as a way to create opportunities and venues that enrich the interest and involvement of youth in Shinjuku City's administration. When the program and schedule are set, they will be announced in the Koho Shinjuku (Shinjuku bulletin), on the Shinjuku City website, and through other means.
Public comment is a system in which proposals for policies that would greatly influence the everyday lives of city residents are announced before any decisions are made, and consideration to public opinion is given in the city's decision making. When a decision is made, the opinions received and the thoughts of the city administration concerning said opinions are publicly announced.
The implementation of public comment programs is announced in Koho Shinjuku (Shinjuku bulletin), on the Shinjuku City website, and through other means.
Shinjuku City conducts an annual survey of 2,500 persons—with the respondents selected at random—to understand the ideas, wishes and thoughts of residents on important issues. The responses serve as the basis for city administration operations. The results are announced on the Information on Everyday Living for Foreign Residents website, and a summary written in four languages (Japanese, English, Chinese and Korean) is available for reading at the public library.
The committee is a fair and neutral third-party institution that handles complaints from city residents concerning city administration.
Complete a Complaint Form with the necessary information and submit it to the Committee for Accepting Residents' Opinions (Shinjuku City Office Annex 1, 2F).
Note: Complaint Forms can be downloaded from the Shinjuku City website.
The Public Information Disclosure System is a system that guarantees the right of all city residents to read public documents belonging to the city and to have access to a copy of such.
Please note that some public documents may not be made available to the public in order to protect the privacy of individuals.
Documents, graphs, and magnetic recordings that were officially created or acquired by the staff during the implementation period and which can be officially used by staff in the applicable implementation period.
Please submit the designated request form at the specific division desk.
The purpose of the Individual Information Protection System is to properly maintain individual information kept by the city in order to protect the privacy of individuals, while at the same time guaranteeing the right to request viewing or revising personal information. Through the registration list for the individual information system, you can see what kind of individual information the city collects and uses.
In addition, since some individual information may not be made available to the individual himself/herself, such as personal evaluations and examinations, please call for more information.


text:
Lease process for public-land energy projects must improve
Tribune edit board
Three decades ago under the Reagan administration, mineral and oil and gas leases were issued in the Badger-Two Medicine, a 130,000-acre area, bounded by Glacier National Park, the Bob Marshall Wilderness and the Blackfeet Indian Reservation. This portion of the Rocky Mountain Front is considered sacred by the Blackfeet Tribe and is part of a Traditional Cultural District.
For 30 years, members of the Blackfeet Tribe lived under the threat that this land they consider sacred would be industrialized, said Harry Barnes, chairman of the Blackfeet Tribal Business Council.
That fear is waning in stages.
Congress legislatively withdrew the area from mineral development in 2006.
In March, the Bureau of Land Management signed a final decision to cancel a 30-year-old oil and gas exploration lease held by Solonex LLC. Solonex is continuing its legal challenge to overturn the Interior Department's cancellation of the lease.
In November, the largest remaining leaseholder in the region — Devon Energy — chose to retire its 15 leases in return for sunk costs. Devon Energy will receive a $206,058 refund on its bid for the land, half of which will be paid by Montana and half by the U.S. Treasury Department. Most of the other companies with leases have since taken advantage of tax incentives set up by Congress to relinquish their claims
In January, the Bureau of Land Management canceled the final two oil and gas leases in the Badger-Two Medicine area.
Former Department of Interior Secretary Sally Jewell said the federal government failed to consult with tribal leaders when it leased the land, which is now officially in the hands of the U.S. Bureau of Land Management. She said if such procedures had been followed in other cases, such as at Standing Rock in North Dakota, there would be better cooperation between Native people and energy companies.
The lease Jewell referenced is for Energy Transfer Partners' almost-finished $3.8 billion Dakota-Access pipeline. Members of the Standing Rock Tribe and its supporters spent months protesting the pipeline's route to cross Lake Oahe, a Corps reservoir on the Missouri River in North Dakota and the major source of water for the Standing Rock Sioux Reservation. The protest is based on fear that a pipeline breach could threaten the drinking water supply for reservation communities and that its path will disrupt culturally significant sites.
The U.S. Army Corps of Engineers, at the direction of the Obama administration, denied an easement for the Dakota Access oil pipeline at Lake Oahe in January. President Trump issued an executive order to advance approval of that easement.
In November at the ceremony when Devon Energy's leases in the Badger-Two Medicine were canceled, Devon Energy CEO David Hager said, "We'd like to see policies continue the responsible development of (oil). For Devon, cancellation of these leases at this time is simply the right thing to do."
In January, when the last two Badger-Two Medicine oil leases were canceled, Montana Petroleum Association Executive Director Alan Olson said coalitions of environmental groups and tribes have placed pressure on agencies to block legally permitted oil and gas projects. The organization is hoping for a more predictable approach to development on federal lands under the Trump administration.
We support the cancellation of leases in the Badger-Two Medicine. While we acknowledge such development may be able to co-exist with a minimal impact to activities such as hunting, fishing and hiking that sportsmen and women enjoy on this public land, the land's cultural significance to the Blackfeet Tribe is the reason for that support.
This is an important moment to review history, however. Jewell said a failure to consult with tribes 30 years ago led to the decades-long conflict that left a lot of energy developers with trapped resources.
Energy development and extraction is a critical contributor to the economy, as Montanans are sorely aware of during this legislative session. Lower energy prices mean there is not as much revenue to go around this year for things such as schools, infrastructure and other government services.
We support energy development on public land.
Vetting those public land projects should be inclusive and long enough to consider all risks and viewpoints. And historical and current events shine a big, bright spotlight on the need to change how Native American Tribes are included in that process. Again, we call on the federal government to exercise skilled diplomacy in these matters. Energy developers are well served to do the same thing with projects involving public land that is significant to tribes.
These events stress that we must work to create a predictable, stable energy permitting environment in this nation when it comes to energy projects on public land. Private industry can't shoulder the risk of the current process where "final" decisions are unreliable.
The risk is great for communities, too. Fractures between opposing sides only widen when regularity decisions are changed under the influence of public opinion and administration turn over.
We must do better on the front end when it comes to this process.
—Tribune editorial board

redpajama_set_name: RedPajamaCommonCrawl


Euro gold rose above �1131, platinum lost $5.50 to $787, and copper dropped 6 cents to about $2.66.
Note: Change in Total Tonnes from yesterday�s data: SPDR added 12.053 tonnes.
Silver Trust (SLV) Total Tonnes in Trust: 9,552.22: No change from yesterday�s data.
Barrick�s (ABX) production in Mali and full year production results, Eldorado�s (EGO) fourth quarter and full year 2018 production results, and Pan American�s (PAAS) full year 2018 production results were among the big stories in the gold and silver mining industry making headlines today.


text:
مقالات inmost switch physical
inmost switch physical آبان ۱۴, ۱۳۹۹
• Explore every nook and cranny to find secret passages and collectables. Hardware Review: Xbox Series X & Xbox Series S Consoles, November Preview: 19 TV Shows & New Movies to Watch at Home, Release Dates for All Notable Upcoming Games, Music title data, credits, and images provided by, Movie title data, credits, and poster art provided by. Inmost is an atmospheric, story-driven puzzle platformer, following three playable characters within one dark, interconnecting story. All rights reserved, © 2020 Nintendo. There are a few other niggles here and there with regards to the game's controls which can be a little finnicky at times – you may find yourself struggling to clamber up and down off certain items as the young girl, for example, and there are also numerous instances of pretty much unavoidable deaths against one or two enemies who'll bamboozle you repeatedly until you finally discover the specific trick in how to avoid them. this looks so incredible. A narrator, who for the most part has been relatively quiet, suddenly comes to life in this final stretch, filling in the blanks and tying things together in a rather heavy-handed and ever-so-slightly hammy fashion. on August 20, 2020 at 7:51AM PDT. Trying not to give Nintendo money right now lol. Inmost may seem like an ordinary 15 dollars indie game that you can kill in a few hours, but it is actually a unique tale full of secrets that will make you play it over and over again to fully discover its creepy world. Any suggestions? That's music to my ears. Explore a crumbling, nightmarish landscape, slice through enemies, and spring deadly traps in … As disorienting and alien as Hidden Layer's world feels, I imagine most players will be surprised by how strongly they relate to its characters by the time the credits roll. Explore a hauntingly beautiful pixel art world, with three playable characters, in one dark, interconnected story. best. Collection. Email news@gamespot.com. The game was announced during the Nintendo Indie World stream earlier this week. It's a unique, short, and probably over-priced game for what it offers, but Inmost's terrific presentation still makes it worth a look. Wildly different games though, if you ask me. Games are property of their respective owners. This website uses cookies to improve usability and security. You'll lure enemies into deadly traps and utilize a scythe, hookshot, and pickaxe to survive the depths of this deteriorating castle. Installment Payments × HOW IT WORKS. In an old abandoned castle, you'll need to explore every nook and cranny, avoid detection, slice your way through enemies and spring deadly traps in order to Inmost is an atmospheric, story-driven puzzle platformer, following three playable … It's a satisfying end. This version of the game adds some new content, including new characters, locations, puzzles, music tracks, and improved performance and physics. Compared to Xenogears, is it a similar situation? In an old abandoned castle, you'll need to explore every nook and cranny, avoid detection, slice your way through enemies and spring deadly traps in order to, Inmost is an atmospheric, story-driven puzzle platformer, following three playable characters within one dark, interconnecting story. not a visually demanding game (despite its very competent audiovisual Most updated physical Switch collection. No shame, no regrets. It should have zero resistance or zero voltage drop in ON state and infinite resistance or zero current during OFF state. It should be closed and open instantaneously independent of current through it. 1 Add items to your Cart. One interweaving story, set across two worlds. The Switch is a great fit for the game, and all of us couldn't be more excited to see it arriving there! Its vibes and images slightly remind me of the point & click Deep Sleep series of flash games. A Nintendo Switch Online membership (sold separately) is required for Save Data Cloud backup. with 4 payments of $ Learn More. After the Apple Arcade version was released the team at Hidden Layer Games went back to develop additional content for INMOST such as new locations, narrative, music, cutscenes and more. Inmost is an atmospheric, story-driven puzzle platformer, following three playable characters within one dark, interconnecting story. Inmost could be the very definition of a hidden gem. Please enter your birth date to watch this video: You are not allowed to view this material at this time. Was curious about this one. an inconsistent framerate, which is difficult to understand as this is @BooJoh True. @Daniel36 If they release Xenogears on Switch, they had better expand upon that awful, rushed final disc. Slice through enemies, and spring deadly traps in this hauntingly beautiful adventure, PR - INMOST Launches on Nintendo Switch Today, Switch hits 68.30 million units sold, officially surpassing the NES, Drawn to Life: Two Realms officially announced for Nintendo Switch, new press release and trailer, Datamine suggests that a Justin Bailey costume for Samus was in development at one point for Metroid: Samus Returns, Famitsu - Sales for October 26th to November 1st, Its unrealistic for the Switch to not last a decade, Predict the remaining playable characters in Hyrule Warriors: Age of Calamity, Predict the 5 DLC characters for Super Smash Bros. Best Game............................................................................................................................................................ Bad performance on the Switch lets this game down massively.
What Was The Apache Territory, 1/10 Scale Garage Accessories, What Happened To Abigail Gibbs, Fitness Gear Customer Service, My Body Before And After Swimming, Adcb Dormant Account, Gli For Sale In Islamabad, Words To Describe Autumn, Word Connect 2020 Money,
فیسبوکپینترسترددیتWhat Was The Apache Territory, 1/10 Scale Garage Accessories, What Happened To Abigail Gibbs, Fitness Gear Customer Service, My Body Before And After Swimming, Adcb Dormant Account, Gli For Sale In Islamabad, Words To Describe Autumn, Word Connect 2020 Money, ... ادامه مطلب" class="cz-delicious" title="اشتراک گذاری در Delicious">Deliciousواتس اپایمیل


text:
Upgrading my '87 Grand Wagoneer's headliner was a mixed success
Benjamin Hunting
Aging headliners are the bane of any classic car owner's existence. Unlike leather upholstery or chrome dash trim, which ask no more than a swipe of conditioner or polish, there's no combination of glue, foam, and fabric that won't eventually demand to be replaced. At some point, the headliner will separate and sag, gently brushing against your head, reminding you that your interior is starting to look more than a little tired.
So it was with my 1987 Jeep Grand Wagoneer, whose own headliner's demise was hastened by the water infiltration occasioned by AMC's relaxed approach to weatherproofing the rack bolted to its roof. The paper backing board had long since morphed from its original mold into some grotesque, bulging parody of stock fit. Dangling strips of light tan (or 'doeskin' in Jeep parlance) material blocked my view out the rear-facing mirror and tickled the necks of rear-seat riders.
At the beginning of the summer I simply couldn't take it anymore. I tore the fabric free, exposing the bare board. Finally, I no longer had to deal with a faded brown sail billowing behind me on the highway—but the ugly, yellowed cardboard that remained prompted me to improve my interior sooner rather than later.
A headliner replacement seemed like a simple-enough DIY project: Remove the trim pieces that were (barely) securing my factory board, toss the panels in the trash, and then replace them with new ones. At the same time, I could take care of several smaller issues associated with the Jeep's cargo rack and roof before buttoning everything up. As I dove deeper into my replacement headliner options, I even discovered a high-tech solution that seemed like a significant upgrade over the factory panel, available at a more affordable price.
I was about to discover what happens when early-adopter instincts combine with overconfidence. Here's what I learned when tackling a novel task never before tried in a vehicle built with the most casual attitude towards quality and uniformity.
Paper or plastic?
This kind of specialized, low-production-run, interior component is an increasingly welcome development in the world of classic automobiles. Benjamin Hunting
In addition to local upholstery shops across the country, many of which will custom-built panels, a number of aftermarket companies specialize in the reproduction of Jeep Grand Wagoneer headliners. Most of their options replicate the standard paper/foam/fabric trinity that had been rain-soaked and then sun-baked into oblivion in my own truck. Though some also offer additional weather protection via Tyvex backing, I was curious whether any panels were made of more modern, durable materials.
I struck pay dirt in one of my full-size Jeep Facebook groups. A fellow member had just begun to produce a set of headliner panels laser-cut from corrugated plastic. This caught my attention for two reasons: First, plastic promised to stand the tests of time, temperature, and humidity far better than traditional foam and fabric. Second, almost design could be printed directly onto the panel, which opened up a world of possibilities beyond my Grand Wagoneer's stock, single-tone colors.
As 3D printers and computerized cutting tools continue to fall into the hands of enthusiasts, previously underserved corners of the hobby will have access to affordable replacement parts not from a shop, but from another owner. Benjamin Hunting
Priced at $400, shipping included, this plastic panel was much less expensive than any other headliner kit I had seen for sale. Throw in another $50 for a custom pattern (I chose a New Mexico-inspired Aztec design), and it was still $100 cheaper than the next-closest option. I placed my order.
Keeping my head dry
Before I could install the new headliner in my Jeep, a few other things needed attention. Water had found its way into my Grand Wagoneer through the many entry points so generously provided by the factory; it was well beyond time to tear out the old panel and address what AMC's assembly line had so readily ignored.
The primary pinpricks centered around the SUV's roof rack, along with the set of metallic cargo slats underneath it. The latter pulled double duty, protecting the Jeep's faded paint from scratches while adding structural integrity to what was essentially one long, thin slab of sheetmetal.
The first order of business was to push out the two major dents in the roof that had been gifted to me by the previous owner. After meticulously researching best bodywork practices, and after a few ineffective bangs of a rubber mallet, I discovered the most effective process. I lay on my back and used the heretofore untapped power of my quads to push against the bowed, metal support ribs spaced across the roof's interior. This proved remarkably effective in removing the dual valleys, and I muscled each crossmember nearly straight—leaving only a small gap between rib and roof that would come back to haunt me.
That done, I turned my attention to the roof-rack supports. Despite the model's reputation as a do-anything utility vehicle, the roof rack will give any Grand Wagoneer owner a bad time. Each of its six "anchor points" are secured using a simple screw that passes through a rubber grommet into a single layer of metal. Stories abound of owners chasing the remnants of their rack into ditches after winds generated at highway speeds caught the roof-stowed luggage and ripped the fasteners straight out of the truck.
Fortunately, there is a solution. BJ's Off-Road markets a set of "heavy-duty" support brackets that replace the grommets and brace the entire rack against the interior via solid steel mounts. With a dab of silicone on the factory screws (which are retained), the setup is also completely waterproof. Aside from the challenge of holding each bracket in place while simultaneously threading a screw through the roof, installation is relatively straightforward.
I also ordered a set of replacement gaskets to slide underneath the metal roof slats. I took the time to remove the gunk that had accumulated in slopes and valleys of the dented metal. Facing yet another screws-directly-into-sheetmetal situation, I assumed I could simply repeat the silicone strategy. Only after installation was I counseled that the sealant wouldn't last long due to the movement of the roof and the temperatures to which it would be exposed. A tedious removal and cleaning process ensued, followed by the internal application of a 3M urethane body sealant and a glob of butyl rubber through which I could run the screw threads on the outside.
Once waterproofed, the final step prior to popping the headline in was to add sound and heat protection to the bare metal. I went with Kilmat, a butyl-based, self-sticking sound deadener 0.08 inches thick that is backed with heat-reflective foil. Slathering my roof with Kilmat added structural rigidity to the steel panel, thus reducing vibrations and booming at speed, and stopped the roof from contorting under the support slats.
You don't need to cover more than 35 percent of a given panel with the product to achieve sound deadening, but I also wanted to keep the sun from heating the cabin, so I aimed for near-total coverage. Installation was relatively simple (cut, stick, and then roll as flat as possible with a simple tool), though in retrospect I should have removed the roof supports rather than cut the Kilmat to fit around them.
Road noise was immediately improved, but making the roof more rigid had the unexpected side effect of creating a gap between the rear-most support ribs and the roof itself, which produced a high-pitched creaking when cruising with the windows down. I consoled myself that, with the headliner in place, there'd be less wind to vibrate the panel.
Too-flat blues
Of course, that gambit relied on my ability to get the headliner installed.
It was here that my DIY plans started to disintegrate. The first set of printed plastic panels had been damaged in shipping—thanks for the footprints all over the box, whoever you are—which meant testing fitment with a creased, dented headliner. The instructions provided by the fabricator suggested sliding the front half along the channels on either side of the cabin, then securing it using the trim piece above the windshield. It hung loosely, waiting to clamp the flat plastic.
Almost immediately, there was trouble. Try as I might, I couldn't get the headliner to slide the final inch or so at the front of the Jeep. Even after I recruited a second set of hands, any attempts at forward motion produced creases and bends in the panel. I contacted the seller—who was, to their credit, available to answer questions throughout the entire process—and he suggested thinning the rear edges of the headliner. Perhaps they were getting caught in the roof channels.
At this point, I realized I was in over my … head. Wary of damaging the pristine replacement that had by now been shipped to me, I asked around for an interior specialist familiar with classics. I settled on Duluth Auto Glass, which was conveniently located only a few blocks from my home in Montreal. Having seen the shop's work, and impressed by the openness towards the project from owner Jack and his colleague Carl, I dropped off Grand Wagoneer and headliner on a Monday morning. I expected it to be ready to go in a day or two.
Little did I know that the experts at Duluth were about to encounter many of the same problems that had flummoxed me, plus a crop of new pain points intrinsic to the design of the plastic headliner.
The slide method for the front half of the headliner was completely unworkable, because roof channels caught on the edge of the headliner. After two full days of work, Jack and Carl devised a method that required popping the plastic into one channel and, in one single motion, angling it precisely to catch the other.
Why the intricate ballet of panel and manpower? The replacement headliner was exactly as wide as the roof, channel to channel. Even worse, the corrugated plastic was completely flat, unlike the molded headliner I had removed. While it did have diagonal creases intended to match the natural bend lines of the roof, the plastic relentlessly tried to return to its original flat state, pulling the edges out of their mounting spots on either side.
This issue was even more pronounced in the rear, where the shop had to install foam behind the headliner to keep enough downward force on the larger, back panel to prevent pop-out. This solution created a pair of tiny humps in the finished ceiling, but these were far from the worst issue. The panel was itself half an inch too short, with a misaligned cut-out for the dome light. With the light in place—even using a single screw to rotate and extend it as far from its crossmember mount as possible—there was still an air gap between the edge of the headliner and the rear trim.
Luckily, the shop discovered this using the damaged, test-fitment panel. The virgin headliner section had yet to be removed from its plastic border, so Jack and Carl recut at the edge of the printed bleed lines, reinforced the edges and the original cut crease, and built a bracket to attach to the crossmember and align the dome light with the headliner cutout. They added felt inserts between each crossmember and the roof, fully solving my earlier vibration-at-speed issue.
A day's work stretched into a full week of trial-and-error fitment and fabrication. Even after all the extra effort, it was discovered that the back half of the Jeep's mount channels weren't level, which meant that my roof's Aztec lines were subtly misaligned front to rear. Due to the flat, unmolded design of the headliner, some creases were unavoidable, and the shiny natural of the corrugated plastic's surface made them easy to spot for anyone with a critical eye.
When it comes to Jeep, one size fits none
I took several lessons away from this excursion into experimental cabin design. For vehicles like the Jeep Grand Wagoneer (which by the mid-'80s was famously assembled by a manufacturer staggering towards bankruptcy, using quarter century-old tooling), the idea of a "universal fit" is probably wishful thinking, especially for components as tolerance-sensitive as interior panels. I have no doubt that the headliner I was shipped probably fit someone else's full-size Jeep—just not mine, given the quirks of the production line.
The creases, bumps, and occasional dents associated with installation would also have been far more acceptable were they covered in foam and fabric, soft materials that obscure folds and bunching. It makes me question whether a plastic, regardless of how cool its printed pattern, is the best material to covering the large expanse of an automobile's roof.
The flatness of the corrugated plastic proved to be its biggest liability. If the panel had been molded into the shape of the Grand Wagoneer's interior from the outset, almost all of the issues we ran into during installation could have been avoided. It's definitely worth paying the extra $100 to $200 for a molded insert.
I don't necessarily regret taking a chance on a new, community-sourced component for my Jeep. Yes, the entire installation process was a hassle. However, the new headliner is light years ahead of the worn-out stock setup. Duluth Auto Glass did excellent work even after I showed up at its shop with a product that clearly wasn't ready for prime time. If I should tire of the panel's imperfections, I can still use it as a backing board for a traditional fabric installation.
The reality is, even from the factory, many parts of this Jeep were poorly designed or cobbled together using whatever AMC could afford to ship down the line before the accountants caught up with them. Each and every owner of a old-school Jeep has to deal with their own particular variation on the mediocre quality-control of the era. While they may not hit the mark every time, I'm always encouraged to see members of the classic car community step up and take a shot at making life easier for their fellow owners.
Check out the Hagerty Media homepage so you don't miss a single story, or better yet, bookmark us.
Opinion Opinion: Bad tech is killing off great cars
James Mills
Maintenance and Tech Just add skis: Ford's Model T is (still) the perfect one-car solution
Read next Up next: The 1978 Cadillac Coupe de Ville was America's favorite luxury car
Lars Aspelin says:
Great article. Can you share where to find the plastic board??
Hi Lars – the manufacturer asked me to keep their name out of the story, which I did as a courtesy due to how willing they were to work with me on making the piece fit. But if you search any of the Facebook full-size Jeep / Grand Wagoneer groups, you'll have no trouble finding them.


As a therapist, you look at the big picture. So do we. We don't just make great websites. We help you reach more clients with a wide variety of online marketing strategies. Start your New Year right and try TherapySites today with 4 months of free website hosting.
Take search rankings to the next level with personalized SEO management.
Build a large network of referrals on the most popular social media networks.
A HIPAA-compliant platform that lets you interact with clients from virtually anywhere.
You couldn't run your practice without your dedicated team of employees. Why should it be any different with your social media presence?
Millennials (born 1980 to 2000) are the "always-connected" They make-up about 80 million people in the USA and have an estimated $2.45US trillion in spending power.
These experts agree that a strong SEO strategy is more important than following the latest trend. Meta tags are the foundation of on-page SEO, title tags being the most important.


The City of Corner Brook wishes to advise residents and businesses in the following areas that a Water Outage and Road Closure has been scheduled for Wednesday, March 13, 2019, commencing at 8:30 AM. The water outage and road closure is expected to last for approximately 6 to 8 hours and is necessary to make repairs to the water distribution system.
In conjunction with the repairs, Washington Street will be closed to through traffic from the intersection of Peddles Lane to the intersection of First Avenue. The general motoring public is advised to use alternate routes.


Do you want to ask Kamran Abbasov to be your local guide in Baku, Azerbaijan?
Kamran Abbasov shows this photo only to his favorite contacts.
Give a gift to chat with Kamran Abbasov at once. Catch his attention!


The 150 kW2 and 165 kW3 six-cylinder turbodiesel engines with 3.0 l capacity have more than enough reserves even in the most demanding situations. Additional power comes from the overboost function, which briefly increases the performance of the V6 165 kW TDI engine by up to 180 kW depending on the driving situation.
In the new Amarok Aventura, the driver and front passenger will enjoy the journey on ergoComfort seats. As well as electrical 12-way adjustment, both leather seats come with manual 2-way adjustment and have been awarded the AGR seal of approval** for outstanding ergonomics.
*Standard equipment for Amarok Highline and Amarok Aventura. Option at extra charge for Amarok Comfortline.
**On 26 November 2015, the ergoComfort seat was awarded the Campaign for Healthier Backs' seal of approval by the German Association of Back Training Facilities (BdR e.V.) and the Campaign for Healthier Backs (AGR e.V.).


text:
Rel Season 2: Premiere Date. Cast, Recap, Update
Shiladitya Ray
'Rel' is an American sitcom television series by Fox that follows the story of a successful man trying to rebuild his life after a divorce. Created by Lil Rel Howery and aired on Fox, the show first made its way to viewers' screens on September 9, 2018, and has seen only one season thus far. While fans of the show are hoping for a new season, 'Rel' might just suffer an untimely demise. Here's what we know about the future of the show.
Rel Cast: Who's in it?
Leading the cast of 'Rel' is the show's creator, Lil Rel Howery of 'The Carmichael Show' fame, who plays the role of the protagonist Rel who is trying to rebuild his own life. Rel is aided in his efforts by his best friend Brittany, who is played by Jessica "Jess Hilarious" Moore, and his younger brother Nat, who is played by Jordan L. Jones. Another important character in the show is Rel and Nat's father, who is played by Sinbad.
These four characters are central to the sitcom with other characters appearing in minor, supportive roles. If 'Rel' does get renewed for a Season 2, we expect to see more of these main characters.
Rel Plot: What is it about?
Loosely based on Lil Rel Howery's own personal life, 'Rel' follows the story of Rel, a successful, hard-working husband and father with a seemingly perfect life. Not only is Rel successful, but he is also a self-made man who believes that self-confidence can get you anywhere. Based in the West Side of Chicago, the story picks up when Rel finds out that his wife is having an affair with his own barber. Not only is the discovery of the affair a devastating blow for Rel, but he is also left dejected and heartbroken, and loses all his self-confidence.
Faced with the reality of his wife's infidelity, Rel has to pick up the pieces and move ahead with his life. He gets divorced from his wife and, in the process, loses both of his children who move to Cleveland to stay with their mother. Now a long-distance single dad, Rel must start his life over again and search for a way to regain respect, dignity, and his self-confidence. Aiding Rel in his journey to rebuild his life is his best friend, Brittany, and his excitable and overly encouraging younger brother Nat, who is fresh out of prison. Rel is also aided sometimes (and chided other times) by his proud and recently widowed father, Milton, who thinks that both his sons are big disappointments.
Despite the serious undertone of the plot, 'Rel' does show some potential to be genuinely funny, even if it fails to be so at times. What lets the series down is its tendency to hit generic beats associated with sitcoms – in essence, it fails to bring innovation and creativity into its humor, despite having a strong ensemble cast who deliver great performances.
Understandably, the show has failed to strike a chord with its viewers, and enjoys a poor rating of 4.2/10 on IMDb. Television critics, too, found the show rather unpalatable, and it has a pretty poor score of 44% on Rotten Tomatoes.
Rel Season 2 Release Date: When will it premiere?
Interestingly, when Season 1 of 'Rel' hit viewers' screens on September 9, 2018, it received an overwhelming response from viewers, with 5.49 million viewers tuning in to catch the pilot episode of the show. Since then, however, 'Rel' failed to maintain the momentum, and its viewership decreased consistently, hitting a low of 1.23 million in its penultimate episode. In terms of TV ratings, too, the show has failed to create a lasting impact among viewers, and has averaged a rating of 0.74 in the age group of 18-49 years.
Unfortunately for the fans, on April 17, 2019, Fox announced the cancellation of the show. Fox didn't reveal the reasons, but the low ratings seem to be the death knell for the show. Also, the Rel family suffered a tragic loss in January when co-creator/executive producer Kevin Barnett died suddenly while vacationing in Mexico, a little over a week after the season one finale had aired. That would have dampened the spirits of the creators too.
Though fans should not give up all their hopes. In the world of TV, you never know what's around the corner. Some other network might revive the show at a later point of time. At this moment, we don't have news of any network being interested.
We will be keeping an eye out for news on 'Rel' season 2 and will update this section when relevant and reliable information on the future of 'Rel' surfaces.
Rel Trailer:
While we await any positive news on the future of 'Rel', here is the trailer for Season 1 to give you a glimpse into what the show is all about.
Read More: Upcoming Fox Movies


Imad search here at the hashmonean.
Glorious news really, there's just no other way to put it. Kudos to whomever found him & blew him up car bomb style, something he so richly deserved. Man I hope we did it.. But if the Americans got him, that would be sweeeeet too!
The side note: Damascus now in the hot seat, knowingly sheltering arch terrorists within its loving embrace. Maybe Pelosi or Obama should jet out there so we can all talk it over and make a few more concessions? "Yes we can!" <– Preferably elect someone who can actually protect freedom as opposed to delivering fancy speeches full of sweet nothings.
Obama's senior foreign policy advisor is INDEED there in Syria already! Oh the irony, what a slap in the face to the foolhardy Obama strategy of "engaging" the Jihad in dialog..
This entry was posted in I Love America, Israel / Zion, Terrorism / War on Terror on February 13, 2008 by saus.


It is being reported by CBS, via Slashdot, that Randy Pausch had died.
Randy Pausch, the charismatic young college professor who chronicled his battle with pancreatic cancer in a remarkable speech widely-known as the "Last Lecture," has died. He was 47.
I first heard about this computer science professor when someone sent me to a link to watch his "Last Lecture," which was videotaped at a Carnegie Mellon lecture hall . Mr. Pausch follow up his lecture with a book titled, "'The Last Lecture."


"Moving past Planet of the Apps and Carpool Karaoke, Apple is believed to be spending $1 billion or more on its first high-budget TV shows, which could hit screens as soon as April 2019. Here are the programs we know about so far," Roger Fingas writes for AppleInsider.
Many more projects and detailed descriptions in the full article here.
MacDailyNews Take: Apple only needs one hit to start the service off right and, by the looks of things, they've assembled high-caliber talent on myriad projects, so the odds look good!
Where's the violence? You need a good dark drama to get this ship off the ground. Where's their version of The Sopranos or Breaking Bad or The Wire or House of Cards or Game of Thrones? All we get with "Appleflix" is this Lifetime Network jolly family crap?
MDM, I so hope your right.
I consider this entire move into content production to be a waste of time and resources, but I still want Apple to be successful at this. It would be nice if they put all of that effort into their current basic services and hardware.
These shows sound utterly underwhelming…I hope there's much much more….
Will these shows be qualitatively/critically good or will they be merely popular because of Apple's wide reach?
We'll know sooner or later.
Regarding the future, this video purports to be about a time traveler who says that entertainment will be all internet based.
Typical progressive nonsense from this site's resident ding dog.
Kind of have mixed feelings about the stories they'll be limited to for Amazing Stories given their current family friendly shows push.


Researchers from the Moscow Institute of Physics and Technology teamed up with colleagues from the U.S. and Switzerland and returned the state of a quantum computer a fraction of a second into the past. They also calculated the probability that an electron in empty interstellar space will spontaneously travel back into its recent past. The study comes out March 13 in Scientific Reports.


Looking for Bath Enclosures in Hawaiian Gardens? We have exemplary workmanship and the finest of products.
We serve Hawaiian Gardens with exemplary workmanship and the finest of products.
and value to your home in Hawaiian Gardens.
There are hundreds of choices when it comes to the design of your perfect shower or bath enclosure for your home in Hawaiian Gardens. You can incorporate the components in a variety of ways to satisfy every member of the family. Our professional designers work with you to achieve the ideal fusion of style and function that complements the aesthetic of your home and your budget.
Deeper tubs are perfect for soaking and relaxing, these tubs are extremely luxurious and provide the perfect place to relax after a long day at work or school. We also offer walk in tubs, which are perfect for individuals with limited mobility or special needs.


Women's 'Rebound' skinny jeans from French Connection with a body-contouring, stretch cotton construction. Showcasing a classic five pocket design and faded finish, the denim jeans feature a metallic button closure, zip fly and belt loops. Tonal stitching throughout. 92% Cotton, 6% Polyester, 2% Elastane Model is 178cm/5'10 and wears a size UK 8.


text:
painting existing kitchen cabinets
updating kitchen ideas
semi flush kitchen lighting fixtures
garde nationale
garde nationale france
garde nationale du québec
garde navarra
garde nationale usa
garde nationale 1789
garde new london
garde nationale tunisie
garde nationale def
garde nationale russe
garde n
hampshire garden furniture
landscape advertising ideas
southwest landscape ideas
kitchen with walnut cabinets
visitcornwall.com
cob.org
fanartreview.com
travelmanitoba.com
janebrockbank.com
s.hdnux.com
Wiki information
The National Guard (French: Garde nationale) is a French military, gendarmerie, and police reserve force, active in its current form since 2016 but originally founded in 1789 during the French Revolution. For most of its history the National Guard, particularly its officers, has been widely viewed as loyal to middle-class interests. It was founded as separate from the French Army and existed both for policing and as a military reserve. However, in its original stages from 1792 to 1795, the National Guard was perceived as revolutionary and the lower ranks were identified with sans-culottes. It experienced a period of official dissolution from 1827 to 1830 but was reestablished. Soon after the Franco-Prussian War of 1870–71, the National Guard in Paris again became viewed as dangerously revolutionary, which contributed to its dissolution in 1871.In 2016, France announced the reestablishment of the National Guard for the second time, in response to a series of terrorist attacks in the country.


text:
What is the similarity between the cause of social justice and environmental justice?
How are environmental justice and social justice related?
How are environmental ethics and environmental or social justice connected?
How are environmental and social issues connected?
What is social & environmental justice?
What is the difference between social justice and environmental justice?
What's the difference between environmental justice and environmental injustice?
Why are environmental issues also social justice issues?
What is the connection between social justice and sustainability?
What is the difference between environmental justice and environmental racism?
What are two social issues that could lead to environmental injustice?
What are two social issues that could lead to environmental injustice 2?
What are environmental justice issues?
What are the social and environmental issues in South Africa?
Why is environmental justice part of the environmental movement?
Both social and environmental justice work are sensitive to power issues (who causes pollution; who suffers from pollution); focus on communities or groups rather than individuals; and tend to adopt a holistic approach to analysing and addressing problems and reforms.
Social justice aims to ensure fair treatment of individuals and groups. … Environmental justice is primarily concerned with the positive as well as negative effects that different environmental factors can have on communities and individuals. There can be environmental advantages as well as disadvantages.
Environmental justice is the social justice expression of environmental ethics. … As a result, this movement devotes itself to the unfair distribution of environmental risks and resources, and promotes efforts to prevent pollution from impacting low income communities.
IT IS AMAZING: Your question: What is an ecosystem in geography GCSE?
Second, environmental problems have a significant impact on people, as do the many other social problems that sociologists study. … Slower changes in the environment can also have a large social impact. As noted earlier, industrialization and population growth have increased the pollution of our air, water, and ground.
It can be thought of as "the fair treatment and meaningful involvement of all people, regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies" (source: U.S. Department of Energy ).
Social justice aims to give individuals and groups fair treatment and an impartial share of social, environmental and economic benefits. … 'Environmental justice' is used here to include aspects of social justice – although sometimes social and environmental goals may be in conflict.
5. Environmental justice affirms the fundamental right to political, economic, cultural, and environmental self-determination of all peoples. … Environmental justice protects the right of victims of environmental injustice to receive full compensation and reparations for damages as well as quality health care.
Issues that impact the environment have impacts on the people who live there as well. And when some people have access to resources that help them relieve those impacts while others don't, that becomes a social justice issue.
IT IS AMAZING: How are bears affected by abiotic factors?
The two priorities of social justice and sustainability are, in essence, collectively confronting the damaging consequences of "uneven development": both in the standard political economic sense (the uneven distribution of economic resources) and in the environmental sense (an uneven development of human versus non- …
Environmental racism is the disproportionate impact of environmental hazards on people of color. Environmental justice is the movement's response to environmental racism.
The most 4 social issues that could lead to environmental injustice is Anti-Social behavior, Poverty, Drug-abuse, racial discrimination.
Causes of Environmental Injustice
Racism/racial discrimination. Alienating low-income community members. Failing to represent all groups and government. Industrialization.
Environment can be defined as the surroundings or conditions in which a person lives. … Environmental justice issues and examples include inadequate access to healthy food, inadequate transportation, air and water pollution, and unsafe homes.
There are three main environmental issues in South Africa – pollution, lack of energy, and deforestation ("Environmental Problems in South Africa").
The environmental justice movement was started by individuals, primarily people of color, who sought to address the inequity of environmental protection in their communities. … The Civil Rights Movement of the 1960s sounded the alarm about the public health dangers for their families, their communities and themselves.
IT IS AMAZING: You asked: Does climate change increase crop yield?


We believe that making the world a better place for children and their families starts with empowering childhood at home and in the community. We stand up for children, passionately working together to create a universe where every child experiences hope, kindness and joy. Through philanthropic giving, product donations and employee volunteering, we make a positive and lasting impact on children and families worldwide.
Caring for children and contributing to the communities where we work and play are immensely important to us. We leverage our purpose-driven culture, signature initiatives and strategic partnerships to continue our more than 90-year tradition of giving back. In 2018, our philanthropic support totaled $20 million and impacted 4 million children around the globe.
We invest our assets — financial resources, toy and game products, employee talent and time, and our beloved brands — in diverse, long-term programs in the cities and towns where we operate. We're also proud to work with strategic nonprofit partners to make the biggest impact possible.
We encourage all employees to get involved in Team Hasbro, our global volunteer program. In addition to our annual signature program, Global Day of Joy, employees volunteer thousands of hours throughout year.
Giving hope to children who need it most.
Inspiring and empowering kids to have the compassion, empathy and courage to stand up for others, include everyone and take action when they see a problem.
Bringing the joy of play to children who otherwise would not have this experience.
BE FEARLESS BE KIND, launched in 2016, is our largest philanthropic initiative to date. It aims to empower kids to have the empathy, compassion and courage to include everyone and stand up for others. Through this initiative, we provide resources and programs that teach and inspire kids to be inclusive, appreciate each other's differences, be compassionate toward one another and know the feeling of fulfilment that comes with making a difference. To learn more, visit BE FEARLESS BE KIND.
Most Hasbro grants are awarded through the Hasbro Children's Fund (HCF), a 501(c)3 organization. We grant funds primarily to global and local nonprofit partners — selected through a rigorous process — that maximize benefits for children in need around the world. HCF also works closely with grantees to help build their capacity and achieve their goals.
For more information, visit our partnerships page and our giving page.
Hasbro believes every child, regardless of his or her circumstances, deserves the joy of play. We donate products and financial support to hospitals, shelters and summer camps that serve or care for sick, at-risk or underserved children. In 2018, Hasbro's Gift of Play, our product donation program, brought joy to 1.2 million children worldwide through toy and game donations valued at $15 million.
Visit our Philanthropy website to learn more about Hasbro's global philanthropy programs.
Read our 2016 Corporate Social Responsibility Report for more information about philanthropy and employee volunteerism at Hasbro.
Hasbro Named One of the Most Community-Minded Companies in the U.S.